*NB - There is nothing in…

*NB - There is nothing in this submission to prevent public posting of this comment on the ERO.

November 15, 2020

To the Application Processor,

Please accept this submission as Environment Hamilton’s formal comments on the proposal submitted by Bartek Ingredients for an Environmental Compliance Approval with limited operational flexibility for the proponent’s facility located at 421 Seaman Street in the City of Hamilton (Stoney Creek).

We have reviewed the file associated with this proposal. The information included in the file has generated some questions and concerns for us. More specifically, we have reviewed the Emission Summary & Dispersion Modelling (ESDM) report that was completed as part of this proposal. The summary chart for that modelling work shows that the facility’s modelled levels of suspended particulate matter (SPM) are at 76% of the MECP maximum allowable level. Seeing a level this close to the maximum allowable level is cause for concern. We would like the MECP to require the company to monitor actual levels of SPM being emitted from this facility. Further, we are very concerned about inhalable, respirable and ultrafine particulate pollution. We are requesting that the company be required to measure particulate pollution levels from this facility, including inhalable, respirable and, if possible, ultrafine particulate levels. These components of SPM are the elements that are of greatest concern where potential for negative impacts on the health of human and other living organisms is concerned.

Several other substances were modelled at levels that, we believe, justify a call for actual monitoring to be required. These include nitrogen oxides and flourides – which both were modelled at almost 60% of the maximum allowable limits. We also note that sodium hydroxide was modelled at 44%. We are requesting that the MECP require Bartek Ingredients to undertake air quality monitoring to provide the public with assurances that the company is capable of operating below MECP maximum allowable levels for the pollutants it releases from this facility.

We also note that the proponent was required to undertake an acoustics assessment. More specifically, the company hired a consultant to undertake the assessment, and the assessment report concluded that the ‘noise predictions for the existing equipment show that the sound levels are above the MECP sound level limits’ and further ‘(T)o address this, a Noise Abatement Action Plan (NAAP) has been developed for the installation of a discharge silencer for two of the Dust Blowers 3 and 4’. Based on the assessment, implementation of the Noise Abatement Action Plan – including the installation of this noise abatement equipment, will ensure that the company is in compliance with provincial noise guidelines. We are requesting that MECP ensure that the company is required, as part of this ECA approval, to implement the measures set out in the NAAP in order to ensure noise issues from the facility are mitigated.

Finally, while we recognize that this proposal does not apply to wastewater handling at this facility, we do want to note that we are very aware of the issues that emerged this past summer at this facility with containment of process liquids and/or wastewater and the fact that the MECP is involved in looking more deeply at challenges that resulted in off-site impacts in ditches and creeks surrounding the plant. This situation concerns us deeply and speaks to potential problems with on-going preventative maintenance at this facility – including upkeep of process liquids and wastewater infrastructure. Given this situation, we would like assurances that the facility’s air pollution control infrastructure systems are being properly maintained and upgraded as warranted. We are formally requesting that, as part of this ECA (Air & Noise) approval process, that the MECP carefully inspect the air pollution control infrastructure at this facility in order to provide the public with the assurance that equipment and technology is in place to properly and rigorously control air emissions from this facility, and that this equipment and technology is being regularly and properly maintained by the proponent.

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

Yours truly

Lynda Lukasik, PhD
Executive Director
Environment Hamilton
TEL: (905) 549-0900