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013-3791

Comment ID

27804

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November 4, 2018

RE: Ministry Reference No 7484-B3EPHS, EBR Registry No 013-3791

Dear Madam/Sir,

Please accept this submission as Environment Hamilton’s formal comments on the National Steel Car proposal for an ECA (Air) with limited operational flexibility for its manufacturing facility located at 600 Kenilworth Avenue North in Hamilton.

While we have not had the opportunity to review the full file for this application, we have had the opportunity to review a copy of the Executive Summary Chart from the Emission Summary Dispersion Model (ESDM) provided as part of the application. The majority of our comments on this application will focus on information provided in the ESDM chart.

Air Emissions of Contaminants of Concern
Our preliminary review of the data generated for the proponent’s current ESDM, makes us concerned about a number of air contaminants. Our detailed concerns are outlined in the sections below.

Hexavalent Chromium
Our biggest concern is the fact that the proponent’s ESDM is showing levels of hexavalent chromium at 100% of the MECP’s annual POI limit. This situation warrants further investigation especially since this facility is operating in an airshed that the Provincial Air Zone Management System has classified as an Air Zone 3 airshed. Zone 3 areas are described by the MECP as ‘(A)reas with a concentration of large industrial sources; where air quality management activities are focused on the abatement of local industrial emissions as well as non-industrial sources’. In other words, we are a hotspot airshed that is already impacted by multiple sources – including a concentration of heavy industry.

The Hamilton/Burlington area has also been included as one of two areas in the province (Sarnia- Corunna being the other) in the MECP’s pilot Cumulative Effects Assessment Policy for benzene and benzo(a)pyrene – a policy which came into force on October 1st of this year. For Hamilton – especially for neighbourhoods near the industrial core – the evaluation of the additive effects of the current levels of emissions to air of these two confirmed human carcinogens confirms that residents living near the industrial core are at a substantially higher risk for health impacts from exposure than residents living further away. Given this reality, we are that much more concerned to see that National Steel Car’s ESDM points to levels of hexavalent chromium – also a confirmed human carcinogen - at 100% of the MECP’s accepted annual POI level. This means that the level could actually be higher than this in reality.

Add to these concerns the fact that National Steel Car IS NOT THE ONLY SOURCE of hexavalent chromium emissions to air in the area and there is even greater reason to investigation further. ArcelorMittal Dofasco – located immediately next door to National Steel Car – is the province’s 5th largest emitter to air of hexavalent chromium. As recently as 2016, with the coming into force of a new provincial air standard for hexavalent chromium, ArcelorMittal Dofasco was reporting air emissions at levels as high as 229% of the province’s annual standard for hexavalent chromium. On an annual loading to air basis, AMD reported a total release to air of 5.4kg of chromium (IV) in 2016, and 4.5 kg in 2017 when the max POI was modelled at 91% of the MECP POI limit. This in itself raises another interesting question – what is the annual loading to air of chromium (VI) from National Steel Car? The company is reporting a HIGHER annual maximum POI level than ArcelorMittal Dofasco and yet, is not reporting annual loadings to the National Pollutant Release Inventory. We are interested to know what the facility’s ANNUAL LOADINGS TO AIR OF CHROMIUM (VI) actually are.

This all points to the URGENT NEED TO CONSIDER HEXAVALENT CHROMIUM EMISSIONS TO AIR IN HAMILTON FROM A CUMULATIVE EFFECTS POINT OF VIEW AS WELL. The Ministry of Environment, Conservation & Parks has an obligation to consider cumulative effects and has started to take preliminary steps to do so in this very airshed. Chromium (VI) needs to be added to the list of air contaminants considered in cumulative effects assessments. In making this urgent request, we note that National Steel Car is within a distance of less than 200 meters from residential homes in the City of Hamilton.

Concerns regarding estimated emission levels of other air contaminants Other air contaminant emission estimates listed in the ESDM chart that caught our attention include the following:

  • Iron at 98% of the 24 hr, health-based standard
  • Iron Oxide at 83% of the 24 hr standard established to prevent soiling
  • Manganese & manganese compounds at 98% of the 24hr health-based standard
  • Nickel at 62% of the annual standard
  • Nitrogen oxides at 66% of the 24 hr and 67% of the 1hr health-based standards

Again, with each and every one of these air contaminants, it is important to point out that National Steel Car IS NOT THE ONLY LOCAL SOURCE. There are multiple facilities in close proximity to National Steel Car that are also emitting these substances. For instance, ArcelorMittal Dofasco right next door has reported in 2017, the following modelled numbers in its ESDM report:

  • Iron Oxide at 56% of the 24 hr standard established to prevent soiling – although, interestingly, AMD does not report a measured max POI for Iron alone.
  • Manganese & manganese products – the company HOLDS A SITE SPECIFIC STANDARD FOR MANGANESE so it is currently above the official standard and is emitting at levels that are 87.4% of the 24 hour Site Specific Standard approved by MECP.
  • Nitrogen oxides at 99.18% of the 1 hr health-based standard.

These details again reinforce concerns we have about multiple facilities IN THE SAME COMMUNITY all emitting various harmful contaminants at levels so close to the MECP POI limit. In the case of manganese – there is added concern given that ArcelorMittal Dofasco has had to apply for a site specific standard for this substance because the company is unable to meet the provincial standard.

Summary and Conclusions
In summary, we have a host of concerns regarding National Steel Car’s emissions of contaminants to air, based on the data provided in the ESDM report generated to support this application We have explained our concerns in detail in the sections above and we are calling for the Minstry of Environment, Conservation and Parks to require the proponent to do more detailed analysis of their emissions to air for these key contaminants of concern. Ideally, we would like to see a requirement for the proponent to undertake actual air monitoring for key contaminants of concern – especially hexavalent chromium. Given the location of this facility, it seems only reasonable that there must be a clearer picture provided of the true emission levels of these contaminants. We are not convinced, for instance, that the proponent does not require site specific standards for some of these contaminants.

Finally, we also urge the Ministry to continue to improve its efforts to address cumulative effects. We believe very strongly that there is an urgent need to assess facilities like this one in a more holistic, inclusive manner given its location in an airshed where there are other sources of these same contaminants. We are requesting that the Ministry undertake a holistic – cumulative assessment of these sources in order to provide the necessary assurances to Hamiltonians – especially those living in within less than 200 m of this facility – that our provincial air quality regulations are providing adequate protection for human health.

We thank you for the opportunity to comment on this proposal posting.

Lynda Lukasik, PhD
Executive Director
Environment Hamilton
TEL: (905) 549-0900