I live north/west of the…

I live north/west of the facility occupied by Digital Chemical Specialties (Entegris) located at 470 Coronation Drive. I have serious concerns related to the Environmental Compliance Application by the proponent. We learned that the company has plans to increase production and output by 45 per cent.

As a nearby resident, I am concerned about the cumulative health effects of toxic emissions in the area. Particulates and toxic chemicals are coming from not only this facility but also from a host of other industrial operations. The predominant winds off of nearby Lake Ontario spread the health risks far and wide. This is why so many residents have joined forces to look out for their health and safety. In fact, our residential area has among the highest cumulative emissions of pollutants in the province. A few years ago, we were second only to the oil fields in Texas, USA!

Once alerted to the ERO posting and the application from the company, residents were left with very little to act upon. The Environmental Compliance Application was only available upon request directly from the proponent. When it was eventually provided, it was a heavily redacted document. Therefore, residents were unable to make comments or analyze what was about to be unleashed over our homes, in our bodies and through our ears (yes, lots of noise comes with the expansion too!)

While the company did reach out to a group of nearby residents, they continued to stand by the redactions, citing competitive reasons. This in itself is a risky proposition. Could every application that comes before MECP now cite “competitive reason” for hiding details of toxic chemicals and other substances? This seems a dangerous precedent and one that should be seriously questioned by MECP. 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.

In the meantime, community members met with the company on several occasions. While residents remained hopeful, the company stood by their decision to only provide concerned residents with a redacted ECA. As a remedy, at the 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.

The details of this review are summarized further below, and the full review is attached. We request that this report be kept confidential.

Key concerns unveiled through our independent peer review:
- The Peer Review findings raises 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 stands to 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.

Another point of concern is that the company has applied to the ministry (MECP) regarding many contaminants with no POI limits, but with predicted impingement concentrations above MECP standards, and one above its benchmark. Any proposed new concentrations must be health-based and the health effects of the cumulative impact of numerous releases of pollutants should be considered in setting POI limits.

All finding from the RWDI report need to be explored and answered before any decision is made regarding this application.