As a regular commenter…

As a regular commenter related to Algoma Steel ERO postings I find this one extremely frustrating.

What am i supposed to comment on? Virtually nothing is provided in this posting except a list ot facilities and contaminants. The supporting materials were provided after a delay forcing an extension of the comment period. However even those are limited and in fact are in error.

The application has a box checked indicating that no Upper Risk Thresholds (URT) were exceeded. However my calculation confirmed by an Algoma environmental manager shows the B(a)P exceeds the URT.

The ESDM shows exceedences for all four of the parameters for which Site Specific Standards will be applied. Apparently this is not within the scope of this ECA application and a subsequent posting will be issued for the new standards. Isn't this putting the cart before the horse?

Without details on how these contaminants are to be controlled it is impossible to comment on the effectiveness of the pollution control units.

For example:

Will the electric arc furnaces (EAF) be allowed to operate if the associated baghouses are out of service.

What systems are in place for the potential but likely generation of dioxins and furans.

What controls will be in place to ensure the scrap feedstock is cleaned.

Where is the continuous improvement that is supposedly the hallmark of
Reg 419/05 when all of the SSS are going up. (Algoma's claim that this is due to the changes in the model is poor reasoning - the reality is that their previous numbers were in fact underestimating the actual POI on the community).

It pains me to conclude by saying that this posting makes a mockery of the ERO process.