Greenfield Global Inc. - Environmental Compliance Approval (air)

All comments were reviewed and, where appropriate, considered as part of the technical review. The in-scope comments have been addressed as follows:

Topic 1: Concerns about the impacts on air quality, residents, the environment, odour issues, and health issues due to emissions:

Ministry Response: The proponent has assessed all significant contaminants (including hydrogen sulphide and ammonia) emitted by the facility and demonstrated that the facility can operate in compliance with Ontario Regulation (O. Reg.) 419/05 (Local Air Quality). This assessment included Air Dispersion Modelling which was completed for all significant contaminants.

Topic 2: Questions about whether the proposed limits of each air-borne contaminant in the plant exhaust will be made available, and whether there will be an estimate of the concentration of each of the air-borne contaminants that are released during normal plant operations when all engineering controls are functioning?

Ministry Response: The proponent has assessed all significant contaminants emitted by the facility and calculated the maximum concentration during normal plant operations through the use of approved Air Dispersion Modelling. This assessment has demonstrated the facility can operate in compliance with Ontario Regulation (O. Reg.) 419/05 (Local Air Quality). Any member of the public may request a copy of the supporting documents submitted with the ECA application through a Freedom of Information (FOI) request to the Ministry.

Topic 3: Concerns about the emission control systems, and how issues including equipment failure may result in elevated emissions and odours that impact residents and the environment:

Ministry Response: The proponent, with its consultants, have assessed potential risks (air emissions, dust and odour) that may result from the proposed facility, and developed methods to mitigate all of them, while ensuring compliance with existing regulations. As part of the air approval application, the proponent submitted an odour evaluation. Odours were assessed at each facility (ethanol plant and anaerobic digester) and combined. The processing and storage at the site will be indoors or in sealed tanks to minimize odour. Further, the facility is equipped with an odour management/treatment system.

The issued ECA document also contains a number of odour-related conditions that the proponent will need to adhere to at all times. These conditions include an Odour Management Plan, Odour Monitoring Program, and the development of a Technology Benchmarking Report (at the request of the local District Office).

Topic 4: Cumulative impacts and infringement on treaty rights:

Ministry Response: The proponent has assessed all significant contaminants emitted by the facility and demonstrated the facility can operate in compliance with O. Reg. 419/05 (Local Air Quality).

The Cumulative Effects Assessment in Air Approvals Policy decision was posted to the Environmental Registry of Ontario (ERO) in April 2018 and came into effect on October 1, 2018. This policy strengthens and clarifies the consideration of cumulative effects when making decisions related to ECAs and indicates when additional measures may be needed beyond current regulatory requirements.

Under this policy, no further action is required for the facility at this time. The ministry will continue to look at other contaminants, sources and geographic areas and consult with public and stakeholders as we expand the cumulative effects policy over time.

The supporting documentation submitted as part of the air and noise ECA application included the combined emissions from two (2) neighbouring facilities (Greenfield Ethanol and the Chatham-Kent Water Pollution Control Plant).

Topic 5: Lack of a baseline air quality assessment as part of the proposal:

Ministry Response: A baseline Air Quality assessment is not required for air/noise ECA applications submitted under s.9 of the Environmental Protection Act.