The approval of an extension…

The approval of an extension for AMD’s SSS for benzene and benzo-a-pyrene should include a condition to report the long-term trends in cokemaking performance. Cokemaking performance can be cyclical based on various factors, including the level of coke production required for operations and decreases in performance overtime due to age and maintenance schedules. It is important for the public to see the improvements overtime, and therefore these trends should be required to be presented in CLC meetings. At the last AMD CLC meeting on April 26, these long-term trends were omitted, and requests were made by CLC members to include these in future meetings subject to AMD approval. This data allows for a comparison to previous periods while providing assurance that there are long-term continued improvements that are not a result of potential cyclic patterns or temporary changes in best management practices (BMPs).

As a former certified emissions auditor for a third-party at Algoma Steel Inc. (ASI) in Sault Ste. Marie, I acquired a thorough understanding of the processes and limitations in mitigating these emissions. The inspection and full auditing of coke oven batteries by ministry staff for cokemaking performance is limited. ASI has a third-party auditor who conducts most of the daily emissions auditing. This contrasts with AMD and Stelco, who have their own employees who perform the daily emissions auditing. Although not impossible, it is unusual to see high performance efficiencies such as the 0.00% lid leaks claimed for entire quarters according to AMD. The MECP in Hamilton should require some independent monitoring by a third-party of these emissions at AMD to confirm continued improvements are being made while verifying the results reflect the data presented in their CLC meetings.

Since the MECP intends to have all steelmakers meet the same emissions standards, the presentation of cokemaking performance should also be the same. ASI provides long term trends and a format that is easier to see how individual stack opacity performance compares to the MECP limit of 20% by using a 30-day rolling daily average. Quarterly averages presented by AMD make it difficult to comprehend how each stack is performing every month relative to the limit. Emissions are modelled, and audited emissions represent a source of real-time data that is not influenced by assumptions made by modelled emissions. This information can assist the public in understanding the potential levels or any impacts of these contaminants as well as the progress in mitigating them until the MECP has developed a technical standard.

The federal and provincial government provide funding, incentives and loans for infrastructure upgrades and repairs which can include coke oven batteries that are a primary source of these contaminants. The SSS for AMD was expected to end based on the 10-year maximum initially conveyed by the MECP. This emphasizes the importance of presenting long-term performance data that demonstrates consistent progress. Performance trends provided to the CLC will aid in validating information conveyed by AMD regarding continual improvements over time. The data will be more informative and more easily understood by the public regarding the industry’s progress, by standardizing cokemaking performance data presented at CLC meetings. This will also ensure public confidence in the effectiveness of the MECP's compliance based approach for the entire steel sector and the justification for extending an SSS until the development the MECP's technical standard.