The following table summarizes the average test results for the three tests conducted by ORTECH and the corresponding emission criteria:

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1 EXECUTIVE SUMMARY ORTECH Environmental (ORTECH) was requested by Clean Harbors to conduct a comprehensive emission testing program at the incineration facility located at 4090 Telfer Road in Corunna, Ontario. The emission testing is required annually as part of the Ontario Ministry of the Environment (MOE) Environmental Compliance Approval (ECA) No (formerly Certificate of Approval (Air) No ), dated April 19, A Notice of Amendment to the ECA was issued on January 24, 2003, ECA Waste/Air No G5MSP (referred to herein as Notice of Amendment ). The primary objective of the testing program was to determine the emission rates of specific contaminants and to demonstrate the facility s ability to meet the allowable emission levels for these contaminants according to the specified point of impingement concentration limits. In addition to the requirements of Regulation 419, the ECA provides criteria for the total hydrocarbon (THC) concentration on an undiluted basis at the incinerator exit, and in the stack. The ECA also provides concentration limits for carbon monoxide, oxygen, particulate matter, mercury, and the toxic equivalent concentration of dioxins and furans in the stack gases. The following table summarizes the average test results for the three tests conducted by ORTECH and the corresponding emission criteria: Stack Gas Concentration Criterion Allowable Value Test Average Value Particulate Matter maximum 20 mg/rm 3(1) 13.0 mg/rm 3(1) Mercury maximum 50 µg/rm 3(1) 1.39 µg/rm 3(1) Dioxin and Furan TEQ maximum 80 pg TEQ/Rm 3(1) 6.04 pg TEQ/Rm 3(1) Carbon Monoxide maximum 100 ppm (1) 46.0 ppm (1) Oxygen minimum 8.0 % (2) % (2) Total Hydrocarbons (3) maximum 100 ppm (1) 9.7 ppm (1) (1) (2) (3) adjusted to 11% oxygen, dry at 25 C and 1 atmosphere dry by volume as per ECA No G5MSP (dry adjusted stack concentration) Note; the dioxin and furan concentration in the above table was calculated using the calculation method detailed in Schedule 3 of the ECA. Included as part of the emission testing program was a comprehensive, internal Quality Assurance/Quality Control (QA/QC) program. This report describes both the emission testing program and the internal QA/QC program conducted by ORTECH, and summarizes the results. The emission testing program was conducted over three days between September 17 and September 19, 2013 during which three valid tests were completed for each emission component group using several types of sampling trains and sampling methods. at the Clean Harbors Sarnia Incineration Facility (2013), Report #21425 Page 6

2 The particulate and metals, semi volatile organics and combustion gas tests were performed simultaneously at the main stack location. During the time required to complete these tests, acid gas and volatile organics tests were also run. Testing was performed at a high feed rate, as specified by the ECA, to demonstrate compliance with MOE emission criteria. During the emission tests, the rich, lean and emulsion feed rates combined were 175.6, and L/min for Test No. 1, Test No. 2, and Test No. 3, respectively. The Thermal Desorber Unit (TDU) was exhausting to the incinerator during Test No. 1 and Test No. 3. The TDU was not operating during Test No. 2. Also during the emission testing program, process data was recorded and composite samples of the liquid waste materials being incinerated were collected for subsequent analysis. The results of these analyses, coupled with the stack gas emission rate measurements, were used to calculate destruction and removal efficiencies (DREs) for six target principal organic hazardous compounds. The average DREs calculated for the emission testing program were as follows: 2 Butanone ( %), Ethyl Acetate ( %), Tetrachloroethene ( %), Toluene ( %), 1,2,4 Trichlorobenzene ( %) and Total Xylenes ( %). The DRE was also determined for pentachlorophenol during the 2013 test program. The DRE for pentachlorophenol was %. Note that the contribution of the Thermal Desorber Unit was not included in the DRE calculations. All tables referenced in this report (excluding the internal QA/QC summary tables) are provided in Appendix 1. Summary results tables for the 2013 emission testing program are provided on the following pages based on calculated ground level point of impingement concentrations for the stack emissions and the DREs. Please note that the dispersion modelling was conducted using the AERMOD model. Point of impingement calculations for previous testing programs (2012 and prior) were conducted using the Regulation 346 model. None of the analytical data was blank corrected, although analytical data for some metals (aluminum, boron, calcium, magnesium, silicon and sodium) does not include amounts detected in the hydrofluoric acid extracts of the sampling train filters because of the normally high background levels of these metals. Therefore, contaminant emission rates would tend to be over estimated. at the Clean Harbors Sarnia Incineration Facility (2013), Report #21425 Page 7

3 Regulation 419 Dispersion Modelling Results for Inorganic and Semi Volatile Organic Compounds Average Calculated Allowable Percentage Contaminant Emission Impingement Impingement of Status of Rate Concentration Concentration Allowable Allowable Concentration Concentration Base Case - 24 hour 1.00 g/s µg/m 3 Base Case - 1 hour 1.00 g/s µg/m 3 Base Case - 1/2 hour 1.00 g/s µg/m 3 Particulate matter 0.23 g/s 0.11 µg/m µg/m S Sulphur dioxide 10.5 g/s 5.19 µg/m µg/m S - 24 hour Sulphur dioxide 10.5 g/s 17.8 µg/m µg/m S - 1 hour Nitrogen oxides 1.79 g/s 0.89 µg/m µg/m S - 24 hour Nitrogen oxides 1.79 g/s 3.03 µg/m µg/m S - 1 hour Carbon monoxide 0.92 g/s 1.87 µg/m µg/m S - 1/2 hour Hydrogen chloride 0.71 g/s 0.35 µg/m 3 20 µg/m S Fluorides (as hydrogen fluoride) 0.25 g/s 0.12 µg/m µg/m S Hydrogen cyanide g/s µg/m 3 8 µg/m S Dioxins & Furans (TEQ) * <0.10 ng TEQ/s pg TEQ/m 3 Dioxins, Furans and Dioxin-Like PCBs (TEQ) ** <0.065 ng TEQ/s pg TEQ/m 3 1 pg TEQ/m URT Naphthalene 40.4 µg/s µg/m µg/m 3 < G Biphenyl 20.1 µg/s µg/m 3 60 µg/m 3 < G - 1 hour Benzo (a) pyrene µg/s µg/m µg/m G 1,2-Dichlorobenzene 4.41 µg/s µg/m µg/m 3 < G - 1 hour 1,4-Dichlorobenzene 1.97 µg/s µg/m 3 95 µg/m 3 < S 1,2,4-Trichlorobenzene 2.82 µg/s µg/m µg/m 3 < G Pentachlorophenol 0.24 µg/s µg/m 3 20 µg/m 3 < G Polychlorinated biphenyls 0.46 µg/s µg/m µg/m G S - Standard G - Guideline URT - Upper Risk Threshold * Calculated using the detection limit for those isomers not detected in quantities greater than the reportable detection limit. ** Calculated using half the detection limit for those isomers not detected in quantities greater than the reportable detection limit. at the Clean Harbors Sarnia Incineration Facility (2013), Report #21425 Page 8

4 Regulation 419 Dispersion Modelling Results for Metals Average Calculated Allowable Percentage Status of Contaminant Emission Impingement Impingement of Allowable Rate Concentration Concentration Allowable Concentration Concentration Base Case - 24 hour 1.00 g/s µg/m 3 Aluminum oxide 11.6 mg/s µg/m µg/m G Antimony mg/s µg/m 3 25 µg/m 3 < S Arsenic 0.12 mg/s µg/m µg/m G Barium (as water soluble) 0.26 mg/s µg/m 3 10 µg/m G Beryllium* mg/s µg/m µg/m S Boron 13.8 mg/s µg/m µg/m S Cadmium mg/s µg/m µg/m S Calcium oxide 24.6 mg/s µg/m 3 10 µg/m S Chromium 0.38 mg/s µg/m µg/m G Cobalt mg/s µg/m µg/m G Copper 0.29 mg/s µg/m 3 50 µg/m S Iron (as metal) 19.8 mg/s µg/m 3 4 µg/m S Lead 0.10 mg/s µg/m µg/m S Lithium mg/s µg/m 3 20 µg/m 3 < S Magnesium oxide 5.46 mg/s µg/m µg/m S Manganese (as compounds) 3.12 mg/s µg/m µg/m G Mercury mg/s µg/m 3 2 µg/m S Molybdenum mg/s µg/m µg/m 3 < G Nickel 0.11 mg/s µg/m 3 2 µg/m S Phosphorus pentachloride 18.4 mg/s µg/m 3 10 µg/m G Potassium hydroxide 20.6 mg/s µg/m 3 14 µg/m G Selenium 0.32 mg/s µg/m 3 10 µg/m G Silica (as respirable silica) 81.5 mg/s µg/m 3 5 µg/m G Silver mg/s µg/m 3 1 µg/m S Sodium hydroxide 90.7 mg/s µg/m 3 10 µg/m G Strontium mg/s µg/m µg/m 3 < G Tin mg/s µg/m 3 10 µg/m S Titanium 2.09 mg/s µg/m µg/m S Vanadium mg/s µg/m 3 2 µg/m S Zinc 0.77 mg/s µg/m µg/m S S - Standard G - Guideline URT - Upper Risk Threshold * These compounds were not detected in any of the emission samples (all analytical results were <MDL). at the Clean Harbors Sarnia Incineration Facility (2013), Report #21425 Page 9

5 Regulation 419 Dispersion Modelling Results for Volatile Organic Compounds Average Calculated Allowable Percentage Status of Contaminant Emission Impingement Impingement of Allowable Rate Concentration Concentration Allowable Concentration Concentration Base Case - 24 hour 1.00 g/s µg/m 3 Base Case - 1 hour 1.00 g/s µg/m 3 Benzene 5.92 mg/s µg/m µg/m URT Bromomethane (methyl bromide) 1.50 mg/s µg/m µg/m 3 < G 2-Butanone (methyl ethyl ketone) 1.00 mg/s µg/m µg/m 3 < S Chloroethene (vinyl chloride)* 0 mg/s 0 µg/m 3 1 µg/m 3 < S 1,1-Dichloroethane (ethylene dichloride)* 0 mg/s 0 µg/m 3 2 µg/m 3 < S trans-1,2-dichloroethene mg/s µg/m µg/m 3 < G Dichloromethane (methylene chloride) * 0 mg/s 0 µg/m µg/m 3 < G Ethyl Acetate 0.52 mg/s µg/m µg/m 3 < G - 1 hour Ethylbenzene mg/s µg/m µg/m 3 < S Isopropylbenzene (cumene) * 0 mg/s 0 µg/m µg/m 3 < S 2-Propanone (acetone) 3.43 mg/s µg/m µg/m 3 < S Styrene mg/s µg/m µg/m 3 < S Tetrachloroethene (perchloroethylene) mg/s µg/m µg/m 3 < S Tetrachloromethane (carbon tetrachloride) mg/s µg/m µg/m 3 < S Toluene 1.24 mg/s µg/m µg/m 3 < S Tribromomethane (bromoform) mg/s µg/m 3 55 µg/m 3 < G 1,1,1-Trichloroethane (methyl chloroform)* 0 mg/s 0 µg/m µg/m 3 < S Trichloroethene * 0 mg/s 0 µg/m 3 12 µg/m 3 < S Trichlorofluoromethane mg/s µg/m µg/m 3 < G Trichloromethane (chloroform) mg/s µg/m 3 1 µg/m S Trichlorotrifluoroethane* 0 mg/s 0 µg/m µg/m 3 < S 1,2,4-Trimethylbenzene (pseudocumene) * 0 mg/s 0 µg/m µg/m 3 < S 1,3,5-Trimethylbenzene * 0 mg/s 0 µg/m µg/m 3 < S Xylenes mg/s µg/m µg/m 3 < S S - Standard G - Guideline URT - Upper Risk Threshold * These compounds were not detected in any of the emission samples (all analytical results were <MDL). at the Clean Harbors Sarnia Incineration Facility (2013), Report #21425 Page 10

6 Summary of Destruction and Removal Efficiencies for Volatile Organic Compounds Compund Destruction and Removal Efficiency Coefficient Test Test Test Average of No. 1 No. 2 No. 3 Variation % % % % % 2 Butanone Ethyl Acetate Tetrachloroethene Toluene Total Xylenes ,2,4 Trichlorobenzene Pentachlorophenol at the Clean Harbors Sarnia Incineration Facility (2013), Report #21425 Page 11