Hamilton Public Health…

Hamilton Public Health Services, Air Quality Coordinator Comments on ERO Posting 019-8263

April 5th, 2024

Re: Environmental Registry Comments from Healthy Environments Division, City of Hamilton for ERO Posting 019-8263

Dear Sir/Madame,

Thank you for the opportunity to comment on Triple M Metal Corp’s (Triple M) proposal for a new Environmental Compliance Approval for the operation of a mobile metal recycling and processing facility, equipped with one screener.

The City of Hamilton’s Health Hazards and Vector-borne Diseases Program exists within the Healthy Environments Division (HED). The Healthy Environments Division of the Healthy and Safe Communities Department within the City of Hamilton is mandated by the Province of Ontario’s Ministry of Health and Long-Term Care (MOHTLC). One goal of Ontario Public Health Standards: Requirements for Programs, Services, and Accountabilities, (2021) is:

“To reduce exposure to health hazards and promote the development of healthy built and natural environments that support health and mitigate existing and emerging risks, including the impacts of a changing climate.”

The HED maintains Ontario Public Health Standards: Requirements for Programs, Services, and Accountabilities, (2021) mandated by the Province of Ontario as well as Healthy Environments and Climate Change Guideline, 2018.

The HED is working towards enhancing public health capacity to address risk factors in the environment, identify and enable mitigation of risk factors related to environmental exposures that can contribute to the burden of illness, as well as facilitate upstream, preventative strategies for advancing healthy built and natural environment.

The City of Hamilton’s Health Hazards and Vector-borne Diseases program (“the Program”) within the HED would like to submit the following comments for the proposed Triple M mobile metal recycling and processing facility ECA:

Concern regarding additive noise and air impacts

The ECA application submitted involves the use of a mobile metal recycling and processing facility, which is equipped with one screener (“mobile screener”). Based on the Emissions Summary and Dispersion Modelling Report (ESDM), the proposed mobile facility will operate at “various Triple M facilities and other locations in Ontario”. This may include the Triple M site located at 799 Parkdale Avenue North, Hamilton, ON (“Parkdale facility”).

The Program is concerned with the additive impacts of operations at the Parkdale facility in conjunction with the use of the mobile screener at the site. The Acoustic Assessment Report (AAR) for noise impacts from the Parkdale facility does not include the mobile screener as a noise source. The Program has previously received complaints regarding noise from the Parkdale facility as a disturbance to community residents. The addition of a mobile screener to the Parkdale facility may create additional noise for community members who reside in proximity to the site, especially at nighttime.

The Program notes that no AAR was provided for the mobile screener when supporting materials for the ECA application were requested.

The use of a mobile screener at the Parkdale facility is also a concern for air emissions. While the ESDM report for the mobile screener shows a setback distance of 450 meters for the use of the mobile equipment, it does not include other sources on site which may contribute to air emissions and increase the setback distance. In addition, the ESDM report for the Parkdale facility does not include the mobile screener as a source. As the ESDM presents air impacts from the worst-case operational scenario, it should include the air impact from all sources that may be operating simultaneously at the Parkdale site, including the proposed mobile screener. The operation of the mobile screener at the Parkdale facility may increase the maximum Point of Impingement (POI) concentrations of contaminants that are expected to be emitted from both the Parkdale facility operations and the mobile screener, which include: Particulate Matter, Beryllium, Cadmium, Chromium, Cobalt, Manganese, and Nickel.

The Program recommends that updated ESDM and AAR reports be prepared by Triple M Metal Corp that show the additive impacts of using the proposed mobile metal recycling and processing facility at the existing Triple M Metal Corp Parkdale Facility in Hamilton, ON.

Use of composite meteorological dataset for air impacts modelling

As a part of the ESDM modelling for the mobile metal recycling and processing facility, composite meteorological data from across Ontario was used as an input in the AERMOD model. If the mobile screener is operating at the Parkdale facility, the composite dataset may not be representative of the meteorological conditions at the site. This is a particular concern due to the Parkdale facility’s close proximity to Lake Ontario and possible lake effects. As such, the setback distance of 450 meters determined in the ESDM may not be a representative setback distance at this site. The Program recommends that the site-specific meteorological data be used to determine the air emissions setback if the proposed mobile screener is operating at the Parkdale facility.

Conviction of Triple M Metal Corp for Shredder Explosion

The Program notes that Triple M has been convicted of multiple environmental charges linked to shredder explosions at the Parkdale facility in Hamilton, ON. The shredder explosions are the source of additional noise disturbances for the surrounding community that has ongoing issues and complaints relating to noise pollution from Triple M and other industrial sites. Given that the Triple M Parkdale facility has recently had issues with noise related charges, the Program recommends that the MECP take the company’s previous non-compliance into consideration when issuing an ECA.

In summary, the Program has concerns regarding the:
1. Additive noise and air impacts from operations of the mobile screener at the Parkdale facility;
2. Use of consolidated meteorological data that does not take into consideration lake effects from Lake Ontario at the Parkdale facility;
3. Consideration of previous non-compliance for noise related issues.

Thank you very much for your review and consideration of the aforementioned concerns. The Health Hazards and Vector-borne Diseases Program continues to look forward to working with MECP to improve air quality in Hamilton and across Ontario to ensure the protection of public health.

Sincerely,

Program Manager
Health Hazards & Vector-borne Diseases
Public Health Services - Healthy Environments Division
Healthy & Safe Communities Department
City of Hamilton