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12 Clean Harbors Canada Inc. Emission Summary and Dispersion Modelling Report Appendix C Supporting Information for Assessment of Negligibility (21) May 2014

13 Clean Harbors Canada Inc. Emission Summary and Dispersion Modelling Report Appendix C Supporting Information for Assessment of Negligibility Clean Harbors Sources were screened for negligibility using the following screening protocols listed in the ESDM Procedure Document: Combustion of natural gas and propane (Section 7.1.1) Screening out sources that emit contaminants in insignificant amounts (Table B-3) Generalized guidance to identifying Insignificant of Significant Sources and Contaminants (Section 7.3) Sources that are insignificant relative to total emissions (Section 7.2.2) The results of the screening are discussed in greater detail in the following text. Combustion of Natural Gas and Propane: As per Section of the ESDM Procedure Document contaminants other than NOx are generally considered negligible from this type of source and only NOx has been assessed. Sources ANC-01 and ANC-02 have not been included in the NOx modelling because they are small boilers that represent less than 5 percent of the total Facility emissions, as per Section of the ESDM Procedure Document. Screening Out Sources that Emit Contaminants in Insignificant Amounts Table B-3 of the ESDM Procedure Document lists sources that can be considered to be insignificant. The following sources at the Facility are listed in Table B-3: Small maintenance activities (Source ANC-03) Generalized Guidance to Identifying Insignificant or Significant Sources and Contaminants The following sources do not exhaust contaminants to atmosphere and have been considered to be insignificant sources of emissions: Lab-13 Lab-14 T111-T (21) May 2014 C-1

14 Clean Harbors Canada Inc. Emission Summary and Dispersion Modelling Report Sources that are Insignificant Relative to Total Emissions (Section 7.2.2) Tailpipe emissions from on-site trucking activities, dozer activity (1 unit, 7 hours per day), and operation of the excavators (2 units, 4 hours per day each) were deemed to be insignificant since they represent less than 5 percent of the facility-wide emissions of NOx. Additionally, the Clean Harbors Facility is well below the NOx POI and were the tailpipe emissions to be modelled this would still be the case. Therefore there is no need to model tailpipe emissions. Conservative nitrogen oxide emission calculations were prepared based on the km/day of onsite trucking activities, and the hp ratings of the dozer and excavators, as provided by Clean Harbors. Emission Factors for heavy duty gasoline trucks published in the USEPA AP-42 document, Appendix H: Highway Mobile Source Emission Factor Tables were used to estimate NOx tailpipe emissions from on-site trucking activities. The tailpipe emissions from the dozer and the excavators were estimated using emission factors published in the US EPA document, Exhaust and Crankcase Emission Factors for Nonroad Engine Modeling - Compression- Ignition. Table C.1 summarizes the tailpipe emission calculations and assumptions, and demonstrates that they account for less than 5 percent of the total facility-wide emissions of NOx (21) May 2014 C-2

15 Page 1 of 1 TABLE C.1 ASSESSMENT OF NEGLIGIBILITY TAILPIPE EMISSIONS CLEAN HARBORS CANADA INC. CORUNNA, ONTARIO Vehicle Kilometers Travelled per day 65.6 (VKT/day) Equipment Horsepower Ratings Dozer 228 hp Excavator hp Excavator hp Emission Factor Estimated Maximum Percentage of Emission Factor Source ID and Description Compound CAS Number Units Emission Rate Facility Wide (g/s) Emission Rate TP Tailpipe Emissions: On-site Truck Traffic (1) Nitrogen Oxides (2) g/vkt 4.85E % Dozer (3) Nitrogen Oxides (4) g/hp-hr 3.53E % Excavator 1 (3) Nitrogen Oxides (4) g/hp-hr 3.47E % Excavator 2 (3) Nitrogen Oxides (4) g/hp-hr 3.09E % Notes: (1) The following assumptions were made for the calculation of tailpipe emissions from on-site truck traffic: - low altitude - 75,000 km average odometer reading of trucks models km travelled by trucks on on-site roadways per day (Refer to Tables A.19A-A.19C for backup) - To calculate a worst-case 1-hr emission rate, it was assumed that this total distance is travelled during an 8 hour day (not averaged over 24 hours) (2) Emission Factor for heavy duty gasoline trucks published in the USEPA AP-42 document, Appendix H: Highway Mobile Source Emission Factor Tables. The emission factor was selected based on the assumptions noted above and converted to the appropriate units (3.431 g/mile = 2.13 g/vkt) (3) The following assumptions were made for the calculation of tailpipe emissions from the dozer and excavators: - One dozer operates for a maximum of 7 hours per day - Two excavators operate for a maximum of 4 hours per day each - Assumed Tier 1 Engines (Conservative) (4) Emission factors published in the US EPA document, Exhaust and Crankcase Emission Factors for Nonroad Engine Modeling - Compression-Ignition. The emission factor was selected for NOx Zero-hour Steady-State, Tier 1, for hp ratings of CRA (21)

16 Page 1 of 1 TABLE C.1 ASSESSMENT OF NEGLIGIBILITY TAILPIPE EMISSIONS CLEAN HARBORS CANADA INC. CORUNNA, ONTARIO Vehicle Kilometers Travelled per day 65.6 (VKT/day) Equipment Horsepower Ratings Dozer 228 hp Excavator hp Excavator hp Emission Factor Estimated Maximum Percentage of Emission Factor Source ID and Description Compound CAS Number Units Emission Rate Facility Wide (g/s) Emission Rate TP Tailpipe Emissions: On-site Truck Traffic (1) Nitrogen Oxides (2) g/vkt 4.85E % Dozer (3) Nitrogen Oxides (4) g/hp-hr 3.53E % Excavator 1 (3) Nitrogen Oxides (4) g/hp-hr 3.47E % Excavator 2 (3) Nitrogen Oxides (4) g/hp-hr 3.09E % Notes: (1) The following assumptions were made for the calculation of tailpipe emissions from on-site truck traffic: - low altitude - 75,000 km average odometer reading of trucks models km travelled by trucks on on-site roadways per day (Refer to Tables A.19A-A.19C for backup) - To calculate a worst-case 1-hr emission rate, it was assumed that this total distance is travelled during an 8 hour day (not averaged over 24 hours) (2) Emission Factor for heavy duty gasoline trucks published in the USEPA AP-42 document, Appendix H: Highway Mobile Source Emission Factor Tables. The emission factor was selected based on the assumptions noted above and converted to the appropriate units (3.431 g/mile = 2.13 g/vkt) (3) The following assumptions were made for the calculation of tailpipe emissions from the dozer and excavators: - One dozer operates for a maximum of 7 hours per day - Two excavators operate for a maximum of 4 hours per day each - Assumed Tier 1 Engines (Conservative) (4) Emission factors published in the US EPA document, Exhaust and Crankcase Emission Factors for Nonroad Engine Modeling - Compression-Ignition. The emission factor was selected for NOx Zero-hour Steady-State, Tier 1, for hp ratings of CRA (21)

17 Clean Harbors Canada Inc. Emission Summary and Dispersion Modelling Report Appendix D Dispersion Modelling Input and Output Files (Electronic) (21) May 2014

18 Clean Harbors Canada Inc. Emission Summary and Dispersion Modelling Report Appendix E Excerpts From Annual Incinerator Emissions Testing Reports ( ) (21) May 2014

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27 Report Annual Compliance Emission Testing Program at the Clean Harbors Sarnia Incineration Facility (2010) A Report to: Attention: Clean Harbors Canada Inc Telfer Road Corunna, Ontario N0N 1G0 Mr. Dale Leonard Facility Maintenance Manager Tel: (519) Fax: (519) Submitted by: Tina Sanderson, B.Sc. Senior Specialist, Emission Testing Tel: (905) , Ext. 522 Fax: (905) tsanderson@ortech.ca Report No.: pages, 30 Appendices Date: February 15, Mississauga Sarnia Windsor 804 Southdown Road, Mississauga, ON Canada L5J 2Y4 Tel Fax

28 ORTECH Environmental Annual Compliance Emission Testing Program at the Clean Harbors Sarnia Incineration Facility (2010) Report #21223 TABLE OF CONTENTS Page EXECUTIVE SUMMARY INTRODUCTION SOURCE DESCRIPTION Process Description Process Operations EMISSION TESTING PROGRAM PROGRAM ORGANIZATION AND RESPONSIBILITIES SAMPLING LOCATIONS SAMPLING METHODOLOGY Isokinetic Sampling Trains Acid Gases Volatile Organics Combustion Gases Process Sample Collection ANALYTICAL METHODOLOGY Particulate Matter and Metals Semi-Volatile Organics Acid Gases Volatile Organics Feed and Baghouse Dust Samples INTERNAL AND EXTERNAL QA/QC PROGRAM General Pre-Test Activities Emission Testing QA/QC Results Sample Recovery, Handling and Custody Analytical Results Metal Sample Analysis QA/QC Dioxin and Furan Sample Analysis QA/QC Acid Gas Sample Analysis QA/QC Volatile Organic Compound Analysis QA/QC Data QA/QC...33

29 ORTECH Environmental Annual Compliance Emission Testing Program at the Clean Harbors Sarnia Incineration Facility (2010) Report #21223 TABLE OF CONTENTS Page 9. RESULTS AND DISCUSSION Stack Gas Sampling Parameters Stack Gas Physical Parameters Volumetric Flowrate Data Particulate Emission Data Acid Gases Emission Data Combustion Gas Emission Data Metal and Sulphur Emission Data Mercury Emission Data Semi-Volatile Organic Emission Data Dioxins and Furans Emission Data Polychlorinated Biphenyl Emission Data Chlorobenzene and Chlorophenol Emission Data Polycyclic Aromatic Hydrocarbon Emission Data Volatile Organic Emission Data DESTRUCTION AND REMOVAL EFFICIENCIES DISPERSION MODELLING FACILITY PROCESS DATA OTHER EMISSION CRITERIA FEED SAMPLE ANALYSIS LIMITATION ON WASTES COMPARISON OF CONTINUOUS EMISSION MONITORING DATA CONCLUSIONS...56 REFERENCES...58 Figure 1 Incinerator Schematic...59 Figure 2 Particulate Material and Metals Sampling Train...60 Figure 3 Semi-Volatile Organic Train...61 Figure 4 Hydrogen Chloride Sampling Train...62 Figure 5 VOST Train...63 Figure 6 MSML #1 Schematic...64

30 ORTECH Environmental Annual Compliance Emission Testing Program at the Clean Harbors Sarnia Incineration Facility (2010) Report #21223 LIST OF APPENDICES Appendix 1 Data Tables Appendix 2 Certificate of Approval (Air) No Appendix 3 Proving Data Appendix 4 Metals Train Field Data Sheets Appendix 5 Semi-Volatile Organics Train Field Data sheets Appendix 6 Acid Gases Train Field Data Sheets and Gas Volumes Sampled Appendix 7 Volatile Organics Train Field Data Sheets and Gas Volumes Sampled Appendix 8 Metals Train Recovery Data Sheets Appendix 9 Metals Analytical Report Appendix 10 Semi-Volatile Organics Train Recovery Data Sheets Appendix 11 Semi-Volatile Organics Analytical Report Appendix 12 Acid Gases Train Recovery Data Sheets Appendix 13 Acid Gases Analytical Report Appendix 14 Volatile Organics Analytical Reports and DRE Compound Analysis in Feeds Report Appendix 15 Feed and Baghouse Dust Metals Analytical Report Appendix 16 Master Sample Log/Chains of Custody Forms Appendix 17 Internal QA/QC Tables Appendix 18 Equipment Calibration Data Appendix 19 Pre-Test Plan Acceptance Letter Appendix 20 ORTECH CEM Linearity Check Data Appendix 21 ORTECH CEM Calibration Data Appendix 22 Particulate and Metals Test Emission Calculations Appendix 23 Semi-Volatile Organics Test Emission Calculations Appendix 24 ORTECH One-Minute Average Combustion Gas Results Appendix 25 Gas Analysis Graphs Appendix 26 Regulation 346 Dispersion Modelling Results Appendix 27 Clean Harbors Process Data Summaries Appendix 28 Clean Harbors One-Minute Average Combustion Gas Results Appendix 29 Clean Harbors One-Minute Average Process Data Appendix 30 Feed Ultimate Analysis Report

31 ORTECH Environmental Annual Compliance Emission Testing Program Page 1 of 64 at the Clean Harbors Sarnia Incineration Facility (2010) Report #21223 EXECUTIVE SUMMARY The results of an emission testing program performed in November 2010 indicated that the Clean Harbors Canada Ltd. (Clean Harbors), Corunna incineration facility was operating well within compliance for all current Ontario Environmental Protection Act (EPA), Ontario Regulation 419/05 Air Pollution Local Air Quality (Reg. 419) standards and guidelines based on ground level point of impingement concentrations. The emission testing is required annually as part of the Ontario Ministry of the Environment (MOE) Certificate of Approval (Air) (C of A) No , dated April 19, A Notice of Amendment to the C of A was issued on January 24, 2003, Certificate of Approval Waste/Air No G5MSP (referred to herein as Notice of Amendment ). The primary objective of the testing program was to determine the emission rates of specific contaminants and to demonstrate the facility s ability to meet the allowable emission levels for these contaminants according to the specified point of impingement concentration limits. In addition to the requirements of Regulation 419, the Certificate of Approval provides criteria for the total hydrocarbon (THC) concentration on an undiluted basis at the incinerator exit, and in the stack. The C of A also provides concentration limits for carbon monoxide, oxygen, particulate matter, mercury, and the toxic equivalent concentration of dioxins and furans in the stack gases. The following table summarizes the average test results and the corresponding emission criteria: Stack Gas Concentration Criterion Allowable Value Test Average Value Particulate Matter maximum 20 mg/rm 3(1) 2.46 mg/rm 3(1) Mercury maximum 50 μg/rm 3(1) 28.3 μg/rm 3(1) Dioxin and Furan TEQ maximum 80 pg TEQ/Rm 3(1) 8.79 pg TEQ/Rm 3(1) Carbon Monoxide maximum 100 ppm (1) 41.1 ppm (1) Oxygen minimum 8.0 % (2) % (2) Total Hydrocarbons (3) maximum 100 ppm 81.0 ppm Total Hydrocarbons (4) maximum 100 ppm (1) 76.6 ppm (1) (1) (2) (3) (4) adjusted to 11% oxygen, dry at 25 C and 1 atmosphere dry by volume as per C of A (Air) No (wet undiluted incinerator outlet concentration) as per C of A (Air) No G5MSP (dry adjusted stack concentration) Included as part of the emission testing program was a comprehensive, internal Quality Assurance/Quality Control (QA/QC) program. This report describes both the emission testing program and the internal QA/QC program conducted by ORTECH, and summarizes the results.

32 ORTECH Environmental Annual Compliance Emission Testing Program Page 2 of 64 at the Clean Harbors Sarnia Incineration Facility (2010) Report #21223 The emission testing program was conducted over a three day period between November 23 to November 25, 2010 during which three valid tests were completed for each emission component group using several types of sampling trains and sampling methods. The particulate and metals, semi-volatile organics and combustion gas tests were performed simultaneously at the main stack location. During the time required to complete these tests, acid gas and volatile organics tests were also run. Testing was performed at a high load, as specified by the C of A, to demonstrate compliance with MOE emission criteria. During the emission tests, the rich, lean and emulsion feed rates combined were 177.7, and L/min for Test No. 1, Test No. 2, and Test No. 3, respectively. Also during the emission testing program, process data was recorded and composite samples of the liquid waste materials being incinerated were collected for subsequent analysis. The results of these analyses, coupled with the stack gas emission rate measurements, were used to calculate destruction and removal efficiencies (DREs) for four target principal organic hazardous compounds. The average DREs calculated for the emission testing program were as follows: 2- Butanone ( %), Tetrachloroethene ( %), Toluene ( %), and 1,2,4-Trichlorobenzene ( %). Two additional contaminants, ethyl acetate and total xylenes, were analyzed in the stack samples and the feed samples to assess if they were viable DRE compounds for future testing programs. Ethyl acetate and total xylenes were detected in stack gas samples and the emulsion feed samples in quantities greater than the detection limit in all three tests. The average DREs calculated for the emission testing program were as follows: Ethyl Acetate ( %), and Total Xylenes ( %). All tables referenced in this report (excluding the internal QA/QC summary tables) are provided in Appendix 1. Summary results tables for the 2010 emission testing program are provided on the following pages based on calculated ground level point of impingement concentrations for the stack emissions and the DREs. None of the analytical data was blank corrected, although analytical data for some metals (aluminum, boron, calcium, magnesium, silicon and sodium) does not include amounts detected in the hydrofluoric acid extracts of the sampling train filters because of the normally high background levels of these metals. Therefore, contaminant emission rates would tend to be over-estimated.

33 Report Annual Compliance Emission Testing Program at the Clean Harbors Sarnia Incineration Facility (2011) A Report to: Attention: Clean Harbors Canada Inc Telfer Road Corunna, Ontario N0N 1G0 Mr. Dale Leonard Facility Maintenance Manager Tel: (519) Fax: (519) leonard.dale@cleanharbors.com Submitted by: Tina Sanderson, B.Sc. Environmental Scientist Tel: (905) , Ext. 522 Fax: (905) tsanderson@ortech.ca Report No.: pages, 30 Appendices Date: January 24, Mississauga Sarnia Windsor 804 Southdown Road, Mississauga, ON Canada L5J 2Y4 Tel Fax

34 ORTECH Environmental Annual Compliance Emission Testing Program at the Clean Harbors Sarnia Incineration Facility (2011) Report #21291 TABLE OF CONTENTS Page EXECUTIVE SUMMARY INTRODUCTION SOURCE DESCRIPTION Process Description Process Operations EMISSION TESTING PROGRAM PROGRAM ORGANIZATION AND RESPONSIBILITIES SAMPLING LOCATIONS SAMPLING METHODOLOGY Isokinetic Sampling Trains Acid Gases Volatile Organics Combustion Gases Process Sample Collection ANALYTICAL METHODOLOGY Particulate Matter and Metals Semi-Volatile Organics Acid Gases Volatile Organics Feed and Baghouse Dust Samples INTERNAL AND EXTERNAL QA/QC PROGRAM General Pre-Test Activities Emission Testing QA/QC Results Sample Recovery, Handling and Custody Analytical Results Metal Sample Analysis QA/QC Dioxin and Furan Sample Analysis QA/QC Acid Gas Sample Analysis QA/QC Volatile Organic Compound Analysis QA/QC Data QA/QC...34

35 ORTECH Environmental Annual Compliance Emission Testing Program at the Clean Harbors Sarnia Incineration Facility (2011) Report #21291 TABLE OF CONTENTS Page 9. RESULTS AND DISCUSSION Stack Gas Sampling Parameters Stack Gas Physical Parameters Volumetric Flowrate Data Particulate Emission Data Acid Gases Emission Data Combustion Gas Emission Data Metal and Sulphur Emission Data Mercury Emission Data Semi-Volatile Organic Emission Data Dioxins and Furans Emission Data Polychlorinated Biphenyl Emission Data Chlorobenzene and Chlorophenol Emission Data Polycyclic Aromatic Hydrocarbon Emission Data Volatile Organic Emission Data DESTRUCTION AND REMOVAL EFFICIENCIES DISPERSION MODELLING FACILITY PROCESS DATA OTHER EMISSION CRITERIA FEED SAMPLE ANALYSIS LIMITATION ON WASTES COMPARISON OF CONTINUOUS EMISSION MONITORING DATA CONCLUSIONS...56 REFERENCES...58 Figure 1 Incinerator Schematic...59 Figure 2 Particulate Material and Metals Sampling Train...60 Figure 3 Semi-Volatile Organic Train...61 Figure 4 Hydrogen Chloride Sampling Train...62 Figure 5 VOST Train...63 Figure 6 MSML #1 Schematic...64

36 ORTECH Environmental Annual Compliance Emission Testing Program at the Clean Harbors Sarnia Incineration Facility (2011) Report #21291 LIST OF APPENDICES Appendix 1 Data Tables Appendix 2 Certificate of Approval (Air) No Appendix 3 Proving Data Appendix 4 Metals Train Field Data Sheets Appendix 5 Semi-Volatile Organics Train Field Data sheets Appendix 6 Acid Gases Train Field Data Sheets and Gas Volumes Sampled Appendix 7 Volatile Organics Train Field Data Sheets and Gas Volumes Sampled Appendix 8 Metals Train Recovery Data Sheets Appendix 9 Metals Analytical Report Appendix 10 Semi-Volatile Organics Train Recovery Data Sheets Appendix 11 Semi-Volatile Organics Analytical Report Appendix 12 Acid Gases Train Recovery Data Sheets Appendix 13 Acid Gases Analytical Report Appendix 14 Volatile Organics Analytical Reports and DRE Compound Analysis in Feeds Report Appendix 15 Feed and Baghouse Dust Metals Analytical Report Appendix 16 Master Sample Log/Chains of Custody Forms Appendix 17 Internal QA/QC Tables Appendix 18 Equipment Calibration Data Appendix 19 Pre-Test Plan Acceptance Letter Appendix 20 ORTECH CEM Linearity Check Data Appendix 21 ORTECH CEM Calibration Data Appendix 22 Particulate and Metals Test Emission Calculations Appendix 23 Semi-Volatile Organics Test Emission Calculations Appendix 24 ORTECH One-Minute Average Combustion Gas Results Appendix 25 Gas Analysis Graphs Appendix 26 Regulation 346 Dispersion Modelling Results Appendix 27 Clean Harbors Process Data Summaries Appendix 28 Clean Harbors One-Minute Average Combustion Gas Results Appendix 29 Clean Harbors One-Minute Average Process Data Appendix 30 Feed Ultimate Analysis Report

37 ORTECH Environmental Annual Compliance Emission Testing Program Page 1 of 64 at the Clean Harbors Sarnia Incineration Facility (2011) Report #21291 EXECUTIVE SUMMARY ORTECH Environmental (ORTECH) was requested by Clean Harbors to conduct a comprehensive emission testing program at the incineration facility. The emission testing is required annually as part of the Ontario Ministry of the Environment (MOE) Certificate of Approval (Air) (C of A) No , dated April 19, A Notice of Amendment to the C of A was issued on January 24, 2003, Certificate of Approval Waste/Air No G5MSP (referred to herein as Notice of Amendment ). The primary objective of the testing program was to determine the emission rates of specific contaminants and to demonstrate the facility s ability to meet the allowable emission levels for these contaminants according to the specified point of impingement concentration limits. In addition to the requirements of Regulation 419, the Certificate of Approval provides criteria for the total hydrocarbon (THC) concentration on an undiluted basis at the incinerator exit, and in the stack. The C of A also provides concentration limits for carbon monoxide, oxygen, particulate matter, mercury, and the toxic equivalent concentration of dioxins and furans in the stack gases. The following table summarizes the average test results for the three tests conducted by ORTECH and the corresponding emission criteria: Stack Gas Concentration Criterion Allowable Value Test Average Value Particulate Matter maximum 20 mg/rm 3(1) 2.80 mg/rm 3(1) Mercury maximum 50 μg/rm 3(1) 2.12 μg/rm 3(1) Dioxin and Furan TEQ maximum 80 pg TEQ/Rm 3(1) 8.09 pg TEQ/Rm 3(1) Carbon Monoxide maximum 100 ppm (1) 68.9 ppm (1) Oxygen minimum 8.0 % (2) 12.8 % (2) Total Hydrocarbons (3) maximum 100 ppm (1) 123 ppm (1) (1) (2) (3) adjusted to 11% oxygen, dry at 25 C and 1 atmosphere dry by volume as per C of A (Air) No G5MSP (dry adjusted stack concentration) Included as part of the emission testing program was a comprehensive, internal Quality Assurance/Quality Control (QA/QC) program. This report describes both the emission testing program and the internal QA/QC program conducted by ORTECH, and summarizes the results. The emission testing program was conducted over three days between September 20 and September 23, 2011 during which three valid tests were completed for each emission component group using several types of sampling trains and sampling methods.

38 ORTECH Environmental Annual Compliance Emission Testing Program Page 2 of 64 at the Clean Harbors Sarnia Incineration Facility (2011) Report #21291 The particulate and metals, semi-volatile organics and combustion gas tests were performed simultaneously at the main stack location. During the time required to complete these tests, acid gas and volatile organics tests were also run. Testing was performed at a high load, as specified by the C of A, to demonstrate compliance with MOE emission criteria. During the emission tests, the rich, lean and emulsion feed rates combined were 170.6, and L/min for Test No. 1, Test No. 2, and Test No. 3, respectively. The Thermal Desorber Unit (TDU) was exhausting to the incinerator during Test No. 2 and Test No. 3. Also during the emission testing program, process data was recorded and composite samples of the liquid waste materials being incinerated were collected for subsequent analysis. The results of these analyses, coupled with the stack gas emission rate measurements, were used to calculate destruction and removal efficiencies (DREs) for six target principal organic hazardous compounds. The average DREs calculated for the emission testing program were as follows: 2-Butanone ( %), Ethyl Acetate ( %), Tetrachloroethene ( %), Toluene ( %), 1,2,4- Trichlorobenzene ( %) and Total Xylenes ( %). Note the contribution of the Thermal Desorber Unit was not included in the DREs calculations. A single spot sample was collected during the test program to determine the Thermal Desorber Unit contribution to the total DRE feedrate. When the Thermal Desorber Unit contribution is included the average DREs calculated for the emission testing program were as follows: 2-Butanone ( %), Ethyl Acetate ( %), Tetrachloroethene ( %), Toluene ( %), 1,2,4-Trichlorobenzene ( %) and Total Xylenes ( %). All tables referenced in this report (excluding the internal QA/QC summary tables) are provided in Appendix 1. Summary results tables for the 2011 emission testing program are provided on the following pages based on calculated ground level point of impingement concentrations for the stack emissions and the DREs. None of the analytical data was blank corrected, although analytical data for some metals (aluminum, boron, calcium, magnesium, silicon and sodium) does not include amounts detected in the hydrofluoric acid extracts of the sampling train filters because of the normally high background levels of these metals. Therefore, contaminant emission rates would tend to be over-estimated.

39 ORTECH Environmental Annual Compliance Emission Testing Program Page 3 of 64 at the Clean Harbors Sarnia Incineration Facility (2011) Report #21291 Regulation 419 Dispersion Modelling Results for Inorganic and Semi-Volatile Organic Compounds Average Calculated Allowable Percentage Contaminant Emission Impingement Impingement of Status of Rate Concentration Concentration Allowable Allowable Concentration Concentration Base Case 1.00 g/s μg/m 3 Particulate matter 44.0 mg/s μg/m μg/m S Sulphur dioxide 10.2 g/s 21.5 μg/m μg/m S Nitrogen oxides 1.01 g/s 2.12 μg/m μg/m S Carbon monoxide 1.23 g/s 2.59 μg/m μg/m S Hydrogen chloride 456 mg/s 0.96 μg/m 3 60 μg/m S Fluorides (as hydrogen fluoride) 211 mg/s 0.44 μg/m μg/m S Hydrogen cyanide 2.52 mg/s μg/m 3 24 μg/m S Dioxins & furans (TEQ) 0.12 ng TEQ/s pg TEQ/m 3 15 pg TEQ/m G Naphthalene 627 μg/s μg/m 3 36 μg/m G Biphenyl 614 μg/s μg/m 3 60 μg/m G Benzo (a) pyrene μg/s μg/m μg/m G 1,2-Dichlorobenzene 2.67 μg/s μg/m μg/m 3 < G 1,4-Dichlorobenzene 1.90 μg/s μg/m μg/m 3 < S 1,2,4-Trichlorobenzene 0.95 μg/s μg/m μg/m 3 < G Pentachlorophenol 1.39 μg/s μg/m 3 60 μg/m 3 < G Polychlorinated biphenyls 9.47 μg/s μg/m μg/m G S - Standard G - Guideline

40 ORTECH Environmental Annual Compliance Emission Testing Program Page 4 of 64 at the Clean Harbors Sarnia Incineration Facility (2011) Report #21291 Regulation 419 Dispersion Modelling Results for Metals Average Calculated Allowable Percentage Status of Contaminant Emission Impingement Impingement of Allowable Rate Concentration Concentration Allowable Concentration Concentration Base Case 1.00 g/s μg/m 3 Aluminum oxide 1.72 mg/s μg/m μg/m G Antimony mg/s μg/m 3 75 μg/m 3 < S Arsenic 0.47 mg/s μg/m 3 1 μg/m G Barium (as water soluble) mg/s μg/m 3 30 μg/m G Beryllium* mg/s μg/m μg/m S Boron 0.37 mg/s μg/m μg/m S Cadmium mg/s μg/m μg/m S Calcium oxide 2.12 mg/s μg/m 3 20 μg/m S Chromium 0.12 mg/s μg/m 3 5 μg/m G Cobalt mg/s μg/m μg/m G Copper mg/s μg/m μg/m 3 < S Iron (as metal) 1.88 mg/s μg/m 3 10 μg/m S Lead mg/s μg/m 3 6 μg/m S Lithium mg/s μg/m 3 60 μg/m 3 < S Magnesium oxide 0.58 mg/s μg/m μg/m S Manganese (as compounds) mg/s μg/m μg/m G Mercury mg/s μg/m 3 5 μg/m S Molybdenum mg/s μg/m μg/m 3 < G Nickel mg/s μg/m 3 5 μg/m S Phosphorus pentachloride 1.01 mg/s μg/m 3 30 μg/m G Potassium hydroxide 1.00 mg/s μg/m 3 28 μg/m G Selenium 1.11 mg/s μg/m 3 20 μg/m G Silica (as respirable silica) 28.9 mg/s μg/m 3 15 μg/m G Silver mg/s μg/m 3 3 μg/m S Sodium hydroxide 15.8 mg/s μg/m 3 20 μg/m G Strontium mg/s μg/m μg/m 3 < G Tin mg/s μg/m 3 30 μg/m S Titanium 0.70 mg/s μg/m μg/m S Vanadium mg/s μg/m 3 5 μg/m S Zinc 0.15 mg/s μg/m μg/m S S - Standard G - Guideline * These compounds were not detected in any of the emission samples (all analytical results were <MDL).

41 ORTECH Environmental Annual Compliance Emission Testing Program Page 5 of 64 at the Clean Harbors Sarnia Incineration Facility (2011) Report #21291 Regulation 419 Dispersion Modelling Results for Volatile Organic Compounds Average Calculated Allowable Percentage Status of Contaminant Emission Impingement Impingement of Allowable Rate Concentration Concentration Allowable Concentration Concentration Base Case 1.00 g/s μg/m 3 Benzene 74.4 mg/s 0.16 μg/m 3 CARC Bromomethane (methyl bromide) 3.80 mg/s μg/m μg/m 3 < G 2-Butanone (methyl ethyl ketone) 21.1 mg/s μg/m μg/m 3 < S Chloroethene (vinyl chloride)* 0 mg/s 0 μg/m 3 3 μg/m 3 < S 1,1-Dichloroethane (ethylene dichloride)* 0 mg/s 0 μg/m 3 6 μg/m 3 < G trans-1,2-dichloroethene * 0 mg/s 0 μg/m μg/m 3 < G Dichloromethane (methylene chloride) 2.31 mg/s μg/m μg/m 3 < G Ethyl Acetate * 0 mg/s 0 μg/m μg/m 3 < S Ethylbenzene 0.13 mg/s μg/m μg/m 3 < S Isopropylbenzene (cumene) * 0 mg/s 0 μg/m μg/m 3 < S 2-Propanone (acetone) 24.6 mg/s μg/m μg/m 3 < S Styrene 0.61 mg/s μg/m μg/m 3 < S Tetrachloroethene (perchloroethylene) * 0 mg/s 0 μg/m μg/m 3 < G Tetrachloromethane (carbon tetrachloride) * 0 mg/s 0 μg/m μg/m 3 < S Toluene 8.40 mg/s μg/m μg/m 3 < S Tribromomethane (bromoform)* 0 mg/s 0 μg/m μg/m 3 < G 1,1,1-Trichloroethane (methyl chloroform)* 0 mg/s 0 μg/m μg/m 3 < S Trichloroethene * 0 mg/s 0 μg/m 3 36 μg/m 3 < S Trichlorofluoromethane* 0 mg/s 0 μg/m μg/m 3 < G Trichloromethane (chloroform)* 0 mg/s 0 μg/m 3 3 μg/m 3 < S Trichlorotrifluoroethane* 0 mg/s 0 μg/m μg/m 3 < S 1,2,4-Trimethylbenzene (pseudocumene) * 0 mg/s 0 μg/m μg/m 3 < G 1,3,5-Trimethylbenzene * 0 mg/s 0 μg/m μg/m 3 < G Xylenes * 0 mg/s 0 μg/m μg/m 3 < S S - Standard G - Guideline CARC - Carcinogen: emissions should be as low as possible * These compounds were not detected in any of the emission samples (all analytical results were <MDL).

42 ORTECH Environmental Annual Compliance Emission Testing Program Page 6 of 64 at the Clean Harbors Sarnia Incineration Facility (2011) Report #21291 Summary of Destruction and Removal Efficiencies for Volatile Organic Compounds Compund Destruction and Removal Efficiency Coefficient Test Test Test Average of No. 1 No. 2 No. 3 Variation % % % % % 2-Butanone Ethyl Acetate Tetrachloroethene Toluene Total Xylenes ,2,4-Trichlorobenzene

43 Clean Harbors Canada Inc. Emission Summary and Dispersion Modelling Report Appendix F Excerpts from Ambient Air Monitoring Reports ( ) (21) May 2014

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