Company Y Facility Z. Sample 2018 Annual Industrial Air Monitoring Report. EPEA Approval Number March 2019

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1 Company Y Facility Z Sample 2018 Annual Industrial Air Monitoring Report EPEA Approval Number March 2019 Sample 2018 Annual Industry Air Monitoring Report Page 1 of 29

2 DISCLAIMER: This sample report is provided as guidance only. The structure, look and layout of monthly and annual reports are not mandated. Submitters are free to include additional or alternative content to that presented here, provided the requirements of the Air Monitoring Directive (AMD) and their approval are met. Users of this sample report must consult Chapter 9 Reporting of the AMD for requirements. This report represents the submission from one fictitious facility. The content of this sample has been generated in order to try to provide guidance on reporting it should not be viewed as establishing or limiting any requirements of actual facilities. Actual facilities will have different operational conditions and reporting requirements, so the content of actual reports will be different. While all reasonable attempts have been made to create a self-consistent sample report, inconsistencies may exist. Sample 2018 Annual Industry Air Monitoring Report Page 2 of 29

3 Table of Contents Cover Letter... 4 Noted Incidents at the Facility... 5 Operational Issue with Pollution Control Equipment... 5 Facility Modifications... 6 Changes to Monitoring... 6 Deviations from Authorized Monitoring Methods... 6 Certification Reporting Forms Summary of Audit Findings Source Emissions and Testing Results Emissions Testing Results Limit Exceedances, Releases, and Pollution Controls Sulphur Recovery and Removal Results Continuous Ambient Network Equipment and Results Summary Station A at Location A Station B at Location B Station C at Location C Time Series Charts and Windroses for Ambient Air Monitoring Data Ambient Intermittent Data Summary Passive Network Results Summary End of Report Sample 2018 Annual Industry Air Monitoring Report Page 3 of 29

4 12 March 2019 ABC Regulator Street Address City, AB Postal Code ed to: Cover Letter Company Y Facility Z Street Address City, AB Postal Code Phone Number Website RE: Company Y - Facility Z EPEA Approval Number Annual Industrial Air Monitoring Report Enclosed is the 2018 Annual Industrial Air Monitoring Report for the air monitoring program of Company Y - Facility Z, as operated from January to December The Person Responsible for this monitoring program is: Joe Smith, Environmental Director, Company Y Street Address City, AB Postal Code Phone Number Address This report is submitted by: Jack Brown, Environmental Coordinator, Company Y Street Address City, AB Postal Code Phone Number Address This report was prepared by John Bee of Monitoring Co., and reviewed by Jack Brown of Company Y. Company Y has retained the services of Monitoring Co. to conduct air monitoring functions on its behalf. Facility monitoring activities are carried out at the facility location, Rge Rd 71. Continuous and passive ambient monitoring is done in the vicinity, at locations provided within the report. Sample 2018 Annual Industry Air Monitoring Report Page 4 of 29

5 Noted Incidents at the Facility The following incidents were reported for the year 2018: Reference #111115: on 5-May a power outage at the plant affected the inlet compressor performance, resulting in lower acid gas flows and instability in the plant. The SRU was bypassed for two hours and the following exceedances were reported: o SO 2 1-hour emissions of 2.12 tonnes on 5-May for clock hour ending 17:00 MST measured at sulphur recovery unit incinerator stack 88H-302 (exceeding limit of 1.76 tonnes/hour). o SO 2 1-hour concentrations on 5-May of ppm (clock hour ending 17:00 MST) and ppm (clock hour ending 18:00 MST) measured at sulphur recovery unit incinerator stack 88H-302 (exceeding limit of 5150 ppm/hour). o Ambient 1-hour SO 2 concentration of ppb recorded at Station A for clock hour ending 17:00 MST on 5-May, exceeding the 1-hour AAAQO of 172 ppb. Reference #111116: o There were no SO 2 passive monitoring data reported for the month of March 2018 at Passive H location. The sample was sent to the laboratory, but the sample was not analyzed by the laboratory and was reported as missing. Reference #111117: o On October , results of the passive analysis for the month of September were received by Monitoring Co. Upon review of these results, it was found that the SO 2 concentration for the month of September at Passive J was 12.9 ppb, in excess of the 30-day AAAQO of 11ppb. This was reported at 10:30 on October 14. Passive J is the nearest site to the facility, and building downwash under high westerly winds in the month of September is believed to have been a major factor in this exceedance. All analyzers met percent availability requirements of 90% in Over 2018 there were no changes made to ambient data that were submitted (resubmission or deletion) to Alberta s Ambient Air Quality Data Warehouse or to monthly reports that were submitted. NOTE: Ambient data submission for facilities begins with January 2019 data, due by February 28, Sample 2018 Annual Industry Air Monitoring Report Page 5 of 29

6 Operational Issue with Pollution Control Equipment Sulphur recovery bed 2 became plugged at approximately 16:35 MST on 12-Aug. Operators on shift switched over to the backup bed at approximately 16:55 MST. No emissions limits were exceeded. Bed 2 was reconditioned and brought back online at approximately 12:30 on 23-Aug. Facility Modifications In 2018, there were no expansions or modifications to the operations at Facility Z that would affect atmospheric emissions from this facility. Changes to Monitoring The ambient PM2.5 analyzer at Station B (TEOM FDMS) was replaced with a SHARP on October 15. This change was described in the October 2018 monthly report. There were no other changes to monitoring locations or equipment. Deviations from Authorized Monitoring Methods CEMS station ID #11111 is located on a small-diameter duct that cannot meet the sample location requirements of the Alberta CEMS Code and Alberta Stack Sampling Code. This variance was authorized in writing by the Director on November Alternate sampling location details are provided in the CEMS Monitoring Plan and QAP. There were no other changes to monitoring methods. Certification I certify that I have reviewed and verified this report and that the information is complete, accurate and representative of the monitoring results, reporting timeframe and the specified analysis, summarization and reporting requirements. Jack Brown, Environmental Coordinator, Company Y 12 March 2019 Sample 2018 Annual Industry Air Monitoring Report Page 6 of 29

7 1 Reporting Forms The following AMD reporting form was submitted for AMD Emissions Summary Form (AMD5) All other emissions summary reporting requirements were met in monthly reports in Summary of Audit Findings An annual audit and evaluation of the CEMS operation at Facility Z, along with associated records, was performed on October 13-14, led by Jane Dee of Auditors Inc. The following deficiencies were found: The SRU Incinerator temperature sensor calibration drift test is required to be conducted twice annually, and Facility Z had completed one test, with one test remaining or outstanding. The SRU Incinerator preventative maintenance quarterly QA/QC activity is required to be conducted four times per year, and Facility Z had completed three of the four, with one remaining or outstanding. The auditor consultant report recommended that Facility Z complete the aforementioned CEMS activities before year end to ensure compliance with the CEMS Code and the facility QAP. The calibration drift test and quarterly maintenance were successfully completed in November Source Emissions and Testing Results 3.1 Emissions o SO 2 Emissions Total SO 2 emissions in 2018 were tonnes. o NO X Emissions Total NO x emissions (reported as NO 2) were tonnes. 3.2 Testing Results o There were two RATAs performed on sulphur recovery unit incinerator stack 88H-302 on 13-Feb and 21-May, Relative accuracy for the RATAs were 4.12% and 6.90% respectively for SO 2 concentration, and 7.98% and 1.39% respectively for flow. o The 2 manual stack surveys were fulfilled using data obtained during the two RATAs (13- Feb and 21-May). There was an agreement of 3.72% and 0.69% respectively on mass SO 2 emissions from the compliance stack survey. o There were two CGAs performed on the sulphur recovery unit incinerator stack 88H-302 on 4-Jan and 6-Aug, All linearity results were within the specifications of the CEMS Code. 4 Limit Exceedances, Releases, and Pollution Controls SO 2 emission limits were exceeded due to the plant upset on 5-May (ref # ) as described in the cover letter. There were a total of 3 limit exceedances in Sample 2018 Annual Industry Air Monitoring Report Page 7 of 29

8 Table 1: Time Spent Exceeding SO 2 Emission Limits over 2013 to 2018 for SRU Incinerator Year 1 Hr Avg. Conc. (Hours) 1 Hr Mass Emission (Hours) 1 Day Mass Emission (Days) 1 Hr Min. Stack Top Temp (Hours) Total # limit exceedances in year There were no unauthorized releases or accidental releases at the facility in 2018 nor over the previous five years. The SRU operated 100% of the time in There were no instances of operating without required pollution controls in Table 2: Instances Operating without Pollution Controls over 2013 to 2018 for SRU Incinerator Year # Instances Timeframe Notes in year :30 MST 6- June to 13:20 Superclaus unit was taken offline due to boiler feed system failure and repair. MST 15-June Sulphur Recovery and Removal Results During 2018, 410,000 tonnes of sulphur were produced; 0 tonnes of sulphur were remelted; 1300 tonnes of liquid sulphur were trucked into the Facility Z site from various locations; and 0 tonnes of production sulphur were poured to block storage because of changes in sulphur markets. The AMD Sulphur Recovery and Removal Form was submitted monthly for the months of January 2018 through to December A summary of the monthly sulphur recovery efficiency for Facility Z is provided in Table 3. Sample 2018 Annual Industry Air Monitoring Report Page 8 of 29

9 Table 3: Facility Z Monthly Sulphur Recovery Efficiency Month Recovery Efficiency (%) Comments January February March April May June July August Sulphur recovery bed 2 became plugged 12-Aug. Switched to back up bed. Switched back to bed 2 on 23-Aug. September October November December Sample 2018 Annual Industry Air Monitoring Report Page 9 of 29

10 6 Continuous Ambient Network Equipment and Results Summary NOTE: Ambient data submission for facilities begins with January 2019 data, due by February 28, Hourly data and calibration reports for continuous ambient stations for the year 2018 were submitted to Alberta s Ambient Air Data Warehouse for Station A, Station B, and Station C. There were no missed calibrations in 2018 and no calibration failures. Descriptions of issues leading to the use of data qualifier flags was reported in monthly reports. Ambient Data qualifier flags noted in this section are as follows: Table 4: Description of Continuous Ambient Data Qualifier Flags Flag Description Instrument is operational? Hour is valid? C Calibration Yes No G Instrument out for repair No No K Recording system failure No No N Not in service No No P Power failure No No Q Quality assurance Yes No R Recovery Yes No S Daily zero/span Yes No X Machine malfunction No No Y Maintenance Yes (unless otherwise noted) No 6.1 Station A at Location A Table 5: Ambient SO 2 Summary Statistics for Station A Parameter: SO 2 (Units: ppb) Annual Statistics Average Min 1-H Max Date Time 24-H Max Date Operational Time Valid Data Jun 17: Jun 99.70% 95.06% Percentage of readings in concentration range > % 0.29% 0.04% 0.01% 0.01% 0.02% 0.00% 0.00% 0.01% Data Qualifier Flag Summary C P S X Y Hours of Lost Operational Time Total Hours Flagged Table 6: Ambient H 2S Summary Statistics for Station A Parameter: H 2S (Units: ppb) Annual Statistics Average Min 1h Max Date Time 24h Max Date Operational Time Valid Data Oct 20: Oct 99.70% 93.53% Percentage of readings in concentration range > % 1.22% 0.32% 0.05% 0.04% 0.02% 0.00% 0.01% 0.00% Data Qualifier Flag Summary C P S X Y Hours of Lost Operational Time Total Hours Flagged Sample 2018 Annual Industry Air Monitoring Report Page 10 of 29

11 Table 7: Ambient PM 2.5 Summary Statistics for Station A Parameter: PM 2.5 (Units: µg/m 3 ) Annual Statistics Average Min 1h Max Date Time 24h Max Date Operational Time Valid Data Dec 08: Jan 99.89% 99.57% Percentage of readings in concentration range > % 1.43% 0.30% 0.11% 0.05% 0.02% 0.01% 0.01% 0.00% Data Qualifier Flag Summary C P X Y Hours of Lost Operational Time Total Hours Flagged Table 8: Wind Speed Summary Statistics for Station A Parameter: Wind Speed (Units: km/h) and Direction (for operational time, valid data, flag summary) Annual Statistics Operational Average Min 1h Max Date Time 24h Max Date Time Valid Data Mar 14: Dec 99.84% 99.82% Data Qualifier Flag Summary P X Y Hours of Lost Operational Time Total Hours Flagged Table 9: AAAQO Exceedances at Station A Date Time Parameter Avg. Period AAAQO Actual Reading Wind Speed Wind Direction Reference # 5-May 17:00 SO2 1-hr 172 ppb ppb 5.4 km/h Context around the SO 2 AAAQO exceedance at Station A was included in May 2018 monthly report and is summarized in the cover letter. There were no other AAAQO exceedances at Station A in All analyzers and sensors at Station A had operational uptime greater than 90% for all months of Sample 2018 Annual Industry Air Monitoring Report Page 11 of 29

12 6.2 Station B at Location B Table 10: Ambient SO 2 Summary Statistics for Station B Parameter: SO 2 (Units: ppb) Annual Statistics Average Min 1h Max Date Time 24h Max Date Operational Time Valid Data May 12: May 99.37% 98.60% Percentage of readings in concentration range > % 0.03% 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% Data Qualifier Flag Summary C K P X Y Hours of Lost Operational Time Total Hours Flagged Table 11: Ambient H 2S Summary Statistics for Station B Parameter: H 2S (Units: ppb) Annual Statistics Average Min 1h Max Date Time 24h Max Date Operational Time Valid Data May 05: May 99.62% 99.01% Percentage of readings in concentration range > % 3.12% 0.59% 0.18% 0.09% 0.03% 0.02% 0.00% 0.00% Data Qualifier Flag Summary C K P X Y Hours of Lost Operational Time Total Hours Flagged Table 12: Ambient PM 2.5 Summary Statistics for Station B Parameter: PM 2.5 (Units: µg/m 3 ) Annual Statistics Average Min 1h Max Date Time 24h Max Date Operational Time Valid Data May 17: Jan 97.98% 97.59% Percentage of readings in concentration range > % 2.98% 0.15% 0.13% 0.08% 0.06% 0.04% 0.02% 0.00% Data Qualifier Flag Summary C K N P Q X Y Hours of Lost Operational Time Total Hours Flagged Sample 2018 Annual Industry Air Monitoring Report Page 12 of 29

13 Table 13: Wind Speed Summary Statistics for Station B Parameter: Wind Speed (Units: km/h) and Direction (for operational time, valid data, flag summary) Annual Statistics Operational Average Min 1h Max Date Time 24h Max Date Time Valid Data Feb 15: Apr 99.64% 99.58% Data Qualifier Flag Summary K P Y Hours of Lost Operational Time Total Hours Flagged There were no AAAQO exceedances at Station B in The PM 2.5 analyzer at Station B (TEOM FDMS) was replaced with a SHARP on October 15. This change was reported in the October 2018 monthly report. All analyzers and sensors at Station B had operational uptime greater than 90% for all months of Station C at Location C Table 14: Ambient SO 2 Summary Statistics for Station C Parameter: SO 2 (Units: ppb) Annual Statistics Average Min 1h Max Date Time 24h Max Date Operational Time Valid Data Mar 16: Mar % 94.76% Percentage of readings in concentration range > % 0.22% 0.01% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% Data Qualifier Flag Summary C S Y Hours of Lost Operational Time Total Hours Flagged Table 15: Ambient H 2S Summary Statistics for Station C Parameter: H 2S (Units: ppb) Annual Statistics Average Min 1h Max Date Time 24h Max Date Operational Time Valid Data May 01: May % 94.78% Percentage of readings in concentration range > % 1.73% 0.66% 0.25% 0.10% 0.04% 0.00% 0.00% 0.00% Data Qualifier Flag Summary C S Y Hours of Lost Operational Time Total Hours Flagged Sample 2018 Annual Industry Air Monitoring Report Page 13 of 29

14 Table 16: Ambient PM 2.5 Summary Statistics for Station C Parameter: PM 2.5 (Units: µg/m 3 ) Annual Statistics Average Min 1h Max Date Time 24h Max Date Operational Time Valid Data May 08: May 98.14% 97.79% Percentage of readings in concentration range > % 0.49% 0.27% 0.19% 0.18% 0.09% 0.05% 0.00% 0.00% Data Qualifier Flag Summary C X Y Hours of Lost Operational Time Total Hours Flagged Table 17: Wind Speed Summary Statistics for Station C Parameter: Wind Speed (Units: km/h) and Direction (for operational time, valid data, flag summary) Annual Statistics Average Min 1h Max Date Time 24h Max Date Operational Time Valid Data Jan 04: Jan % 99.95% Data Qualifier Flag Summary Y Hours of Lost Operational Time Total Hours Flagged There were no AAAQO exceedances at Station C in All analyzers and sensors at Station C had operational uptime greater than 90% for all months of Sample 2018 Annual Industry Air Monitoring Report Page 14 of 29

15 7 Time Series Charts and Windroses for Ambient Air Monitoring Data 9 5-Year Chart of Annual Average SO 2 Concentrations Concentration (ppb) Station A Station B Station C Objective (8 ppb) Sample 2018 Annual Industry Air Monitoring Report Page 15 of 29

16 0.6 5-Year Chart of Annual Average H 2 S Concentrations Concentration (ppb) Station A Station B Station C Note: Springtime lake outgassing of H 2S believed to be responsible for spike in H 2S concentrations at Station A in Sample 2018 Annual Industry Air Monitoring Report Page 16 of 29

17 16 5-Year Chart of Annual Average PM 2.5 Concentrations Concentration (µg/m 3 ) Station A Station B Station C Note: A wildfire near Station A is believed to be responsible for spike in PM 2.5 concentration at Station A in Sample 2018 Annual Industry Air Monitoring Report Page 17 of 29

18 12 5-Year Chart of Annual Average Wind Speed 10 8 Wind Speed (km/h) Station A Station B Station C Sample 2018 Annual Industry Air Monitoring Report Page 18 of 29

19 240 5-Year Chart of Annual Average Wind Direction Wind Direction ( ) Station A Station B Station C Sample 2018 Annual Industry Air Monitoring Report Page 19 of 29

20 Windrose - Station A NW (315 ) NNW N (0 ) 30% 25% 20% NNE NE (45 ) WNW W (270 ) 15% 10% 5% 0% ENE E (90 ) km/hr km/hr 7-10 km/hr 5-7 km/hr 3-5 km/hr WSW ESE 0-3 km/hr SW (225 ) SE (135 ) SSW S (180 ) SSE Sample 2018 Annual Industry Air Monitoring Report Page 20 of 29

21 Windrose - Station B NNW N (0 ) 15% NNE NW (315 ) 10% NE (45 ) WNW 5% ENE km/hr km/hr W (270 ) 0% E (90 ) 9-12 km/hr 7-9 km/hr 5-7 km/hr WSW ESE 0-5 km/hr SW (225 ) SE (135 ) SSW S (180 ) SSE Sample 2018 Annual Industry Air Monitoring Report Page 21 of 29

22 Windrose - Station C NNW N (0 ) 20% NNE NW (315 ) 15% NE (45 ) WNW 10% 5% ENE km/hr km/hr W (270 ) 0% E (90 ) 8-12 km/hr 5-8 km/hr 4-5 km/hr WSW ESE 0-4 km/hr SW (225 ) SE (135 ) SSW S (180 ) SSE Sample 2018 Annual Industry Air Monitoring Report Page 22 of 29

23 8 Ambient Intermittent Data Summary NOTE: Ambient data submission for facilities begins with January 2019 data, due by February 28, Table 18: Benzene Summary Statistics for Intermittent Monitoring Parameter: Benzene Annual # of AAAQO Exceedances Station Average Minimum Date Maximum Date Samples Station A 0.47 µg/m µg/m3 26-Jan 1.62 µg/m3 14-May 61 0 Station B 1.08 µg/m µg/m3 25-Feb 3.14 µg/m3 13-Jun 61 0 Station C 1.39 µg/m µg/m3 27-Mar 2.72 µg/m3 13-Jul 61 0 Notes: Benzene was sampled at Station A, Station B, and Station C, by Summa Canister per the NAPS Schedule in There were no exceedances of the annual benzene AAAQO in Benzene intermittent data and certificates of analysis from ACME Laboratories were submitted to Alberta s Ambient Air Data Warehouse on a monthly basis Year Chart of Annual Average Benzene Concentrations Concentration (µg/m 3 ) Station A Station B Station C Objective (8 ppb) Sample 2018 Annual Industry Air Monitoring Report Page 23 of 29

24 9 Passive Network Results Summary NOTE: Ambient data submission for facilities begins with January 2019 data, due by February 28, A total of 10 passive stations (measuring SO 2 and H 2S) are operated as part of the ambient air quality monitoring network as follows: Passive D, Passive E, Passive F, Passive G, Passive H, Passive I, Passive J, Passive K, Passive L, and Passive M. Passive samples including replicate samples and blanks were handled and deployed in accordance with the AMD. The passive sample analyses were performed by ACME Laboratories. The full results of this analysis and certificates of analysis from ACME Laboratories were submitted to Alberta s Ambient Air Data Warehouse on a monthly basis. Except for the events noted below, which were reported in monthly reports and summarized in the cover letter, there were no operational issues in 2018 in the passive ambient monitoring network. Passive H: The March 2018 passive SO 2 sample at Passive H went missing after being sent to the laboratory. Passive J: Results of the passive analysis for the month of September indicated that the SO 2 concentration for the month of September at Passive J was 12.9 ppb, in excess of the 30-day AAAQO of 11ppb. This was reported at 10:30 on October 14, with reference # Passive J is the nearest site to the facility, and building downwash under high westerly winds in the month of September is believed to have been a major factor in this exceedance. There were no other AAAQO exceedances in Sample 2018 Annual Industry Air Monitoring Report Page 24 of 29

25 Table 19: SO 2 Summary Statistics for Passive Stations for 2018 Parameter: SO 2 (Units: ppb) Station Annual Average Minimum Month Maximum Month # of Samples AAAQO exceedances Passive D September 2.5 January 13 0 Passive E August 2.1 December 13 0 Passive F September 1.5 January 13 0 Passive G September 0.1 February 12 0 Passive H October 1.1 February 12 0 Passive I July 2.1 January 24 0 Passive J September 12.9 April 13 1 Passive K September 0.2 April 13 0 Passive L October 1.0 February 13 0 Passive M September 0.6 January 24 0 Notes: Results from SO 2 passive samples and their replicates were compared and are within ± 0.6 ppb of each other throughout the year. There was no replicate sample at Passive G in 2018, a replicate will be taken at that site in The blanks indicated no apparent contamination throughout the year. Table 20: H2S Summary Statistics for Passive Stations for 2018 Parameter: H 2S (Units: ppb) Station Annual Average Minimum Month Maximum Month # of Samples Passive D August 2.3 September 13 Passive E February 1.9 August 13 Passive F June 1.5 January 13 Passive G February 0.4 May 12 Passive H April 1.2 June 13 Passive I April 1.9 March 24 Passive J June 2.7 October 13 Passive K June 0.4 January 13 Passive L February 1.1 May 13 Passive M July 0.8 November 24 Notes: Results from H 2S passive samples and their replicates were compared and are within ± 0.32 ppb of each other throughout the year. There was no replicate sample at Passive G in 2018, a replicate will be taken at that site in The blanks indicated no apparent contamination throughout the year. Sample 2018 Annual Industry Air Monitoring Report Page 25 of 29

26 Year Chart of Annual Average SO 2 Concentrations (Passives) Concentration (ppb) Passive D Passive E Passive F Passive G Passive H Passive I Passive J Passive K Passive L Passive M Objective (8 ppb) Year Chart of Annual Average H 2 S Concentrations (Passives) 2.00 Concentration (ppb) Passive D Passive E Passive F Passive G Passive H Passive I Passive J Passive K Passive L Passive M Sample 2018 Annual Industry Air Monitoring Report Page 26 of 29

27 Sulphur Dioxide Spatial Plot of Annual Average Results from Passive Samplers Sample 2018 Annual Industry Air Monitoring Report Page 27 of 29

28 Hydrogen Sulphide Spatial Plot of Annual Average Results from Passive Samplers Sample 2018 Annual Industry Air Monitoring Report Page 28 of 29

29 End of Report This page, 29 of 29, ends the 2018 Annual Air Quality Monitoring Report. Sample 2018 Annual Industry Air Monitoring Report Page 29 of 29