The exemption for Ellsin…

The exemption for Ellsin Environmental should not be approved until a more representative ESR is prepared. The 2019 report is based on data which has been selected since it is all that was available. However closer scrutiny will show that the data used is favourable to the company and detrimental to the residents of the surrounding area.

The ESR used data from the two Algoma Steel stations and the AAQI station located at Sault College to determine the background levels of contaminants of concern. When the background levels were added to the modelled predictions the company showed compliance with the regulations/guidelines. It is unlikely that this is a realistic conclusion.

The PM 2.5 background level of
10.6 ug/m3 was based on the AAQI station data. This site is 6.5 km from the facility and at a bearing not commonly affected by prevailing winds. This can be confirmed by analyzing the wind roses published on the Algoma Steel website. It would be more significant to consider that the modelled PM 2.5 concentration from the 2019 Algoma Steel ESDM report. This report shows 33.89 ug/m3 as a POI value for PM 2.5 representing 135.57% of the 25 ug/m3 limit.

The Ellsin facility is within one kilometre of the steel plant boundary and at a more usual wind direction. Using more realistic background levels would most likely result in both the PM 2.5 and PM 10 concentrations exceeding the criteria.

Before the exemption regulation is considered a new ESR should be required using data from field samples collected in close proximity to the facility. While not indicative of long term trends it would provide data to compare with that used in the report on which the proposed exemption is based. A different result is likely.