To: Environmental Registry…

To: Environmental Registry of Ontario

Subject line: Air Quality Peer Review: ERO 019-2771

Dear ERO Representative,

This letter is to request the Ministry of Environment and the Government of Ontario investigate thoroughly the concerns we have with the ERO submission No. 019-2771, which is an Environmental Compliance Approval (Air) application from Digital Specialty Chemicals Limited (aka Entegris).

Our request is made based on an independent peer review we commissioned regarding the ECA application submitted by Digital Specialty Chemicals Limited. The details of this review are summarized further below, and the full review is attached. We request that this report be kept confidential.

Our communities have long expressed valid concerns to the ERO, and to City and Provincial government officials, about the emissions from the companies on Coronation Drive in Scarborough. The cumulative emissions of pollutants to local and regional air in this area are among the highest in the province. Now, the situation stands to be greatly exacerbated with Digital Specialty Chemicals’ application to enlarge its operations by 45 per cent.

This plant is at the west end of Coronation Drive, directly adjacent to homes and close to schools and low-income high-rises.

The copy of the ECA application made available to us is heavily redacted and therefore impossible for residents to prepare substantive comments to the ERO before the deadline, April 17. There are close to 100 chemicals in the Emission Summary Tables, and the names of more than half are redacted. Many have no point of impingement (POI) limits.

The company has met with us virtually but will not change the redactions.

In response to our request, the company agreed to grant a restricted non-disclosure agreement to a qualified consultant, and supply that person with the un-redacted documents. To that end, we retained RWDI Consulting Engineers and Scientists (RWDI) to conduct an Air Quality Peer Review of documents prepared for Digital Specialty Chemicals Limited by Pinchin Ltd. As noted above, a copy of the Peer Review Report is included with this submission, and we request that it be kept confidential.

Key concerns unveiled through our independent peer review:

The Peer Review findings are of serious concern and raise doubts about the assurances we have received so far from the company. The report identifies the following issues with Pinchin’s modelling.

● The company is proposing to install a new thermal oxidizer that it says will greatly reduce the emissions from the expanded plant, however, the Emission Summary and Dispersion Modelling (ESDM) report does not include sufficient detail to validate the expected emission rates and the mitigating effects of the thermal oxidizer.
● The method of calculating emissions from by-products of combustion from the thermal oxidizer were not provided.
● In addition to the main treatment process reactors, there are numerous references to other equipment and operations that are also ducted through the air treatment system, including material transfer operations, filtration, distillation, holding tanks, etc. No details were provided on how the contribution from these sources were considered in the emission calculations. This raises the possibility that emissions may be underestimated.
● Emissions from “Specific Future Processing” were simply listed as “Provided by Entegris” and could not be validated.
● Overall, the calculation of process emissions does not have sufficient information provided to allow RWDI to understand details on the process or the calculations involved, so Pinchin’s conclusions cannot be validated.
● There are many other more minor items in the report that require clarification or confirmation.

In addition, another point of concern is that the company has applied to the MECP for an increase to the allowable limits for some emissions that are above MECP standards. If granted, will these extensions consider health-based impacts, and will the health effects of the cumulative impact of these numerous releases of pollutants be considered in setting POI limits?

These findings need to be explored and answered before the application is approved.

Sincerely,

Concerned residents of East Scarborough, Ontario

Attachment: RWDI Peer Review Report