Response to ERO application…

Response to ERO application 091-2771

Digital Specialty Chemicals Limited- Environmental Compliance Approval (air) - Entegris

Instrument type: Environmental Compliance Approval (air)

I have six concerns about this application as outlined below.

Missing (redacted) Information
So much critical information has been redacted from the copy of the ECA that I was provided with by the Ministry.

This application is submitted under the Environmental Registry of Ontario and is intended to allow the public to comment on proposals that may affect the environment

This plant involves the manufacture of industrial chemicals, and the submitted technical reports related to air quality adjacent to the plant include the names and emission levels of numerous different chemical compounds. However, the names of more than half of the chemicals being emitted have been redacted, supposedly because they are business confidential.

Therefore, the community clearly could not comment on the impact the proposal will have on adjacent individuals, communities, schools, and wildlife.

Issues with the Pinchin Air Quality Report
After several meetings, the Proponent agreed to release an unredacted version of the air quality report (prepared by Pinchin) for a peer review by a qualified consultant of our choice (RWDI), as long as that individual signed a Non-disclosure Agreement (NDA). That peer review report, a copy which has already been submitted to the Ministry in confidence, raised a number of questions and concerns about the report, and we insist that the Ministry investigate all the issues and concerns raised, and ensure that they are corrected or resolved.

Cumulative chemical emissions in the Coronation area
Based on the findings of recent ChemTrac reports, the residents in the vicinity of Coronation Drive are very concerned that cumulative exposures to contaminants in the community from local and regional air are already some of the highest in the City. It is imperative that this proposed application for a major expansion, be approached with the utmost caution to protect the environment and human health of the adjacent residents.

Concerns about noise impacts
I am also concerned about the noise that will be generated by the expansion of this facility. Residents on Manse Road, Woodgarden Crescent, Woodgrove Drive and the nearby parks are already subjected to noise from this facility. Noise complaints against Digital Speciality Chemicals have been lodged in the past.

Sources of noise are outlined in the ECA, specifically in the Acoustic Assessment Report (AAR).

The conclusion of the AAR is that noise will exceed MECP for a period of six years until the Proponent’s noise abatement measures - Phase 2 can be completed. Six years is a long time for home owners and residents to wait to reasonably expect to be able to enjoy their homes, backyards and parks.

I urge the MECP to take a very close look at the Proponent’s noise abatement plan.

Concerns about truck volumes
I would also raise concerns about the issue of the Proponent’s truck volumes in and out of the plant, which are increasing, along with trucks from other companies in the area. This issue is causing significant health and safety issues to the neighbouring schools and residential areas, that should be evaluated, and controls or remedial measures should be put in place.

Need for an Environmental Emergency Plan (EEP)
I am concerned that the Proponent does not have an Environmental Emergency Plan. This is a federally-legislated requirement under the Environmental Emergency Regulation. There are more than 240 substances listed under that regulation that require any company processing those substances to have such a plan. There was a serious accident at the plant a few years ago that involved the release of chemicals.

We cannot determine if an EEP is required because the Proponent’s ECA has redacted more than 50 per cent of the chemicals from the public view on their application. Hence, I urge the MECP to investigate if Digital Specialty Chemicals needs to have an Environmental Emergency Plan in place, since it has access to the unredacted application.

Conclusion
I hereby request that this ECA application be rejected, or significantly amended, to address my concerns outlined above.