December 14, 2020 Client…

December 14, 2020

Client Services and Permission Branch
135 St Clair Ave West
1st Floor
Toronto, ON
M4V 1P5

Re: ERO 019-2297 Approval of site-specific air standard ArcelorMittal Dofasco G.P.

Dear Sir/Madame,

Thank you for the opportunity to comment on the proposed Approval of a site-specific air standard for ArcelorMittal Dofasco G.P.

About the Health Hazards and Vector Borne Disease Program

The Health Hazards and Vector Borne Disease Program, Healthy Environments Division of the Healthy and Safe Communities Department within the City of Hamilton (herby referred to as HHVBD) 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, (2018) is:

“To reduce exposure to health hazards9 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.”

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

The HHVBD 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.

Discussion Points

The HHVBD supports the extension of the site-specific standards for ArcelorMittal Dofasco G.P integrated iron and steel facility in Hamilton. The HHVBD also strongly recommends the Ministry of Environment, Conservation and Parks (MECP) to consider and require the following recommendations:

Ensuring Transparency and Public Participation

The HHVBD staff have participated since the first approvals of several site-specific standards in Hamilton and wish to continue to do so. The MECP is strongly recommended to continue to require that any company registered within the site-specific standard compliance option continue to host, at a minimum, public meetings on a quarterly basis. At these meetings companies shall present information on their action plans for continuous improvement in reducing emissions that have required them to request a site-specific standard. Since the COVID-19 pandemic these meetings have been hosted virtually and have been a viable option and should continue to do so.

Ensuring Continuous Improvement

The HHVBD strongly recommends the MECP to continue its historical efforts to require continuous improvement for reducing emissions, especially as it relates to harmful carcinogens including Benzene and Benzo[a]pyrene.

Furthermore, MECP stated in its original Instrument Decision Notice (EBR# 012-4675, 2016) that:

“In an effort to facilitate a future assessment of new potential technologies and approaches to reduce benzene air emissions, this site-specific standard will expire after five years (i.e., the benzene site-specific standard be from July 1, 2016 to June 30, 2021).”

Currently ERO# 019-2297 states:

“The facility is expected to continue its efforts to reduce benzene emissions to as low as reasonably achievable”

The HHVBD strongly recommends the MECP require that before any extension or renewal of the site-specific standard is approved, that any company requesting the extension also submit an action plan, based on a robust scan of new potential technologies, provide details on how the company plans to achieve ongoing continuous improvement for all the emissions that require the site-specific standard.

Thank you very much for your time. The HHVBD 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 Yours,

Program Manager
Health Hazards and Vector Borne Disease Program,
Healthy Environments Division
Healthy and Safe Communities Department
City of Hamilton