SAMPLE APPROVAL ABC REGULATOR. ENVIRONMENTAL PROTECTION AND ENHANCEMENT ACT R.S.A. 2000, c.e-12, as amended. January 02, 2018.

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1 SAMPLE APPROVAL ABC REGULATOR ENVIRONMENTAL PROTECTION AND ENHANCEMENT ACT R.S.A. 2000, c.e-12, as amended. APPROVAL NO.: APPLICATION NO.: EFFECTIVE DATE: EXPIRY DATE: APPROVAL HOLDER: January 02, 2018 December 31, 2028 COMPANY Y ACTIVITY: Construction, operation and reclamation of the FACILITY Z is subject to the attached terms and conditions. Designated Director under the Act: JS Joe Smith Acting Approvals Manager ABC Regulator Date Signed: January 02, 2018 DISCLAIMER: This sample approval is a sample only. While it is based on actual and possible approval conditions, it represents a fictitious industrial facility. The purpose of this sample approval is only to set out fictitious reporting requirements to guide the development of a sample monthly and sample annual report for stakeholder us in preparation to meet the reporting requirements of the Air Monitoring Directive.

2 PART 1: DEFINITIONS SECTION 1.1: DEFINITIONS All definitions from the Act and the regulations apply except where expressly defined in this approval In all PARTS of this approval: (d) (e) Act means the Environmental Protection and Enhancement Act, R.S.A. 2000, c.e-12, as amended; air effluent stream means any substance in a gaseous medium released by or from a plant; application means the written submissions from the approval holder to the Director in respect of application number and any subsequent applications where amendments are issued for this approval; CEMS Code means the Continuous Emission Monitoring System (CEMS) Code, Alberta Environmental Protection, Pub.No.Ref: 107, May 1998, as amended; conditioning of SUPERCLAUS catalyst means the period after replacement of the catalyst required to activate the catalyst; (f) day, when referring to sampling, means any sampling period of 24 consecutive hours; (g) (h) (i) (j) (k) (l) (m) Director means an authorized employee of the ABC Regulator; downtime means the period of time when equipment is not effectively functioning due to breakdown, repair, calibration, servicing, maintenance or replacement of any of its components; fugitive emissions means emissions of substances to the atmosphere other than ozone depleting substances, originating from a plant source other than a flue, vent, or stack but does not include sources which may occur due to breaks or ruptures in process equipment; ISO/IEC means the international standard, developed and published by International Organization for Standardization (ISO), specifying management and technical requirements for laboratories; manual stack survey means a survey conducted in accordance with the Alberta Stack Sampling Code, Alberta Environment, 1995, as amended; month means calendar month; plant means all buildings, structures, process and pollution abatement equipment, vessels, storage facilities, material handling facilities, roadways, railways, pipelines and other installations, and includes the land that is being or has been used or held for or in connection with Facility Z, located on:

3 (i) (ii) (iii) (iv) the SE ¼ of Section 15, Township 74, Range 7, W5M; the S ½ of Section 14, Township 74, Range 7, W5M; the NE ¼ of Section 10, Township 74, Range 7, W5M; and the N ½ of Section 11, Township 74, Range 7, W5M; (n) (o) (ii) (ll) regulations means the regulations enacted pursuant to the Act, as amended; tank means a stationary device, designed to contain an accumulation of a substance, which is constructed primarily of non-earthen materials that provide structural support including wood, concrete, steel, and plastic; TRS means Total Reduced Sulphur as defined in the Alberta Stack Sampling Code, Alberta Environment, 1995, as amended; week means any consecutive 7-day period; and (mm) year means calendar year, unless otherwise specified. PART 2: GENERAL SECTION 2.1: REPORTING The approval holder shall immediately report to the Director by telephone any contravention of the terms and conditions of this approval at The approval holder shall submit a written report to the Director within 7 days of the reporting pursuant to The approval holder shall immediately notify the Director in writing if any of the following events occurs: (d) (e) the approval holder is served with a petition into bankruptcy; the approval holder files an assignment in bankruptcy or Notice of Intent to make a proposal; a receiver or receiver-manager is appointed; an application for protection from creditors is filed for the benefit of the approval holder under any creditor protection legislation; or any of the assets which are the subject matter of this approval are seized for any reason If the approval holder monitors for any substances or parameters which are the subject of operational limits as set out in this approval more frequently than is required and uses procedures authorized in this approval, then the approval holder shall provide the results of such monitoring as an addendum to the reports required by this approval.

4 2.1.5 The approval holder shall submit all monthly reports required by this approval to be compiled or submitted to the Director on or before the end of the month following the month in which the information was collected, unless otherwise specified in this approval The approval holder shall submit all annual reports required by this approval to be compiled or submitted to the Director on or before March 15 of the year following the year in which the information was collected, unless otherwise specified in this approval. SECTION 2.2: RECORD KEEPING The approval holder shall: record; and retain all the following information in respect of any sampling conducted or analyses performed in accordance with this approval for a minimum of ten years, unless otherwise authorized in writing by the Director: (i) (ii) (iii) (iv) (v) the place, date and time of sampling, the dates the analyses were performed, the analytical techniques, methods or procedures used in the analyses, the names of the persons who collected and analysed each sample, and the results of the analyses. SECTION 2.3: ANALYTICAL REQUIREMENTS With respect to any sample required to be taken pursuant to this approval, the approval holder shall ensure that: (d) (e) collection; preservation; storage; handling; and analysis shall be conducted in accordance with the following unless otherwise authorized in writing by the Director:

5 (i) for air: (A) the Alberta Stack Sampling Code, Alberta Environment, 1995, as amended, (B) (C) (D) the Methods Manual for Chemical Analysis of Atmospheric Pollutants, Alberta Environment, 1993, as amended, the Air Monitoring Directive, Alberta Environment, 1989, as amended, and the CEMS Code, as amended; The approval holder shall analyse all samples that are required to be obtained by this approval in a laboratory accredited pursuant to ISO/IEC 17025, as amended, for the specific parameter(s) to be analysed, unless otherwise authorized in writing by the Director The term sample used in does not include samples directed to continuous monitoring equipment, unless specifically required in writing by the Director The approval holder shall comply with the terms and conditions of any written authorization issued by the Director under SECTION 2.4: OTHER The terms and conditions of this approval are severable. If any term or condition of this approval or the application of any term or condition is held invalid, the application of such term or condition to other circumstances and the remainder of this approval shall not be affected thereby All tanks shall conform to the Guidelines for Secondary Containment for Above Ground Storage Tanks, Alberta Environmental Protection, 1997, as amended, unless otherwise authorized in writing by the Director All above ground storage tanks containing liquid hydrocarbons or organic compounds shall conform to the Environmental Guidelines for Controlling Emissions of Volatile Organic Compounds from Above ground Storage Tanks, Canadian Council of Ministers of the Environment, PN 1180, 1995, as amended. PART 3: CONSTRUCTION Not used at this time.

6 PART 4: OPERATIONS, LIMITS, MONITORING AND REPORTING SECTION 4.1: AIR OPERATIONS The approval holder shall not release any air effluent streams to the atmosphere except as authorized by this approval The approval holder shall only release air effluent streams to the atmosphere from the following sources: (d) (e) (f) (g) (h) (i) (j) (k) (l) (m) (n) (o) (p) (q) (r) the sulphur recovery process unit incinerator stack; the Plant A emergency flare stack; the Plant B emergency flare stack; the Plant C emergency flare stack; the 20,000 kw compressor engine exhaust stack; the 1,200 kw compressor engine exhaust stack; the two 1,500 kw compressor engine exhaust stacks; the utility boiler exhaust stack; the 2,000 kw boiler exhaust stack; the 750 kw boiler exhaust stack; the two 8,000 kw steam boiler exhaust stacks; the 6900 kw process heat medium heater; the emergency electrical generator exhaust stack; the sulphur recovery unit air boiler vents; the space ventilation exhaust stacks; the space heater exhaust vents; the compressor engine starter gas vents; and any other source authorized in writing by the Director The approval holder shall maintain the following stacks according to the minimum height requirements specified in: TABLE 4.1-A; and TABLE 4.1-B:

7 TABLE 4.1-A STACK HEIGHTS STACK MINIMUM HEIGHT ABOVE GRADE (metres) Sulphur recovery process unit incinerator stack Plant A emergency flare stack 51.1 Plant B emergency flare stack 75.1 Plant C emergency flare stack kw process heat medium heater 4.7 TABLE 4.1-B STACK HEIGHTS COMPRESSOR ENGINE RATED CAPACITY KILOWATTS (kw) NUMBER OF ENGINES MINIMUM HEIGHT ABOVE GRADE (metres) 20,000 kw compressor ,200 kw compressor ,500 kw compressor The approval holder shall operate the emergency flare stacks in accordance with Residue gas shall be added to the sour gas released to the emergency flare stacks such that the net or lower heating value of the combined gas stream is not less than 12 MJ/m 3 (at kpa and 15 C) The approval holder shall ensure the combustion of all combustible gases released to the emergency flare stacks The approval holder shall equip and operate all emergency flare stacks with: a wind guard; and a continuously burning pilot light; and an electric, or equivalent, ignitor All plant pressure safety valves in sour gas service shall be connected to the flare system Except as provided for by the Director in writing, the approval holder shall not emit fugitive emissions or an air contaminant from any source not specified in or an air contaminant from the emergency flare stacks that causes or may cause any of the following:

8 impairment, degradation or alteration of the quality of natural resources; material discomfort, harm or adverse effect to the well being or health of a person; or harm to property or to vegetative or animal life. AIR LIMITS Releases of the following substances to the atmosphere shall not exceed the limits specified in TABLE 4.1-C. TABLE 4.1-C LIMITS EMISSION SOURCE Sulphur Recovery Process Unit Incinerator Stack AIR CONTAMINANT/ PARAMETER Sulphur Dioxide Temperature LIMIT 1.76 tonnes per hour 24.8 tonnes per day 5150 parts per million by volume for a one-hour averaging period. a minimum of 425 C for a onehour averaging period Releases of the following substances to the atmosphere shall not exceed the limits specified in TABLE 4.1-D during any of the following activities: a) start-up of SUPERCLAUS unit; b) shut-down of SUPERCLAUS Unit; c) replacement of SUPERCLAUS catalyst; and d) conditioning of SUPERCLAUS catalyst. TABLE 4.1-D OPERATING LIMITS DURING PLANT START-UP, SHUT- DOWN, REPLACEMENT AND CONDITIONING OF SUPERCLAUS EMISSION SOURCE Sulphur Recovery Process Unit Incinerator Stack AIR CONTAMINANT/ PARAMETER Sulphur Dioxide Temperature LIMIT 2.15 tonnes per hour 24.8 tonnes per day a minimum of 425 C for a onehour averaging period MONITORING AND REPORTING The approval holder shall monitor the air emission sources as specified in TABLE 4.1- E.

9 The approval holder shall report to the Director the results of the air emission source monitoring as required in TABLE 4.1-E. TABLE 4.1-E SOURCE MONITORING AND REPORTING EMISSION SOURCE/ EFFLUENT STREAM PARAMETER SAMPLING FREQUENCY MONITORING METHOD METHOD OF ANALYSIS REPORTING FREQUENCY Sulphur Recovery Process Unit Incinerator Stack Sulphur Dioxide Flow Rate Temperature Sulphur Dioxide TRS Continuous CEM CEMS Code Twice per year Manual Stack Survey Emergency Flare Stacks Sulphur Dioxide Daily Measured or estimated 6900 kw process heat medium heater Oxides of nitrogen (expressed as NO2) Once within six months of commissioning Manual Stack Survey Alberta Stack Sampling Code Measured or estimated Alberta Stack Sampling Code Monthly, before the end of the next month Month after the survey is done Monthly, before the end of the next month Month after the survey is done In addition to other requirements in this approval the approval holder shall: monitor; and report the information required by: (i) ; (ii) ; (iii) ; and (iv) The information required in , shall at a minimum, comply with: (d) the Alberta Stack Sampling Code, Alberta Environment, 1995 as amended; the Continuous Emission Monitoring Systems (CEMS) Code, Alberta Environmental Protection Environmental Service, 1998, as amended; the Air Monitoring Directive AMD 1989, Environment Protection Services, Standards and Approvals Division, June 26, 1989, as amended; and the Electronic Reporting of Continuous Emissions Monitoring (CEMS) Information User Manual, Alberta Environment, 2003, as amended.

10 The approval holder shall notify the Director in writing a minimum of two weeks prior to any manual stack survey that is required to be conducted by this approval The approval holder shall submit the monthly CEMS Code data required in section electronically to the Alberta Environment and Parks File Transfer Protocol (FTP) site which is used for the electronic submission of continuous emissions monitoring information The approval holder shall monitor ambient air parameters as specified in TABLE 4.1-F, unless otherwise authorized in writing by the Director The approval holder shall report to the Director the results of the ambient air monitoring as required in TABLE 4.1-F, unless otherwise authorized in writing by the Director. TABLE 4.1-F AMBIENT AIR MONITORING AND REPORTING MONITORING STATION PARAMETER TO BE ANALYSED OR MEASURED FREQUENCY METHOD OF MONITORING METHOD OF ANALYSIS OR MEASUREMENT REPORT FREQUENCY Monthly Annually Sulphur dioxide hydrogen sulphide Air Monitoring Directive Monthly Annually 3 continuous monitoring stations wind speed wind direction PM2.5 Continuously, for a minimum of 12 months of the year Continuous sampling As per manufacturer s specifications unless otherwise required in the Air Monitoring Directive Monthly Annually benzene Intermittent as per NAPS schedule Summa Canister As per manufacturer s specifications unless otherwise required in the Air Monitoring Directive Monthly Annually 10 passive stations Sulphur dioxide hydrogen sulphide Monthly Passive Sampling As per manufacturer s specifications unless otherwise required in the Air Monitoring Directive Monthly Annually In addition to the reporting required under and , the annual summary and evaluation report shall be submitted to the Director by March 15 of each year that contains the previous year information related to plant operation, performance of air pollution control equipment and air contaminant emissions.

11 SPECIAL REPORTING The approval holder shall continuously measure or estimate and record on a daily basis the average sulphur inlet rates in tonnes per day If the percentage of daily SO 2 mass emission rates as reported in are less than or equal to the values in Column 3 in TABLE 4.1-G for the applicable daily SO 2 mass emission (Column 2, TABLE 4.1-G) based on the average daily sulphur inlet rates (Column 1, TABLE 4.1-G) at which the plant operated during the reporting period; OR If the percentage of hourly SO 2 mass emission rates as reported in are less than or equal to the values in Column 5 in TABLE 4.1-G for the applicable hourly SO 2 mass emission (Column 2, TABLE 4.1-G) based on the average daily sulphur inlet rates (Column 1, TABLE 4.1-G) at which the plant operated during the reporting period; then the following information shall be provided in the monthly report by the approval holder: a description of the events or circumstances that lead to higher cumulative mass emission readings; and an outline of the action taken to control the magnitude and/or duration of the event; and a description of any long-term measures or actions that are required to prevent or minimize such occurrences in the future and a schedule of implementation for these measures or actions. TABLE 4.1-G: SO 2 MASS EMISSION TIERS COLUMN 1 COLUMN 2 COLUMN 3 COLUMN 4 COLUMN 5 PLANT DAILY AVERAGE SULPHUR INLET RATE (TONNES/DAY) DAILY SO 2 MASS EMISSION (TONNES/DAY) Sulphur Recovery Process Unit Incinerator Stack % OF DAILY READINGS IN A MONTH THAT ARE TO BE LESS THAN THE DAILY MASS EMISSION VALUE IN COLUMN 2 HOURLY SO 2 MASS EMISSION (TONNES/HOUR) Sulphur Recovery Process Unit Incinerator Stack % OF HOURLY READINGS IN A MONTH THAT ARE TO BE LESS THAN THE HOURLY MASS EMISSION VALUE IN COLUMN The approval holder shall report the frequency distribution of both the hourly and daily mass emission rates of sulphur dioxide versus the monthly average daily sulphur inlet rate monthly.

12 REGIONAL INITIATIVES The approval holder shall participate in implementing the Regional Air Quality Management Framework (RAQMF) including programs developed under the RAQMF when requested in writing by the Director The approval holder shall develop a proposal for an Air Emissions Management Plan for specified parameters which shall incorporate the outcomes and requirements outlined in the Airzone Air Emissions Management Program by Environment and Parks when requested in writing by the Director The approval holder shall submit the proposal for an Air Emissions Management Plan required to be developed in to the Director for the specified parameters within the timeline specified in writing by the Director The proposed Air Emissions Management Plan referred to in shall include, at a minimum, all of the information as outlined in the written request from the Director in If the proposed Air Emissions Management Plan is found deficient by the Director, the approval holder shall correct all deficiencies as outlined in writing by the Director, within the timeline specified in writing by the Director The approval holder shall implement the Air Emissions Management Plan as authorized in writing by the Director The approval holder shall submit the: information; data; and reports to the Director as specified in the Air Emissions Management Plan authorized in