American Iron & Metal Company Inc. - Environmental Compliance Approval (air)

Fifteen (15) comments were received by the Ministry through the Environmental Registry and one (1) comment was received by mail.  Comments received were reviewed and, where appropriate, were considered in the ministry’s decision whether or not to proceed with this proposal. The following concerns were raised:

1. Concerns in regards to the noise and vibration generated by the operations on-site; the noise limits used in the acoustic assessment; and the explosions which may be generated by the proposed shredder.

Ministry’s response: The proposal's Acoustic Assessment Report demonstrates that the operations of this facility will meet Ministry's noise limits upon the completion of a Noise Abatement Action Plan, and demonstrated that the site currently complies with the Ministry's vibration limits.

Following the implementation of the Noise Abatement Action Plan, an Acoustic Audit will be required so that the noise impact and compliance can be verified by a third party acoustical consultant.  Any changes to the site operations will also require that the site's Acoustic Assessment Report be updated.

The noise limits used for the nearest and most exposed receptors to the south are lower than the recorded ambient noise in order to match the noise generated by the vehicular traffic along Nikola Tesla Boulevard and exclude the sounds from other industrial facilities.

Based on information received from the company, policies and procedures will be implemented to restrict the chances of an explosion occurring during shredder operations, including but not limited to supplier contracts and audits to prevent prohibited materials, shredder design to minimize noise and the potential for explosions, staff training for shredder inspection and operation, incident investigation by company Operations Manager and reporting to MECP.  Information received from the company indicated that the company’s operations will be adjusted to meet a zero explosion goal, and that the site and buildings had been designed to meet the requirements of the Ontario Building Code regarding fire services and fire routing, which were reviewed and approved by the City of Hamilton through the site plan approval process.

It should be noted that ECA (Air and Noise) applies only to s.9 EPA. Issues related to inappropriate land use/city zoning, residential property values, air and noise pollution from delivery trucks on public roads and future development of the area are beyond the scope of the ECA (Air and Noise).

2. Concerns about the air emissions including dust emissions, torch cutting emissions, shredder emissions.

Ministry’s response: The application has demonstrated that the operation of the facility complies with the ministry’s applicable air requirements including but not limited to the air discharge requirements in Reg. 419/05: Local Air Quality Regulation.

A Dust Best Management Practices Plan was submitted as part of the application. Condition 8 has been included to require the company to implement the plan and update it.

The company submitted a Torch Cutting Procedure with the application. Condition 9 has been included to require the company to conduct all oxy-propane metal cutting in accordance with the plan.

3. Concern about changes at the facility and a request that an assessment be completed for each change.

Ministry’s response: The Environmental Compliance Approval with Limited Operational Flexibility requires the facility to meet specific performance limits and maintain an up to date Emission Summary and Dispersion Modelling Report and Acoustic Assessment Report to reflect any changes and document ongoing compliance. Condition 6 requires the facility to submit a Written Summary Form to the Ministry annually which includes a summary of modifications.

4. Concern about the cumulative effects from other scrap metal yard and industry in the area.

Ministry’s response:

The Cumulative Effects Assessment in Air Approvals Policy decision was posted to the Environmental Registry in April 2018 and came into effect on October 1, 2018. This policy strengthens and clarifies the consideration of cumulative effects when making decisions related to environmental compliance approvals and indicates when additional measures may be needed beyond current regulatory requirements.

Under this policy, no further action is required for the facility at this time. The Ministry will continue to look at other contaminants, sources and geographic areas and consult with public and stakeholders as we expand the cumulative effects policy over time.