The ERO proposal 019-3370 to…

The ERO proposal 019-3370 to permit Ellsin Environmental Ltd. to begin a commercial scale operation from its current operations, should not be granted by the MECP at this time. The proposal requires a more thorough evaluation of the ASI AAQM network and the MECP PM 2.5 monitor at Sault College in providing acceptable background data. There have been consistent concerns from the public for over a decade regarding the efficiency of the current air quality network at characterizing particulate levels closer to the industrial sector. Since the removal of the PM 2.5 monitor from the Patrick St. site in 2003, there has been no reliable measured data of the ambient air concentrations of PM 2.5 that could reasonably approximate the background levels in areas closer to the industrial sector.

A fundamental consideration for approval should require that background data be robust and collected from an ambient air quality network that the local MECP can be confident is reliable and accurate in keeping residents safe and protecting the natural environment. On January 21, 2019, a request was made by the local MECP office for the MECP Technical Support to assess the accuracy and reliability of the current AAQM network in Sault Ste Marie. On September 03, 2019, the local ministry provided a response from MECP Technical Support based on that request stating, “Due to limited resources and priority ranking, a definitive date for completion has not been set”. In ACLC meetings, it was stated they are in talks to consider adding monitoring devices on the east side of ASI, but it would require the development of a technical standard.

Since emissions are modelled, the current AAQM must be able to more conclusively demonstrate that predicted levels reflect the actual air quality around the industrial sector. Air quality data from ASI’s AAQM network accessible to residents living around the industrial sector is limited and does not include an air quality index. An air quality index to advise residents on the overall air quality cannot be provided without a monitor that measures PM 2.5 levels and the additional parameters once provided by the former Patrick St. location (Wm. Merrifield) near the industrial sector.

There is only one monitor in the ASI AAQM network that continuously measures PM 10. Since there is no correlation between the PM 10 levels and PM 2.5 levels, the readings and recommended air quality index provided by the MECP monitor at Sault College, do not provide useful information to residents living near the industrial sector. Due to the higher elevation and distance from the industrial sector, the MECP monitor can not be exclusively used in modelling data and should be compared to another monitor which is at a similar elevation and closer proximity to the area being evaluated such as its former location at Patrick St. (71068). The geographical circumstances of the industrial sector being at a lower elevation favours the accumulation of particulate matter closer to locations where it is being released. Despite a small population under 16,000 people and no heavy industry, the monitors in Sault Michigan have higher average PM 2.5 readings when compared to the MECP monitor at Sault College. In its last year of operation at Patrick St. site, the MECP PM 2.5 monitor recorded the highest number of exceedances compared to the any other year at the new location at Sault College.

In 2019, the MECP convicted Ellsin on multiple offences from 2015 and 2017 including altering the approved extraction methods. By altering the process without MECP consent, the modelled emissions for the pilot plant would be less accurate and the deficiencies in the monitoring network would not have accounted for any discrepancies. Current ambient air quality testing does not regularly account for chemicals specifically related to processes like tire recycling. A 2020 Q2 GHD report for ASI’s AAQM network noted the presence and an exceedance of chloroform that could be attributed to Ellsin Environmental operations. The current extraction process may not be sufficient at increased production rates to ensure that the limits are within the predicted modelled emissions. Further real-time air quality data would be required to confirm that the current process is more accurately reflecting the modelled emissions since there were changes in the accepted methodology approved by the MECP. Since the company plans to construct additional commercial facilities in Ontario, it would be important to ensure that emissions are accurately characterized since this proposal will be referenced in the future.

The MECP does not have sufficient data to conclude that background levels in the proposal represent the area around the facility. Since more time is required to develop a technical standard for the steel industry which impacts the assessment and arrangement of the AAQM network, the proposal should be referred to a later date when a technical standard has been developed and the ASI AAQM network has been reassessed by the MECP Technical Support Branch as accurate and reliable.