Coronation Organics…

Coronation Organics Processing Centre and Anaerobic Digester - 2683517 Ontario Inc.
ERO: 019-1444 / 019-1446
I offer the following comments on the application package for package. Unfortunately, my review was very limited due to the large amount of material and the short time to review it. These comments are based upon the Design and Operation Report and the Emissions Summary and Dispersion Modelling (ESDB) Report which are both dated December 2019 and which were in the ECA application for public reviewing obtained from the Province of Ontario.

Questions / Comments from the Design and Operation Report – ECA Application, December 2019, Prepared by CHFour Biogas for
Section 3.1 Paragraph 3 states “The materials accepted at the OPC will not include human bio-solids. At some point, the facility may decide to accept SSO material that could possibly contain diapers.”.
The first sentence states that the facility will not be accepting bio-solids, however, the second sentence (and subsequent statements) state the OPC will be accepting diapers, which in my limited experience are usually found to contain biosolids. At some point in the future, 100% of the feedstock of this facility could ultimately consist of dirty diapers. In this situation, are the conclusions of the report, particularly as they relate to odours, valid?

Section 3.4 States “The trucks coming and leaving the site will generally travel south/north to/from Highway 401. Given that the area is zoned for heavy industrial use, it is not anticipated that the increased truck traffic will cause a nuisance”.
Nuisance from truck traffic should have been anticipated by anyone familiar with the location of the site. While the report is correct in stating that the proposed site is zoned for heavy industrial, the industrial area is completely surrounded by residential areas. I can see no north/south route from the 401 to the proposed site, or any other route, that does not require the trucks to pass by houses, schools or parks. What is the proposed trucking route – other than a vague description - it is not provided in any detail in the report (e.g., shown on a map)? Did the person preparing this report actually travel along the proposed trucking route to determine the nature of the areas that the trucks would have to pass through?
While the report indicates that a secondary noise screening assessment was carried out at the point of reception (and the material is provided in the ECA Application, although I gave it only a cursory review), there is no indication that any assessment was done on the impact caused as the trucks moved through the surrounding residential areas.
The ECA Application should be updated to include an assessment of the impact upon the surrounding communities of the noise, odours, particulate or any other environmental impacts caused by transportation, prior to any approval being considered.

Section 3.2 Site storage of feedstocks
This states that “Materials received in the OPC are process and moved through the facility in a timely manner. Putrescible materials are processed immediately and non-putrescible materials are processed within 72 hours of receipt.”
This describes normal operation. What happens in the case of equipment malfunction or other conditions (electrical blackout) lead to extended conditions where materials already received on site cannot be processed within the specified timeframes (immediately or 72 hours)? Is there possibility that this will lead to impact on the surrounding area (particularly odours)? In these cases are all emissions from the facility shown within required limits? If not, by how much will they exceed the limits?

Section 2.2 Anaerobic Digestion
This section describes a flare and pressure release valve that will operate to deal with overpressure situations within the digester. While I am not familiar with digester code, I anticipate that these are required by code to prevent overpressure conditions that could lead failure of structure of the digester itself.
I would expect that a competent and experienced engineering firm could design a process control system keep the pressure within its safe operating range and not require the use of these devices in normal situations. In the case of process upset or failure of the process control system (perhaps as a result of operator error, programming error in the control algorithms, equipment malfunction or cyber-attack directed against the process control system), the pressure within the digester could exceed the limits which require the operation of either the primary or secondary pressure relief mechanisms.
In the case where a primary relief mechanism (the flare) is unavailable or insufficient, and the secondary mechanism (PRV) operates, the gases from the digester will be released directly to the atmosphere. The ESDM report states in Table I that “Emergency Emission from PRV” will result in Total Reduced Sulphur (TRS) emissions that are 9,485% above the ministry point of impingement (POI) limit for odour and 5,735 % above the ministry POI limit for health.
Clearly this raises potential concerns for people in the surrounding area. While this is not expected to be a normal occurrence, this raises following questions:
- With what frequency is it expected that gases will be released to the atmosphere via the PRV?
- Are there be any limits specified within the permits regarding the frequency with which the PRV operates?
- Where is the point of impingement (POI) for the PRV located? Is it on the site (the ESDM describes the POIs but does not provide a map of their location).
- What impact is a release cause by operation of the PRV expected to have on workers in the surrounding locations, and in the nearby residential areas?

Section 2.3 Gas Demonstration Plant
This proposes an R&D development where a new process will be scaled up, presumably to demonstrate commercial viability. Clearly the environment impact of this is quite uncertain given that this project is currently at lab-scale only, and the report states that odour control will be increased during scale up. Will separate permits, or permit amendments, be required to ensure that the appropriate environmental measures are put in place prior to any increase in scale of the activities (i.e., as the process grows)? Without this, there is a risk that the need to increase odour control, for example, will only be identified following scale up of activities and complaints from the neighbours.

Questions / Comments from the the Emission Summary and Dispersion, Modelling ESDM Report (AERMOD with SiteSpecific Meteorological Data)
Section 2, Initial Identification of Sources and Contaminants, page 11, in the description of the 1st method used to determine significance of the contaminant, there is a statement “The site is located in a rural setting and ….”. The site is actually located in an industrial area within an urban setting, as anyone who is familiar with the site would know. Does this mistaken characterization of the setting change any of the results of the report? Does this incorrect characterization it change any of the conclusions? Did anyone involved in writing this report or drawing conclusions visit the site to confirm the actual site conditions?