Opening Preamble…

Opening Preamble
“Cumulative effects” ought to take into consideration health and environmental effects to plants, animals and fish as well as humans
There should specific reference to consultations and information sharing with other ministries on the cumulative effects in E.C.A.’s. Not only would this provide the public with the assurance that all ministries are aware of ongoing research but specifically in this case that the Ministry of Labour is advised.
Environmental working groups must consult with all First Nations groups on the traditional territories of their study area. It is not good enough for just “some First Nations groups” to be included.

Proposal Details
The cumulative effects policy should apply to all existing facilities as well as those expanding and new facilities.
The selected contaminants are known carcinogens such as Benzene, and Benzo (a) Pyrene and any other chemicals that may be found during independent site specific analysis which are known to be carcinogenic.

Action Levels and Management Actions Comments and questions
When emissions are detected outside the industrial property line

No Action Level - below AAQC . What happens if all industries apply for a site specific standard because they cannot meet this criteria.?

Action Level I At AAQC level to 10 X AAQC
No further action by industry
Tacit acceptance of this level could mean that industries were allowed to routinely operate at 10 X the AAQC and as worded that makes no sense to me. All “Industries” need to monitor and provide assurance that they can operate most of the time with a process capable of producing “emissions” below the AAQC X 10 limits during operating hours .
Triggers periodic evaluations by MOE
Unannounced spot checks by MOE should occur during any of the posted hours of operation on a regular basis.

Action Level 2 to 100X AAQC
All facilities whether existing, expanding and new must have a “technology benchmarking report”. The phrase with “some exceptions” should be deleted and replaced with site specific comments as necessary.
The word “may” should be deleted so that the sentence reads “best available pollution control methods for the removal of Benzene and Benzo a pyrene and other site specific chemicals known to be carcinogenic.”
A time limit to achieve “ no action or action level 1” on a regular basis should be imposed by MOE ..

Action Level 3 above 100 X AAQC
This is problematic as it refers to accidental failures with Benzene and Benzoa a pyrene removal . Notice of accidental failures occur after the fact. While existing industries must grapple with this issue it makes sense that when applying for approval of expanding facilities that they must immediately achieve the Action Level 1 or lower. New facilities should not be given the option of a site specific standard but be required to use methods which meet lowest possible emission rates. If this requires incorporating global initiatives then that should be the benchmark.
In the Hamilton area industries often quote wind direction when attempting to minimise the effect of accidental emissions of any sort. Residents know that the wind direction is both capricious and dependent on time of day and temperature.

Comment re Independent monitoring
During community discussions it has become clear that citizen organised independent and mobile emission monitoring is becoming essential. Consideration should be given to how that might be achieved.

Further comments re benzene and benzo a pyrene emissions within industrial properties
During the course of community discussions it came to my attention that since these standards only apply to Air levels at the site boundary the health of industrial workers on these sites is not taken into consideration. This is one instance where the MOE should provide the Ministry of Labour etc with their research and intended actions re cumulative effects of benzene and benzo a pyrene.
It also underscores the importance of water runoff and water treatment monitoring at this type of facility.

[Original Comment ID: 212375]