633 Coronation Drive…

633 Coronation Drive Organics Processing Center and Anaerobic Digester

Comments on Noise Reports

Introduction
I have reviewed both the August 25th, 2020 Acoustic Assessment Report and Checklist (herein referred to as Report A (Ref 1.)) prepared by Jade Acoustics, and the previous Secondary Noise Screening Method Form assessment (herein referred to as Report B (Ref 2.)) that was submitted on 11 December, 2019 to ERO by the Proponent. They both relate to the proposed Organic Processing and Anaerobic Digester Plant at 633 Coronation Drive.

There is no indication that Report A supersedes Report B.

General Concern
My overriding concern about both these assessments is that they only deal with the noise from the proposed organic processing plant which will be located on the south portion of the site. However, there will also be noise emanating from the existing demolition/construction waste processing plant which will also be operating concurrently on the north portion of the site. It is only reasonable to evaluate the combined cumulative assessment of the noise from both plants operating together on the site at 633 Coronation Drive.

Specific Concerns
I have the following specific concerns.

Acoustical Classification
Report B, on pages 3 and 4, indicates that the acoustical classification for both the evaluated Points of Reception (POR -1 and POR - 2) is Class 2, and shows a maximum allowable noise level limit of 45 dBA. However, Report A, on page 6, indicates that the classification for the three PORs considered should be Class 1, which has a higher allowable noise level limit of 50dBA for daytime hours 07.00 to 23.00 hours, and 45 dBA for nighttime hours.

The process for the selection of the appropriate Class level for a given site, as outlined in Section C.4.4.1 of MOE NPC-300 (Ref 3.), seems to be somewhat arbitrary.

Section 4.0 of Report A states -
"The ambient sound levels have not been investigated at this time and the above noted Class 1 Area sound level limits have been used to assess the proposed facility."

This would seem to be a questionable decision, because Report B had already selected Class 2 as the appropriate choice. It also should be noted that based on information contained in the April 2017 "Environmental Noise Study in the City of Toronto" Report (Ref 4.) it is shown that that the ambient sound levels around the proposed site are among the lowest in the City, especially during the night-time hours, when the levels are below 40dBA.

We therefore recommend that a Class 2 designation be used, unless actual field measurements can prove otherwise. On this basis the OLA levels for the evening hours impulsive noise at Receptor 5 would exceed the allowable limit of 45dBA.

Sounds from trucks
Based on the figures indicated in Table A on page 14 of Report A, the truck loading/unloading impulses amount to some of the highest individual sound power levels.

There is no indication in Report A of the number of trucks used to estimate the cumulative noise levels indicated in Report A, however we assume that the numbers indicated in the Design and Operations Report (DOR) were used.

The DOR indicates that there will be about 60 trucks carrying waste material into the plant and 30 carrying the digestate out, and other miscellaneous trucks for total of about 100 per day. Since the trucks bringing in waste will be different from those carrying residues out there could be 100 coming in and 100 going out for about 200 trips per day.

However, it should be noted that these figures are based on 1240 tonnes per day of incoming organic waste. The ERO 019-1444 indicates there could be 2480 tonnes per day of waste imported per day. If the full 2500 tonnes per day waste limit is utilized, there could also be a similar or greater number of construction/demolition waste trucks going to and from the site. Thus, there could be around 400 truck trips per day. I would therefore request that the noise calculations allow for all these trips.

Many of these trucks will be operating at night, when ambient sound levels at their lowest. It is especially important that the noise from the truck's back-up alarms are allowed for, as these can be particularly penetrating and annoying, especially on a warm summer evening when the residents have their windows open.

If the Class 1 designation is applied this choice will severely impact the ability and right of the adjacent residents to a peaceful and quiet enjoyment of their properties, especially since the sound level indicated for truck loading/unloading impulses on Table A on page 14 of Report A is an astounding 111 dBA. It is also not clear whether this level includes the noise from the back-up alarms or not. This is an issue which must be addressed, both for summer evening operations and for night-time operations all year round.

Standby Generator
There is no mention of a standby generator in the original Report B. However, it does appear in Report A, and according to Table A on page 14 it has the highest individual sound power level. This is especially worrisome because the report indicates that the actual equipment model has not yet been selected. I am concerned that if a larger capacity generator is selected the sound levels could be higher than shown. It also a concern that other aspects for the proposed plant design may have changed since the original submission.

References (see Supporting documents for the referenced files)

Ref 1. Acoustic Assessment Report and Checklist - Jade Acoustics

Ref 2. I have tried to attach below the full 18 pages of the Secondary Noise Screening Method Form, however it appears to be password protected. I have therefore attached pages 1, 14 and 15 of 633 Coronation Drive - Secondary Noise Screening Method Form, which show the name of the applicant, the date of submission, and the acoustical classification and applicable sound level limit. The full 18 pages can be obtained for MOECP.

Ref 3. MOE NPC 300 - Environmental Noise Guideline - Stationary and Transportation Sources - Approval and Planning

Ref 4. Toronto Public Health - Environmental Noise Study - 2017