I am providing the following…

I am providing the following comments regarding the Emission Summary and Dispersion Modelling (ESDM) report for the Millbank Sawmill located at 6870 Perth Road 121, Millbank, Ontario. The ESDM report was submitted in support of their application for an Environmental Compliance Approval (ECA).

Overview

It is my opinion that the above noted ESDM report is incomplete as it does not address all possible sources of air emissions from the Millbank Sawmill, and fails to provide any support for ongoing controls or mitigations of dust impacts from the property. Furthermore, the report contains no discussion regarding best management practices for the sawmill to mitigate against any potential adverse air quality impacts on the surrounding residents. This omission is of particular importance as there are current and historic complaints by the neighbouring residents against the sawmill regarding dust and odour impacts.

Detailed Comments

The ESDM report in support of the Millbank Sawmill ECA application has several significant omissions.

• The report does not include all potential sources of particulate emissions from the sawmill operations. The analysis considers particulate emissions from the debarker and the cutting saw, but does not include particulate emissions from the sawdust conveyors, material handling operations, vehicle operations, material stockpiles or fugitive missions. These omissions would significantly underestimate the potential for particulate emissions from the sawmill and sawmill operations.

• The ESDM report assumes 50% emissions control of the debarker, which is outdoors and fully open on one side, and assumes 90% emissions control on the sawmill cutting saw, which is in an unventilated building with roof openings and openable doors. These assumed emission controls do not have any support in the ESDM report as to why they were selected. Further, it has been noted by the local residents that the sawmill operators routinely leave the building high bay doors open during the work day, negating any effective emissions control from the enclosed building. These assumptions regarding emissions control would again underestimate the emissions from the debarker and cutting saw operations.

• The ESDM report does not include any assessment of fugitive dust emissions and screens out fugitive emissions as negligible without sufficient justification. Fugitive emission sources can only be screened out as negligible if they (a) either pose no human health risk, or (b) if are minimal or can be shown to be properly mitigated. Sawmill dust is composed primarily of fine particulate matter (defined as PM2.5 and PM10), so it is considered a human health risk and should not be screened out as negligible. No assessment is made of the size, location or potential to emit contaminants from the stockpiles or any other fugitive process sources, such as the building vents, and therefore no conclusion can be made as to whether or not they are emitted in small amounts. No discussion is provided in the ESDM report of a best management practices plan for particulates, and therefore no conclusion can be drawn as to whether or not they are properly mitigated.

• Volatile organic compounds (VOCs) and odour are also regulated contaminants under O.Reg 419 and are known emissions from the wood products industry. VOCs and odour are not addressed in the ESDM report. This is especially relevant in this case as there is a history of both odour and dust impact complaints regarding the facility from the nearby residents.

The most significant omission in the application is the lack of any requirement for a Best Management Practices (BMP) plan for the control of fugitive emissions. A detailed BMP plan is crucial for the continued operation of this facility as there is a history of odour and dust complaints from the surrounding community going back to 2021. The plan should include guidance from the MECP document “Management Approaches for Industrial Fugitive Dust Sources”, dated February 2017 and include:

• Relocation of material stockpiles as far away as practical from the impacted property.
• Reduction of the potential dust emissions from material stockpiles using enclosures, designed specifically to reduce off property dust emissions, fixed tarpaulin or plastic sheeting, or the use of water or other dust suppression materials such as soil or latex binders.
• Relocation of any outdoor cutting, debarking, wood chipping or other dust emitting operations to an indoor, properly ventilated building with dedicated dust collectors.
• Any unpaved roads used for heavy truck traffic should be either paved, or covered in crushed aggregate to minimize dust accumulation and wind scavenging. Paved roads should be regularly swept to reduce dust accumulation, and unpaved roads should be routinely sprayed with water to reduce dust emissions.
• A mechanism for community liaison and feedback to allow the community to communicate with the company when they are being impacted and for the company to take immediate steps to mitigate the impact.

It is also worth noting that the local MECP district office had visited the sawmill in the summer of 2021, responding to dust complains from a nearby resident. The MECP field officer recommended in email correspondence with the resident that a Best Management Practices plan for dust control should be applied to the sawmill, however apparently no follow-up to this recommendation was undertaken by the sawmill operators or the District Office.

Personal Qualifications

I am a licensed professional engineer in the province of Ontario with over 30 years of experience as an industrial air quality consultant. My specific areas of expertise include air emission inventories, air quality impact studies, atmospheric dispersion modelling, preparation of Environmental Compliance Approval (ECA) applications, greenhouse gas emission inventories and verifications, air emission measurement and control strategies and technologies.