Toxic Reduction Act Shell Canada Products Sarnia Manufacturing Center Phosphorous, Total Toxics Reduction Action Plan Summary

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1 Toxic Reduction Act Shell Canada Products Sarnia Manufacturing Center Phosphorous, Total Toxics Reduction Action Plan Summary December 18, 2015

2 Toxic Reduction Plan Summary Substance Substance Name and CAS # Phosphorous, Total ** Substances for which other plans have been prepared Beneficial Uses/Reason for Use or Creation at Facility Previously Implemented Reduction Activities Ammonia, benzene, ethylbenzene, naphthalene, toluene, xylene, cadmium, lead, mercury, various PAH's, methanol, sulphuric acid, tetrachloroethylene, fluorene, acetone, TRS compounds, hydrogen sulphide, 1,2,4-trimethylbenzene, cyclohexane, diethanolamine, ethylene, iso-propanol, isopropyl benzene (cumene), n-hexane, propylene, PM, PM10, PM2.5, NOx, SO2, CO, light aliphatic naphtha, octane (all isomers), propane, butane (all isomers), butene (all isomers), heptane (all isomers), pentane (all isomers), pentene (all isomers). Phosphorous is created through the use of phosphoric acid in isopropyl alcohol production, the use of water treatment chemicals containing phosphates, and the treatment of sanitary waste. The phosphorus created is used as an essential nutrient in the biological oxidation treatment process in the wastewater treatment plant. Direct additions of phosphoric acid to support this process are also a source of phosphorus. Subsequently, solids (biosludge) that are regularly removed from the WWTP and treated onsite through approved landfarming practices are the largest contributor of phosphorous at the facility. Shell SMC has previously implemented the following reduction activities: Phosphate targets and monitoring in wastewater feed to optimize efficiency of wastewater treatment plant and reduce discharges of phosphorus into surface waters ESP (Ensure Safe Production) in place, includes mandated/scheduled operator rounds (visual inspection etc.) PLC program utilized to automate dosing of chemicals and prevent overuse Spill Prevention and Contingency Plan already established; material storage has secondary containment Specific Operating Procedures in place due to handling hazards Facility Information Company Name Shell Canada Products

3 Facility Name Shell Sarnia Manufacturing Center 150 St. Clair Parkway Facility Physical Address P.O.Box 2000 Corunna, ON N0N 1G0 Facility Mailing Address Same as physical address Spatial Coordinates of Facility (UTM, NAD83) Number of Employees 405 NPRI ID Digit NAICS Code Digit NAICS Code 3241 / Digit NAICS Code / Parent Company Information Parent Company Name Shell Canada Limited 400 4th Avenue Southwest Address Calgary, AB T2P0J4 Percent Ownership 100% Facility Contact Public Contact Address Kristina Zimmer 150 St. Clair Parkway P.O.Box 2000 Corunna, ON N0N 1G0 Kristina.zimmer@shell.com Phone (519) Fax (519) Statement of Intent Shell is responsible for meeting its environmental commitments. For the purposes of the Toxics Reduction Act, Shell Sarnia Manufacturing Centre (SMC) will not be implementing any options to reduce the use of Phosphorous in its operations because no feasible options were identified. Whenever practicable, we will eliminate, or reduce the discharge of Phosphorous in full compliance with all Federal and Provincial Regulations. Plan Objectives While Shell SMC does not intend to reduce the use of Phosphorous, the plan was developed with the following objectives: we will continue to operate in full compliance with all applicable environmental regulations; and

4 we will continue to manage releases of Phosphorous through current and future pollution prevention and best management practices. Description of Substance Phosphorous enters the wastewater treatment plant (WWTP) through the use of phosphoric acid as a catalyst in the production of isopropyl alcohol. Phosphates from various water treatment chemicals also enter the WWTP from cooling tower and boiler blowdown. Sanitary waste treated at the WWTP also contains phosphorus. The phosphorus from these sources is utilized as an essential nutrient in the biological oxidation treatment process at the WWTP. When concentrations are low, phosphoric acid must be added at the WWTP to ensure efficient operation. Solids (biosludge), which contain phosphorus, are regularly removed from the WWTP and treated onsite through approved landfarming practices. This is the largest contributor of phosphorous at the facility. Toxic Substance Reduction Option(s) To Be Implemented For the purposes of the Toxics Reduction Act, Shell SMC will not be implementing any options to reduce the use of Phosphorous in its operations because it plays a critical role in the waste water treatment process. In the past, Shell SMC has implemented multiple programs to reduce spills/leaks and discharges. There were no further feasible reduction options identified. Plan Summary Statement This plan summary accurately reflects the content of the toxic substance reduction plan for Phosphorous, prepared by Shell SMC, dated December 18, 2015.

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