October 12
Mr. Mori H. Mortazavi
Manager and Chief Engineer
Peto MacCallum Ltd.
165 Cartwright Avenue
Toronto, Ontario
M6A 1V5
Dear Mr. Mortazavi:
Re: City Peer Reviewer - Manson Insulation Factory Plant
With respect to the technical meeting which had been arranged, but on the advice of their solicitors - R.V. Anderson Inc. did not attend, I am writing to you as requested. The following issues are outstanding:
1. Adequacy of the air monitoring:
Are there separate reports which deal with the proposed air monitoring program? If so, please provide them. It is illogical that there are only four stationary air monitors on the site and placed over 500 metres apart, contrasted with the level of monitoring done for the adjourning Coscan site.
2. Panel & Roof Removal:
As I mentioned to you, I do not understand how exactly it is being proposed that the outside panels will be removed from the building and dropped inside? As mentioned by Ralph Wissborn, it seems to be somewhat of a "violent" means of removal (dropping the panels)? Bearing in mind the height of the building, the walls, and, of course, the roof, would the panels dropping not result in the release of friable asbestos dust? Is this a wise thing to do? How do you implement dust containment with respect to the outside panels? Is the process of panel and roof removal multi-tasked? How do you air monitor and/or contain the dust once the panels and/or the roof are partially removed? We were originally advised that the plant was going to be encapsulated when the walls and roof were removed. Why has this decision changed?
3. Wetting:
At one time we were advised that to help suppress the dust, there was going to be a chemical mixed with the water? Is this still true, and if so, what is the chemical? If water is the only misting agent being used to encapsulate the dust, does the dust problem not continue once the water evaporates?
4. Soil removal:
How do you remove the dust that falls to the ground from the misting procedure? How do you measure the amount of new contamination in the soil caused by the misting? Why isn't the entire soil on the site being scraped off similarly as to the adjoining Coscan site. (This is a very serious question bearing in mind there is a suggestion that the land is to be eventually used for human habitation - it appears that the present process is re-contaminating the Factory land.) Is the trucking of the asbestos dust/waste through the community a special concern?
5. Comparisons to past clean-ups:
The Past Environmental Clean-up of the Johns Manville Land (the adjoining property subsequently developed by Coscan) did not involve the Factory property. The Centennial Community Recreation Association was very involved in the past partial clean-up of the sister site. In the circumstances, can someone advise us why the procedures and safeguards which were previously mandated by the Environmental Assessment Board and are not being following now? (i.e. the number of air monitors, dust control mechanisms, soil removal, etc.)
6. Site safety protocols:
On the sister property, Monenco Inc, was hired by the City and Johns Manville Inc. to act as an independent inspector/investigator in order to provide site accountability. Has there been any consideration by Penn Fund (or whomever is in charge of the project) and/or the City to hire an independent? We would be pleased if Peto MacCallum Ltd and/or some other reputable company were hired to act as a site investigator with the authority to "stop work".
7. Contamination of the surrounding neighborhood:
It appears the proponent will not notify the community of possible contamination of errant asbestos dust until after there has been a determination of whether the asbestos contaminant originated from their site. Are we to presume there is another major asbestos clean up going on at the same time on a different property? If so we would like to know where and by whom? Would it not be more feasible to assume that should there be errant asbestos contaminant in the community it comes from the demolition and site clean-up of the Asbestos contaminated Johns Manville Factory and all activities should be stopped until the problem is rectified?
8. Warnings:
The proposed warnings to the surrounding community are inadequate. Will notice or warnings be given to the public prior to demolition and site clean-up as to what emergency measures are to be in place? We would like to know the exact evacuation, notification and emergency procedures prior to demolition bearing in mind the subject asbestos contaminated property is immediately adjacent to homes, two schools, a plaza, and a playground? Should the schools and playgrounds be closed during the demolition? Should parents keep their children inside?
The City Works Department has an emergency response - has it been considered?
9. Liability:
We would like to know who is signing off on the property and what exactly is being signed? Do the future owners of the land assume the liability for future contamination? Who is assuming the liability for any future problems?
Based on the outstanding issues the applicant/proponent's plan is inadequate and premature. If it is allowed to proceed as it is presently constituted it will result in the unnecessary risk of asbestos contamination to the surrounding neighbourhood and will leave the land contaminated. In my opinion the proposed plan does not protect the community. A demolition permit should not be approved. There are too many questions which have not been yet been addressed.
Yours very truly,
Joseph Pileggi, CCRA Environment Chair
with copies to Ms. Elizabeth Stanley; Hon. Steven Gilchrist; Ms. Gay Cowbourne; Mr. Ron Moeser; Mayor Mel Lastman; Mr. David Soknacki
