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March 7, 2019

RE: EBR Registry No. 013-4572. Ministry Ref No. 2707-B7KLTG – American Iron & Metal – 75 Steel City Court, Hamilton

Dear Madam/ Sir,

Please accept this submission as Environment Hamilton's formal comments regarding American Iron & Metal's application for an Environmental Compliance Approval (Air) for its facility at 75 Steel City Court in Hamilton.

Environment Hamilton has been tracking issues with environmental impacts from Hamilton's scrapyards for many years now. American Iron & Metal is no exception. Back in 2012, we submitted comments in response to AIM's original ECA (Air) application, raising concerns about the importance of ensuring that metal cutting torches do not generate air emissions, and wanting to see strong requirements put in place to ensure that the company uses best management practices to avoid the generation of drag out and dust/ particulate pollution at and near the site. For the latter concern, we also emphasized the need to ensure that, once in place, conditions set out in the ECA are enforced. To date, we continue to see significant problems with particulate pollution on-site and migrating off of AIM's Steel City Court facility into public roadways and beyond. We have also, on occasion, seen pretty horrible cutting emissions coming from this site. We have a collection of photographs taken near the site within the last year that illustrate the nature of the problems we continue to see. We urge the MECP staff reviewing this file to reach out to us so that we can send you these photos. Right now – given that this posting is on the old EBR registry site – we are unable to append photos. Please email us at llukasik@environmenthamilton.org and we will provide these pictures to you. This site continues to have SERIOUS PROBLEMS WITH PARTICULATE POLLUTION.

We are subsequently asking that conditions be added to the ECA (Air) to ensure that the company actually follows through on implementing the on-going requirements of its best management practices plan for this facility. This is that much more important given that this is site is getting larger as time goes on. We understand that AIM has acquired additional land from the City of Hamilton – including a purchase of a portion of Steel City Court itself. This means that AIM's activities are moving even closer to public roadways, and the public park and residential neighbourhood to the south of the site. We also wonder whether this expansion of the site was taken into consideration in the preparation of the emission summary dispersion model (ESDM) for the facility as the "fenceline" has essentially been moved closer to sensitive receptors. We also wonder whether the ESDM has properly accounted for the extreme level of dust generated on the roadway (Steel City Court) in and out of the site. This must be considered too. Based on the data we reviewed in the ESDM summary, the TSP levels appear to be far too low. We expect that the facility is regularly exceeding TSP limits and we are urging the MECP – the regulator – to do something about it. We have undertaken our own fine, respirable particulate monitoring along Steel City Court and have documented the highest PM2.5 levels out of anywhere in the city that we have done air quality monitoring (~ 600 ug/m3). We have one very basic and viable suggestion to make in addition to enforcing the fugitive dust BMP – we would like the MECP to require that the company create a "green shield" or buffer around their site that will help – along with proper implementation of the BMP for fugitive dust – to mitigate any off-site impacts from particulate/dust pollution. We would like the company to be required to plant a row of trees to serve as this green shield. Past operators at this location had done precisely this – but these trees need to be replaced and better maintained – there is no longer a solid green barrier in place. More must be done to require facilities like this one to minimize their particulate pollution problems – especially in light of the grow – on human health.

We are also concerned about the proponent's plans to start operating an automotive shredder at this location. Almost immediately to the east of AIM is Triple M Metals. This scrapyard operation also runs a very large shredder. We have had on-going concerns about problem emissions – blue smoke, smouldering emissions – from Triple M's shredder but have not been able to get the Ministry to do anything about it. At one point, we had a District Supervisor agree that it was a concern and that monitoring would be useful to get a better sense of the impacts of the operation. This step was never taken and that individual is no longer working at the Hamilton District Office. We continue to observe, document and report when we see problems at this plant. AIM will be setting up another shredder in this same subairshed – potentially adding further to the problem with shredder emissions. We also believe the MECP must take into account the cumulative effects of having several shredders within such close proximity.

We reviewed the ESDM summary for the facility and we have a number of concerns. The Chromium VI numbers jumped out at us and we would like to better understand whether the real numbers will be as high as these modelled values. We are also concerned about the modelled value for ferric oxide and for manganese. In the case of manganese, we note that to the east, ArcelorMittal Dofasco has had to secure a site specific standard for manganese under Regulation 419 – Local Air Quality, so we know that this is a contaminant of concern in this airshed. For all of these substances, we are also concerned about cumulative effects. AIM is located in a heavily industrialized airshed that includes multiple sources of most of these contaminants. We urge the MECP to consider the cumulative effects of these sources when evaluating whether to grant new or amended ECAs for expanded activities in the airshed. We are also requesting that, if the shredder is approved – the MECP must require actual monitoring to be done to assure the public that the facility is, in fact, operating within MECP air quality limits.

We also believe that there are other air pollutants that might be generated by AIM's shredder that have not been included in the ESDM generated as part of this current application. We found this list of additional paramters in an assessment done for Northern Metal's shredder located in Minneapolis, MN. See "Shredder Building Test Results" completed for this facility – and available via the following link: https://www.pca.state.mn.us/air/northern-metals-shredder-building-test-results. Note that not all of the contaminants tested have established regulatory limits in Minnesota. Also useful is another document associated with the permit for this facility that sets out technical justifications for the various conditions imposed on Northern Metal's shredder in Minneapolis –including limits for PM10 and PM2.5:

https://www.pca.state.mn.us/sites/default/files/northern_metals_mtg_tsd7_23_12.pdf.

It is also worth noting that the shredder at this facility is located indoors – within a LEED-certified building, no less!

Additional contaminants in evaluation of air emissions from a shredder located in Minneapolis, MN:

• PM2.5,
• PM10
• Beryllium
• Mercury
• Asbestos
• PCBs
• Dioxins/Furans
• VOCs

The information our research efforts has uncovered related to the permitting and test results for Northern Metals in Minneapolis, MN leaves us feeling that more must be done in Ontario to assess the emissions from shredder facilities like AIM's Steel City Court facility. We are formally requesting that these additional contaminants be considered in the assessment of the facility – including as part of our request for air quality monitoring on-site - to ensure that human health and the environment are protected.

Another document that we found in our research points to the real risk of mercury emissions from automotive shredders. A study undertaken by the Ohio Environmental Protection Agency confirms this reality: onlinelibrary.wiley.com/doi/pdf/10.1002/ep.670210412. We urge the Ministry to thoroughly assess the AIM Steel City Court shredder to ensure that there are no issues with mercury emissions which, we understand, can result when not all mercury switches are removed from automotive bodies prior to feeding them into the shredder.

We also have questions and concerns about the generation and storage of shredder fluff at this site. Where will this material be stored? Will limits be imposed as far as the amount of this material that AIM will be allowed to stockpile onsite? Is there any fire risk associated when it comes to storing this material in piles? Further, while this ECA is a permit for air and noise, we worry about the shredder fluff itself and any contaminants it might contain. We note that in the State of California, extensive work has been done to assess and set rules for the safe handling/management of automotive shredder fluff, and the effective "fixing" of this material before it can be used as landfill cover material. More details are available on the California Department of Toxic Substances Control website and, more specifically, the section that deals with metal shredding facilities and wastes – see: https://www.dtsc.ca.gov/HazardousWaste/MetalShredderPortal.cfmConcerns

We thank you for the opportunity to comment on this application.

Lynda Lukasik, PhD
Executive Director
Environment Hamilton
TEL: (905) 549-0900
llukasik@environmenthamilton.org

cc Environment Hamilton Board of Directors