News/Media

Great Lakes

Wildlife

Kids

FAQ

Executive Summary
ENVIRONMENTAL MANAGEMENT AGREEMENT

Appendices:

Appendix 1
Appendix 2
Appendix 3
Appendix 4

May 25, 2000 Draft

ENVIRONMENTAL MANAGEMENT AGREEMENT

between

Algoma Steel Inc.

and

Her Majesty the Queen in Right of Canada as represented by

the Minister of Environment for Environment Canada "EC"

and

the Minister of Environment for the Ministry of the Environment "MOE"

Section 1 - Definitions

1.1 In this document,

1.1.1 ASI means the steelworks located in Sault Ste. Marie owned by Algoma Steel Inc.

1.1.2 CEPA means the Canadian Environmental Protection Act S.C. 1999 and as amended from time to time.

1.1.3 contaminant means any solid, liquid, gas, odour, heat, vibration, radiation or combination of any of them resulting directly or indirectly from human activities that may cause an adverse effect.

1.1.4 Director(s) means the Regional Director of the Ministry of the Environment and/or the Regional Director of Environmental Protection Branch-Ontario Region.

1.1.5 EBR registry means the Environmental Bill of Rights registry administered by the Ontario Ministry of the Environment (www.ene.gov.on.ca).

1.1.6 EMA means the approved final version of the three-party Environmental Management Agreement.

1.1.7 EPA means the Environmental Protection Act R.S.O. 1990 c. E.19 administered by the Ontario Ministry of the Environment and as amended from time to time.

1.1.8 Green Lane means the Environment Canada internet environmental page (www.on.ec.gc.ca/or-home.html).

1.1.9 PAH means the group of 18 polynuclear aromatic hydrocarbon as listed in appendix 1.

1.1.10 the parties means ASI, EC and MOE.

Section 2 - Introduction and Background

2.1 Introduction

The development of several inter governmental agreements and initiatives over the past few decades have resulted in an opportunity for the parties to this document to negotiate an Environmental Management Agreement (EMA),which advances several environmental issues at Algoma Steel Inc. This EMA is a voluntary initiative designed to complement the existing regulatory process. It provides a mechanism for ASI to commit to environmental initiatives that exceed existing regulatory requirements while taking into consideration the criteria and principles embodied in the Voluntary Non-Regulatory Initiatives (VNRI) document of November 1997. The VNRI document was developed by the New Directions Group, which has multi-stakeholder membership and is comprised of representatives from government, industry and environmental non-governmental organizations and was used as guidance in completing this EMA.

A key goal of this EMA is to bring together several federal and provincial objectives in one concise document and provide one window through which ASI can deal with government agencies. Progress towards reduction or elimination of the "beneficial use impairments" and pollution incident reports are important objectives considered in the development of this EMA.

Under Annex 2 of the 1987 Protocol to the 1978 Canada- U.S. Water Quality Agreement, an Area of Concern (where the impairment of beneficial uses of a geographic area has been realized) was established for the St. Mary's River in 1988. This led to the development of a Remedial Action Plan led by the Ontario Ministry of the Environment with support from Environment Canada and other federal departments and the formation of a Binational Public Advisory Council. Criteria for the delisting of the "beneficial use impairments" have been completed in the development of the Remedial Action Plan Stage 2 document.

An Air Quality Committee formed pursuant to the United States-Canada Air Quality Agreement between Canada and the United States, requested in 1997, that a bi-national multi-stakeholder consultation be undertaken to evaluate complaints from Michigan residents regarding transboundary pollution from Sault Ste. Marie, Ontario. An ongoing consultation and monitoring partnership between federal , state, provincial and tribal stakeholders has been developed to address this issue.

This EMA between the federal and provincial government and ASI has been completed to further the goals of the 1994 Canada-Ontario Agreement, Great Lakes Water Quality Agreement, Remedial Action Plan, United States-Canada Air Quality Agreement and other government programs, and align them with the environmental initiatives which the parties agree are current priorities. The EMA is also consistent with ASI's policy on reducing the impact of its operations on the overall environment and adjacent residential areas. All parties agree that the establishment of a list of environmental projects, with appropriate time lines in a clearly defined plan, is beneficial to all stakeholders and provides a clear path to realizing the goals and mandates of the parties who are signatories to this agreement.The draft EMA was presented at a public meeting held in Sault Ste. Marie on May 18, 2000, and posted on the MOE Environmental Bill of Rights Registry and the Environment Canada Green Lane internet site for a 30 day period ending June 30, 2000.

2.2 Background

ASI is an integrated steel producer, with annual production of finished steel products of approximately 2.1 million tonnes. It is located on an 810 hectare parcel of land, which includes a 328 hectare non-hazardous landfill site (MOE Certificate of Approval #A560101). Finished products include plate, strip and cold rolled steel. The facility is operated with three cokemaking batteries, one operational blast furnace, one basic oxygen steel plant and a variety of finishing mills, including a recently completed direct strip production complex.

Environmental improvements over the last decade have resulted in ASI currently achieving full compliance with Ontario Regulation 214/95 (MISA) at its eleven control points, which discharge to the St. Mary's River. Major environmental upgrades to reduce and treat waste streams at ASI over the past decade include the installation of a main wastewater treatment plant, blast furnace wastewater recirculation system, pH control of process wastewater discharges from the Bar and Strip Lagoon, fixed ammonia removal, biological treatment of phenol in cokemaking wastewater and secondary emission controls for visible emissions from the steelmaking operation. A commitment to address particulate emissions from the Ironmaking's dekishing operations was provided to MOE in a Program Approval issued in November 1998. Controls on this source will be fully implemented by September 2002. Over the past ten years, ASI has committed approximately $100 Million for capital environmental facilities.

Regarding climate change issues, ASI has made changes to its processes, incorporating direct strip casting and rolling technology. This addition of the newest steel processing technology, along with reductions in the amount and types of fuel used, advancements in fuel burner technology and a change to its iron ore source has resulted in significant reductions in the production of greenhouse gases. Between 1990 and 2000, ASI will realize a 6.5% reduction in carbon dioxide (CO₂) emissions. ASI has increased the use of natural gas in new and refurbished facilities and thereby reduced its reliance on heavy fuels.

ASI has been actively upgrading electrical equipment to newer, more energy efficient types that has resulted in net energy savings. This commitment will continue with future improvements planned for equipment upgrades and energy use monitoring.

ASI is a participant in the Voluntary Challenge Registry (VCR), the Accelerated Reduction/Elimination of Toxics (ARET) Program, the Ontario Anti Smog Action Plan and is a signatory to the Canadian Steel Producers' Association, Statement of Commitment and Action.

ASI sponsors a used oil collection day, twice per year, in Sault Ste. Marie, as a public service to collect and recover waste oil from the community. Since beginning this program in 1991, ASI has collected approximately 74,000 litres of waste oil from the public. Waste oils collected both on and off site are processed into waste derived fuel and utilized by ASI as a fuel source, reducing the need to purchase virgin fuel. Within the operations, a program has also begun to directly recycle oil at the mill source. This approach will be expanded wherever possible and maintenance programs will ensure that the volume used is minimized

ASI believes that the commitments contained in the Agreement represent realistic and achievable goals and, wherever possible, ASI will work toward improving the timetable and the levels of reduction.

Section 3 - Goals and Objectives

3.1 Goals and Objectives are as follows:

- the reduction or elimination of specific substances which are found to be persistent, bioaccumulative and toxic in the environment and appear in appendix 2 of the 1994 Canada-Ontario Agreement as Tier I and Tier II substances (appendix 2 attached),

- the reduction or elimination of air discharges in the form of visible and gaseous emissions, which exceed or are inconsistent with existing or proposed limits or guidelines or are the subject of pollution reports to MOE,

- improved management of solid waste and contaminated sediments,

- continued discussions on developing an air quality monitoring partnership with the MOE,

- the de-listing of the "beneficial use impairment" associated with the ASI boat slip as identified in the Stage 1 report for the Remedial Action Plan (RAP) for the St Marys River,

- participation in the discussion and resolution of local trans-boundary air issues between Sault Ste. Marie Ontario and Sault Ste. Marie Michigan,

- enhancement of pollution prevention planning initiatives, such as raw products substitution, new technology applications and energy or water use reduction programs, and,

- continued participation in other steel sector initiatives and other voluntary programs as outlined below:

• Strategic Options Process for the Steel Sector (SOP)
• Accelerated Reduction/Elimination of Toxics Program (ARET)
• Voluntary Challenge Registry for Climate Change (VCR)
• Anti Smog Action Plan (ASAP)
• Canadian Steel Producers Association Best Practices Manuals

Section 4 - Activities

4.1 The following schedule outlines the activities which ASI agrees to undertake to assist in achieving the goals and objectives outlined in Section 3.1

Environmental Management Agreement

Table 4.

4.1.1 Benzene Air Emissions Reduction (Cokemaking)

For the purposes of this Agreement, the 1993 base year for Benzene air emissions from ASI is reported to be 432 grams/tonne coke production.

ASI has reduced total benzene loadings by approximately 27% since 1993. These reductions are a result of shutting down an older phenol plant in 1997 and replacing this facility with a biological waste treatment system. Benzene discharge levels were reduced in 1995 by loading and shipping of light oil by rail, rather than by ship, as was previously the case.

In addition to the above noted achievements, ASI will continue to reduce benzene air emissions over the period from 2000 to 2005. The reductions will occur in steps, with a reduction of 50% being achieved by December 31, 2000(216 g/t); 75% being achieved by December 31, 2003(108 g/t); and further reductions to 85% (of the 1993 base year) by December 31, 2005. It is anticipated that the above reductions will use a technology referred to as "gas blanketing", whereby the volatiles such as benzene are prevented from gaining access to the atmosphere by use of an inert gas and a system to carry the resulting mixture to coke oven gas lines to be used as a fuel. The emission reductions associated with the Benzene control program will be verified using third party auditing and the results of these audits will be reported in the following semi-annual report as identified in section 7.1.

Good management practices will continue to be applied to the cokemaking process to reduce emissions from this source. ASI will make every effort to improve on the above schedule.

4.1.2 PAH Air Emissions Reduction(Cokemaking)

For the purposes of this Agreement, the 1993 base year for PAH air emissions rate from ASI is reported to be 21.3 grams/tonne of coke produced from the three batteries.





PAH emissions are reduced by the use of good operating and maintenance practices on the coke oven batteries. ASI has made significant reductions in the level of PAHs as a result of adopting these practices and the application of annual cokemaking plans over the past 10 years.





ASI will reduce PAH air emissions in steps, with a reduction of 20% being achieved by December 31, 2000(17g/t); and 54% being achieved by December 31, 2005(9.8 g/t) from the base year.

These reduction levels satisfy the 1996 Strategic Options Report objectives and are equivalent to the reductions committed to in the Canadian Steel Producers Association (CSPA) Statement of Commitment and Actions.





Measurement of PAH emission levels to monitor progress towards the above goals, will occur by the use of the observation and calculation methods developed by the CSPA, Environment Committee. The emission reductions associated with the PAH reduction program will be verified using third party auditing and the results of these audits will be reported in the following semi-annual report as identified in section 7.1.





The measurement of ambient levels of PAHs will continue to assist in measuring progress in meeting these reduction targets.

4.1.3 Blast Furnace Visible Emissions

ASI will continue to apply flame technology to enhance the control of visible emissions from this source. ASI will set up a study team to further develop and maximize this control method. A flame emission control system is presently in use on the #7 Blast Furnace.





The present system while meeting its original purpose, was recognized by ASI as being less than optimally efficient. The design of the flame suppression system will be changed to enhance the blanketing and dispersion characteristics of the flame. This will allow more efficient displacement of oxygen at the interface of molten iron and air and thereby prevent the formation of fugitive particulate emissions of iron oxide.





ASI believes there is opportunity to better understand the technical aspects of the application and thereby develop a very practical and innovative technology. It is expected that the flame suppression equipment will be installed in mid-2000. The results of this study will be provided to MOE and EC in the February 1, 2001 semi-annual progress report.





In the event that the flame suppression trial does not produce satisfactory results, ASI will continue to pursue alternative methods to reduce Blast Furnace visible emissions. All activities arising from this effort will be reported in each semi annual progress report.

4.1.4 Annual Cokemaking Plans

ASI will provide the MOE and EC with annual Cokemaking Plans included in each February 1 semi-annual report as outlined in section 7.1. The purpose of these plans is to provide continuous improvement to the coke oven batteries and to reduce emissions over time, through the application of proactive maintenance techniques.





Annual Cokemaking Plans have been provided to the MOE for a number of years and have proven to be a valuable tool in reducing emissions from the batteries. ASI will continue to implement these plans to reduce both visible and PAH emissions in accordance with the ongoing commitments made in the annual plans.

4.1.5 PCB Destruction

ASI's holdings of waste Polychlorinated Biphenyls (PCBs) and equipment are contained in secure storage that currently meets both provincial and federal legislation.





An inventory of ASI's total PCB holdings as of December 31, 1999 , is attached as Appendix 3. The amount recorded in the report represents the current stored inventory for the purposes of this agreement. ASI will eliminate a volume of PCB's equivalent to the stored inventory by December 31, 2005. Elimination of PCB's will begin no later than December 31, 2001. ASI will make every reasonable effort to eliminate all PCBs and equipment from usage.

4.1.6 ASI Boat Slip

The ASI boat slip was last dredged in 1995. At that time approximately 11,500 cubic metres of dredge materials from the Slip were disposed of in the ASI waste disposal site. ASI will sample and analyze the sediments for Contaminants above Provincial Sediment Quality Guidelines, in accordance with the same terms of reference used in the 1993 study of Slip sediment quality. The results of this monitoring plan along with appropriate recommendations for any remedial work will be provided to MOE and EC for their review and comment as part of the February 1, 2001, semi-annual report. If remedial work is required, this would be completed during the 2001 work season and a summary report on the clean-up activities will be provided to MOE and EC in the first semi annual report following the completion of the clean-up activities.





4.1.7 ASI Landfill

ASI commits to continue a program of monitoring of the landfill site to assess trends in groundwater quality. The groundwater monitoring will be conducted on a four-year cycle commencing in 2001 and again in 2005. The results of the monitoring will be included in the first semi-annual report following completion of the studies as required in section 7.1.

ASI commits to continue to make efforts to reduce the overall load of material sent to the landfill for disposal.





ASI will commit to develop and implement a suitable long-term plan for the waste disposal site describing its site operations and closure. The plan will be submitted to MOE and EC as part of the February 1, 2002, semi-annual report.

4.1.8 Mercury Recycling

Elemental mercury has a number of uses in industry, including electrical switching components. As a result of taking this equipment out of service, ASI has accumulated an inventory of mercury that is being stored in steel vaults. ASI will have removed, by a licensed waste contractor, all stored mercury by December 31, 2001. The details of this program, including total Mercury recovered, will be provided in the first semi-annual progress report subsequent to completion of the work.





4.1.9 Environmental Code of Practice

Environment Canada has developed an Environmental Code of Practice for Integrated Steel Mills as an outcome of the Strategic Options Process (SOP) for the Steel Manufacturing Sector. The Code is designed to identify the minimum environmental performance standard for new integrated steel mills and to provide a set of voluntary environmental performance goals for existing facilities.





ASI will continue to participate in the SOP and supports the principle of enhanced voluntary initiatives for the purpose of advancing environmental protection in Ontario and Canada.

Algoma Steel Inc. will

i Conduct a thorough review of the Code to determine:

- ASI's current level of achievement with regard to each recommendation in the Code;

- which of the Code recommendations are achievable with the current equipment at ASI;

- what limitations there are in achieving any of the Code recommendations.

This review will be completed by December 31, 2000.

ii Develop an Implementation Strategy which will prioritize the Code recommendations into a schedule that is in step with ASI's other environmental initiatives and commitments. This will include an implementation timeline for the Code recommendations that are deemed to be achievable within the timeframe of this Environmental Management Agreement. This Implementation Strategy will be completed by June 30, 2001.





iii Provide an annual progress report to the MOE and the EC, which is consistent with the reporting method developed by the CSPA. In the absence of such a reporting method, the progress will be reported in a manner consistent with the requirements set out in Section 7.





 

Section 5 - General

5.1 Any request by ASI to change a requirement in this Agreement shall be made in writing to the MOE and EC with reasons for the request, at least 30 days prior to any specified date for meeting that requirement. Details of this request will be subject to assessment and/or verification by the Director(s) and may require posting on the EBR registry and Environment Canada Green Lane internet sites.





5.2 The requirements of this Agreement are undertaken on a voluntary basis and currently exceed regulatory requirements. Compliance with this Agreement does not relieve ASI from:

5.2.1 complying with any applicable order, statute, regulation, municipal, provincial or federal requirements; and





5.2.2 obtaining any approvals, such as certificates of approval or consents, required by law.





5.3 Nothing in this Agreement shall be interpreted as preventing the MOE or EC from issuing orders against ASI, taking any other steps to bring about compliance by ASI or to prosecuting ASI for any non-compliance, including anything related to this Agreement.





5.4 Nothing in this Agreement shall be interpreted as preventing the MOE or EC from proposing and implementing new legislation or new policies, including that which is related to matters covered by this Agreement.





5.5 In the event any party to this Agreement is, in the opinion of the Director(s), rendered unable to perform or comply with any commitments herein because of





5.5.1 natural phenomenon of an exceptional, inevitable or irresistible nature, or insurrections, or





5.5.2 strikes, lockouts or other industrial disturbances, or





5.5.3 inability to obtain materials or equipment for reasons beyond the control of ASI, or





5.5.4 any other cause whether similar to or different from the foregoing beyond the reasonable control of the parties,





the commitments herein, to the extent that they are affected by the circumstances in 5.5.1 through 5.5.4 above, may be modified in a manner mutually agreed upon by the parties.





ASI must notify the MOE and EC immediately of any of the circumstances in 5.5 and provide details that demonstrate that no practical alternatives are feasible in order to meet the commitments. ASI shall provide a written explanation for its failure to meet the commitments herein, and such explanation shall be in a format suitable for posting on the EBR registry and Environment Canada Green Lane internet sites.

5.6 This Agreement shall be in force from the date of signing to December 31, 2005.

5.7 Termination of this Agreement can be initiated by any of the parties at any time. Notice of intent to terminate this Agreement, along with an appropriate rationale, shall be provided to the other parties no less than 30 days prior to the date of termination. The rationale will be posted on the EBR registry and the Environment Canada Green Lane internet sites.

5.8 This agreement shall not be legally binding and shall not give rise to any rights or obligations and shall not be enforceable in any court of law.





 

Section 6 - Public Consultation

6.1 Two (2) members representing the broader public participated on an advisory committee which have evaluated and commented on matters relating to the development of the draft EMA. The Terms of Reference for this committee, which have been agreed to by the parties, are appended to this EMA as appendix 4.





 

 

Section 7 - Reporting





7.1 ASI shall provide semi-annual progress reports to the Director of Northern Region of MOE and the Regional Director of EPB-OR, in a format acceptable to the Director(s). The reports will detail all activities associated with the advancement of the goals and objectives identified in Section 3 of this Agreement and shall include, but not be limited to, the following:

7.1.1 A discussion of the status of activities as they relate to completion dates specified in Section 4.





7.1.2 A discussion of the impact of work completed as it relates to reductions of emissions or other progress towards the goals and objectives agreed to in Section 3.





7.1.3 A full accounting of issues that occurred which have resulted in ASI not being able to maintain the progress on and completion of activities set out in Section 4.





7.1.4 Facility wide emission inventories, which will include an assessment of the primary pollutants [oxides of nitrogen (NOx), oxides of sulphur (SOx), Volatile Organic Compounds (VOCs), total suspended particulate (TSP) Carbon Monoxide (CO)] and Carbon Dioxide (CO2) will be produced and submitted with the appropriate semi-annual report for the calendar years 2000, 2003 and 2005. The TSP evaluation will include a reporting of the fine particulate matter (PM10, 2.5).





7.2 Semi-annual progress reports shall be provided to MOE and EC by August 1^st and February 1^st in each year that this Agreement is in effect.

7.3 The first semi-annual progress report will be due by August 1, 2000, and will summarize activities including all matters set out in this Agreement.





7.4 Progress reports submitted by ASI pursuant to 7.1 are public and will be subject to public distribution. The semi-annual reports will include an executive summary. Information regarding the progress reports will be posted on the EBR registry and the Environment Canada Green Lane internet site.





7.5 On site assessment associated with progress and completion of projects identified in this Agreement will be the responsibility of the MOE.





 

 

 

Dated: ______________________________________________

Signed: ______________________________________________

Algoma Steel Inc.

____________________________________________

Ministry of the Environment, Province of Ontario

______________________________________________ Her Majesty the Queen in Right of Canada as represented by the Minister of the Environment for Environment

Canada

Top of Page
Français | Contact Us | Help | Search | Canada Site
What's New | Topics | Publications | Weather | Home | About Us