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1 R E P O R T E P O R T EMISSION SUMMARY AND DISPERSION MODELLING REPORT GENERAL MOTORS OF CANADA COMPANY ST. CATHARINES CET CASTING, ENGINE AND TRANSMISSION Company Address: GENERAL MOTORS OF CANADA COMPANY 1908 COLONEL SAM DRIVE OSHAWA, ONTARIO L1H 8P7 Facility Address: ST. CATHARINES CET 570 GLENDALE AVENUE ST. CATHARINES, ONTARIO L2R 7B3 December 21, 2016

2 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." EXECUTIVE SUMMARY AND EMISSION SUMMARY TABLE General Motors of Canada Company has updated this Emission Summary and Dispersion Modelling (ESDM) Report for the St. Catharines Casting, Engine and Transmission Facility (St. Catharines CET or the Facility) as required by its Amended Environmental Compliance Approval with Limited Operational Flexibility Air and Noise (ECA with LOF) Number M7F, dated January 25, 2013 and in support of this application. This report also acts as documentation for the Renewable Energy Approval for the proposed landfill gas generators. The ESDM report was prepared in accordance with Section 26 of O. Reg. 419/05. The inventory and modelling development follows the Ontario Ministry of the Environment and Climate Change (MOECC) Procedure for Preparing an Emission Summary and Dispersion Modelling Report dated March 2009 (ESDM Procedure Document) as appropriate. GM Canada operates the manufacturing Facility located at 570 Glendale Avenue in St. Catharines, Ontario. The Facility is located in an area zoned for industrial use. The closest distance from the Facility to residential zoning is approximately 300 meters as described in the figures in Section 1 and the Land Use Zoning Designation Plans (Appendix A3). The zoning by-law amendment ( ) conforms to the City Plan and revises the piece of land at 555 Glendale Ave., previously zoned as TC-H (tourist Commercial-Holding), to Medium Density Residential. According to the City of St. Catharines zoning technician, this piece of land still carries a holding provision because it is suspected of being contaminated. There were no active applications, permits or proposals for this piece of land throughout The zoning by-law amendment also changes the Facility zoning from Industrial to General Employment however there are no impacts to the Facility based on this revised zoning. The Facility currently machines and then assembles automotive engines and transmissions, with a maximum annual production rate of 2,190,000 automotive engines and 1,095,000 transmissions per year. The Facility generally operates on three shifts, 5 days per week, 48 weeks per year, but is capable of operating 24 hours per day, 365 days per year. The Facility is currently subject to Section 20 of O. Reg. 419/05. The modelled impact of the Facility was assessed against Schedule 3 limits for 24-hr and 1-hr averaging times using the US EPA AERMOD dispersion model. The Facility is expected to emit 28 contaminants, including nitrogen oxides and other products of landfill gas combustion. All sources and contaminants are listed in the Sources and Contaminants Identification Table (Table 2-1). Some of the sources and contaminants were considered negligible in accordance with Section 8 of O. Reg 419/05. The maximum POI concentrations were calculated based on the Operating Conditions where all significant sources are operating simultaneously at their individual maximum production rates as described in Appendix B Supporting Calculations and Operating Scenarios of Significant Sources and Contaminants. The maximum emission rates for the significant contaminant emitted from significant sources were calculated in accordance with Section 11 of O. Reg. 419/05 and the data quality assessment follows the process outlined in the requirements of the ESDM Procedure Document. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21, 2016

3 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." A POI concentration for each significant contaminant emitted from the Facility was determined based on the calculated emission rates and the output from the approved dispersion model; the results are presented in the following Emission Summary Table (Table 1) in accordance with Section 26 of O. Reg. 419/05. In addition, Table 5-1 Source Summary Table (Appendix A) was also completed in accordance with Section 26, of O. Reg. 419/05. Both contaminants listed in Table 1 Emission Summary Table have limits in Schedule 3 of O. Reg. 419/05. The POI concentrations listed in the Emission Summary Table were compared against criteria listed in the publication Summary of Standards and Guidelines to support O. Reg. 419/05: Air Pollution Local Air Quality dated April 2012 (List of Ministry POI Limits) or other acceptable guidelines and standards. All the predicted POI concentrations are below the corresponding limits. US EPA AERMOD dispersion modelling of the Facility predicts that the MOECC POI limits are met. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21, 2016

4 Emission Summary Table RWDI Project Notes: Receptor Contaminant CAS Total Air Maximum Averaging MOECC Limiting Regulation Percentage Property Line Number Facility Dispersion POI Period POI Effect Schedule of MOECC Emission Model Concentration Limit [1] # POI Limit Rate Used (g/s) (µg/m³) (hours) (µg/m³) (%) Nitrogen Oxides E+01 AERMOD 3.21E Health 3 80% E E Health 3 83% Property Line Particulate Matter PM 7.08E-01 AERMOD 7.07E Visibility 3 59% Property Line Carbon Monoxide E+00 AERMOD 5.33E ,000 Health 3 9% Property Line Sulphur Dioxide E-01 AERMOD 1.06E Health and Vegetation 3 15% E E Health and Vegetation 3 16% Property Line Hydrogen Sulfide [2] E-03 AERMOD 3.11E Odour 3 4% E E Odour 3 7% Property Line 1,1,2-Trichloroethane [2] E-05 AERMOD 3.54E N/A JSL 1% [1] The term MOECC POI Limit refers to the following information (there may be more than one relevant MOECC POI Limit for each contaminant): - Air quality standards in Schedule 3 of O. Reg. 419/05; - The Upper Risk Thresholds (URTs) in Schedule 6 of O. Reg. 419/05; - The guidelines for contaminants set out in the MOECC publication, Summary of Standards and Guidelines to Support Ontario Regulation 419: Air Pollution Local Air Quality"; - The Daily Assessment Values (DAV) from the MOECC technical bulletin, Methodology for Using "Assessment Values" for Contaminants with Annual Air Standards"; - The Annual Assessment Values (AAV) from the MOECC technical bulletin, Methodology for Using "Assessment Values" for Contaminants with Annual Air Standards"; or - JSL values set out in the MOECC publication, "Jurisdictional Screening Level (JSL) List A Screening Tool for Ontario Regulation 419: Air Pollution Local Air Quality"; or, - An acceptable concentration for contaminants with no standards or guidelines. [2] These contaminants are only emitted from the landfill gas generators and boiler; for modelling purposes, a unit emission rate was run and scaled to reflect specific contaminant emissions. 24-hr Unit emission rate result: 48 µg/m³ 1-hr Unit emission rate result: 88 µg/m³ [3] As per the MOECC Procedure for Preparing an Emission Summary and Dispersion Modelling Report, draft version 4.0, to avoid complex post-processing steps, annual concentrations from a single 5-year model run can by multiplied by 140% in order to be compared against annual standards.

5 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." Table of Contents 1.0 INTRODUCTION AND FACILITY DESCRIPTION Purpose and Scope of ESDM Report Description of Processes and NAICS Code Description of Products and Raw Material Process Flow Diagram Operating Schedule Facility Production Limit INITIAL IDENTIFICATION OF SOURCES AND CONTAMINANTS Sources and Contaminants Identification Table ASSESSMENT OF THE SIGNIFICANCE OF CONTAMINANTS AND SOURCES Identification of Negligible Contaminants and Sources Rationale for Assessment OPERATING CONDITIONS, EMISSION ESTIMATING AND DATA QUALITY Description of Operating Conditions Explanation of the Methods Used to Calculate Emission Rates Sample Calculations Assessment of Data Quality SOURCE SUMMARY TABLE AND SITE PLAN Source Summary Table Site Plan DISPERSION MODELLING Dispersion Modelling Table Land Use Zoning Designation Plan Dispersion Modelling Input and Output Files Coordinate System Terrain Receptors Building Downwash Stack Height for Certain New Sources of Contaminant Averaging Times and Conversions EMISSION SUMMARY TABLE AND CONCLUSIONS Emission Summary Table Assessment of Contaminants with no MOECC POI Limits Conclusions Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21, 2016

6 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." Electronic copies of the input and output files for the AERMOD model have been submitted on a compact disc (CD), included in the front cover of the application binder. List of Figures FIGURE 1-1: LOCATION OF GM ST. CATHARINES CET 2 FIGURE 1-2: GM ST. Catharines CET Modelled Fenceline 3 FIGURE 1-3: ENGINE ASSEMBLY 6 FIGURE 1-4: TRANSMISSION ASSEMBLY 7 FIGURE 6-1: SOURCE IDENTIFICATION AND ROOF LAYOUT 17 FIGURE 6-2: DISPERSION MODELLING RECEPTORS 18 List of Tables TABLE 1: EMISSION SUMMARY TABLE (PLEASE SEE APPENDIX A1) TABLE 2-1: SOURCES AND CONTAMINANTS IDENTIFICATION TABLE (PLEASE SEE APPENDIX A1) TABLE 3-1: EMISSION THRESHOLD NEGLIGIBILITY ASSESSMENT (PLEASE SEE APPENDIX C) TABLE 5-1: SOURCE SUMMARY TABLE (PLEASE SEE APPENDIX A1) TABLE 6-1: DISPERSION MODELLING INPUT SUMMARY TABLE (PLEASE SEE APPENDIX A1) Appendices APPENDIX A1 TABLES 1, 2-1, 5-1, 6-1 APPENDIX A2 SITE PLAN APPENDIX A3 LAND USE ZONING DESIGNATION PLANS APPENDIX B SUPPORTING CALCULATIONS AND OPERATING SCENARIOS OF SIGNIFICANT SOURCES AND CONTAMINANTS APPENDIX C TABLE 3-1 & SUPPORTING INFORMATION FOR ASSESSMENT OF NEGLIGIBILITY APPENDIX D CURRENT ECA AND PROOF OF LEGAL NAME APPENDIX E ESDM REPORT CHECKLIST Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21, 2016

7 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 1.0 INTRODUCTION AND FACILITY DESCRIPTION This Emission Summary and Dispersion Modelling (ESDM) Report was prepared in accordance with Section 26 of O. Reg. 419/05. In addition, guidance in the Ministry Publication Procedure for Preparing an Emission Summary and Dispersion Modelling Report dated March 2009 (ESDM Procedure Document) was followed as appropriate. For ease of review and to promote clarity this ESDM report is structured to correspond to each of the items listed in the ministry Publication 2009 Emission Summary and Dispersion Modelling Report Checklist. The completed 2009 ESDM Checklist is provided in Appendix E. This section provides a description of the Facility as required by sub-paragraph 1 of Section 26(1) of O. Reg. 419/05. Note that this ESDM report references the Ministry and MOE which are synonymous with the currently named Ministry of the Environment and Climate Change or MOECC. 1.1 Purpose and Scope of ESDM Report This ESDM Report was prepared as required by its Amended Environmental Compliance Approval with Limited Operational Flexibility Air and Noise (ECA with LOF), Number M7F, dated January 25, 2013 and in support of this application. The purpose of the application is to include four (4) proposed natural gas fired boilers that are each greater than 10.5 million kilojoules per hour. This report also acts as documentation for the Renewable Energy Approval for the proposed landfill gas generators. The ESDM report was prepared in accordance with Section 26 of O. Reg. 419/05. The Facility, located at 570 Glendale Avenue, St. Catharines, Ontario is an automotive CET manufacturing Facility producing engines and transmissions, including a variety of production, ancillary and support processes, operations and activities. The Facility consists of approximately 2.08 million square feet (193,232 square meters) of floor space on 142 acres (57.4 hectares) of land. The Facility is located in an area of general employment which includes industrial zoning. The location of the Facility is presented in Figure 1-1: Location of GM St. Catharines CET and an aerial photo showing the Facility and modelled fenceline is presented in Figure 1-2: GM St. Catharines CET Modelled fenceline. The location of the modelled sources and the building heights are presented in Figure 6-1, Source Identification and Roof Layout included in section 6 below. The Facility is located in an industrial area bounded by Glendale Avenue to the north, and by St. Lawrence Seaway Management Corporation (SLSMC) property to the east, south, and west. The CNR Railway line runs east-west immediately outside the south boundary of the plant property and is between the plant property and the SLSMC property. The Welland Canal (operated by the SLSMC) runs along the west side of the plant property and separates GM owned land from its nearest neighbouring residential areas located to the west of SLSMC property. Land Use Zoning Designation Plans for the municipalities of Thorold, St. Catharines, and Niagara-on-the-Lake are provided in Appendix A3. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

8 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." Figure 1-1: Location of GM St. Catharines CET Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

9 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." Figure 1-2: GM St. Catharines CET Modelled Fenceline Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

10 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 1.2 Description of Processes and NAICS Code The Facility currently machines engine parts and then assembles them into automotive engines, manufacturing various engine types. The plant also machines and assembles transmission components and full transmissions. The processes used to manufacture the engines and transmissions are similar for the different engine types and transmissions. Figure 6-2, Source Identification and Roof Layout included in section 6 below, and in Appendix A2 shows the current layout of the modelled buildings in which the production processes and support processes take place. The Facility machines crankshafts, blocks, heads, and transmissions. The blocks and heads may be cast iron or aluminum depending upon the model. Transmission parts are made up of steel, aluminum, plastic and powdered metal. These main production processes are briefly described below. The Facility, governed by this application is inherently complex, diverse and dynamic. It is in the very nature of our operations that short, medium and long-term fluctuations in volumes and processes occur. An important component of this ESDM report is the appropriate acknowledgement and reflection of this inherent complexity, diversity and dynamism in the Environmental Compliance Approval with Limited Operational Flexibility. GM also contemplates the development of appropriate air quality levels based on sound science for species that may emerge in the course of our operations. The protocol for assessment of those levels is conducted by an independent third party expert consistent with the requirements in the ESDM Procedure Document and MOECC document Supporting Information for a Maximum Ground Level Acceptability Request Supplement to Application for Approval, EPA Section 9. The North American Industry Classification System (NAICS) Code that applies to this Facility is Motor Vehicle Gasoline Engine and Parts Mfg. Code is under code 336 Transportation Equipment Manufacturing. The main production processes that occur at the Facility to manufacture automotive engines and components can be broken into machining, washing, gauging, assembly and testing and are described below. Support processes include the powerhouse, maintenance, QA/QC labs, dynamometer, Cogen building and other activities associated with the operation of the Facility. Machining Raw castings and forgings are brought into the plant to be machined. This process involves honing, grinding, drilling and polishing the raw casting/forging. The machining operations create heat and chips. Tools are kept cool and cleared of chips by flooding the tooling with a water-soluble coolant. The chips are carried away by the coolant into a hydromation system which separates the chips from the coolant. Water/oil mist emissions generated by the machining operations are captured by an oil mist collection system. This system filters water/oil mist out of the air through oil mist collectors. The treated air is then vented back into the plant for energy conservation. There are no emissions from these activities. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

11 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." Washing Washers remove residual oils and fine cuttings from the parts after they have undergone the machining processes. The washers associated with engine production use a low volatile watersoluble detergent and are vented directly to the atmosphere. Due to the nature of the detergent, no contaminants are expected to be in the exhaust to the atmosphere and therefore there are no emissions from these activities. Gauging Parts are measured for a variety of QA/QC parameters prior to assembly. This could happen at any stage of the machining process. There are no emissions from these activities. Assembly On the engine and transmission assembly lines, the various components are brought together and assembled into a fully functional engines and transmissions. There are no emissions from the assembly process. Testing There is a cold test at the Facility. The engines and transmissions undergo a cold test prior to shipment. The test consists of turning parts of the engine or transmission to ensure they move smoothly. These cold tests are powered by electricity, and have no emissions associated with them. In addition, there are other support activities that include a powerhouse for compressed air and steam for comfort heating. Support Processes The significant source of NOx emissions are from combustion processes, including the powerhouse and cogeneration building. There are two powerhouse natural gas steam boilers, four proposed landfill gas cogeneration generators, four proposed large boilers (>10,000,000 BTU/hr) in the cogeneration building and various other smaller natural gas combustion equipment such as shower room natural gas boilers and an assortment of natural gas fired heaters including door heaters, radiant heaters and water heaters. The large boilers will meet the required emissions limits as laid out in Guideline A-9; letters from the manufacturer confirming that A-9 requirements are met will be available once a supplier has been chosen. The significant source of PM emissions is from a large baghouse which exhausts a number of activities occurring in the tool room. Support processes and emissions, if applicable, are described in Appendix B and C. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

12 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 1.3 Description of Products and Raw Material The Facility produces engines for rear and front wheel drive vehicles and six speed automatic transmissions. Major production operations include metal machining, subassembly, final assembly and testing. Some of the parts are made elsewhere and some are further processed or machined at the Facility. The machined parts are generally steel or aluminum and machining fluids are used for wet machining processes. Product usages and process information are provided in greater detail in Appendix B - Supporting Calculations and Operating Scenarios of Significant Sources and Contaminants and Appendix C Supporting Information for Assessment of Negligibility. Refer to Table 2-1 Sources and Contaminants Identification Table (Appendix A1) which lists the individual sources of emissions at the Facility. 1.4 Process Flow Diagram Refer to Figure 1-3 Engine Assembly and Figure 1-4 Transmission Assembly for graphical representations of the manufacturing operation processes at the Facility. Figure 1-3: Engine Assembly Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

13 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." Figure 1-4: Transmission Assembly Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

14 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 1.5 Operating Schedule Generally, the plant operates on a three shift basis, up to seven days a week, 24 hours/day approximately 48 weeks per year. The Facility employs approximately 1700 employees. There may be weekend operations based on production schedules and maintenance requirements. 1.6 Facility Production Limit The maximum annual production rate of automotive engines is 2,190,000 per year, and the maximum annual production rate of transmissions is 1,095,000 per year. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

15 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 2.0 INITIAL IDENTIFICATION OF SOURCES AND CONTAMINANTS This section provides an initial identification of all of the sources and the contaminants emitted at the Facility as required by sub paragraphs 2 to 4 of Section 26(1) of O. Reg. 419/05. There may be general ventilation from the Facility that discharges only uncontaminated air from the workspaces or air from the workspace that may include contaminants that come from commercial office supplies, building maintenance products or supplies and washrooms. These types of ventilation sources are considered to be negligible and were not identified as sources at the Facility. 2.1 Sources and Contaminants Identification Table Table 2-1 Sources and Contaminants Identification Table (Appendix A1) lists all of the emission sources at the Facility. Table 2-1 Sources and Contaminant Identification Table (Appendix A1) provides the information required by sub-paragraphs 2-4 of Section 26(1) of O.Reg. 419/05. The expected contaminants from each source are identified in Table 2-1 Sources and Contaminants Identification Table (Appendix A1). For example, the contaminants from Natural Gas Combustion are identified as nitrogen oxides and other products of combustion. Each of the identified sources has been assigned a source reference identifier. For example, Natural Gas Combustion has been designated CM. The location of the discharges from each of the significant sources and/or contaminants is provided in Table 5-1 Source Summary Table (Appendix A1). The sources deemed negligible are further explained in Section 3.1 Identification of Negligible Contaminants and Sources. The details of the significant sources are included in Section 4.0 and in Appendix C Supporting Information for Assessment of Negligibility. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

16 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 3.0 ASSESSMENT OF THE SIGNIFICANCE OF CONTAMINANTS AND SOURCES This section provides an explanation for each source and contaminant identified as negligible in Table 2-1 Sources and Contaminants Identification Table (Appendix A1) as required by subparagraph 5 of Section 26(1) of O. Reg. 419/05. In accordance with Section 8 of O. Reg. 419/05 emission rate calculations and/or dispersion modelling does not have to be performed for emissions from negligible sources or for the emission of negligible contaminants from significant sources. 3.1 Identification of Negligible Contaminants and Sources Air emission sources and contaminants at this Facility are categorized as significant or negligible. There are three types of negligible sources or contaminants: exempt from requiring a permit, minor by rationale (i.e. as per the ESDM Procedure Document), and not Compounds of Concern as a result of modelling. A Compound of Concern is defined by the Facility as a contaminant with a modelled POI concentration which is 10% or more of the POI limit or MCL recommendation. Of all of the sources listed in Table 2-1 Sources and Contaminants Identification Table, most have been identified as negligible. Each negligible source is identified in Table 2-1 Sources and Contaminants Identification Table; for example, the Metallurgy Lab has been determined to be negligible. The remaining sources are significant. For example, the Powerhouse is considered a significant source. These sources are included in the dispersion modelling for the Facility and the contaminants emitted from these sources are referred to as modelled contaminants. Some of the contaminants from the sources that are considered significant have been identified as negligible. Each negligible contaminant from a significant source is identified in the table, for example, the expected contaminants emitted from the proposed dual-fired generators (LFG) are identified as nitrogen oxides, sulphur dioxide, particulate matter, carbon monoxide and various VOCs. The emission of carbon monoxide and some of the VOCs are identified as negligible in Table 2-1 Sources and Contaminants Identification Table as per Section of the Procedure for Preparing an ESDM Report, entitled, Identifying Significant Contaminants Using an Emission Threshold. The remaining contaminants emitted from LFG are considered significant. 3.2 Rationale for Assessment For each source in Table 2-1 Sources and Contaminants Identification Table that has been identified as negligible there is an accompanying documented rationale, for example the rationale for aqueous washers is an exemption as per O.Reg. 524/98, Section 1(1)(10). Exempt sources include sources that have been classified as exempt under the Environmental Protection Act, R.S.O 1990 and its regulations. The technical information required to substantiate the argument that each of the identified sources is negligible is presented in Appendix C Supporting Information for Assessment of Negligibility. Emission threshold calculations can be found in Table 3-1, Emission Threshold Negligibility Assessment in Appendix C. Negligible sources and contaminants include air emissions from ancillary and support services at the Facility such as mobile equipment exhaust and cafeteria exhaust. As per the guidance provided in the ESDM Procedure Document, a source has been considered negligible if its emission rate for a specific contaminant is less than 5% of the total site emission or because they are deemed, using professional judgment, to have minimal impact on the POI concentration. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

17 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 4.0 OPERATING CONDITIONS, EMISSION ESTIMATING AND DATA QUALITY This section provides a description of the operating conditions used in the calculation of the emission estimates and an assessment of the data quality of the emission estimates for each significant contaminant from the Facility as required by sub paragraphs 6 and 7 of Section 26(1) of O. Reg. 419/05. In accordance with Section 8 of O. Reg. 419/05 emission rate calculations and/or dispersion modelling does not have to be performed for emissions from negligible sources or for the emission of negligible contaminants from significant sources. Facility processes and support activities and the air inventory were reviewed to identify air emission sources. Emission estimations were calculated based on EPA AP-42 emission factors and conservative engineering calculations. Appendix B Supporting Calculations and Operating Scenarios of Significant Sources and Contaminants details the calculations and methodologies used to determine emission rates for significant emission sources. Since emissions from these sources were modelled they are referred to as modelled contaminants in this ESDM Report. There are seven significant contaminants emitted from the Facility: Nitrogen Oxides (NO x ) and Particulate Matter (PM) Oil Mist (OM), Carbon Monoxide, Sulphur Dioxide, Hydrogen Sulfide and 1,1,2-Trichloroethane. 4.1 Description of Operating Conditions As noted in Section 1.2 the NAICS code for the Facility is Motor Vehicle Gasoline Engine & Parts Mfg. Code is grouped under code 336 Transportation Equipment Manufacturing which is listed in Schedule 5 of Regulation 419/05. The Facility transitioned to Section 20 of O. Reg. 419/05 on February 1, 2013, and the modelled impact of the Facility was assessed against Schedule 3 limits for 24-hr, 1-hr and other averaging times using the AERMOD approved model. Section 10 of O. Reg. 419/05 states that an acceptable operating condition is a scenario that assumes operating conditions that would result, for the relevant contaminant, in the highest concentration of the contaminant at the POI. The operating condition used for the Facility that results in the maximum concentration at the POI is the scenario where all significant sources are operating simultaneously at their individual maximum rates of production throughout the operating schedule of the Facility. The specific operating scenarios with explanations of calculation methodology of the various sources are described in Appendix B Supporting Calculations and Operating Scenarios of Significant Sources and Contaminants. 4.2 Explanation of the Methods Used to Calculate Emission Rates The maximum emission rates for each significant contaminant emitted from the significant sources for each averaging time was calculated in accordance with requirements of the ESDM Procedure Document. The emission rate for each modelled contaminant emitted from a significant source was estimated and the methodology for the calculation is documented in Appendix B Supporting Calculations and Operating Scenarios of Significant Sources and Contaminants and in Table 5-1 Source Summary Table in Appendix A1. For example, the emission of nitrogen oxides from the natural gas combustion was calculated using an emission factor (EF) technique. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

18 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 4.3 Sample Calculations The technical rationale, including sample calculations, required to substantiate the emission rates presented in Table 5-1 Source Summary Table in Appendix A1 are described in Appendix B Supporting Calculations and Operating Scenarios of Significant Sources and Contaminants. 4.4 Assessment of Data Quality This section provides a description of the assessment of the data quality of the emission estimates rate for each modelled contaminant from the Facility as required by sub-paragraph 7iii of Section 26 (1) of O. Reg. 419/05. The assessment of the data quality of the emission rate estimates for each modelled contaminant emitted from the significant sources was performed in accordance with the requirements of the ESDM Procedure Document. For each contaminant the emission rate was estimated and the data quality of the estimate is documented in Table 5-1 Source Summary Table. The assessment of data quality for each source listed in Table 5-1 Source Summary Table is documented in Appendix B - Supporting Calculations and Operating Scenarios of Significant Sources and Contaminants. For example, an AP-42 emission factor was used to calculate the emission rate of nitrogen oxides from natural gas combustion is documented as Above-Average data quality because the US EPA emission factor rating was B. All the emission rates listed in Table 5-1 Source Summary Table (Appendix 2) correspond to the operating scenario where all significant sources are operating simultaneously at their individual maximum rates of production. Therefore, the emission rate estimates listed in Table 5-1 Source Summary Table are not likely to be an underestimate of the actual emission rates. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

19 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 5.0 SOURCE SUMMARY TABLE AND SITE PLAN This section provides the information required by sub-paragraph 8 and the Site Plan required by sub-paragraph 9 of Section 26(1) O. Reg. 419/ Source Summary Table The emission rate estimates for each source of modelled contaminants and the source data information are documented in Table 5-1 Source Summary Table (Appendix A1) in accordance with requirements of sub-paragraph 8 of Section 26(1) of O. Reg. 419/05. Only modelled contaminants are listed on the Source Summary Table. For each source of modelled contaminants, the following parameters are referenced: Contaminant Chemical Abstract Society (CAS) reference number Source reference number Source description Stack parameters for point sources (flow rate, exhaust temperature, diameter, height above grade, height above roof), and for virtual sources (height of virtual source) Location referenced to a Cartesian coordinate system presented on the Site Plan Maximum emission rate (g/s) Averaging period (hr) Emission estimating technique Estimation data quality Percentage of overall emission 5.2 Site Plan Together, Figure 1-2 and Figure 6-1 present the information required by sub-paragraph 9 of Section 26(1) O. Reg. 419/05. The locations of the modelled discharges and the elevation of the structures on the property are presented in Figure 6-1, Source Identification and Roof Layout in Section 6 and Appendix A2. The location of each source is referenced to the UTM system under a column in Table 5-1. The location of the modelled fenceline, with the end points of each section clearly referenced to the UTM coordinate system, is indicated on Figure 1-2, St. Catharines CET Modelled Fenceline found in Section 1 and Appendix A2. Self-contamination modelling was not considered in this assessment as there are no sensitive receptors on the Facility property (i.e. child care Facility). Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

20 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 6.0 DISPERSION MODELLING The dispersion modelling assessment was conducted in order to calculate the maximum predicted concentration at points of impingement as required by sub-paragraphs 10 to 13 of Section 26(1) of O. Reg. 419/05. The dispersion modelling was conducted in accordance with MOECC Guideline A11: Air Dispersion Modelling Guideline for Ontario (ADMGO) dated March The Facility became subject to Section 20 of O. Reg. 419/05 on February 1, Therefore, the predicted concentrations due to contaminant emissions from the Facility were compared to the Schedule 3 Standards under O. Reg. 419/05. The appropriate model to assess to Schedule 3 Standards is the US EPA AERMOD dispersion model. The most recent US EPA AERMOD dispersion model at the time of the assessment was version 14134, which was used for this assessment. The AERMOD dispersion model consists of two input data processors; AERMET and AERMAP. AERMET is a meteorological data pre-processor that prepares hourly surface data and upper air data for use in the US EPA AERMOD dispersion model by incorporating air dispersion based on planetary layer turbulence structure and scaling concepts. AERMET processes meteorological data in three stages: Stage 1: AERMET extracts the meteorological data from the data files, Stage 2: AERMET merges all data available for 24 hour periods and stores the data together in a single file Stage 3: AERMET reads the merged meteorological data and estimates the necessary boundary layer parameters for AERMOD use. AERMAP is a terrain data pre-processor that produces terrain base elevations for each receptor and source as well as a hill height scale value for each receptor by incorporating digital elevation data. First AERMAP determines the base elevations at each receptor and source, it then searches for the terrain height and location that has the greatest influence on dispersion for each individual receptor (hill height scale) and produces those values in a file that can be used directly in AERMOD. 6.1 Dispersion Modelling Table Table 6 1 (Appendix A1) provides a summary of the way in which the approved dispersion model was performed. This table meets both the requirements of Section 26(1)11 and Sections 8 to 17 of O. Reg. 419/05 and follows the format provided in the ESDM Procedure Document. As per section 4.5 of the ADMGO the significant sources at the Facility were classified as either point or volume sources. The source data that is required for each source was determined according to the procedures provided in the ADMGO. The sources are a combination of point and volume. The sources, roof layout and building heights are presented in Figure 6-1. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

21 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 6.2 Land Use Zoning Designation Plan A meteorological data set consisting of five years ( ) of hourly readings for surface and upper air conditions were used in the AERMOD model. The MOECC meteorological data recommended for this site are for the West Central Region. These include surface data from London, Ontario and upper air data from White Lake, Michigan. The data for these sites were obtained from the MOECC Ontario Regional Meteorological Data website. Sub-paragraph 10 of Section 26(1) of O. Reg. 419/05 requires a description of the local land use conditions if meteorological data described in paragraph 2 of Section 13(1) of O. Reg. 419/05 was used. The dispersion modelling at the site did not use meteorological data described in paragraph 2 of Section 13(1) therefore a description of the local land use conditions is not required. However, the Land Use Zoning Designation Plans that describe the nearby land use is provided in Appendix A Dispersion Modelling Input and Output Files The dispersion model input data are summarized in the Dispersion Modelling Input Summary Table (Table 6-1 in Appendix A2). Electronic copies of the input and output files for the AERMOD model are available through the Environmental Officer. 6.4 Coordinate System The coordinate system that was used for dispersion modelling was the Universal Transverse Mercator (UTM) geographic co-ordinate system. The Facility is located in zone 17 north. 6.5 Terrain Terrain data for the area surrounding the Facility were obtained from the MOECC Ontario Digital Elevation Model Data web site. The terrain data are based on the North American Datum 1983 (NAD83) horizontal reference datum. These data were run through the AERMAP terrain preprocessor to estimate base elevations for receptors, which allow the model to account for changes in elevation of the surrounding terrain. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

22 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 6.6 Receptors The area of modelling coverage was designed to meet the requirements outlined in O. Reg. 419/05, s 14. A multi-tiered receptor grid was developed with reference to Section 7.2 of the ADMGO; therefore, interval spacing was dependent on the receptor distance from on-site sources. All receptors in the grid were positioned at ground level. The interval spacing was dependent on the receptor distance from the on-site sources. The receptor spacing for each tier of the receptor grid is summarized below: 20m spacing up to 200 m distance; 50m spacing up to 300 m distance; 100 m spacing up to 800 m distance; 200 m spacing up to 1800 m distance; 500 m spacing up to 4800 m; and 1000 m spacing beyond 4800 m. There is no child care Facility, health care Facility, senior residence, long term care Facility or education Facility located at the Facility. Furthermore, the nearest POI is located approximately 635 meters from the point which emissions are located. As such, same structure contamination was not considered. The area of modeling coverage is illustrated in Figure 6-2, Dispersion Modelling Receptors. 6.7 Building Downwash Building downwash was taken into account for in this assessment. The building outlines and their associated heights were entered into the dispersion model setup. The building downwash program Building Profile Input Program (BPIP) was run to calculate the appropriate building downwash parameters, which were then used in the dispersion modelling. 6.8 Stack Height for Certain New Sources of Contaminant This is an existing Facility, and therefore Section 15 of O. Reg. 419/05 does not apply. 6.9 Averaging Times and Conversions 1-hour and 24-hour averaging times were used with the AERMOD model to compare to Schedule 3 Standards under O. Reg.419/05, and other ministry POI Guidelines listed in the MOECC publication 6570e: Ontario s Ambient Air Quality Criteria, dated April Half hour and 10-min averaging period results were calculated using the 1-hour result and multiplying by a factor of 1.2 and 1.65, respectively, as per MOECC Guidance.. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

23 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." Figure 6-1 Source Identification and Roof Layout Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

24 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." Figure 6-2 Dispersion Modelling Receptors Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

25 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 7.0 EMISSION SUMMARY TABLE AND CONCLUSIONS This section provides the table required by sub-paragraph 14 of Section 26(1) of O. Reg. 419/05 and provides an interpretation of the results as required by the ESDM Procedure Document. 7.1 Emission Summary Table A POI concentration for each modelled contaminant emitted from the Facility was calculated based on the emission rates listed in Table 5-1 Source Summary Table and the output from the approved dispersion model presented in Appendix D Dispersion Modelling Printouts. The results are presented in Table 1-1 Emission Summary Table. This table follows the format provided in the ESDM Procedure Document. For each source of modelled contaminants the following parameters are referenced: Contaminant name Chemical Abstract Society (CAS) reference number Approved dispersion model used Standard or indication of the likelihood of an adverse effect Maximum POI concentration Averaging period for the dispersion modelling Indication of the limiting effect Schedule in Regulation 419/05 Percentage of standard or indication of the likelihood of an adverse effect 7.2 Assessment of Contaminants with no MOECC POI Limits Sub-paragraph 14(viii) of Section 26(1) O.Reg. 419/05 requires an indication of the likelihood, nature and location of any adverse effect if the contaminant is not listed in any of the Schedules 1, 2 and 3. There is one non-negligible contaminant that does not have a MOECC standard or JSL: oil mist. A half hour reference level of 100 µg/m 3 for oil mist was accepted by the MOECC in the previous Certificate of Approval #7069-6NRHFS. The 24 hour limit recommended by a third party toxicologist is 50 µg/m 3. The predicted POI concentration for oil mist using 24 hour averaging time is 0.69 µg/m 3, which is approximately 1% of the recommended limit. As such, oil mist is not considered a compound of concern. The POI concentrations listed in Table 1 Emission Summary Table were compared against their standards listed in Schedule 3 of O.Reg. 419/05 and also listed in the publication Summary of Standards and Guidelines to support Ontario Regulation 419: Air Pollution Local Air Quality dated April Both contaminants listed in Table 1 Emission Summary Table have limits in Schedule 3 of O. Reg. 419/05. All the predicted POI concentrations are below the corresponding limits. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

26 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." 7.3 Conclusions This Emission Summary and Dispersion Modelling (ESDM) Report was prepared in accordance with Section 26 of O. Reg. 419/05. In addition guidance in the ministry Publication Procedure for Preparing an Emission Summary and Dispersion Modelling Report dated March 2009 (ESDM Procedure Document) PIBS 3614e03 was followed as appropriate. The Facility is currently subject to Section 20 of O. Reg. 419/05 and the modelled impact of the Facility was assessed against Schedule 3 limits for 24-hr and 1-hr averaging times using the US EPA AERMOD dispersion model. The emission rate estimates for each source of modelled contaminants are documented in Table 5-1 Source Summary Table (Appendix A1). All the emission rates listed in Table 5-1 are documented as having a Data Quality of Marginal or better, and correspond to the operating scenario where all significant sources are operating simultaneously at their individual maximum rates of production. Therefore these emission rate estimates listed in Table 5-1 Source Summary Table are conservative and are not likely to be an underestimate of the actual emission rates. A POI concentration for each compound of concern emitted from the Facility was determined based on the calculated emission rates and the output from the US EPA AERMOD model. The results are presented in Table 1 Emission Summary Table. The modelled POI concentrations were compared against criteria listed in the publication Summary of Standards and Guidelines to Support Ontario Regulation 419: Air Pollution Local Air Quality dated April 2012 (List of Ministry POI Limits) and recommended limits from a third party toxicologist. Both contaminants listed in Table 1 Emission Summary Table have limits in Schedule 3 of O. Reg. 419/05. All the predicted POI concentrations are below the corresponding limits. This ESDM Report demonstrates that the MOECC POI limits are met at this Facility. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

27 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." Review and Revision History *Note: The revision history has traditionally tracked revisions, not reviews. Revisions occur throughout the year and the ESDM text is modified when changes are required. Effective 2015 this revision history we will also include a review date by March 31 of the following year for the end of the reporting year if no changes have occurred. 31-Jan-13: Added the ECA Number and date to the Executive Summary and section 1.1. In section 1.2, removed the camshafts and connecting rods, and also removed the hot test. Revised figure 1.2 to reflect that there are no longer emissions to the atmosphere due to the hot test. Added this revision history section as per the new ECA, section Jul-13: Removed Engine Test Stands and added a Torque Converter Washer to the Sediment Lab on table 2-1, Sources and Contaminants Identification Table. 13-May-14: The closest distance from the Facility to residential zoning changed from 600 meters to 300 meters due to zoning by-law amendment ( ). Land Use Zoning Designation Plans (Appendix A3) updated. 15-July-14: Updated the Table 1 Emission Summary Table to reflect the slight change in NOx and reduction in PM. 19-August-15: Detailed review of the ESDM report with FES Air staff. Minor revisions as required. 22-Sep-15: Updated Figure 1-3 to remove dust collector (replaced with a new one which vents inside) and Figure 1-4 to include one final washer that vents outside. 15-Nov-15: updated ESDM for name change from GMCL to GM of Canada Company. 19-Feb-2016: reviewed ESDM report for 2015 to ensure reflective of 2015 operations. Minor revisions as required. June 2016: reviewed prior to MOECC visit. No major changes required however figures can be updated to reflect company name change. 20-Oct-16: Updated executive summary EST to RWDI modelling results from March Nov-16: Updated report to include LFG generators and 6 new NG boilers; added in emergency generators to modelling as they can no longer be written off as negligible without considering NOx. Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 21,

28 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." APPENDIX A1: Tables 1, 2-1, 5-1, 6-1 Table 1 Emission Summary Table Table 2-1 Sources and Contaminants Identification Table Table 5-1 Source Summary Table Table 6-1 Dispersion Modelling Input Summary Table Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 6, 2016

29 Table 1: Emission Summary Table RWDI Project Notes: Receptor Contaminant CAS Total Air Maximum Averaging MOECC Limiting Regulation Percentage Property Line Number Facility Dispersion POI Period POI Effect Schedule of MOECC Emission Model Concentration Limit [1] # POI Limit Rate Used (g/s) (µg/m³) (hours) (µg/m³) (%) Nitrogen Oxides E+01 AERMOD 3.21E Health 3 80% E E Health 3 83% Property Line Particulate Matter PM 7.08E-01 AERMOD 7.07E Visibility 3 59% Property Line Carbon Monoxide E+00 AERMOD 5.33E ,000 Health 3 9% Property Line Sulphur Dioxide E-01 AERMOD 1.06E Health and Vegetation 3 15% E E Health and Vegetation 3 16% Property Line Hydrogen Sulfide [2] E-03 AERMOD 3.11E Odour 3 4% E E Odour 3 7% Property Line 1,1,2-Trichloroethane [2] E-05 AERMOD 3.54E N/A JSL 1% [1] The term MOECC POI Limit refers to the following information (there may be more than one relevant MOECC POI Limit for each contaminant): - Air quality standards in Schedule 3 of O. Reg. 419/05; - The Upper Risk Thresholds (URTs) in Schedule 6 of O. Reg. 419/05; - The guidelines for contaminants set out in the MOECC publication, Summary of Standards and Guidelines to Support Ontario Regulation 419: Air Pollution Local Air Quality"; - The Daily Assessment Values (DAV) from the MOECC technical bulletin, Methodology for Using "Assessment Values" for Contaminants with Annual Air Standards"; - The Annual Assessment Values (AAV) from the MOECC technical bulletin, Methodology for Using "Assessment Values" for Contaminants with Annual Air Standards"; or - JSL values set out in the MOECC publication, "Jurisdictional Screening Level (JSL) List A Screening Tool for Ontario Regulation 419: Air Pollution Local Air Quality"; or, - An acceptable concentration for contaminants with no standards or guidelines. [2] These contaminants are only emitted from the landfill gas generators and boiler; for modelling purposes, a unit emission rate was run and scaled to reflect specific contaminant emissions. 24-hr Unit emission rate result: 48 µg/m³ 1-hr Unit emission rate result: 88 µg/m³ [3] As per the MOECC Procedure for Preparing an Emission Summary and Dispersion Modelling Report, draft version 4.0, to avoid complex post-processing steps, annual concentrations from a single 5-year model run can by multiplied by 140% in order to be compared against annual standards.

30 Table 2-1 Sources and Contaminant Identification Table Source ID CM LFG HV Source Description of Title Combustion of Landfill Gas HYDROMATION VENTS CoGen Building Main Building - basement DC DUST COLLECTORS Main Building DL PB NATURAL GAS COMBUSTION DYNOMOMETER LAB (Engine testing) PRODUCTION & BUILDING EXHAUSTS Main Building Source Information General Description Location There are two powerhouse natural gas steam boilers and various other smaller natural gas combustion equipment such as shower room natural gas Powerhouse, 4 boilers by V8 W Assembly, 2 boilers, boilers dedicated to the new transmission transfer gear line, and an X22 Project boilers, 2 Bryan boilers by assortment of natural gas fired heaters including door heaters, radiant dancefloor, 2 proposed Steam Boilers in heaters and water heaters. The 6 proposed boilers will be used as process Mechanical Room, 4 proposed boilers in the boilers. CoGen Building. Dynomometer Lab There are 4 proposed generators that will use landfill gas transported from Walker Landfill as fuel. Products of combustion, VOC Yes Not Applicable There is a hydromation coolant system located in the basement below the production area. The purpose of this hydromation system is to filter out metal chips from the coolant used in the machining process. Filtered dust collectors remove particulate matter generated from dry machining processes. PM Yes The Glendale Avenue plant has a dynamometer facility with five cells that can be used for load testing of engines. The engines are fueled with gasoline. The cells are run on an as needed basis only, and generally never operate at the same time, but it is possible two could run simultaneously. Building exhausts balance the positive pressure within in plant, preventing drafts and larger problems. The building air in process areas contains a low concentration of oil mist, which is accounted for in the emissions below. The large exhaust fans (W23-38), with the exception of W28-30, are no longer in service. They were installed around 1998 but were used in conjunction with the gas-fired units which no longer exist. W28-30, and FR1-4 can be turned on manually and run as needed, but are rarely used. Expected Contaminants NOx Products of combustion OM NOx PM SOx CO VOC OM Significant (Yes or No?) Yes No No Yes No No No Considered a significant, however modelled results indicated OM is not a contaminant of concern, as it 1% of the limit proposed by a third party toxicologist (AMEC). Not Applicable Rationale for Negligible Not Applicable Only NOx emissions are significant as per Section of the Procedure for Preparing an ESDM Report Document. Not Applicable As per section of the Procedure for Preparing an ESDM Report, the emissions do not exceed the calculated threshold. Cell #4 can be operated with either gasoline or ethanol. However, because the ethanol option has not been used in the past 2 years and assuming that gasoline is the worst case scenario in relation to ethanol the calculations will be done for gasoline use using the AP-42 emission factors for gasoline fuel. Considered a significant, however modelled results indicated OM is not a contaminant of concern, as it 1% of the limit proposed by a third party toxicologist (AMEC). CT COOLING TOWERS Main Building - outside AW SL ML PCT TAO MP AQUEOUS WASHERS SEDIMENT LAB (fumehood, drying oven) METALLURGY LAB (fumehood, storage cabinet, dust collector, test apparatus) PARTS CLEANING TANKS TANKS AND OFFLOADING MAINTENANCE PAINT Main Building Sediment Lab Metallurgy Lab Main Building (Tool Grind Area) South Tankfarm, West Tankfarm, Powerhouse Construction Shop WLD WELDING BOOTH Tinsmith and Maintenance shops RD ROAD DUST Main Plant - Outside BV BUILDING VENTILATION Main Building The St. Catharines facility has four cooling towers, one of which is five-celled and can operate with chillers 15, 16, 17 and 21. The others are small and support production or are used for comfort cooling. These existing cooling towers will be used as a back-up to cool canal water from the chilled water loop Aqueous process washers if necessary are used and to clean no new production cooling towers parts. will be installed. The sediment lab is in operation for quality assurance/control purposes only. The metallurgy lab is in operation for quality assurance/control purposes only. Parts Cleaning Tanks are used to rinse and derust parts prior to repairs. Both tanks are heated and covered. There are nine tanks that contain fuel, one tank that contains sulphuric acid and one tank that contains automatic transmission fluid. All tanks have secondary containment. There are an additional 19 tanks of varying sizes which contain various oils (Engine, waste, soluble, synthetic etc.) and process waste. Some of the tanks are idled and not in use. The filtered paint booth is used for maintenance painting purposes only such as painting a lugger bin. There is no production welding at the St. Catharines CET. Welding takes place for maintenance or machine repair purposes only. The majority of the welding occurs in five locations, one of which is solely used for the annual welding test of the welders. The Facility has a paved roadway around the perimeter of the plant. The general ventilation unit allows circulation of air within the plant and allows for the intake of fresh air from the atmosphere. PM OM OM OM VOCs VOCs VOCs PM PM OM No No No No No No No No No No As per Section of the Procedure for Preparing an ESDM Report document, General Ventilation is a negligible source because it represents less than 5% of total PM emissions. All parts washers use aqueous/liquid detergents. Therefore, as per O. Reg. 524/98, s.1(1)10, emissions from these parts washers are exempt sources. As per Table B-3 in the "Procedure for Preparing an Emission Summary and Dispersion Modelling Report" (July 2005), fume hood emissions for laboratories that are used for quality control and quality assurance purposes at industrial facilities are considered negligible. Emissions from the Sediment Lab fume hood are therefore considered minor sources. As per Table B-3 in the "Procedure for Preparing an Emission Summary and Dispersion Modelling Report" (July 2005), fume hood emissions for laboratories that are used for quality control and quality assurance purposes at industrial facilities are considered negligible. Emissions from the Metallurgy Lab fume hood are therefore considered minor sources. As per Table B-3 in the "Procedure for Preparing an Emission Summary and Dispersion Modelling Report" (March 2009), parts washers for maintenance shops can be considered to be negligible. Therefore the parts cleaning tanks are negligible sources. Since the tanks are self-contained, it is assumed that no fugitive emissions come from the tanks. Therefore the only instances where they could generate emissions is during the delivery of material to the tank. Due to the low frequency of offloading, it is assumed that the emissions from offloading activities to the tanks are negligible. Tank offloading is therefore considered As per Section to be 9(3)(a) a minor of the source. EPA, routine maintenance carried out on any plant, structure, equipment, apparatus, mechanism or thing can be considered to be negligible. Therefore a maintenance paint booth is a negligible source. As per Table B-3 in the "Procedure for Preparing an Emission Summary and Dispersion Modelling Report" (July 2005), emissions from maintenance welding stations are considered negligible. Emissions from the Welding Booth are therefore considered minor sources. As per section 7.4 of the Procedure for Preparing an ESDM Report, since the St. Catharines CET NAICS Code ( Transportation Equipment Manufacturing) is not listed in Table 7-2 or 7-3, the facility may consider fugitive emissions for road dust as negligible. In addition, the roads on the GM property are paved; that there is limited traffic on these roads; that the speed limit is low and controlled; and that the roads are swept on a regular basis, it is assumed that road dust emissions are minor. Sources that are Insignificant Relative to Total Emissions Office / washroom / locker / cafeteria areas are exempt under O. Reg. 524/98, s.1(1)7i. EG NCM NDC TOC EMERGENCY GENERATORS NATURAL GAS COMBUSTION NEGLIGIBLE DUST COLLECTORS NEGLIGIBLE TOCCO INDUCTION PROCESSES Pumphouse, Small building near Gate, Blue building on south side of plant Main Building, Butler Building, Powerhouse Met Lab, Construction Shop Main Building: V8 West ME MOBILE EQUIPMENT Main Building BAT BATTERY CHARGE EQUIPMENT Main Plant Emergency generators and pumps are only for use when the site has no power or in the event of a fire. Natural gas combustion equipment that are back up units or that have <0.3 MM Two small dust collectors used to filter particulate matter from maintenance an Products of combustion NOx and Products of Combustion Two Inductoheat machines use a mix of water with 4.5-6% Aquaquench 3600 to quench the parts after being heated. OM No There are seven gasoline powered towmotors and six gas cranes. Battery chargers are used to charge mobile equipment for use in transportation around the facility. PM VOC No No No No No As per Appendix B, Table B-3 in the Procedure for Preparing an ESDM Report (March, 2009),emergency generators firing liquid fuel or gaseous fuel that are used for emergency only with periodic testing are considered to emit negligible amounts of contaminants. As per Table B-3 in the "Procedure for Preparing an Emission Summary and Dispersion Modelling Report" (March 2009), equipment such as natural gas fired boilers, water heaters, space- heaters, and make-up air units when the total facility wide heat input usage for this equipment is less than 20 million kilojoules per hour may considered negligible. In addition, sources that, in combination, represent less than 5% of total property-wide emissions of a contaminant can, in many cases, be considered negligible sources. (Section 7.2.2). The Carpenter Shop dust collector is considered negligible because it is used for routine maintenance and has very low usage. The Met Lab dust collector is considered negligible because it is used for quality purposes and has very low usage. As per Table B-3 of the Procedure for Preparing an ESDM report "small maintenance and janitorial activities" and laboratories for QA/QC at industrial facilities emit contaminants in negligible No outside amounts. emissions. Exempt as per O.Reg. 524/98, s.1(1)8.1 As per Appendix B, Table B-3 from the Procedure for Preparing an ESDM Report document, battery chargers are considered negligible sources. CAF CAFETERIA Cafeteria Cafeteria exhausts No Exempt as per O. Reg. 524/98, s.1(1) 9 PV PLUMBING VENTS Main Building Plumbing vents No Exempt as per O. Reg. 524/98, s.1(1) 8

31 Table 5-1: Source Summary Table - Sorted by Contaminant RWDI Project Contaminant CAS Source Source Modelling Modelling Roof Zone Source Data Emission Data Number ID [1] Description ID Description Stack Stack Stack Stack Stack Stack Source Maximum Averaging Emission Emissions % of Volumetric Exit Inner Exit Height Height Coordinates Emission Period Estimating Data Overall Flow Gas Diameter Velocity Above Above X Y Rate Technique [2] Quality [3] Emissions Rate Temp. Grade Roof (Am³/s) (ºC) (m) (m/s) (m) (m) (m) (m) (g/s) (hours) (%) Nitrogen Oxides GAP001 Stack for Boiler #3 and #4 GAP001 Point Powerhouse E+00 1, 24 EF Above-Average 23% W9 Shower Boiler Room #4 W9 Point RZ4W E-02 1, 24 EF Above-Average <1% W10 Shower Room Boiler #3 W10 Point RZ4W E-02 1, 24 EF Above-Average <1% W11 Shower Room Natural Gas #2 W11 Point RZ4W E-02 1, 24 EF Above-Average <1% W12 Shower Room Natural Gas #1 W12 Point RZ4W E-02 1, 24 EF Above-Average <1% Boiler Exhaust S196 Point RZ5E E-02 1, 24 EF Above-Average <1% Boiler Exhaust S197 Point RZ5E E-02 1, 24 EF Above-Average <1% Boiler S204 Point RZ12W N/A E-02 1, 24 EF Above-Average <1% Boiler S207 Point RZ12W N/A E-02 1, 24 EF Above-Average <1% A Dyno Room Cell #1 Engine Exhaust S102A Point RZ1E E-01 1, 24 EF Above-Average 2% B Dyno Room Cell #4 Engine Exhaust S102B Point RZ1E E-01 1, 24 EF Above-Average 2% C Dyno Room Cell #2 Engine Exhaust S102C Point RZ1E E-01 1, 24 EF Above-Average 2% LFGGEN1 Landfill Gas-Fired Generator Set LFGGEN1 Point CoGen E-01 1, 24 EF Above-Average 4% LFGGEN2 Landfill Gas-Fired Generator Set LFGGEN2 Point CoGen E-01 1, 24 EF Above-Average 4% LFGGEN3 Landfill Gas-Fired Generator Set LFGGEN3 Point CoGen E-01 1, 24 EF Above-Average 4% LFGGEN4 Landfill Gas-Fired Generator Set LFGGEN4 Point CoGen E-01 1, 24 EF Above-Average 4% BOIL1 CoGen Boiler (12 MMBTU) BOIL1 Point CoGen E-02 1, 24 EF Above-Average <1% BOIL2 CoGen Boiler (12 MMBTU) BOIL2 Point CoGen E-02 1, 24 EF Above-Average <1% BOIL3 CoGen Boiler (12 MMBTU) BOIL3 Point CoGen E-02 1, 24 EF Above-Average <1% BOIL4 CoGen Boiler (12 MMBTU) BOIL4 Point CoGen E-02 1, 24 EF Above-Average <1% BOIL5&6 NG Boilers ( MMBTU) BOIL5&6 Point CoGen E-01 1, 24 EF Above-Average <1% Particulate Matter PM 102A Dyno Room Cell #1 Engine Exhaust S102A Point RZ1E E EF Marginal 3% PM 102B Dyno Room Cell #4 Engine Exhaust S102B Point RZ1E E EF Marginal 4% PM 102C Dyno Room Cell #2 Engine Exhaust S102C Point RZ1E E EF Marginal 4% PM W4 Tool Grind Dust Collector W4 Volume RZ3W N/A N/A N/A N/A E EC Average 27% PM LFGGEN1 Landfill Gas-Fired Generator Set LFGGEN1 Point CoGen E EF Above-Average 16% PM LFGGEN2 Landfill Gas-Fired Generator Set LFGGEN2 Point CoGen E EF Above-Average 16% PM LFGGEN3 Landfill Gas-Fired Generator Set LFGGEN3 Point CoGen E EF Above-Average 16% PM LFGGEN4 Landfill Gas-Fired Generator Set LFGGEN4 Point CoGen E EF Above-Average 16% Carbon Monoxide LFGGEN1 Landfill Gas-Fired Generator Set LFGGEN1 Point CoGen E EF Above-Average 25% LFGGEN2 Landfill Gas-Fired Generator Set LFGGEN2 Point CoGen E EF Above-Average 25% LFGGEN3 Landfill Gas-Fired Generator Set LFGGEN3 Point CoGen E EF Above-Average 25% LFGGEN4 Landfill Gas-Fired Generator Set LFGGEN4 Point CoGen E EF Above-Average 25% Sulphur Dioxide LFGGEN1 Landfill Gas-Fired Generator Set LFGGEN1 Point CoGen E-01 1, 24 EF Above-Average 25% LFGGEN2 Landfill Gas-Fired Generator Set LFGGEN2 Point CoGen E-01 1, 24 EF Above-Average 25% LFGGEN3 Landfill Gas-Fired Generator Set LFGGEN3 Point CoGen E-01 1, 24 EF Above-Average 25% LFGGEN4 Landfill Gas-Fired Generator Set LFGGEN4 Point CoGen E-01 1, 24 EF Above-Average 25% Hydrogen Sulfide LFGGEN1 Landfill Gas-Fired Generator Set LFGGEN1 Point CoGen E , 24 ST Highest 25% LFGGEN2 Landfill Gas-Fired Generator Set LFGGEN2 Point CoGen E , 24 ST Highest 25% LFGGEN3 Landfill Gas-Fired Generator Set LFGGEN3 Point CoGen E , 24 ST Highest 25% LFGGEN4 Landfill Gas-Fired Generator Set LFGGEN4 Point CoGen E , 24 ST Highest 25% 1,1,2-Trichloroethane LFGGEN1 Landfill Gas-Fired Generator Set LFGGEN1 Point CoGen E ST Highest 25% LFGGEN2 Landfill Gas-Fired Generator Set LFGGEN2 Point CoGen E ST Highest 25% LFGGEN3 Landfill Gas-Fired Generator Set LFGGEN3 Point CoGen E ST Highest 25% LFGGEN4 Landfill Gas-Fired Generator Set LFGGEN4 Point CoGen E ST Highest 25% Nitrogen Oxides Total Total of all listed sources 1.78E % Particulate Matter PM Total Total of all listed sources 7.08E % Carbon Monoxide Total Total of all listed sources 4.37E % Sulphur Dioxide Total Total of all listed sources 4.25E % Hydrogen Sulfide Total Total of all listed sources 6.52E % 1,1,2-Trichloroethane Total Total of all listed sources 7.43E % Notes: [1] Source ID, Source Type: should provide information on the modelling source type (e.g., Point, Area or Volume Source); the process source or sources within the modelling source (e.g., Process Line #1); and the stack or stacks within each process source. [2] Emission Estimating Technique Short-Forms are V-ST (Validated Source Test), ST (Source Test), EF (Emission Factor), MB (Mass Balance), and EC (Engineering Calculation). [3] Data Quality Categories: Highest; Above-Average; Average; and Marginal.

32 6-1 Dispersion Modelling Input Summary Table RWDI Project Relevant Section Title Description of How the Approved Dispersion Model was Used Section of the Regulation Section 8 Negligible Sources Please refer to Section 3.1 of the ESDM report, "Identification of Negligible Sources". Section 9 Same Structure Contamination Same structure contamination is not applicable for this facility. Section 10 Operating Conditions Please refer to Section 4.1 of the ESDM Report, "Description of Operating Conditions". For this assessment, it was assumed that all equipment was operating at maximum capacity simultaneously and continuously. Section 11 Source of Contaminant Please refer to Section 4.0 Operating Conditions of the ESDM Report, "Emission Estimating Emission Rates and Data Quality", for an explanation of the methods used to estimate contaminant emissions. The source summary table (Table 5-1) includes an assessment of how accurately the methods estimate the emission rate. Section 12 Combined Effect of Assumptions for Operating Conditions and Emission Rates The operating conditions and emission rates (as described in the preceeding sections) were used in MOE approved dispersion models. The model predicted results that were less than the applicable POI Limits; therefore, no further refinemens were made to either the operating conditions or emission rates. Section 13 Meteorological Conditions Please refer to Section in the report. A meteorological data set consisting of five years ( ) of hourly readings for surface and upper air conditions was used in the AERMOD model. The MOE meteorological data recommended for this site is for the West Central Region. This includes surface data from London, Ontario and upper air data from White Lake, Michigan. The data for these sites were obtained from the MOE Ontario Regional Meteorological Data website. Section 14 Area of Modelling Coverage Please refer to Section in the report. The area of modelling coverage was designed to meet the requirements outlined in O. Reg. 419/05, s 14. A multi-tiered receptor grid was developed with reference to Section 7.2 of the ADMGO; therefore interval spacing was dependent on the receptor distance from on-site sources. Section 15 Stack Height for Certain New Please refer to Section in the report. Sources of Contaminant This is an existing facility, and therefore Section 15 of O. Reg. 419/05 does not apply. Section 16 Terrain Data Please refer to Section in the report. Terrain information for the area surrounding the facility was obtained from the MOE Ontario Digital Elevation Model Data web site. The terrain data is based on the North American Datum 1983 (NAD83) horizontal reference datum. These data were run through the AERMAP terrain pre-processor to estimate base elevations for receptors and to help the model account for changes in elevation of the surrounding terrain. Section 17 Averaging Periods Please refer to Section in the report. 1-hour and 24-hour averaging times were used with the AERMOD model to compare to Schedule 3 Standards under O. Reg.419/05, and other ministry POI Guidelines listed in the MOE publication 6570e: Ontario s Ambient Air Quality Criteria, dated February 2008.

33 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." APPENDIX A2: Site Plan Figure 1-2 St. Catharines CET Modelled Fenceline Figure 6-1 Source Identification and Roof Layout Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 6, 2016

34 ! ! ! BOIL5&6!( LFGGEN1 LFGGEN2 LFGGEN3 LFGGEN4! BOIL1 BOIL2 BOIL3 BOIL4!(!(!(!(!(!(!(!(! !!!!!! Legend!( Sources Building Property Boundary Service Layer Credits: First Base Solutions Web Mapping Service - Niagara Region, m Site Plan Showing Significant Sources, Volume Source, Buildings, and Property Line Map Projection: NAD 1983 UTM Zone 17N True North General Motors St. Catharines CET - St. Catharines, Ontario Project # [ Drawn by: DJH Fig: 6-1a Approx. Scale: 1:4,000 Date Revised: Dec. 21, 2016

35 HT=4m HT=16.46m HT=17.45m HT=11.43m HT=17.45m HT=20.07m HT=14.97m HT=12.67m HT=4.72m HT=4.72m HT=4.72m HT=16.28m HT=10.19m HT=13.11m HT=11.91m HT=12.34m HT=5.49m HT=11.30m HT=14.33m HT=12.50m HT=16.46m HT=17.45m HT=15.11m HT=16.64m HT=12.67m HT=13.71m HT=12.67m HT=14.33m HT=12.67m HT=12.67m HT=15.11m HT=15.11m HT=11.91m HT=13.41m HT=17.42m HT=24.38m HT=18.29m HT=14.12m HT=15.54m HT=18.29m HT=12.67m HT=11.89m HT=8.38m HT=11.30m HT=17.45m HT=11.30m HT=11.30m HT=11.30m HT=23.62m HT=13.37m HT=10.21m HT=12.67m HT=10.21m HT=26.26m HT=26.06m HT=16.05m HT=13.37m HT=25.20m HT=25.35m HT=12.67m HT=10.21m HT=17.42m HT=14.12m HT=15.67m HT=14.12m HT=15.98m HT=17.42m HT=14.12m HT=14.12m HT=12.60m HT=18.29m HT=9.53m HT=14.63m HT=14.63m HT=10.21m HT=15.80m HT=10.06m HT=6.96m HT=12.50m HT=12.80m!( HT=16.08m HT=17.31m HT=19.08m HT=12.19m HT=11.28m HT=8.99m HT=4.72m HT=12.47m!(!(!( HT=6.40m HT=12.47m HT=12.22m Legend!(!(!(!( HT=12.47m HT=10.01m HT=12.22m HT=4m !( Sources Building Property Boundary Service Layer Credits: First Base Solutions Web Mapping Service - Niagara Region, 2010 HT=4m m Site Plan Showing Significant Sources, Volume Source, Building Heights, and Property Line Map Projection: NAD 1983 UTM Zone 17N General Motors St. Catharines CET - St. Catharines, Ontario Project # True North Drawn by: [ Approx. Scale: DJH Fig: 1:2, b Date Revised: Dec. 21, 2016

36 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." APPENDIX A3: Land Use Zoning Designation Plans Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 6, 2016

37 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." St. Catharines Land Use Zoning Designation Plan Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 6, 2016

38 Section 15.1 Schedule A - Principal Zoning Maps Index City of St. Catharines Zoning By-Law NOT TO SCALE

39 Location of GM Facility Zones Low Density Residential - Suburban Neighbourhood Low Density Residential - Traditional Neighbourhood Medium Density Residential High Density Residential Local Convenience Commercial Community Commercial Arterial Commercial Major Commercial Downtown Commercial Core Downtown Traditional Main Street Business Commercial Employment General Employment Medium Density Mixed Use Medium / High Density Mixed Use High Density Mixed Use Conservation / Natural Area Minor Green Space Major Green Space Local Neighbourhood Institutional Community Institutional Major Institutional Agriculture Agriculture Only Agriculture Commercial / Industrial Municipal Boundary City of St.Catharines Zoning By-Law December 16, 2013 In addition to the zoning shown on this schedule, the use of land may be subject to additional regulations or restrictions by upper tier governments or agencies (refer to Sections and 2.19, Schedule D, and Appendices to ). ** **

40 Zones Low Density Residential - Suburban Neighbourhood Low Density Residential - Traditional Neighbourhood Medium Density Residential High Density Residential Local Convenience Commercial Community Commercial Arterial Commercial Major Commercial Downtown Commercial Core Downtown Traditional Main Street Business Commercial Employment General Employment Medium Density Mixed Use Medium / High Density Mixed Use High Density Mixed Use Conservation / Natural Area Minor Green Space Major Green Space Local Neighbourhood Institutional Community Institutional Major Institutional Agriculture Agriculture Only Agriculture Commercial / Industrial Municipal Boundary ** City of St.Catharines Zoning By-Law December 16, 2013 In addition to the zoning shown on this schedule, the use of land may be subject to additional regulations or restrictions by upper tier governments or agencies (refer to Sections and 2.19, Schedule D, and Appendices to ). **

41 Zone Your ST. CATHARINES City of St. Catharines Zoning By Law December 16, 2013

42 City of St. Catharines Zoning By-law December 16, 2013 SECTION 4 ESTABLISHMENT OF ZONES 4.1 List of Zone Names and Symbols The following zones are established and are referred to by name or by the symbol opposite the name as set out below: Zone Symbol R1 R2 R3 R4 C1 C2 C3 C4 C5 C6 E1 E2 M1 M2 M3 G1 G2 G3 I1 I2 I3 A1 A2 A3 Zone Name Low Density Residential - Suburban Neighbourhood Low Density Residential - Traditional Neighbourhood Medium Density Residential High Density Residential Local Convenience Commercial Community Commercial Arterial Commercial Major Commercial Downtown Commercial Core Downtown Traditional Main Street Business Commercial Employment General Employment Medium Density Mixed Use Medium/High Density Mixed Use High Density Mixed Use Conservation / Natural Area Minor Green Space Major Green Space Local Neighbourhood Institutional Community Institutional Major Institutional Agriculture Agriculture Only Agriculture Commercial / Industrial Uses and regulations specific to each zone are set out in Sections 5 to

43 City of St. Catharines Zoning By-law December 16, Uses and Zones The following sets out the uses permitted within the zones contained in this By-law. The placement of the zone symbol opposite the permitted use indicates the zone(s) in which the use is permitted. The table must be read in conjunction with the regulations for each zone as established in Sections 5 to 11. Other uses may be permitted by special provisions as set out in Section 13 of this By-law. PERMITTED USES Adult Oriented Entertainment Establishment Agricultural Farm Related Commercial or Industrial E1 ZONES E2 A3 Agriculture Farm A1 A2 A3 Agri-tourism / Value Added A1 (a) Ancillary Retail Sales / Display of Products E1 E2 Animal Care Establishment C1 C2 C3 C4 C5 C6 E1 (a) E2 (a) M1 M2 M3 Apartment Building R3 R4 C2 C4 C5 C6 M1 M2 M3 I2 Boat Ramp G1 G2 G3 Bulk Fuel Depot E2 Car Wash C2 C3 C4 E1 E2 M1 Cemetery G2 G3 Commercial Parking Structure C2 C3 C4 C5 C6 Community Garden R1 R2 R3 R4 C1 C2 C3 C4 C5 C6 E1 E2 M1 M2 M3 G2 G3 I1 I2 I3 A1 A2 A3-23 -

44 City of St. Catharines Zoning By-law December 16, 2013 PERMITTED USES ZONES Concession Stand G2 (a) G3 (a) Contractor's Yard E2 Cultural Facility C1 C2 C3 C4 C5 C6 M1 M2 M3 G3 I1 I2 Day Care C1 C2 C3 C4 C5 C6 M1 M2 M3 I1 I2 I3 Accessory Dwelling Unit Interior R1 (a) R2 (a) R3 (a) R4 (a) M1 (a) M2 (a) M3 (a) A1 (a) Dwelling Unit(s), Apartment C1 C2 C4 C5 C6 M1 M2 M3 Dwelling, Detached R1 R2 R3 M2 I1 I2 A1 Dwelling, Duplex R2 R3 M2 I2 Dwelling, Fourplex R2 R3 R4 M1 M2 M3 I2 Dwelling, Semi-Detached R1 R2 R3 M2 I1 I2 Dwelling, Quadruplex R1 R2 R3 R4 M2 I1 I2 Dwelling, Triplex R2 R3 R4 M1 M2 M3 I2 Emergency Service Facility C2 C3 C4 C5 C6 M1 M2 M3 I1 I2 I3 Employee Convenience Facilities Essential Operations for Service Infrastructure and Utilities Golf Course and Driving Range E1 E2 G1 G2 G3 G3-24 -

45 City of St. Catharines Zoning By-law December 16, 2013 PERMITTED USES Heavy Equipment Sales and Service ZONES E2 Help house A1 (a) Home Based Business R1 (a) R2 (a) R3 (a) R4 (a) C1 (a) C2 (a) C4 (a) C5 (a) C6 (a) M1 (a) M2 (a) M3 (a) A1 (a) Home Based Business - Kennel Home Industry A1 (a) A1 (a) Hospital C5 M1 M2 M3 I3 Hotel / Motel C3 C4 C5 C6 E1 M1 M2 M3 Industry, Heavy E2 Industry, Light E1 E2 Long-Term Care Facility R3 R4 C5 M1 M2 M3 I1 I2 I3 Maintenance / Utility Building / Administration Office / Greenhouse Associated with Park Operation G2 (a) G3 (a) Major Transit Station C5 Marina G3 Motor Vehicle Gas Station C1 C2 C3 C4 E1 E2 M1 Motor Vehicle Repair Garage C2 C3 C4 E1 E2 M1-25 -

46 City of St. Catharines Zoning By-law December 16, 2013 PERMITTED USES ZONES Motor Vehicle Sales / Rental Service Centre C3 Nightclub C3 C4 C5 C6 Off Leash Dog Park G2 G3 Office C1 C2 C3 C4 C5 C6 E1 E2 (a) M1 M2 M3 Petting Zoo G3 Picnic Area and Shelter G1 G2 G3 Place of Assembly / Banquet Hall C2 C3 C4 C5 C6 E1 M1 M2 M3 I2 Place of Worship C1 C2 C3 C4 C5 C6 M1 M2 M3 I1 I2 Playground R1 (a) R2 (a) R3 (a) R4 (a) C1 (a) C2 (a) C3 (a) C4 (a) C5 (a) C6 (a) E1 (a) E2 (a) M1 (a) M2 (a) M3 (a) G2 (a) G3 (a) I1 (a) I2 (a) I3 (a) A1 (a) A2 (a) A3 (a) Private Road Development R1 R2 R3 R4 M1 M2 M3 I1 I2 Recreation Facility, Indoor C1 C2 C3 C4 C5 C6 E1 (a) E2 (a) M1 M2 M3 G3 I1 I2 I3 Recreation Facility, Outdoor G2 G3 I1 I2 I3 Research Facility E1 E2 Residential Convenience Uses R3 (a) R4 (a) Restaurant C1 C2 C3 C4 C5 C6 E1 (a) E2 (a) M1 M2 M3 Retail Store C1 C2 C3 C4 C5 C6 E1 (a) E2 (a) M1 M2 M3-26 -

47 City of St. Catharines Zoning By-law December 16, 2013 PERMITTED USES ZONES School, Elementary M1 M2 M3 I1 I2 School, Secondary M1 M2 M3 I1 I2 I3 Service Commercial C1 C2 C3 C4 C5 C6 E1 (a) E2 (a) M1 M2 M3 Social Service Facility C1 C2 C3 C4 C5 C6 E1 M1 M2 M3 I1 I2 I3 Spectator Seating G2 (a) G3 (a) Theatre C2 C3 C4 C5 C6 M1 M2 M3 Townhouse R1 R2 R3 R4 M1 M2 M3 I1 I2 Trail R1 R2 R3 R4 C1 C2 C3 C4 C5 C6 E1 E2 M1 M2 M3 G1 G2 G3 I1 I2 I3 A1 A2 A3 Transportation Depot E2 University / College C2 C3 C4 C5 C6 M1 M2 M3 I3 Washroom Facility / Change Room G2 (a) G3 (a) Winery A1 (a) A2 (a) Footnote to Section 4.2 Uses and Zones a) Only permitted as an accessory use

48 City of St. Catharines Zoning By-law December 16, Special Provisions Where special provisions are established for certain lots, the applicable regulations of the special provisions apply in addition to, or as an exception to, the normal zone provisions that apply to the subject lot(s). Where on Schedule A to this By-law, a zone symbol (such as R1) applying to a lot contains a suffix at the end of the zone symbol consisting of a dash and number (e.g. R1-1), this indicates that a special provision applies to the subject lot. The number after the dash corresponds with the special provision number as set out in Section 13. There may be more than one number and, hence, special provision, that applies to certain lots (such as R and thus Special Provision 1 and 14 would apply). 4.4 Holding (H) Provisions Where a zone symbol contains the suffix H with or without a special provision (for example R4-H1 or R4-1-H1) the zoning shall not take effect until the prescribed conditions are met and the (H) is removed from the subject lot. When the amending by-law removing the H Holding symbol from a zone is enacted, the permitted uses and regulations for that lot shall apply. Until such time as the prescribed conditions are met the identified lot shall only be used for the existing permitted use as of the date of this By-law including the expansion of the existing permitted use, or other uses as set out in the Holding provision(s). Lots with Holding provisions, including the conditions required to be satisfied prior to the removal of Holding (H) Zone symbol, are identified in Section

49 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." Thorold Land Use Zoning Designation Plan Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 6, 2016

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51 sectton 5 ZONES

52 City of Thorold Gomprehensive Zoninq Bv-law 2140ß71 SEGTION 5: ZONES 5.1 Establishment of Zones For purposes of this By-law, the following zones are established ZONE CLASS ZONE SYMBOL SECTION RESIDENTIAL ZONES Residential First Density A Zone Residential First Density B Zone Residential First Density C Zone Residential First Density D Zone Residential Second Density Zone Residential Second Density Special Zone Residential Third Density Zone Residential Fourth Density A Zone Residential Fourth Density B Zone Office Residential OR Zone R1A R1B R1C R1D R2 R2S R3 R4A R4B OR 7 I COMMERCIAL ZONES Central Commercial Zone Neighbourhood Commercial Zone Commercial Shopping Centre Commercial Zone Hig hway Com mercial Zone H ighway Commercialil ndustrial Zone Highway Commercial Node Zone cc NC c SC HC HCt HCN A INDUSTRIAL ZONES Prestige Office Zone Prestige lndustrial Zone Light lndustrial Zone Heavy lndustrialzone Dry lndustrialzone PO PI LI HI DI INSTITUTIONAL ZONE lnstitutional Zone 28 OPEN SPACE ZONE Open Space Zone Environmental Conservation Zone OS EC

53 Gitv of Thorold Comprehensive Zoninq Bv-law 2140ß71 ZONE SYMBOL SECTION DEVELOPMENT ZONE Development Zone Residential Development Residential Development Deferred Rural Residential AGRICULTURAL ZONE Agricultural Zone Rural Commercial Zone WEST NEIGHBOURHOOD ZONES West Neighbourhood Residential First Density B Zone West Neighbourhood Residential First Density D Zone West Neighbourhood Residential First Density EZone West Neighbourhood Residential First Density F Zone West Neighbourhood Residential Second Density Zone West Neighbourhood Residential Third Density B Zone West Neighbourhood Open Space Zone West Neighbourhood Open Space/ lnstitutional Zone West Neighbourhood Open Space/ Woodlot Zone West Neighbourhood Neighbourhood Commercial Zone ROLLING MEADOWS ZONES Rolling Meadows Open Space Rolling Meadows Residential First Density B Zone Rolling Meadows Residential First Density C Zone Rolling Meadows Residential Second Density Rolling Meadows Residential Third Density D RD RDD RR A RUC wn-r1b wn-r1d wn-r1e wn-r1f wn-r2 wn-r3 wn-os wn-os/l wn-osw wn-nc RM-OS RM-R1B RM-R1C RM-R2 RM-R C A zone class may be identified solely by its zone symbol and may be referred to as a zone e.g. R1A Zone means Residential First Density R1A Zone Class and may be referred to as a Residential First Density R1A Zone. On a Zone Map, the zone symbol R1A has the same meaning Whenever lands on any Zoning Schedule have the zone symbol followed directly by a dash (-) and a number, e.g. A-1, such lands shall be considered to have a "Special Provision" number 42

54 Citv of Thorold Comprehensive Zoninq Bv-law 21 40ß71 and to have reference to a Zone subsection. The said lands shall be subject to the provisions of the relevant zone category and all other provisions contained herein, and shall in addition, be subject to any special provisions provided for within the relevant special provision subsection of the relevant zone Holding zones are hereby established by the use of the symbol (H) as a suffix to the zone symbols in Sections and Lands subject to the symbol (H) shall not be used, nor any building or structure used, altered or erected until the (H) is removed by amendment, pursuant to the provisions of the Planning Act, provided the following occurs: (a) adequate servicing including sanitary sewers, storm sewers, stormwater management facilities and waterlines can be provided to the lands to the satisfaction of Regional Niagara and the City of Thorold, andiql (b) approvals have been obtained from the Regional Public Health Department, and (c) the provisions of Section of the Official Plan are satisfied This provision shall not prevent continuation of uses existing at the time of establishment of the (H) symbol on said lands Zone Maps - Schedule A Maps ldentified The Zone Maps comprising Schedule A to this By-law shall form part of this By-law, and consist of the following: (1) Key Map - Schedule A (2) Area Maps - Schedules A1 to Zones lndicated on Maps The boundaries and zone symbols of the lands included in each zone class established by this By-law are shown on the Area Maps forming Schedule A1 to A12 of this By-law. 5.3 Determination of Zone Boundaries The boundaries of any zone shown on a Zone Map shall be determined in accordance with the following rules: Zone boundaries are indicated by heavy black lines Centre lines Where a zone boundary is indicated as following approximately the centre line of a street or lane andior its production, such centre line and/or its production shall be deemed to be the boundary. 43

55 Citu of Thorold Comorehensive Zonino Bv-law 2140ß Railways Where a zone boundary is indicated as following the centre line or outer limit of a railway right-of-way or an electrical, gas or oil transmission line, the centre line or outer limit of such right-of-way, as the case may be, shall be deemed to be the boundary Watercourses Where a zone boundary is indicated as following the centre line or edge of a body of water, such centre line or edge, as the case may be, shall be deemed to be the boundary Welland Ship Canal Where a zone boundary is indicated as following a side of the Welland Ship Canal, the boundary shall be deemed to coincide with the lot line, on that side of the Welland Ship Canal, of lands owned by or under the jurisdiction of the St. Lawrence Seaway Authority ldentified Lot Lines Where a zone boundary is indicated as following an identified lot line and/or its production shown on a registered plan or former Township lot line, such lot line and/or its production shall be deemed to be the boundary. A street line and/or its production shall be deemed to be an identified lot line Top of Bank Where a zone boundary is indicated as following the top of bank, such top of bank as the case may be, shall be deemed to be the boundary and in the event of change to the top of bank, the boundary shall be construed as moving with the actualtop of bank City Limits Where a zone boundary is indicated as following the limits of the City, such City limits, as the case may be, shall be deemed to be the boundary Street Closure ln the event a dedicated street, road allowance or lane shown on any Schedule forming part of this By-law is closed, the property formerly in such street, road allowance, or lane shall be included with the zone of the joining property on either side of such closed street, road allowance or lane. lf a closed street, road allowance or lane is the boundary between two or more different zones, the new zone boundaries shall be the former centreline of the closed street, road allowance or lane as such are adjacent to such zones Zone Measurement Where the zone boundary is not a street, road allowance or lane, nor a lot line and a specific measurement indicating the position of the said boundary is not shown on the Zoning Schedules or indicated in the text of this By-law, the position thereof shall be determined by scaling from the Zoning Schedules. 44

56 Citv of Thorold Comprehensive Zoninq Bv-law 2140(97) Zoning Maps The extent and boundaries of all zones are shown on the following Schedules which form part of this By-law and are attached hereto: Schedule A Schedule A1 Schedule A2 Schedule Schedule Schedule Schedule Schedule Schedule Schedule Schedule Schedule Schedule Schedule A3 A4 A5 A6 A7 A7-1 A8 A9 410 All Ê.12 Key Map (Zone Schedules) Decew (Northwest Rural) Lake Gibson/Blackhorse/The Neighbourhoods of Rolling Meadows (Northeast Rural) Thorold South East (Southeast Rural) Turners Corners (Southwest Rural) Brock Neighbourhood (Lake Gibson Brock) Confederation Heights Thorold Centre (Old Town) Permissible Bed & Breakfast Locations Beaverdams Thorold South/The Neighbourhoods of Rolling Meadows Allanburg Allanport Road Port Robinson 5.4 Deemed Amendme to the Zone Maps The Zone Maps, Schedule A and any other schedule affected, shall be deemed to be amended from time to time as necessary to reflect changes, correction, alterations and additions to lot lines, lot numbers, road patterns, railway lines, hydro, gas and other utility lines, watercourses, subdivisions, municipal boundaries, status and jurisdiction, and all similar or other features, except zoning changes. 45

57 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." Niagara-on-the-Lake Land Use Zoning Designation Plan Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 6, 2016

58 GM Facility to the Southwest

59 "General Motors of Canada Company is providing this information to the government in confidence. We believe this is confidential information and may also be a trade secret of our company. Public release of this information would be harmful to GM and, in certain jurisdictions, may result in similar information no longer being supplied to government institutions. If the head of any government institution intends to disclose this information, or part thereof, we request that prior written notice be given to General Motors of Canada Company, Attention: General Counsel, 1908 Colonel Sam Drive, Oshawa, Ontario L1H 8P7." Niagara Falls Land Use Zoning Designation Plan Emission Summary and Dispersion Modelling Report General Motors of Canada Company St. Catharines CET December 6, 2016

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