ERO PROPOSAL 019-2301 As a…

ERO PROPOSAL 019-2301

As a former certified emissions auditor of the coke oven batteries at Algoma Steel Inc. (ASI) in 2018, I would encourage the province to reject the proposal (ERO# 019-2301) for an extension of the current site-specific-air standard (SSS). The extension is requested by the MECP since the original targets set for Benzene for 2021 (2.2 ug/m3) in the current ERO# 012-4677 (2016) will not likely be achieved.

BENZENE

The deficiency in the MECP’s plan for ASI to meet its intended target by 2021 is partly because the SSS for benzene that was set in 2016 (5.5 ug/m3) was only a 7.4% decrease from their modelled value in 2015 (5.94 ug/m3) according to ASI’s Emission Summary Dispersion Model (ESDM) report. Although, ASI is currently below their current SSS for Benzene (5.5 ug/m3), the data from ASI ESDMs’ from 2017-2019 shows an increasing trend of values closer to their current limit over time, rather than a gradual trend down towards their 2021 limit of 2.2 ug/m3 before ERO #012-4677 expires. By the end of 2019, ASI decreased their modelled benzene emitted by 15.1% (to 4.67 ug/m3) in three years compared to their limit of 5.5 ug/m3. If ASI is to achieve the limit of 2.2 ug/m3 by 2021, this would require an additional decrease of 52.9% in a year and a half (January 01, 2020 to June 30, 2021). Even at current modelled production rates, this would not likely occur since there has been no significant upgrades to emissions controls that reduce emissions that produce benzene, and production rates can increase in the future.

ASI’s No.7 battery (its oldest battery with an average opacity over two times the current limit) and its By-Products plant are within 400m of residents and are high sources of benzene compounds. Any criteria from the order should be public prior to an extension to avoid the perception of the potential dangers and concerns of “unanticipated” exposure rates to the public. The current order (ERO# 012-4677) stated, “In addition, the order includes a requirement for a benzene measurement program that is intended to confirm that all necessary actions to reduce benzene air emissions have been taken”. The public has not seen the specific results of any corrective actions and air sampling results from the program that confirm the requirement was satisfied. ASI stated in their ACLC meetings minutes, they have identified and have taken corrective actions of three potential sources of benzene not currently controlled in the by-product area. The specific details and results of the monitoring program completed in the fall of 2018 as well as the corrective actions taken, have not been fully disclosed to the public.

PARTICULATE MATTER (PM)

PM 10 and PM 2.5 are of greater health concern to the public and the environment than PM 44. According to ASI’s ESDMs reports from 2015-2019, ASI has failed to meet every year, the standards set by the MECP for PM 10 and PM 2.5. PM 44 is less concerning since the particulate size is much larger and assumed to be contained within the property line. Since 2015, ASI has failed to meet the MECP standard for PM 44 until 2018 (90.76% of the limit of 120 ug/m3). However, according to the 2018 ESDM, there was a Site-Specific-Standard (SSS) that increased the previous value of 120 ug/m3 in 2017 to 167 ug/m3 in 2018, and this increase could account for ASI meeting the 2018 limit. In 2019 ASI was 91.7% of the PM 44 Limit but the modelled production rates were significantly lower than those in 2015-2018. The modelled production values in 2019 for Cokemaking, Ironmaking and Steelmaking were respectively 24.4%, 52.4% and 56.6% lower than 2018. The lower production values modelled in 2019 could account for the reason ASI met the PM 44 limit of 127 ug/m3 in 2019.

ASI states they have a production capacity of 2.8 million tonnes of iron which is 29.4% higher than the 2019 modelled value. ASI’s production will potentially increase during the extension and create higher levels of particulate above the limits with their planned expansion to the Direct Strip Production Complex (DSPC) and the addition of a second Ladle Metallurgy Furnace to generate 2.4 million tons of steel at their #2 Basic Oxygen Steelmaking Plant (BOSP). The current baghouse arrangement at the BOSP is currently deficient for capturing current fugitive emissions. Also, Tenaris Algoma Tubes Ltd. plans to increase production by the end of 2021 and proposes to procure rolled steel from ASI.
A high source of particulate matter and other contaminants is the number of coke oven battery stack violations (Sec. 46 Ontario Regulation 419/05) at ASI which increased in 2020 compared to 2019. From January 2020 to the end of August 2020, ASI had a total of 12,213 violations. US companies are required to meet stricter standards and are fined for opacity violations compared to those in Ontario. Currently, there are also no continuous monitors that actively sample air for PM 10 and PM 2.5 within 1 km of many residents in Bayview. Modelled data relies on assumed data and information provided by ASI including the capture efficiency of their baghouses and level of reporting of operational “upsets”.

TECHNICAL STANDARD DEVELOPMENT

The proposal will also extend the time while the MECP “develop and consult on a proposed technical standard for the integrated iron and steel sector”. Specific details of technologies and new control measures developed to reduce emissions have not been discussed with the public by the MECP or the operators in this sector. The ERO proposal states, “If the technical standard is published, extending the expiry dates will also provide time for the company to register under that technical standard for these contaminates, or to apply for new site-specific standards.” Therefore, the extension may be ineffective or unproductive in respect to the development of a technical standard that is optional and may not be realized even after the expiry of the proposed extension (ERO Proposal 019-2301) on June 30, 2023.

PUBLIC CONSULTATION AND COMMENTING

The details regarding the initial public consultation to develop Site-Specific Standards (SSS) are currently not available to the public for review. There is currently no MECP consultations or programs to educate the public on the SSS and all the factors they should consider. For effective evaluation, the information related to the development of the SSS should be available (linked) to the ERO proposal to allow for sufficient understanding of these standards before the end of the commenting period set by the MECP.

FINAL COMMENTS

Due to the current economic situation, ASI has postponed some environmental work and could further delay actions in the future. This proposal should not be approved in its entirety and the current order should not be extended for more than one year from its established expiry date until the results of the benzene measurement program are available to the public and production level established. The public should be confident through sampling data and MECP reports that ASI is within the targeted acceptable levels of benzene and suspended particulate. The MECP is entrusted with protecting the health of the public and the environment from contaminants. They should have public confidence that any violations will be enforced and there is a science based approached using real-time data to determine compliance.