*NB - There is nothing in…

*NB - There is nothing in this submission to prevent it from being shared publicly in the decision posting. This submission does not contain any personal information - only publicly available organizational informaiton.

RE: EBR Registry No 013-3980, Ministry Reference No 9229-B4SMNR

Dear Madam/Sir,

Please accept this submission as Environment Hamilton’s formal comments on CRH Canada Group Incorporated’s application for an ECA (Air) for the corporation’s Dufferin Concrete Hamilton facility located at 886 Nebo Road in Hamilton.

We have had the opportunity to review the file associated with this proposal and we have some concerns we would like to raise. In our review of the Emission Summary Dispersion Model (ESDM) executive summary chart, we noticed that there are several contaminants that the modelled results show as being very close to the MECP POI Limit. Of particulate note are the total suspended particulate (TSP) levels modelled for the facility. The proponent’s ESDM indicates that the site-wide modelled amount of TSP is 93% of the MECP POI Limit. It is worth noting that this facility is located in an area that has been identified as a problem area for particulate pollution levels. Clean Air Hamilton has highlighted this fact through mobile monitoring completed in the area in 2015 by Corr Research Associates – see http://cleanairhamilton.ca/wp-content/uploads/2017/05/Hamilton-Neighbourhoods-Phase-2-Mobile-Air-Quality-Monitoring.pdf. The proponent’s ESDM also shows crystalline silica at 71% of the MECP POI Limit and we are concerned about this as well. This is not the only facility in this area with the potential to contribute to TSP levels in the neighbourhood. We urge the MECP to require the proponent to undertake actual monitoring to confirm the TSP and crystalline silica levels being generated from activities at this site. Further, it would be ideal if the MECP considered the larger, cumulative effects of TSP-generating activities in this area of Nebo Road. Finally, we urge the MECP to incorporate into the ECA (Air) the most stringent best management practices for the control of particulate pollution at this facility – including everything from proper road dust and road drag out management to any more sophisticated control requirements for the concrete batching activities that take place at this facility.

We are also concerned about the fact that NOx is being modelled at 85% of the 1 hour MECP limit and wonder whether there is the need to further investigate and require additional controls to reduce NOx levels at this facility.

We thank you for the opportunity to comment on this proposal
Lynda Lukasik, PhD
Executive Director
Environment Hamilton