APPROVAL TO OPERATE I Irving Oil Refining G.P. Saint John Oil Refinery

Transcription

1 APPROVAL TO OPERATE I-8902 Pursuant to paragraph 5 (3) (a) of the Air Quality Regulation - Clean Air Act, this Approval to Operate is hereby issued to: Irving Oil Refining G.P. for the operation of the Saint John Oil Refinery Description of Source: PETROLEUM REFINERY Source Classification: Air Quality Regulation Class 1A Parcel Identifier: Mailing Address: P.O. Box 1260

2 Saint John, NB E2L 4H6 Conditions of Approval: See attached Schedule "A" of this Approval Supersedes Approval: I-6672 Valid From: July 01, 2015 Valid To: June 30, 2020 Recommended by: Environment Division Original Signed Original Signed Issued by: A/D for the Minister of Environment and Local Government Date

3 Page 1 of 23 SCHEDULE "A" A. DESCRIPTION AND LOCATION OF SOURCE Irving Oil Refining G.P. operates a petroleum refinery in east Saint John, with a reference crude rate of 313,000 barrels per day. Principal products of the refinery are combustion fuels for use in the transportation sector as well as for space heating and electricity generation. The site consists of two crude distillation towers, two fluidized catalytic cracking units, hydrocracker and reforming operations, desulphurization units, two sulphur plants, a hydrogenation amine tail gas unit (HATGU), a sulphuric acid regeneration unit, two cogeneration units with natural gas-fired turbines and heat recovery steam generators, boilers for steam heating of feedstock and finished products, three flares, three cooling towers and associated tankage for product handling, blending and storage. There exist potential air quality impacts from: 1) the emission of air contaminants principally sulphur dioxide, particulate matter, oxides of carbon and nitrogen, and volatile organic compounds (VOCs) from 32 stacks of various dimensions located throughout the refinery and associated with process units including the catalytic cracking units, sulphur plants, tail gas and acid regeneration units, heat recovery steam generators and boilers, process heaters for the crude units, hydrocracker, rheniformers, hydrogen plant, hydrodesulphurizer, hydrotreaters, visbreaker, and flares; 2) fugitive hydrocarbon vapour emissions; 3) fugitive particulate matter emissions from construction activities;

4 Page 2 of 23 4) VOCs lost from storage tanks, railcars and tank trucks as a result of product storage and shipping; 5) the release of fuel gases through the flares; 6) the evaporation of petroleum products from spillage; 7) elevated noise levels; and 8) emissions of odorous compounds. The Operation of the Petroleum Refinery, located on Loch Lomond Road, in the City of Saint John, County of St. John, and the Province of New Brunswick and identified as Property Identification Number is hereby approved under the Air Quality Regulation - Clean Air Act subject to the following: B. DEFINITIONS 1. "Approval Holder" means Irving Oil Refining G.P. 2. "Department" means the New Brunswick Department of Environment and Local Government. 3. "Minister" means the Minister of Environment and Local Government and includes any person designated to act on the Minister's behalf.

5 Page 3 of "Director" means the Director of the Impact Management Branch of the Department of Environment and Local Government and includes any person designated to act on the Director's behalf. 5. "Facility" means the property, buildings, and equipment identified in the Description of Source above and all contiguous property in title to the Approval Holder at that location, including but not limited to the following: a) Crude Units Nos. 3 and 4 including atmospheric and vacuum distillation towers which separate crude oil into a range of distinct boiling point fractions. Product streams are directed to other process units where they may be further processed to remove impurities, cracked or reformed to provide products for blending, shipping or storage. b) Fluid Catalytic Cracking Unit (FCCU) where vacuum gas oils are cracked to form gasoline, diesel and liquefied petroleum gas. c) Residue Fluid Catalytic Cracking Unit (RFCCU) where vacuum gas oils and residues are converted to fuel gas, propane, propylene, butane, butylene, gasoline, diesel and decant oil. The RFCCU includes the CD Tech Unit, which removes sulphur from gasoline. d) Flue Gas Scrubber (FGS) where particulates and sulphur dioxide are removed from flue gas from the RFCCU. e) Amine Sulphur Recovery Units which strip sulphur (hydrogen sulphide) from the sour gas producing refinery fuel gas which is burned in process heaters and boilers throughout the refinery.

6 Page 4 of 23 f) Sour Water Stripping Units which strip sulphur and nitrogen compounds from sour water prior to its re-use within the refinery or discharge following treatment in the waste water treatment plant. g) Sulphur Recovery Units (SRUs), No. 1 and 2, also known as the Sulphur Plants, which extract sulphur from gas produced by the Amine Sulphur Recovery and the Sour Water Stripping Units. h) Hydrogenation Amine Tail Gas Unit (HATGU) where the majority of any remaining hydrogen sulphide in the tail gas from the SRUs is absorbed in an amine solution and recovered as sulphur before being released. i) Sulphuric Acid Regeneration Unit (SARU) where spent sulphuric acid and sour gas are converted to sulphuric acid. j) Boilers Nos. 1, 3, 5 and 6 burning refinery fuel gas. k) Two Cogeneration Units producing up to 45 MW of electricity each from natural gas-fired turbines and coupled to Heat Recovery Steam Generators (HRSGs) Nos. 1 and 2 using waste heat from the gas turbines and burning refinery fuel gas where required to produce steam at 4100 kilopascals (600 psig). l) Hydrogen Plants where natural gas is converted into hydrogen for use in the Hydrocracker. Naptha and butane can also be used as feed. m) High Pressure Diesel Hydrotreater where heavy diesel and light cycle oil are desulphurized in the presence of hydrogen and a catalyst resulting in the production of ultra-low sulphur diesel products. n) Visbreaker where high temperature is used to crack crude unit bottoms (residuum) into gasoline, diesel and black oil blending stock.

7 Page 5 of 23 o) Rheniformers Nos. 1 and 2 where gasoline blending stocks are reformed to yield a higher octane value fuel. p) Isomerization / Butamer Unit which changes the structure of butane, pentane and hexane. q) Alkylation Units Nos. 1 and 2 where butanes are converted to gasoline blending components having a low vapour pressure. r) Aromatics Saturation Unit where aromatics in light reformate are converted to cyclohexane. s) Naphtha Hydrotreating Unit which removes sulphur compounds from naphtha. t) Hydrodesulphurizer which removes sulphur from blend components for diesel fuel. u) Merox Plant which removes odorous compounds from diesel and jet fuels. v) Tank storage area for raw, intermediate and finished product storage. w) Flares Nos. 1, 2 and 3 used to combust non-condensible gases as well as to provide emergency combustion of gaseous products that are collected during planned or emergency unit shut-downs. 6. "Inspector" means an Inspector designated under the Clean Air Act, the Clean Environment Act, or the Clean Water Act.

8 Page 6 of "environmental emergency" means a situation where there has been or will be a release, discharge, or deposit of a contaminant or contaminants to the atmosphere, soil, surface water, and/or groundwater environments of such a magnitude or duration that it could cause significant harm to the environment or put the health of the public at risk. 8. normal business hours means the hours when the Department's offices are open. These include the period between 8:15 a.m. and 4:30 p.m. from Monday to Friday excluding statutory holidays. 9. "after hours" means the hours when the Department's offices are closed. These include statutory holidays, weekends, and the hours before 8:15 a.m. and after 4:30 p.m. from Monday to Friday. 10. "30 day rolling average" means for each pollutant, the average of the consecutive daily emission rates, determined for the preceding 30 days of Facility operation. 11. Total Reduced Sulphur, abbreviated TRS, is a mixture of sulphur compounds with a characteristic rotten egg odour. The main components in TRS include hydrogen sulfide, methyl mercaptans, dimethyl sulfide, and dimethyl disulfide. 12. "normal cubic metre" or "Nm 3 " means, in respect of a gas, the quantity of gas occupying a volume of one cubic metre at 25 C and at a pressure of kpa. 13. "2-month rolling average" means for each pollutant, the average of the consecutive monthly emission rates, determined for the preceding 2 months of Facility operation. 14. "Sour gas" means the hydrocarbon off-gas generated by several of the process units, and which contains sulphur normally present in the form of hydrogen sulphide.

9 Page 7 of "Volatile Organic Compound", abbreviated VOC, means any organic compound which participates in atmospheric photochemical reactions creating ozone, other than the following which have been excluded because of their negligible photochemical reactivity: methane, ethane, 1,1,1-trichloroethane, acetone, methylene chloride, chlorofluorocarbons (CFCs), fluorocarbons (FCs), and hydrochlorofluorocarbons (HCFCs). 16. "Refinery fuel gas" means sour gas which has been stripped of the majority of its sulphur bearing compounds and which may supplemented with liquefied petroleum gas or natural gas. C. TERMS AND CONDITIONS GENERAL 17. This Facility has been classified as a Class 1A Facility, pursuant to the Air Quality Regulation filed under the Clean Air Act. The Approval Holder shall pay the appropriate fee on or before April 1 of each year. 18. The Approval Holder shall operate the Facility in compliance with the Air Quality Regulation filed under the Clean Air Act of the Province of New Brunswick. Violation of this Approval or any condition stated herein constitutes a violation of the Clean Air Act of the Province of New Brunswick. 19. The issuance of this Approval does not relieve the Approval Holder from compliance with other by-laws, federal or provincial acts or regulations, or any guidelines issued pursuant to regulations.

10 Page 8 of An Inspector, at any reasonable time, has the authority to inspect the Facility and carry out such duties as defined in the Clean Air Act, the Clean Environment Act and/or the Clean Water Act. 21. Prior to April 01, 2019, the Approval Holder shall make application in writing for a renewal of this Approval on a form provided by the Minister. 22. In addition to any requirements under the Environmental Impact Assessment Regulation, the Approval Holder shall make application in writing for an Approval at least two hundred and forty (240) days prior to construction or modification of the source which could result in a change in the characteristics of or an increase in the authorized rate of release of any contaminant into the air. The Approval Holder shall make application on a form provided by the Minister. 23. In the event of Facility closure, the Approval Holder shall notify the Minister at least six (6) months prior to this closure and shall, at that time, prepare and submit to the Minister for review an updated site plan and an engineering proposal for the site rehabilitation and closure. 24. If, in the opinion of the Minister, the environmental impact of the Facility is unacceptable, the Minister reserves the right to cancel this Approval and issue a new Approval as deemed necessary. 25. The terms and conditions of this Approval are severable. If any term and/or condition of this Approval is held invalid, is revoked or is modified, the remainder of the Approval shall not be affected. 26. The Approval Holder shall ensure that all air pollution control equipment, including but not limited to, the Amine Sulphur Recovery and Sour Water Stripping Units, the Sulphur Plants, the Tail Gas Unit, the FCCU cyclonic separators, the RFCCU carbon monoxide combustor, the Flue Gas Scrubber, the flares, and any pollution control or ambient monitoring equipment, are operated in compliance with all Conditions of the Approval.

11 Page 9 of 23 EMERGENCY REPORTING 27. Immediately following the discovery of an environmental emergency, a designate representing the Approval Holder shall notify the Department in the following manner: During normal business hours, telephone the Department s applicable Regional Office until personal contact is made (i.e. no voice mail messages will be accepted) and provide all information known about the environmental emergency. This notification, at the very least, shall include the following information: (a) the name and phone number of the person notifying the Department; (b) the date and time the incident occurred; (c) a description of the incident that occurred; and (d) a summary of any related air quality concern calls including: i) the date, time and location (subdivision) from which a call was received; and ii) the nature of the call including, if an odour, a description of the type of odour, if provided Either during the initial notification, or in a subsequent verbal notification, the Approval Holder shall provide the following additional information: (e) the known or suspected impact (or additional information that has become available since the initial notification) of the incident; (f) what was done to minimize the impact of the incident; and (g) the results of investigation(s) into concern calls including the results of any measurements taken.

12 Page 10 of 23 The telephone number for the Regional Office is provided below: Saint John Regional Office (506) After hours, telephone the Canadian Coast Guard until personal contact is made and provide all information known about the environmental emergency. The telephone number for the Canadian Coast Guard is Within five (5) days of the time of initial notification, a copy of a Detailed Emergency Report shall be faxed, by a designate representing the Approval Holder, to the Department s applicable Regional Office as well as the Department s Central Office using the fax numbers provided below. The Detailed Emergency Report shall include, as a minimum, the following: i) a description of the problem that occurred; ii) a description of the impact that occurred; iii) a description of what was done to minimize the impact; and iv) a description of what was done to prevent recurrence of the problem. Saint John Regional Office Fax No: (506) Central Office Fax No: (506) If at the time of this report, the investigation has not been completed, the report shall provide as much information as is known about the incident at that time. When the investigation is complete, and no more than 15 days following the incident, the Approval Holder shall provide a report containing full details on the known or suspected cause(s) of the incident, mitigation measures implemented to reduce impacts, a qualitative assessment of any off-site impacts and what measures have or will be implemented to prevent a recurrence.

13 Page 11 of At a time convenient to both the Department and the Approval Holder and at least once during the term of the Approval, the Approval Holder shall provide the Department with training on the Irving Oil Refining G.P. Environmental Emergency Response Plan. This training shall provide an overview of the entire plan with specific focus on potential air quality issues, communication and environmental response during an emergency. LIMITS 30. The Approval Holder shall ensure that odour, dust, and/or noise being released from the Facility do not cause adverse impacts to any off-site receptor. In the event impacts are suspected by the Department to be adversely impacting any off-site receptor, the Approval Holder may be required to investigate the degree of impact and/or develop, submit, and implement a Prevention and Control Plan in accordance with a timetable established by the Department. The plan shall be submitted in writing to the Department for review and approval prior to implementation. 31. The Approval Holder shall ensure that the total emission of sulphur compounds (expressed as sulphur dioxide) to the atmosphere from the Facility is: a. less than 14.5 tonnes per day as determined by the 30-day rolling average b. less than 5,200 tonnes per calendar year 32. The Approval Holder shall ensure that the total emission of sulphur compounds (expressed as sulphur dioxide) to the atmosphere from the Sulphur Block (consisting of the sum of emissions from stacks associated with the Sulphur Recovery Units, Tail Gas Unit and Sulphuric Acid Regeneration Unit) is less than 4,000 kilograms per day based on a annual average. 33. The Approval Holder shall ensure total emissions of Nitrogen Oxides (NOx) from the operation of the Facility do not exceed 5,500 metric tonnes per calendar year.

14 Page 12 of The Approval Holder shall ensure that total point source emissions of Particulate Matter (PM) from the operation of the Facility do not exceed 500 metric tonnes per calendar year. 35. The Approval Holder shall ensure that the emission rate of particulate matter from the Flue Gas Scrubber is less than 50 mg/nm3 on a dry basis. 36. The Approval Holder shall ensure that the emissions of particulate matter from the Fluidized Catalytic Cracking Unit are, during normal operation, limited to 300 kg/day as an annual average. In the event of a mechanical failure or in the event that a 2-month rolling average exceeds 325 kg/day, the Approval Holder shall prepare and submit to the Department within 30 days a plan to ensure emission levels remain within the specified limit. ENVIRONMENTAL QUALITY LIMITS 37. The Approval Holder shall ensure that the total reduced sulphur (TRS) ground-level concentrations do not exceed: a) 13 micrograms per cubic metre (9 parts per billion) as a 10 minute average b) 7 micrograms per cubic metre (5 parts per billion) as a 24 hour average 38. The Approval Holder shall ensure that all activities at the facility related to the maintenance, decommissioning, construction and commissioning of any units are carried out in a manner which is as quiet as is feasible. For the purposes of this requirement, the Approval Holder shall ensure that the aforementioned activities do not cause the noise levels at the nearest receptor to exceed the following limits measured on the A-weighted scale over a 1 hour equivalent period.

15 Page 13 of 23 Time of Day 90th Percentile Noise Limit 07:00 to 23: :00 to 07:00 50 FUEL QUALITY AND HANDLING 39. The Approval Holder shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed and secured with a uniquely numbered seal. The numbers on the seal shall be recorded at the Facility and registered with the Saint John Regional Office. In the event that it becomes necessary to open the sour-gas-to-sweet-gas by-pass valve, this may be done only with the authorization of the Shift Manager. In such case, the Approval Holder shall immediately notify the Department upon opening of the valve. 40. The Approval Holder shall ensure that emissions of VOCs from above ground storage tanks at the Facility are controlled in a manner that is consistent with methods described in "Environmental Guidelines for Controlling Emissions of Volatile Organic Compounds from Aboveground Storage Tanks" published by Canadian Council of Ministers of the Environment, dated June, EPISODE CONTROL 41. The Approval Holder shall maintain, and provide updates to the Director as they are prepared, a Sulphur Dioxide Response Plan, the purpose of which is to prevent exceedances of the maximum permissible ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality Regulation - Clean Air Act. 42. The Approval Holder shall implement procedures as required to prevent exceedances of the maximum permissible ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality Regulation - Clean Air Act. This includes, but is not necessarily limited to, implementation of procedures invoked by the Irving Oil Refining G.P. Sulphur Dioxide Response Plan.

16 Page 14 of The Approval Holder shall ensure that, within sustainable limits, the feed to the HATGU is maximized so as to minimize sulphur dioxide emissions from the Sulphur Block. 44. The Approval Holder shall ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour Water Stripping Units, is directed, during normal operation, to the Sulphur Recovery Units and HATGU and/or the Sulphuric Acid Regeneration Unit, and during upset conditions to flare stacks No. 2 and/or No. 3, where upset means an inability to beneficially operate any of the components associated with the recovery of sulphur. 45. The Approval Holder shall conduct all Maintenance and Turnaround operations in a manner that minimizes emissions to the environment. All necessary and reasonable measures shall be taken to prevent impacts on the ambient environment including the creation of odorous or noisy emissions. Where Turnarounds are conducted the Approval Holder shall continue to conduct all operations in compliance with the Approval. 46. The Approval Holder shall ensure that maintenance, decommissioning, construction and/or commissioning activities which are known or suspected to be noisy shall be limited to the hours between 07:00 and 23:00 Monday to Saturday. During periods when noisy activities are scheduled to be conducted either between the hours of 23:00 and 07:00, on Sunday or on Statutory Holidays, the Approval Holder shall provide the Department's Saint John Regional Office with advance notification of 2 days. 47. At least once per year the Approval Holder shall conduct training for its staff with respect to the impacts of its operation (normal and abnormal) such that operation staff are aware of the potential for environmental impacts on the surrounding communities and are thereby better prepared to operate the Facility in a manner which is pro-active in identifying and mitigating impacts. TESTING AND MONITORING 48. The Approval Holder shall conduct any testing and monitoring at such times and in such manner as the Minister may in writing require.

17 Page 15 of The Approval Holder shall continuously monitor the flow rate, temperature, and sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs), when flue gases are being directed through the SRU stacks. The Approval Holder shall also continuously monitor the flow rate, temperature, sulphur dioxide and nitrogen oxide concentrations from stacks associated with the Tail Gas Unit, the Sulphuric Acid Regeneration Unit, the Flue Gas Scrubber and the Heat Recovery Steam Generators. Continuous Emission Monitors shall be maintained and performance tested in accordance with the "CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE" dated 1998 as published by Alberta Environmental Protection Environmental Service. Records of quality-assured data shall be maintained for a minimum of three years and made available in electronic or hard copy when requested by the Department. 50. The Approval Holder shall continuously record the motor amperage used in recirculating, and the ph of, the scrubbing solution fed to the Flue Gas Scrubber. Records of qualityassured data shall be maintained for a minimum of three years and made available in electronic or hard copy when requested by the Department. 51. The Approval Holder shall continue to implement the Fugitive Volatile Organic Compound Emissions Measurement and Reduction Program in accordance with the "Environmental Code of Practice for the Measurement and Control of Fugitive Emissions from Equipment Leaks" as published by the Canadian Council of Ministers of the Environment, dated October, By September 30 of each year, the Approval Holder shall further investigate odour mitigation as it may be applied the tank farm and in particular the tanks, within the tank farm, that are or have been determined to have the greatest contribution to odorous impacts. As part of this on-going investigation the Approval Holder shall prepare annual reports that delineate the efforts to control odours from these source types, the results of these investigations, any mitigation to be permanently applied and any further investigations that are planned for the succeeding year. If the Approval Holder determines that there is a no more that can be done to mitigate odours, the report submitted is to reflect this conclusion. 53. The Approval Holder shall continue to operate and maintain in good working order the following:

18 Page 16 of 23 a) four ambient sulphur dioxide (SO 2 ) monitors located at the following air monitoring stations: Forest Products, Silver Falls, Grandview West 1, and Midwood Avenue; b) an ambient total reduced sulphur (TRS) monitor at the Midwood Avenue air monitoring station. c) an ambient particulate matter (PM 2.5 ) monitor at the Champlain Heights School air monitoring station; d) an ambient monitor for nitrogen oxides (NOx) at the Grandview West 2 air monitoring station; and e) a meteorological tower at the Midwood Avenue air monitoring station. 54. The Approval Holder shall continue to operate and maintain in good working order the appropriate hardware and software which will provide the Facility with independent and real-time access to data from the following: a) six ambient sulphur dioxide (SO 2 ) monitors located at the following air monitoring stations: Forest Hills, Silver Falls, Grandview West 1, Midwood Avenue, Champlain Heights School, and Forest Products; b) three ambient total reduced sulphur (TRS) monitors located at the following air monitoring stations: Champlain Heights School, Midwood Avenue and Forest Hills; c) an ambient particulate matter (PM 2.5 ) monitor at the Champlain Heights School air monitoring station; d) an ambient monitor for nitrogen oxides (NOx) at the Grandview West 2 air monitoring station; and e) a meteorological tower located at the Midwood Avenue air monitoring station. 55. During periods when noisy activities are conducted, the Approval Holder shall ensure that the noise levels at the locations close to the property boundary with residential properties e.g. nearest receptor, are periodically monitored. As the intent of noise monitoring is to control the impacts of noise generated on Facility property, consideration will be given to those impacts that are identified as not being related to the Facility.

19 Page 17 of The Approval Holder shall continue to implement the Refinery Implementation Strategy Plan for Continuous Improvements in Odour Management and prepare an annual update to summarize the year's work to address odours and/or odour assessment. 57. Prior to February 01, 2016, the Approval Holder shall develop an Ambient VOC Monitoring Plan to implement around the refinery boundary to better quantify the ambient air quality in relation to VOCs. REPORTING 58. In the event the Approval Holder violates any Term and Condition of this Approval or the Air Quality Regulation, the Approval Holder is to immediately report this violation by electronic mail to the Saint John Regional Office at and the Central Office in Fredericton to the approvals engineer. If there are concern calls received in relation to the violation, the Approval Holder shall include details of these concern calls in the same notification. In the event the violation may cause the health or safety of the general public to be at risk and/or significant harm to the environment could or has resulted, the Approval Holder shall follow the Emergency Reporting procedures contained in this Approval. 59. In the event that the Approval Holder plans to shut down a unit or units within the refinery, experiences a trip to a unit which results in increased emissions or experiences a trip to a pollution control unit, or any other event which is considered noteworthy but is of a non-emergency or non-violation nature, the Approval Holder shall notify by electronic mail the Department at both the Saint John Regional Office elg.eglregion4@gnb.ca and the Central Office in Fredericton to the approvals engineer, including details of the event and the details of any concern calls received that relate to the subject event(s). 60. Within 30 days of the end of each month, the Approval Holder shall submit to the Director, with a copy to the Director of the Saint John Regional Office, in an electronic and hard copy format acceptable to the Director, an Air Quality Monthly Summary Report which contains, but is not limited to, the following quality-assured data in SI units:

20 Page 18 of 23 a) a summary of daily average emissions of sulphur dioxide and total monthly emissions of sulphur dioxide, nitrogen oxides, particulate matter and carbon monoxide from stacks associated with the: i. Flue Gas Scrubber; ii. iii. iv. Fluidized Catalytic Cracking Unit; Tail Gas and Sulphuric Acid Regeneration Units (and / or the Sulphur Recovery Units where applicable); Boilers, heat recovery steam generators and process heaters; and v. Flares. Where CEMs are used to measure emissions, the data from the CEMs shall be used in the calculation of daily and monthly reported emissions. b) the 30-day rolling average of the total emissions of sulphur compounds as sulphur dioxide from the Facility, including the average at the end of each calendar day; c) a summary of the air quality related calls received from the public including the following information for each call: i) Date, time, and location (subdivision) from which the call was received; ii) iii) Nature of the call including, if an odour, a description of the type of odour noted, if provided; and Results of the call investigation including the results of any measurement taken d) a summary of incidents related to the following i) mitigation measures taken under the Sulphur Dioxide Response Plan; ii) iii) releases to the air environment; and notifications of relevant activities, such as planned or unplanned shutdowns.

21 Page 19 of The Approval Holder shall ensure that where noise monitoring is conducted in accordance with the requirement under Testing and Monitoring, the results of the monitoring shall be compiled within an Excel spreadsheet and provided to the Director within 30 days of the end of the month in which the noise monitoring was conducted. These results can be included in the monthly report if applicable. 62. Within 6 weeks of conducting performance tests, the Approval Holder shall submit to the Director a report detailing the results of the tests. As a minimum, the report shall include accurate and quality-assured emissions data in SI Units on the concentrations and emission rates of: i) sulphur dioxide, ii) nitrogen oxides iii) carbon monoxide, iv) total hydrocarbons, v) carbon dioxide, vi) particulate matter viii) particulate matter particle size distribution from each source tested and ix) particulate matter metal concentrations from the Fluid Catalytic Cracking Unit, Flue Gas Scrubber and each tested unit fired with refinery or low sulphur fuel oil. Operating data at the time of the tests shall be included with the report as well as a comparison with emission data normally generated for compliance purposes. The reporting requirements may be adjusted from time to time at the discretion of the Director. 63. By January 31 of each year, the Approval Holder shall provide to the Director, for review and approval, any updates that have been developed for the Five Year Source Testing Plan including an outline of the performance tests to be carried out during the period of the approval. The Plan shall continue to be designed to measure emissions rates from the major sources within the refinery and to confirm the validity of reported emissions. It shall also be designed to progressively become consistent with the requirements in the Monitoring and Reporting Strategy developed under the National Framework for Petroleum Refinery Emission Reductions. The Approval Holder shall ensure that all performance tests are conducted in accordance with the Department's Guidance Document for Source Testing, dated January 2003 or latest revision. 64. By March 31 of each year, the Approval Holder shall submit to the Director, in electronic and hard copy format acceptable to the Director, an Air Quality Annual Report which contains, but is not limited to, the following quality-assured data in SI units : a) a summary of the environmental performance of the Facility for the previous calendar year

22 Page 20 of 23 b) a list of significant air quality related environmental events or milestones achieved during the year (i.e. additional noise/odour mitigation measures applied throughout the year, etc.) c) a summary of the annual emissions in metric tonnes of sulphur dioxide, nitrogen oxides, particulate matter (Total, PM 10 and PM 2.5 ), and carbon monoxide, by source category including: i) Flue Gas Scrubber ii) iii) iv) Fluidized Catalytic Cracking Unit Sulphur Recovery Units and Sulphuric Acid Regeneration Units Boilers, heat recovery steam generators and process heaters v) Flares Emissions resulting from upsets and maintenance operations should be included. d) a summary of emissions of VOCs in metric tonnes and benzene in kilograms under the following source categories: i. Fugitive ii. iii. iv. Tank Farm Fuel Distribution (Tank truck and Railcar) Stack v. Spills vi. Wastewater Treatment e) the annual average, maximum and standard deviation of the daily mean concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas.

23 Page 21 of 23 f) an updated spreadsheet (provided electronically in Excel) summarizing the refinery stack details including the average annual concentrations and mass emission rates of sulphur dioxide, nitrogen oxides, particulate matter (total, PM 10 and PM 2.5 ), carbon monoxide and VOCs for all refinery stacks based on the current estimation techniques. g) a summary of air quality related calls received by the Approval Holder from the public and the Department; and h) dates and time periods for any ambient monitoring exceedances with a brief summary of the cause. All emissions data included in the annual report shall be provided in spreadsheet format. Any deviations from the Emissions Monitoring and Reporting Plan (NFPRER) shall be noted in the report. 65. By June 30 of each year, the Approval Holder shall prepare and submit a report on the Tank Repair Program aimed at ensuring continuing compliance with the "Environmental Guidelines for Controlling Emissions of Volatile Organic Compounds from Aboveground Storage Tanks" published by the Canadian Council of Ministers of the Environment, dated June, The report shall contain a list of all tanks at the Facility that are affected by the guidelines, including details of the product stored, vapour pressure, and the status of the tank with respect to the 2005 requirements of the aforementioned guideline. The report should also include an estimate of the total annual emissions of VOCs from the tank field. 66. By October 31 of each year, the Approval Holder shall provide to the Director a report for the current year on the Fugitive Volatile Organic Compound Emissions Measurement and Reduction Program in accordance with Part 7 of the "Environmental Code of Practice for the Measurement and Control of Fugitive Emissions from Equipment Leaks" as published by the Canadian Council of Ministers of the Environment, dated October, A table summarizing the estimated fugitive emissions before and after repairs shall be included in the report.

24 Page 22 of By October 31 of each year, the Approval Holder shall provide the Director, for review and approval, the Report prepared under Testing and Monitoring with respect to the investigation of odour mitigation from the tank farm. 68. Each time the Approval Holder plans to install new equipment in the Fluidized Catalytic Cracking Unit or the Residue Fluidized Catalytic Cracking Unit, the aim of which is to maintain or reduce Particulate Matter emissions, the Approval Holder shall provide the Department with advance notification within 5 business days of the information being available. 69. Within 30 days of the end of each year, the Approval Holder shall provide the Director with a report providing an update on the Refinery Implementation Strategy Plan for Continuous Improvements in Odour Management and any work completed to improve odours or the assessment of odours over the year. 70. Prior to February 01, 2016, the Approval Holder shall submit to the Director for review and approval the Ambient VOC Monitoring Plan required under Testing and Monitoring. Prepared by: Sheryl Johnstone, P.Eng. Industrial Approvals Engineer, Industrial Processes

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