Timco’s New ECA First of…

Timco’s New ECA

First of all, I would like to express that Timco’s ECA be revoked and not renewed. Between the MOE
and the County of Brant the costs for the taxpayers must be staggering. This is foremost a full
shutdown. Enough is enough. Constantly dealing with odours on a daily base is taxing & tiresome.
Sometimes Odour Complaint forms have not been processed and given for odour complaints to the MOE
by Timco. In the past when calling Timco for odour concerns individuals have being verbally abused.
Calls & emails just go to the MOE and the County of Brant now. Not at all to Timco. Who wants to be
verbally abused and swore at.
Open doors left open for long period of times showing no negative pressure loss in the building.
Timco’s computers were not working we were told.
Other times doors left open for long period of times. Information given to the MOE. Nothing done.
Timco’s doors been open for an extended periods of time totally denied by Timco at the last open
house with everyone present.
Timco in the past has been so untruthful many times how can they be trusted.
Source test results are based on the material that Timco wants to produce the day of the source
test. For the days of really bad odours nobody knows the material Timco is producing, the
temperature of the boiler and the product that Timco is working on.
County of Brant has a by-law about bones being boiled processed. Timco states boiling temperature
between 140-180F degrees. Technically not being boiled. When MOE is not around what is the actual
boiling temperature. No one knows only what Timco tells everyone.
Timco had an open house for the public on March 20/19. With all of the people in attendance it once
again had proven that the odour concerns from Timco have not been resolved. It has never stopped.
New neighbour’s had shown their frustrations with the odours & noise. There were many heated
exchanges.
Timco is asking for their ECA to be amended to allow the installation on a new boiler & two water
cooling towers.
Why are we making comments on something that has already being built, installed and being used? We
now find out there maybe venting issues which were not approved by the MOE.
The MOE should have taken measures against Timco for the installation of this equipment and being
used before any approvals have been given.
This is what took place years. Same occurrence with the building of the Bio-filter
Article from Brantford Expositor:
Two weeks ago, ministry officials caught the company attempting to install a bio-filter without
approval. The company immediately ceased construction upon demand, but the matter remains under
investigation.
More articles of Timco’s past history being untruthful:
ST. GEORGE – Edible oils processor TimCo Foods and its president have been fined $8,000 after
pleading guilty to charges in connection with the improper use of the company’s sewage works.
TimCo, which renders fat trimmings from area butchering operation into edible oils, lard and tallow
at its St. George plan, pleaded guilty last week in Ontario Court in Brantford to one charge under
the Ontario Water Resources Act of operating its sewage works without ministry approval.
The company was fined $3,000 for the violation.
Company president Raj Selvaratnum was fined $5,000 after pleading guilty to a charge of providing
false information to the ministry.
"Both are significant and serious charges," Kate Jordan, spokeswoman for the Ministry of the
Environment, said Monday.
Another Article from MOE when Timco told everyone at the open house denying any hydro loss when
there was an ice storm where nobody had hydro in the area.

Archived Court Bulletin
Company Fined $7,500 For Non-Compliance
April 11, 2016 9:00 A.M.
Ministry of the Environment, Conservation and Parks
Brantford - Timco Foods Limited and company director, Rajkumar Selvaratnam pleaded guilty to two
offences. The company was fined $7,500 plus a suspended sentence and Mr. Selvaratnam was issued two
suspended sentences for failing to comply with two conditions of the company's Environmental
Compliance Approval (ECA), contrary to the Environmental Protection Act (EPA).
The company operates a rendering facility in the County of Brant. The facility operates under an
approval which governs the use of a biofilter and maintaining a negative pressure facility
environment, in order to remove odorous contaminants from air emissions prior to discharge.
Conditions require that the company to notify the ministry of a loss of airflow over the biofilter
in writing within two business days of an event and also to monitor and record negative pressure
measurements every five minutes, respectively.
The ministry received a complaint that there was an odour in the area. An investigation revealed
that there was no external power from Hydro One to the facility for approximately seven hours, but
this had not been reported to the ministry.
The company and its director were each convicted of two offences. The company was fined $7,500 plus
a victim fine surcharge of $1,875 and Mr. Selvaratnam received two suspended sentences.

How can anyone know what is the truth?
Timco is asking for changes to production. At the open house it was quite apparent there was so
much anger and frustration as the odours have never ceased.

If the MOE will not rescind the current ECA for Timco and not renew Timco’s ECA this would be the
maximum allowed on the new ECA.
I am requesting that Timco’s production be scaled back to produce the minimum amount of product to
keep the biofilter bed active. During this course of a 6-month period the beds can be changed and
wood chips be added.
During this course of time Timco can come up with a different plan of action beside another raising
up of the stack to combat odour concerns as the last time when the odours occurred after the new
biofilter and its original stack was installed.
It was at the first design of the biofilter and its stack that it was discovered that there were
still odour concerns. With the raising of the stack to an all-time height the odours still existed.
New larger biofilters needs to be addressed, designed and built and the old ones removed. Once
Timco has addressed all of the concerns and there have been no odour or noise concerns the
allowance of a 10% increase. When this being allowed a source test to prove that there are no odour
concerns. Someone from OMFRA present to be able to go through all of Timco’s products to see which
product can be put through the source test. Not the choice material to be determined. OMFRA chooses
the material.
Once this has been completed and there are no odour concerns allow Timco another increase of 10%
doing the same process as before with OMFRA present going through all of Timco’s products to be
able to go through all of Timco’s products to see which product can put through the source test.
Not the choice material. OMFRA chooses the material.
All the gauges showing boiler temperature, filter bed, stack temperature negative pressure on the
building must be analog & digital.
Security cameras be installed at every gauge digital & analog with the recording sent to a computer
showing the times and dates with a 30-day recording. The MOE and The County of Brant By-law
enforcement officers must be granted permission to be able to receive the recordings and view the
recordings at the Timco if there are any concerns about odours or noise. This way the type of
product and the temperature of the product being processed canbe monitored.
Security cameras installed at every door, especially any garage doors. The recordings sent to a
computer showing the times & dates with a 30-day recording. The MOE and The County of Brant By-law
enforcement officers must be granted permission to be able to receive the recordings and view the
recordings if there are any concerns about doors being open.
On the new ECA it must be documented the MOE must work with the County of Brant and its by-law
officers and the County of Brant Health Unit explaining to the County of Brant and the County of
Brant Health Unit on what material is being processed, the temperature, the quality and the
finished product.
Security cameras installed on the production floor showing production and the material being
processed with the recording sent to a computer showing the times and dates with a 30-day
recording. The MOE and The County of Brant By-law enforcement officers must be granted permission
to be able to receive the recordings and view the recordings at the Timco if there are any concerns
about odours or noise. On the days of any odour concerns OMFRA must be called in to inspect the
quality of the product to see if this is a cause of the odours.
All new computers installed showing the negative pressure in the building at all times. Excuses
such as broken computers should not be tolerated. All new computers showing analog & digital
recordings on all gauges for a 30-day period.
A call center 24/7 for 365 days a year that will answer the phone taking any noise & odour
complaints if Timco does not answer the phone. No voice recordings will be permitted. In the case
of hours when no one is present at the Timco plant the call center will call Timco’s manager or
competent staff member that within 60 minutes of receiving the call someone must go to the Timco
Plant to determine the cause of the complaint and make out a report to the MOE before leaving the
plant.

All in all, we are tired of this. This is our personal time away from work and we are now once
filling out EBR comments which sometimes we feel go unheard.
The best way to save all of this time and for everyone to enjoy their lives with no odours and the
thousands of taxpayer dollars wasted on this is to shut Timco down and take away their ECA. It is
not working. Whatever attempts Timco has made in the past for odour concerns it is not working.
Since 2011 enough is enough. Take away the ECA and let us move on with our lives