The MRA has been granted permission from the MOE (Ministry of Environment) and the resident to post the following communication so that the greater community better understands some of the technical aspects of an Environmental License.
Email to Rod Adams from a Resident from the Judson Street Area
Dear Mr. Adams:
Further to our discussions regarding ML Ready Mix in Mimico, we are under the impression that the required Ministry Of Environment Certificate of Approval is dictated by Ontario regulations pertaining to Air and Noise Pollution. We understand the intent is to protect communities against adverse effects from local sources of air and noise emissions.
I believe “Points of Impingement” with respect to the discharge of contaminant and noise are categorized and prioritized according to sensitive receptors which include residences’ and RETIREMENT HOMES. In fact the minimum separation distance to the nearest receptor depends on the type of environment in which the subject plant is located. So not every situation for approval is the same.
Within the immediate neighbourhood in which ML Ready Mix Concrete operates is;
A) Edwards Manor Cooperative Living (mix of seniors and special needs persons), located across the street at 340 Royal York Road.
B) Griggs Manor Seniors Citizen’s Residence, located across the tracks at 100 Cavell Ave.
C) Coronation Park located across the street at the corner of Judson Street and Royal York Road.
D) Mimico Lawn Bowling Club located across the street and used by seniors in summer months.
E) Residential homes across the street from the facility.
We trust that your assessment reports will include zoning maps with all applicable sensitive receptors identified.
One of the most important factors in Environmental Code of Practice for Ready Mix Concrete Batch Plants is the selection of a site. Effects of both noise and dust on nearby populated areas are of PRIMARY concern. In some jurisdictions the operation needs to be at least 1 km from any residential areas, recreational facilities or commercial establishments. ACCESS TO THE SITE IS NOT TO BE THROUGH RESIDENTIAL AREAS.
The wash water from these facilities kills vegetation and fish instantly. We have attached a photograph of a recent situation where huge amounts of toxic wash water flowed like a stream out the front gate and on to the roadway where it froze and later melted into the sewers.
We ask that a proper and concise evaluation of all the factors involved be investigated to the fullest. We also ask that the results of your evaluations be made available to the Mimico Residents Association in order that an independent review can be made.
Response from the MOE (Rod Adams)
The following comments are with respect to your email:
- In reviewing information provided with an application for an Environmental Compliance Approval the Ministry of the Environment evaluates contaminant discharge information (other than noise) at the property boundary of the applicant/source. This is considered the “Point of Impingement”. The emissions are required to meet the ministry standards at the Point of Impingement.
- With respect to noise – the applicant/source is required to demonstrate that the noise levels will meet ministry requirements at the nearest sensitive receptor – wherever that may be – in this case it would be at the homes across the street. The other locations you identify, such as Edwards Manor Cooperative Living at 340 Royal York Road and Griggs Manor Seniors Citizen’s Residence at 100 Cavell Ave are further away than the homes across the street and therefore based on meeting the standard at the homes across the street, the standards would also be met at these locations.
- Locations such as Coronation Park, located across the street at the corner of Judson Street and Royal York Road, and Mimico Lawn Bowling Club, located across the street and used by seniors in summer months, are not included in the assessment as they are temporary uses; however they would be further away than the homes across the street and therefore the standards would also be met at these locations.
- The location of the facility is not within the Ministry of the Environment’s jurisdiction. Siting of the facility falls under the City’s zoning control. Based on information provided by the City the site is zoned to allow a concrete batching plant. The ministry’s role is to ensure that the emissions and noise from the operation of the facility are controlled and meet the ministry’s standards, which is done through the Environmental Compliance Approval process.
- As I mentioned at the meeting, ML had put in a recirculation system to contain washwater. The water discharge that occurred in early February was due to one of the water level sensors freezing solid on the recirculation system which resulted in excessive runoff which included mud from the yard being discharged on to the road and accumulated at the catch basin just east of the facility. ML has since fixed the problem with the sensor. It should not be occurring right now. As for the “killing of vegetation and fish” from the wash water, the pH (alkaline level) of the wash water would have neutralized as it combined with other water on the site and would not have been at a concentration to effect vegetation or fish. However, I agree runoff from the site or from any operation on the site should not occur and the ministry is addressing this with the company.
Toronto District Office
Ministry of the Environment
5775 Yonge Street – 9th floor