DOCUMENT NO. No. Emission Summary and Dispersion Modelling Report, prepared by Golder Associates Ltd. May 2016; and

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1 TECHNICAL MEMORANDUM DATE October 24, 2016 TO Mr. Louis Prevost United Counties of Prescott and Russell CC Marc Bataille, James Parkin DOCUMENT NO. No FROM Rachel Lee Gould INFORMATION RESPONSE TO WSP CANADA INC. On behalf of Colacem Canada Inc. (Colacem), applications to amend the United Counties of Prescott and Russell Official Plan and the Township of Champlain Zoning By-law were submitted on June 10, 2016 to facilitate the development of a cement plant in L Orignal, Ontario. The United Counties of Prescott and Russell (UCPR) contracted WSP Canada Inc. (WSP) to complete a peer review of the following two supporting documents: Emission Summary and Dispersion Modelling Report, prepared by Golder Associates Ltd. May 2016; and Acoustic Assessment Report, prepared by Golder Associates Ltd. January WSP provided comments/questions on the two supporting documents to the UCPR on August 31, 2016; a copy of their letter is provided in Attachment A. Colacem and Golder Associates Ltd. (Golder) have prepared the following responses to address WSP s comments. Emission Summary and Dispersion Modelling Report 2) The air contaminants impacts have been assessed only at the property lines and compliance with the MOECC guidelines have been indicated. However, because of several tall stacks at the facility, it is most likely that the impact at nearby off-site points of receptor (PORs) beyond the Facility boundaries may exceed those of at the property lines. Therefore, dispersion modeling should be completed at the nearest PORs in all critical directions and compliance should be confirmed. The dispersion modelling was conducted following the Ministry of Environment and Climate Change (MOECC) modelling guidelines which includes a tiered receptor grid centered around the facility sources. The grid of receptors is denser closer to the Site and gradually loosens as the distance from the facility increases. As a result, dispersion modelling was completed for receptors located within a 20 km by 20 km Golder Associates Ltd Century Avenue, Suite #100, Mississauga, Ontario, Canada L5N 7K2 Tel: +1 (905) Fax: +1 (905) Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.

2 Mr. Louis Prevost United Counties of Prescott and Russell October 24, 2016 grid, allowing the model to capture the maximum concentration off-site and at receptors within the modelling grid, including receptors beyond the property line. 3) Also, in order to satisfy concerns regarding the impact of contaminants travelling off-site, the critical air contaminants resulting from the proposed facility at points of reception up to two (2) kilometers from the site, at 250 m intervals should be evaluated and compared with the applicable compliance limits. As discussed in Question 2, a tiered receptor grid of 20 km by 20 km was used for the dispersion modelling which includes over 4,000 receptors. Receptor spacing of 200 m or less is used within 2 km from the facility. 4) The facility seems to be using Selective Non-Catalytic Reduction (SNCR) system as a means of converting nitrogen oxides (NOx) with the aid of a catalyst into nitrogen (N2) and water (H2O). A gaseous reductant, typically anhydrous ammonia, aqueous ammonia or urea, is added to as stream of flue or exhaust gas and is adsorbed. The latter may bring in issues related with ammonia emission etc. Since, oxide of nitrogen (NOx) compliance is achieved easily even when the estimate emission rate has been evaluated quite conservatively, it is suggested that retrofitting of SNCR system should be avoided. The proposed SNCR will be a new installation and is part of the proposed cement plant yet to be built. In the ESDM study, Colacem is using a conservative concentration of 1,200 mg/nm 3 of NOx at the point of emission. This assumption results in a maximum value of 286 µg/nm 3 of NOx at the point of impingement, and is within the O. Reg. 419 limit of 400 µg/nm 3. Besides O. Reg. 419, Colacem must comply with O. Reg. 194/05 and meet the tonnes NOx/tonnes clinker limit at the point of emission; this translates to 383 mg/m 3. The Best Available Control Technology Economically Achievable to meet this regulation is SNCR. These systems are also the most commonly used technology in the cement industry within Ontario, USA and Europe. Ammonia emissions from this process were considered in the ESDM report and are well within the limit. 5) The main fuel used is Pet Coke and the emission rates calculation for various contaminants seem to be reasonable, however, its raw composition should be provided. The raw composition of petroleum coke (Pet coke) is enclosed in Attachment B. 6) It has also been proposed that an alternative fuel may also be used in the event of non- availability of Pet coke. However, details of this fuel and its composition have not been provided. Only Pet coke will be used in the proposed cement plant. Should the use of alternative fuels be considered in the future, a new application will be submitted to the relevant regulatory agencies for approval. 2/6

3 Mr. Louis Prevost United Counties of Prescott and Russell October 24, ) The process flow diagram (PFD) provided should contain the mass balance as well as provide quantities of different raw material and finished products at various stage. The process flow diagram with mass balance is enclosed in Attachment C. 8) For the sources E18 and E27 of the kiln, the control measures are mentioned as hybrid dust collector and dust collector. Some more details of these control measures should be provided as they seem to be controlling organics and other pollutants as well apart from Particulate Matters. The only hybrid filter used in the proposed cement plant will be the kiln filter E18. Filter E27, for grate cooler discharge de-dusting, is a standard bag filter and is not associated with the kiln. The hybrid filter is a combination of an electrostatic precipitator sections installed before bag filter sections, both in the same casing. The hybrid filter is an emission control technology that removes particulates (including fines) from exhaust gases. The hybrid filter does not control emissions of organics. These compounds were included as they may be emitted from the kiln operation, as per the emission factors from the US EPA AP-42 Chapter 11.6 Portland Cement manufacturing. Description of the methodology to estimate emissions from the kiln are provided in Appendix B of the ESDM. The hybrid filter integrates electrostatic precipitation (ESP) and filter bag technologies into the same casing. The unique synergy between these two technologies suppresses particle re-entrainment and thus creates a compact, durable, cost-effective, and highly efficient particulate matter collection system that is superior to either technology just by itself. Benefits Superior collection efficiency (>99.99%) for all particle sizes. A long, effective bag life, as the bags are well protected and cleaned without normal dust re-entrainment. System size reduction (less than the normal number of ESP components and 65% 75% fewer bags than a conventional fabric filter) as it operates at a high filtration velocity. Low energy consumption during continuous operation. Easy to implement and retrofit, as there is little reliance on external control parameters. Acoustic Assessment Report Noise Impact Assessment due to the Facility: 1) Under Noise Source Library in CadnaA Model output, all noise sources from E01 to E17 have been shown to have same sound power levels with same octave band frequencies. Similarly, sources from E19 to E38 are shown to have same sound power levels with same octave band frequencies. It is most unlikely that several sources will have exactly the same sound power levels. If they have been taken conservatively, it should be clearly stated. 3/6

4 Mr. Louis Prevost United Counties of Prescott and Russell October 24, 2016 The noise emissions associated with noise sources E01 to E17 and E19 to E38 (i.e., dust collectors) are based on the information available at the time of preparing the Acoustic Assessment Report (AAR). Due to the range in sizes for these noise sources, Golder conservatively established the noise emissions for the unit up to 150,000 cubic feet per minute (cfm) and applied it to all units. Noise sources E18, E39 and E40 were evaluated in further detail due to their capacity exceeding 150,000 cfm. 2) The overall ground absorption co-efficient in the CadnaA model has been taken as 1.0 which mean that the entire ground surface between the sources and the PORs are 100% absorptive in nature which does not seem to be case here. Also, for the ponds, two ground absorption co-efficient have been taken as 0.0 and 0.3, however, no rationale has been provided for these values and why they are distinct from each other. The two ground absorption coefficients 0.0 and 0.3 were inadvertently labelled as both representing the pond. This labelling is incorrect and in actuality the 0.0 represents the pond and 0.3 represents the facility. The geometry for each of these ground absorption areas remains the same. Ground absorption coefficients near or at 0.0 represent acoustically hard conditions (i.e., more reflective) and ground absorption coefficients near or at 1.0 represent acoustically soft conditions (i.e., more absorptive). Based on Golder's experience in noise predictive modelling using measured data, ground absorption coefficients of 0.0, 0.3 and 1.0 are possible but will depend on the actual site conditions. Furthermore, due to the close proximity of the most sensitive Points of Reception (PORs) and the extent of the ground conditions representing the facility, a preliminary analysis on the predicted noise levels across a range of varying ground conditions confirmed a minimal change in predicted noise levels. 3) In the CadnaA model output, for few sources, operating time has been taken while for others, they have been left blank; this should be clarified. In CadnaA, a blank cell under the operating time heading represents the reference time defined under Calculation Configuration. For the purposes of this AAR, the reference time is a one hour period therefore those noise sources with blank cells under the operating time heading, are modelled as operating for the entire one hour period. 4) Truck speeds within the premises are taken as 15 km per hr which seems to be on the higher side. Perhaps, 10 km per hr would represent a more realistic speed. A conservative on-site truck speed estimate of 15 km/hr was used for the assessment. Truck speeds of 10 km/hr would be the speed limit for the site. 4/6

5 Mr. Louis Prevost United Counties of Prescott and Russell October 24, ) There seems to be a noise barrier wall being planned along the entire perimeter of the Facility as per the Planning Justification Report, Official Plan & Zoning By-law, Amendment Applications, Lot 217, Plan M100, Township of Champlain, United Counties of Prescott & Russell, March 15, However, the model seemed to have used only a small portion of the barrier wall for predicting the noise impacts. Moreover, the details of the barrier wall with a drawing giving various dimensions should be shown within the report for clarity. The Planning Justification Report identifies only one acoustical barrier, limited to a section of the facility s south eastern property line. This acoustical barrier is presented in Section 4.1.2, Figure 3 and Figure 4 of the Planning Justification Report. As presented on Figure 2 and Appendix F in the AAR, the acoustic barrier height is 4.9 m, with a length of approximately 150 m. Traffic Noise Impacts at the PORs for Background Noise Level 1) It will be better if a figure/drawing is provided clearly showing roads, receptors and their angles of exposure to the traffic. Please refer to Figures 1 to 4 in Attachment D. Each figure presents the road, existing buildings considered as a barrier, receptor location and the extent of the road and barrier angles of exposure for POR01 to POR05. These were inputs into the STAMSON noise prediction modelling. 2) In various STAMSON models, barrier option has been used, however, google street map is not showing any barriers. It should may be clarified. The use of the barrier option in the STAMSON models represented the localized shielding of the residential dwelling structure itself at each of the PORs. 3) The traffic counts have been used for the year 2015; however, it will be a couple of years before the Facility will start production. Perhaps, a projected traffic count for the year of proposed production may be used. The purpose of the traffic noise analysis was to evaluate if elevated background noise level due to road traffic exists in the vicinity of the facility. For this type of analysis, the accepted approach is to use the minimum one hour traffic count. The use of the 2015 road traffic data is considered to be a conservative approach for the assessment as background noise levels are expected to be the lowest in 2015 relative to future years (thus project changes are more pronounced). 5/6

6 Mr. Louis Prevost United Counties of Prescott and Russell October 24, 2016 Rachel Lee Gould, M.Sc. Senior Project Manager Alyson Beal, P.Eng. Associate RLG/AB/wlm Attachments: Attachment A WSP Comments Attachment B ESDM Question 5: Petcoke Raw Composition Attachment C ESDM Question 7: Simplified Mass Balance Attachment D AAR Traffic Noise Impacts Question 1: Stamson Model Inputs Figures 1 to 4 \\golder.gds\gal\mississauga\active\2015\3 proj\ colacem_l'orignal_champlain\09 information requests\ucpr - wsp and snca and public works\ tm colacem ir wsp 24oct2016.docx 6/6

7 Mr. Louis Prevost United Counties of Prescott and Russell October 24, 2016 ATTACHMENT A WSP Comments

8 MEMORANDUM Date: August 31, 2016 To: Copies: From: County of Prescott-Russell Marco Vincelli, P. Eng., Director, Business Development, Water/Wastewater, WSP Bhuwan M. Prasad, WSP, Markham Project No.: Subject: Peer Review, ESDM and AAR, Colacem Canada Inc., Ontario WSP Canada Inc. (WSP) was retained by the County of Prescott and Russell to peer review the following reports: Emission Summary and Dispersion Modelling Report, Version 1.0, May, 2016 ( ESDM Report ). Acoustic Assessment Report, January, 2016 ( AAR Report ). The reviewer has not had the opportunity of visiting the site, run any of the modeling files (such as, AERMOD, CadnaA, Stamson) and this peer review is based on a desk review of documents as provided above and the following referenced Ontario Minister of the Environment and Climate Changes (MOECC) documents: Guide to Applying for an Environmental Compliance Approval, PIBS 8527e, dated November Procedure for Preparing an Emission Summary and Dispersion Modelling Report PIBS 3614e03, dated March Environmental Noise Guideline Stationary and Transportation Sources Approval and Planning Publication, NPC-300, PIBS 9588e, August WSP Comments WSP comments are as below: There are several forms which need to go with the ECA application. WSP has not been provided with these forms, so, our review does not include them. Since, we have not been provided with the main MOECC application form, WSP is not in a position to confirm whether or not application with regard to sewage, stormwater, waste management would be required. The following comments are specific to the two reports-- the ESDM Report and the AAR Report. MARKHAM 600 Cochrane Drive, Suite 500, Markham, Ontario L3R 5K3 Tel.: (905) Fax: (905)

9 Peer Review, ESDM and AAR, Colacem Canada Inc., Ontario Memorandum Page 2 ESDM Report 1. It was good that AERMOD modeling was used for air dispersion even though s.20 of O. Reg. 419/05 will apply only from February 1st, 2020, since plant will be commissioned in next few years. 2. The air contaminants impacts have been assessed only at the property lines and compliance with the MOECC guidelines have been indicated. However, because of several tall stacks at the facility, it is most likely that the impact at nearby off-site points of receptor (PORs) beyond the Facility boundaries may exceed those of at the property lines. Therefore, dispersion modeling should be completed at the nearest PORs in all critical directions and compliance should be confirmed. 3. Also, in order to satisfy concerns regarding the impact of contaminants travelling off-site, the critical air contaminants resulting from the proposed facility at points of reception up to two (2) kilometers from the site, at 250 m intervals should be evaluated and compared with the applicable compliance limits. 4. The Facility seems to be using Selective Non-Catalytic Reduction (SNCR) system as a means of converting nitrogen oxides (NOx) with the aid of a catalyst into nitrogen (N2) and water (H2O). A gaseous reductant, typically anhydrous ammonia, aqueous ammonia or urea, is added to a stream of flue or exhaust gas and is adsorbed. The latter may bring in issues related with ammonia emission, etc. Since, oxides of nitrogen (NOX) compliance is achieved easily even when the estimated emission rates have been evaluated quite conservatively, It is suggested that retrofitting of SNCR system should be avoided. 5. The main fuel used is Pet Coke and the emission rates calculation for various contaminants seem to be reasonable, however, its raw composition should be provided. 6. It has also been proposed that an alternative fuel may also be used in the event of non-availability of Pet Coke. However, details of this fuel and its composition have not been provided. 7. The Process Flow Diagram (PFD) provided should contain the mass balance as well as provide quantities of different raw materials and the finished products at various stages. 8. For the sources E18 and E27 of the kiln, the control measures are mentioned as hybrid dust collector and dust collector. Some more details of these control measures should be provided as they seem to be controlling organics and other pollutants as well apart from Particulate Matters. AAR Report The Report has two distinct sections: (i) Noise Impact Assessment due to the Facility and (ii) Traffic Noise Impacts at the PORs for background noise level. WSP s review for these two sections is provided below: Noise Impact Assessment due to the Facility 1. Under Noise Source Library in CadnaA Model output, all noise sources from E01 to E17 have been shown to have same sound power levels with same octave band frequencies. Similarly, sources from E19 to E38 are shown to have same sound power levels with same octave band frequencies. It is most unlikely that several sources will have exactly the same sound power levels. If they have been taken conservatively, it should be clearly stated. 2. The overall ground absorption co-efficient in the CadnaA model has been taken as 1.0 which mean that the entire ground surface between the sources and the PORs are 100% absorptive in nature which does not seem to be case here. Also, for the ponds, two ground absorption co-efficient have

10 Peer Review, ESDM and AAR, Colacem Canada Inc., Ontario Memorandum Page 3 been taken as 0.0 and 0.3, however, no rationale has been provided for these values and why they are distinct from each other. 3. In the CadnaA model output, for few sources, operating time has been taken while for others, they have been left blank; this should be clarified. 4. Truck speeds within the premises are taken as 15 km per hr which seems to be on the higher side. Perhaps, 10 km per hr would represent a more realistic speed. 5. There seems to be a noise barrier wall being planned along the entire perimeter of the Facility as per the Planning Justification Report, Official Plan & Zoning By-law, Amendment Applications, Lot 217, Plan M100, Township of Champlain, United Counties of Prescott & Russell, March 15, However, the model seemed to have used only a small portion of the barrier wall for predicting the noise impacts. Moreover, the details of the barrier wall with a drawing giving various dimensions should be shown within the report for clarity. Traffic Noise Impacts at the PORs for background noise level The background traffic noise was conducted using STAMSON, the MOECC's computerized model of ORNAMENT. The Application of the model for the site was consistent with the ORNAMENT technical documents. The computer model input parameters include, among other data, the number of road segments, number of house rows, the positional relationship of the receptor to a noise source or barrier in terms of distance, elevation and angle of exposure to the source, the basic site topography, the ground surface type, traffic volumes, traffic composition and speed limit. However, the following points should be seen: 1. It will be better if a figure/drawing is provided clearly showing roads, receptors and their angles of exposure to the traffic. 2. In various STAMSON models, barrier option has been used, however, google street map is not showing any barriers. It should may be clarified 3. The traffic counts have been used for the year 2015; however, it will be a couple of years before the Facility will start production. Perhaps, a projected traffic count for the year of proposed production may be used. CLOSURE This peer review was prepared for the sole benefit of the County of Prescott and Russell. Our peer review results are based on information provided in the referenced report. We have assumed that the information presented is true and accurate. We cannot be held responsible for the information presented or conclusions if the site conditions differ from those reported. Should you have any questions or concerns, please, do not hesitate to contact Bhuwan Prasad at or bhuwan.prasad@wspgroup.com.

11 Mr. Louis Prevost United Counties of Prescott and Russell October 24, 2016 ATTACHMENT B ESDM Question 5: Petcoke Raw Composition

12 Attachment B Pet coke raw composition

13 Mr. Louis Prevost United Counties of Prescott and Russell October 24, 2016 ATTACHMENT C ESDM Question 7: Simplified Mass Balance

14 Attachment C: Simplified Mass Balance (dry basis) Inlet raw material for raw meal Limestone (for raw meal) z 159 ton/h Shale z 10 ton/h Silica z 17 ton/h Iron ore z 3 ton/h Bauxite z 6 ton/h Process gases 114 ton/h Raw mix 195 ton/h Raw meal 195 ton/h Clinker 125 ton/h Clinker 125 ton/h Inlet material for cement Gypsum z 8 ton/h Cement Limestone Fly ash Silica fume z 7 ton/h z 4 ton/h z 1 ton/h O2 for Combustion 32 ton/h 145 ton/h Pet coke 12 ton/h Not used

15 Mr. Louis Prevost United Counties of Prescott and Russell October 24, 2016 ATTACHMENT D AAR Traffic Noise Impacts Question 1: Stamson Model Inputs Figures 1 to 4

16 MISSISSAUGA, ONTARIO, CANADA POR01_POW DRAFT STAMSON SUMMARY PROJECT TITLE COLACEM CANADA L ORIGINAL CEMENT P LANT SITE LEGEND Road Exposure Angle * Road Building Barrier Barrier Exposure Angle * Distance to Road POR * Road and Barrier Exposure Angles are Approximate and for Illustrative Purposes Only PROJECT # DRAWN BY SC CHECKED BY JT DATE FILENAME _Colacem_29jan2016 STAMSON FIGURE.cna FIGURE:

17 MISSISSAUGA, ONTARIO, CANADA POR02_POW DRAFT STAMSON SUMMARY PROJECT TITLE COLACEM CANADA L ORIGINAL CEMENT P LANT SITE LEGEND Road Exposure Angle * Road Building Barrier Barrier Exposure Angle * Distance to Road POR * Road and Barrier Exposure Angles are Approximate and for Illustrative Purposes Only PROJECT # DRAWN BY SC CHECKED BY JT DATE FILENAME _Colacem_29jan2016 STAMSON FIGURE.cna FIGURE:

18 MISSISSAUGA, ONTARIO, CANADA POR03_POW DRAFT STAMSON SUMMARY PROJECT TITLE COLACEM CANADA L ORIGINAL CEMENT P LANT SITE LEGEND Road Exposure Angle * Road Building Barrier Barrier Exposure Angle * Distance to Road POR * Road and Barrier Exposure Angles are Approximate and for Illustrative Purposes Only PROJECT # DRAWN BY SC CHECKED BY JT DATE FILENAME _Colacem_29jan2016 STAMSON FIGURE.cna FIGURE:

19 POR04_POW POR05_POW MISSISSAUGA, ONTARIO, CANADA DRAFT STAMSON SUMMARY PROJECT TITLE COLACEM CANADA L ORIGINAL CEMENT P LANT SITE LEGEND Road Exposure Angle * Road Building Barrier Barrier Exposure Angle * Distance to Road POR * Road and Barrier Exposure Angles are Approximate and for Illustrative Purposes Only PROJECT # DRAWN BY SC CHECKED BY JT DATE FILENAME _Colacem_29jan2016 STAMSON FIGURE.cna FIGURE: