Addressing environmental issues at old manufacturing plants that have been shuttered can be a significant undertaking. The storage and use of chemicals and products used in decades past may have been perfectly legal and acceptable at the time. These same practices may now be both illegal and pose human health and environmental risks.
Century-Old Manufacturing Plant is Potential Source of Contamination
We were reminded of these risks again recently as the closed General Motors (GM) Plant in St. Catharines, Ontario, has been identified for potentially releasing pollutants. As a point of reference, this is the old plant (more than 100 years old), not the active St. Catherines Propulsion Plant.
The GM facility was shut down in 2010 and sold to Bayshore Group, which began demolishing it in 2010.
PCB and Cadmium
A report in The Standard in July 2020 stated, “A new Ontario Ministry of the Environment study found high levels of dangerous chemicals – PCB and cadmium – in the waters of Twelve Mile Creek near the old GM property on Ontario Street in St. Catharines.”
The article stated that the samples of surface water and stormwater runoff near the General Motors site taken in February “found PCB levels sometimes reached more than twice the threshold allowed by the ministry’s water quality standard.”
According to a report in the Welland Tribune, “St. Catharines NDP MPP Jennie Stevens is appealing to Premier Doug Ford to address environmental hazards at the former General Motors site on Ontario Street.”
The article goes on to say that Stevens wrote a letter to Premier Ford requesting the government find a solution to ensure the site is “immediately sealed to keep toxic materials from leaking off the site into the adjoining Twelve Mile Creek and neighbourhoods.”
The articles did not discuss what action items the Province might be considering.
Environmental Closure at Industrial Sites
Addressing environmental issues at shuttered manufacturing plants can be a significant undertaking. This is especially true for older manufacturing plants that predate our current environmental laws and regulations.
Old, large manufacturing plants can have a myriad of potential environmental issues including
- Steel, single-wall underground storage tanks and piping (prone to leaking) that may have contained a variety of products (leaded gasoline, solvents, fuel oil, to name a few).
- Storage and management of chemicals in outside areas (prior to regulations). Storage and runoff of coal from the Powerhouse.
- On-site fill areas.
- Use and potential spill of chemicals.
- Disposal of chemicals/liquids/waste products at the property . These activities were acceptable 50 or 100 years ago.
- General environmental management practices.
All of these conditions or activities had the potential to cause impacts to soil and groundwater at these older facilities and, over time, the potential to impact third parties.
There are also a variety of hazardous substances in these facilities (mercury switches/lighting, asbestos, lead-based paint, etc.), but before demolition can take place, these substances must be evaluated (see Designated Substances).
Plant Closure and Decommissioning
As older plants are closed (hopefully to make way for newer plants or new commercial developments), it’s likely that environmental issues from the past will continue to be discovered. Based on traffic on our website, we are guessing others are considering these issues as well. This blog from 2015 (Plant Closures and Decommissioning: Essential Environmental Considerations) continues to be one of our most read blogs.
If you need assistance in developing a strategy for a plant closure or decommissioning, please contact me, and I’ll be happy to discuss how we can assist you. You can reach me at our new phone number 519-948-7300, Ext. 114.
Principled Foundation | Thoughtful Advice | Smart Solutions