Comment on GE’s proposal to renew ECA 7836-9HDRYN

Background

On May 20, 2026, the Ontario Ministry of the Environment, Conservation and Parks (MECP) posted on the Environmental Registry of Ontario (ERO) a proposal for the renewal of the Limited Operational Flexibility for an Environmental Compliance Approval (air & noise) No. 7836-9HDRYN for GEPR Energy Canada Inc. The posting indicated that “This proposal is for the renewal of the Limited Operational Flexibility for an Environmental Compliance Approval (air & noise) No. 7836-9HDRYN for GEPR Energy Canada Inc. an electric motor and generator manufacturing facility, located in the City of Peterborough, Ontario.” The comment period (45 days) on the ECA application was to close on July 4, 2026.

The ERO posting indicates that some supporting materials may not be available online. If this is the case, one can request to view the materials in person in Toronto by contacting the MECP’s Client Services and Permissions Branch (CSPB).

On June 1, 2026, I emailed the MECP to request copies of any supporting materials relating to GEPR’s proposal. On June 19, 2026, the MECP emailed four documents to me:

1. GEPR Energy Canada Inc., Environmental Compliance Approval Application, February 5, 2026 (ECA Application Form – GE Vernova – Peterborough – Signed (redacted).pdf).
2. AECOM, Acoustic Assessment Report (AAR), March 5, 2025 (RPT_2026-03-05-GE Peterborough AAR-60746233-signed (redacted).pdf).
3. AECOM, Emission Summary and Dispersion Modeling (ESDM) Report, January 23, 2026 (RPT_2026_01_20_GE Peterborough_ESDM_60746233-Final (redacted).pdf).
4. GEPR Energy Canada Inc., Request for Notice Under s. 7(1) of Local Air Quality Regulation for Use of a Specified Dispersion Model, April 6, 2026 (Request s.7(1) Specified Model.GEPET – Signed.pdf).

The first three documents are heavily redacted.

On June 23, 2026, I submitted several concerns and requests to the MECP with respect to GEPR’s proposal..

Concerns and requests

Concern 1. GEPR’s heavy redaction of key documents prevents the public from understanding fully and commenting meaningfully on GEPR’s application. GEPR’s application asserts no claim or basis for confidentiality. Neither GEPR nor the MECP has explained why so much information has been deemed confidential and unsuitable for public viewing.

Requests:

1. MECP should negotiate with GEPR for the release of unredacted versions of these documents, and
2. MECP should extend the comment period to allow sufficient time for the review of any newly unredacted materials.

Concern 2. GEPR is seeking approval to sever its operations from BWXT’s at the site under the renewed Environmental Compliance Approval (ECA). While GEPR claims that BWXT will apply for its own ECA, no such application appears on the Environmental Registry of Ontario.

Requests:

1. MECP should ensure that both GEPR’s and BWXT’s operations – now jointly covered by the ECA No. 7836-9HDRYN – continue to be covered without interruption under an equivalent set of ECAs.
2. MECP should not approve GEPR’s request for severance until equivalent coverage of BWXT’s operations, under its own ECA, is in place.

Concern 3. GEPR is wanting the renewal of its current Environmental Compliance Approval to cover “two operational scenarios”:

(a) Existing Operation: All current and relevant operations with the inclusion of the new Groundwater Extraction and Treatment System (GETS) unit.

(b) Future Operation: Most of the GEPR buildings are demolished, leaving only Buildings 2, 2A, 8A and 30. The demolition includes Building 14, within which the existing GETS unit is currently housed. A new GETS will be located on the south side of the property, equidistant to or further from the property line than the current unit’s location, with its exhaust stack extending vertically from the north side of the unit.

GEPR claims that noise and trichloroethylene (TCE) emissions from the new, relocated GETS under the Future Operation scenario will be less than assessed emissions from the current GETS under the Existing Operation scenario.

GEPR’s claim ignores notable differences between the Existing Operation and Future Operation, including:

GEPR’s estimate of noise emissions from the news GETS ignores the effect of removing the unit from the sound-dampening confines of Building 14 and relocating the new unit to “the south side of the property.”

Requests:

1. MECP should recognize that the changes entailed by GEPR’s planned shift from Existing Operations to Future Operations (after demolishing most of its buildings on the property) far exceed the minor, low-risk changes that are permitted under the Limited Operational Flexibility terms of GEPR’s current ECA No. 7836-9HDRYN.
2. MECP should ask GEPR to remove any reference to a Future Operation scenario from its application to renew ECA No. 7836-9HDRYNGEPR’s Future Operation scenario.
3. MECP should advise GEPR that consideration of its Future Operation scenario would require a separate application for a new Environmental Compliance Approval.

Concern 3b. In the alternative, the changes entailed by GEPR’s planned shift from Existing Operations to Future Operations (after demolishing most of its buildings on the property) raise serious concerns that are impossible to address, given GEPR’s heavy redaction of key documents.

(a) Noise Emissions

Again, GEPR is wanting the renewal of the current Environmental Compliance Approval to cover “two operational scenarios”:

Existing Operation: All current and relevant operations with the inclusion of the new GETS unit will be assessed.

Future Operation: Most of the GEPR buildings are demolished, leaving only Buildings 2, 2A, 8A and 30 and the Groundwater Extraction and Treatment System (GETS). The GETS unit is modelled in the same location as in the Existing Operation scenario.

Again, GEPR claims that modeling under the Future Operation scenario represents a conservative assessment of noise emissions from the GETS since the unit will be equidistant to or further from the property line than the unit’s current location. In general, GEPR’s heavy redaction of key documents make its claims difficult to assess in general.

There is, however, one notable difference that GEPR omits from its analysis of the Future Operations scenario: Building 14, within which the GETS unit is currently housed, will be torn down. A new GETS will be located on the south side of the property, with its exhaust stack extending vertically from the north side of the unit.

GEPR’s modeling of noise emissions under the Future Operation scenario takes account of the distance from the GETS to the property line, but ignores the effect of removing the GETS from the sound-dampening confines of building 14 to “the south side of the property.”

Request:

1. MECP should question GEPR’s calculation of noise emissions under the Future Operation scenario (after GEPR has demolished most of its buildings on the property).

(b) Air emissions

AECOM’s ESDM addresses two scenarios:

“Existing Operation: All current and relevant operations will be assessed; and

“Future Operation: Most of the GEPR buildings are assumed to be demolished leaving only Buildings 2, 2A, 8A and 30 and the GETS unit in operation. The [GETS] unit is modelled in the same location as Scenario 1. This represents a conservative assessment since any relocation of the GETS will be equidistant to or farther from the property line than the current GETS location.

“The scope of the Future Operation will include the following equipment in the remaining buildings:

“* One groundwater treatment system [GETS] with an air stripper, exhausting [redacted] above ground through [redacted]. …

“A maximum design flow rate of [redacted] for the air stripper in the ground water treatment system [GETS] is proposed for the production limit under the Limited Operational Flexibility. …

“For the Existing Operation, the groundwater treatment system [GETS] is currently located [redacted] on [redacted]. Ground water contaminated with Volatile Organic Compounds (VOC) is sprayed into an aerator tank from above, where it is met with a counter-current of air. The VOCs present in the water are released into the air and are exhausted into the atmosphere. The groundwater treatment system has a design flow rate of [redacted] with a maximum air exhaust of [redacted].

“For the Future Operation, the same groundwater treatment system [GETS] is proposed for relocation, following the removal of [redacted]” [1.1 Purpose and Scope of ESDM Report, p. 1; 1.3 Description of Products and Raw Materials, p. 2]

GEPR is inconsistent in redacting its description of the GETS unit in AECOM’s ESDM and AAR Reports. The AAR Report includes unredacted details of the GETS unit under the Existing Operation and Future Operation scenarios:

“In addition, GEPR plans to demolish most the buildings on the part of the property controlled and occupied by GEPR … Buildings 2, 2A, 8A and 30 shall remain and the Groundwater Extraction and Treatment System (GETS) currently located within Building 14 and will be replaced by a new GETS unit located on the south side of the property. An exhaust stack serving the new GETS will be extended vertically from the north side of the unit.” [Executive Summary; 1.1 Purpose and Scope of ESDM Report]

With these additional details in hand, the adequacy of AECOM’s assessment of air emissions under the Future Operation scenario is still unverifiable.

The mass of Volatile Organic Compounds released into the atmosphere is a function of water flow rate and influent concentration and would essentially be unaffected by the mere relocation of the GETS under the Future Operation scenario. Other changes entailed by GEPR’s planned shift from the Existing Operation scenario to the Future Operation scenario may impact the dispersion of VOCs into the environment:

1. 1. 1. the GETS is to be moved to the south side of the property and a new exhaust stack is to be extended vertically from the north side of the relocated unit, and
      2. Building 14, which currently houses the GETS, along with most surrounding buildings, are to be demolished in the shift from the Existing Operation to the Future Operation.

Changes in stack location, stack height, and surrounding-building geometry under the Future Operation scenario may impact the Point-of-Impingement (POI) concentration of VOCs at the nearest receptors — the adjacent homes and Prince of Wales Public School. I am unable to confirm that GEPR’s application takes sufficient account of these changes when modelling air emissions under the Future Operation scenario:

1. 1. 1. the ESDM Report’s discussion of Emission Threshold Screening (pp. 8-9) and Explanation of the Methods Used for Emission Estimates and Data Quality – Air Stripper – Groundwater Treatment (p. 11) are both heavily redacted.
      2. GEPR’s Request for Notice Under s. 7(1) of Local Air Quality Regulation for Use of a Specified Dispersion Model lists both “Surrounding Building Information” and “Downwash Effect” as “Not available.” [6. Additional Facility Information, p. 6]

Finally, I am also unable to determine whether AECOM considered any effect of the extensive demolition — for example, removal of the existing surface cap or changes to subsurface drainage — on the VOC concentration of the groundwater feeding the GETS, because the explanation of the emission-estimate methodology (p. 11) is redacted.

Accordingly, I request:

1. 1. 1. the MECP confirm that GEPR’s Future Operation scenario adequately models the as-built, post-demolition configuration — the new stack location and height, with surrounding buildings removed,
      2. the MECP confirm that predicted VOC concentrations at the nearest homes and at Prince of Wals Public School remain within the applicable O. Reg. 419/05 limits.

Paul Allen

1292 Ridge Rd., Picton, ON

556 Howden St., Peterborough, ON

[email protected]

 

 

 

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