Thank you for giving…

Thank you for giving Ontarians the opportunity to provide input into ArcelorMittal Dofasco's site specific standards (SSS). I understand that the Suspended Particulate Matter for Dofasco expires on the last day of December 2020. The last day of commenting for this Proposal is December 14, 2020. This is very close to the Xmas holiday period. I have concerns that public input and consideration may not take place in a meaningful manner due to this abbreviated input time.

The Ministry needs to phase in more stringent limits and require actions that lead to continuous improvement so that Dofasco works towards meeting the Reg 419 limits for all three of these contaminants (benzene, suspended particulate matter, and manganese) over the next 2.5 years.

I noticed the Ministry is not proposing an update to the action plans for Suspended Particulate Matter (SPM). I ask that a reduction update to the action plans for SPM is included in the extension. Dofasco’s limits for SPM have been at the same level for 10 years. There is a need for constant improvements and that needs to be prescribed by the ministry in writing to the industry. It’s time to reduce the limit from 177 ug/m3 to something closer to the Reg. 419 limit of 120 ug/m3.

Another issue for those of us in the community is that the SPM is combined. I would like to see a breakdown of PM10 and PM2.5 in limits. Enough data exists regarding the two sizes of the particulate & it’s health effects and combining them is outdated. 3 of the HAMN monitor stations collect data regarding PM2.5 and 7 of them collect data on PM10 not mentioning monitors on the industry site that you have access to.

I am asking you to update the action plan regarding making the levels for Benzene in the SSS more stringent. This known carcinogen in present in high concentrations in Hamilton as per the Ministry’s Cumulative study. The dangers are great and a concern to all that live in the yellow and purple zone that stretches from Hamilton to Burlington to Stoney Creek and Dundas. I would like to see another reduction for the period of Jan 2021 to Jun 2023. It’s been 5 years that the level of this contaminant was brought down to 10 ug/m3 from 11.1 ug/m3, it’s time to bring this closer to the 0.45 ug/m3 goal of Reg. 419 limit.

The SSS for Benzene does not expire until June 2021, the Ministry must take more time than Dec 31, 2020 to extend the SSS and consider making the limits LOWER for Benzene.

The SSS for Manganese does not expire until June 2021. The Ministry must take more time than Dec 31, 2020 to extend the SSS and consider making the limits LOWER for Manganese.

Community liaison committees (CLC) are important in ensuring transparency about steel operations in Hamilton. This proposal does not indicate a commitment to continuing these committees during the extension of the SSS. We need to see regular updates on the progress of the industry in meeting pollution requirements which they provide through their quarterly reports to the CLC. This is really important because these are harmful chemicals and we should have a right to know what is happening. This commitment needs to be confirmed in the mandate for this SSS.