• Because of the large…

• Because of the large numbers of chemicals entering the thermal oxidizer 24/7/365, stack testing should be required by MECP on a regular basis, including testing for dioxins and furans. The health impacts from poorer local and regional air quality in this area from an expansion of this magnitude must be assessed, with attention to releases of numerous additional chemicals, some of which with no POI limits. Long-term exposure involves both direct inhalation and secondary exposure to emissions from dust, and soil buildup.
• It is also of real concern that the company has applied for a “new acceptable limit” for contaminants with no POI limits but with predicted impingement concentrations above MECP standards, and one above its benchmark. This again is a surprising element of previous ECAs. Any proposed new POI limits must be health-based
• The Ministry should require a Cumulative Effects Assessment of combined exposures from this source, and with the aggregate emissions from adjacent chemical facilities along Coronation Drive, e.g NOx. Section 3 of the Statement of Environmental Values established under the Environmental Bill of Rights requires the Ministry to take reasonable steps to consider cumulative effects.