R E P O R T E P O R T - PDF Free Download

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

"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 9039-924M7F, 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 (2013-282) 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 2016. 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

Emission Summary Table RWDI Project 1100778 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 10102-44-0 1.78E+01 AERMOD 3.21E+02 1 400 Health 3 80% 10102-44-0 1.78E+01 1.66E+02 24 200 Health 3 83% Property Line Particulate Matter PM 7.08E-01 AERMOD 7.07E+01 24 120 Visibility 3 59% Property Line Carbon Monoxide 630-08-0 4.37E+00 AERMOD 5.33E+02 0.5 6,000 Health 3 9% Property Line Sulphur Dioxide 7446-09-5 4.25E-01 AERMOD 1.06E+02 1 690 Health and Vegetation 3 15% 7446-09-5 4.25E-01 4.42E+01 24 275 Health and Vegetation 3 16% Property Line Hydrogen Sulfide [2] 7783-06-4 6.52E-03 AERMOD 3.11E-01 24 7 Odour 3 4% 7783-06-4 6.52E-03 9.49E-01 0.17 13 Odour 3 7% Property Line 1,1,2-Trichloroethane [2] 79-00-5 7.43E-05 AERMOD 3.54E-03 24 0.31 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.

"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 9039-924M7F, 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, 2016 1

"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 336310 Motor Vehicle Gasoline Engine and Parts Mfg. Code 336310 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, 2016 4

"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 7.1.2 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, 2016 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." 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 336310 Motor Vehicle Gasoline Engine & Parts Mfg. Code 336310 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, 2016 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." 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 2009. The Facility became subject to Section 20 of O. Reg. 419/05 on February 1, 2013. 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, 2016 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." 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 2012. 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, 2016 19

Table 1: Emission Summary Table RWDI Project 1100778 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 10102-44-0 1.78E+01 AERMOD 3.21E+02 1 400 Health 3 80% 10102-44-0 1.78E+01 1.66E+02 24 200 Health 3 83% Property Line Particulate Matter PM 7.08E-01 AERMOD 7.07E+01 24 120 Visibility 3 59% Property Line Carbon Monoxide 630-08-0 4.37E+00 AERMOD 5.33E+02 0.5 6,000 Health 3 9% Property Line Sulphur Dioxide 7446-09-5 4.25E-01 AERMOD 1.06E+02 1 690 Health and Vegetation 3 15% 7446-09-5 4.25E-01 4.42E+01 24 275 Health and Vegetation 3 16% Property Line Hydrogen Sulfide [2] 7783-06-4 6.52E-03 AERMOD 3.11E-01 24 7 Odour 3 4% 7783-06-4 6.52E-03 9.49E-01 0.17 13 Odour 3 7% Property Line 1,1,2-Trichloroethane [2] 79-00-5 7.43E-05 AERMOD 3.54E-03 24 0.31 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.

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 7.1.1 of the Procedure for Preparing an ESDM Report Document. Not Applicable As per section 7.1.2 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 7.2.2 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 (336310 -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

Table 5-1: Source Summary Table - Sorted by Contaminant RWDI Project 1100778 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 10102-44-0 GAP001 Stack for Boiler #3 and #4 GAP001 Point Powerhouse 24.1 200 2.5 4.90 50.3 39.0 647174 4777989 4.08E+00 1, 24 EF Above-Average 23% 10102-44-0 W9 Shower Boiler Room #4 W9 Point RZ4W 4.9 250 0.73 11.80 15.2 5.1 647336 4778067 6.19E-02 1, 24 EF Above-Average <1% 10102-44-0 W10 Shower Room Boiler #3 W10 Point RZ4W 4.9 250 0.73 11.80 15.2 5.1 647339 4778066 6.19E-02 1, 24 EF Above-Average <1% 10102-44-0 W11 Shower Room Natural Gas #2 W11 Point RZ4W 1.6 250 0.41 11.80 19.99 9.8 647358 4778069 4.95E-02 1, 24 EF Above-Average <1% 10102-44-0 W12 Shower Room Natural Gas #1 W12 Point RZ4W 1.6 250 0.41 11.80 19.99 9.8 647357 4778067 4.95E-02 1, 24 EF Above-Average <1% 10102-44-0 196 Boiler Exhaust S196 Point RZ5E 0.79 175 0.41 5.98 18.70 2.90 647451 4777974 7.43E-02 1, 24 EF Above-Average <1% 10102-44-0 197 Boiler Exhaust S197 Point RZ5E 0.79 175 0.41 5.98 18.70 2.90 647450 4777970 7.43E-02 1, 24 EF Above-Average <1% 10102-44-0 204 Boiler S204 Point RZ12W 0.46 175 0.15 26.03 12.30 N/A 647399 4777903 3.71E-02 1, 24 EF Above-Average <1% 10102-44-0 207 Boiler S207 Point RZ12W 0.46 175 0.15 26.03 12.30 N/A 647399 4777903 3.71E-02 1, 24 EF Above-Average <1% 10102-44-0 102A Dyno Room Cell #1 Engine Exhaust S102A Point RZ1E 3.1 38 0.46 18.65 9.86 2.9 647602 4778114 3.40E-01 1, 24 EF Above-Average 2% 10102-44-0 102B Dyno Room Cell #4 Engine Exhaust S102B Point RZ1E 3.1 38 0.46 18.65 9.86 2.9 647597 4778124 4.08E-01 1, 24 EF Above-Average 2% 10102-44-0 102C Dyno Room Cell #2 Engine Exhaust S102C Point RZ1E 3.1 38 0.46 18.65 9.86 2.9 647605 4778126 4.08E-01 1, 24 EF Above-Average 2% 10102-44-0 LFGGEN1 Landfill Gas-Fired Generator Set LFGGEN1 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647193 4777839 7.13E-01 1, 24 EF Above-Average 4% 10102-44-0 LFGGEN2 Landfill Gas-Fired Generator Set LFGGEN2 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647193 4777833 7.13E-01 1, 24 EF Above-Average 4% 10102-44-0 LFGGEN3 Landfill Gas-Fired Generator Set LFGGEN3 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647194 4777828 7.13E-01 1, 24 EF Above-Average 4% 10102-44-0 LFGGEN4 Landfill Gas-Fired Generator Set LFGGEN4 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647194 4777824 7.13E-01 1, 24 EF Above-Average 4% 10102-44-0 BOIL1 CoGen Boiler (12 MMBTU) BOIL1 Point CoGen 1.6 175 0.46 9.64 15.5 9.1 647189 4777813 9.85E-02 1, 24 EF Above-Average <1% 10102-44-0 BOIL2 CoGen Boiler (12 MMBTU) BOIL2 Point CoGen 1.6 175 0.46 9.64 15.5 9.1 647190 4777810 9.85E-02 1, 24 EF Above-Average <1% 10102-44-0 BOIL3 CoGen Boiler (12 MMBTU) BOIL3 Point CoGen 1.6 175 0.46 9.64 15.5 9.1 647192 4777807 9.85E-02 1, 24 EF Above-Average <1% 10102-44-0 BOIL4 CoGen Boiler (12 MMBTU) BOIL4 Point CoGen 1.6 175 0.46 9.64 15.5 9.1 647194 4777804 9.85E-02 1, 24 EF Above-Average <1% 10102-44-0 BOIL5&6 NG Boilers (10.124 MMBTU) BOIL5&6 Point CoGen 1.4 175 0.51 7.0159 20.7 4.6 647673 4777956 1.31E-01 1, 24 EF Above-Average <1% Particulate Matter PM 102A Dyno Room Cell #1 Engine Exhaust S102A Point RZ1E 3.1 38 0.46 18.65 9.86 2.9 647602 4778114 2.08E-02 24 EF Marginal 3% PM 102B Dyno Room Cell #4 Engine Exhaust S102B Point RZ1E 3.1 38 0.46 18.65 9.86 2.9 647597 4778124 2.50E-02 24 EF Marginal 4% PM 102C Dyno Room Cell #2 Engine Exhaust S102C Point RZ1E 3.1 38 0.46 18.65 9.86 2.9 647605 4778126 2.50E-02 24 EF Marginal 4% PM W4 Tool Grind Dust Collector W4 Volume RZ3W N/A N/A N/A N/A 11.19 1.00 647265 4778049 1.89E-01 24 EC Average 27% PM LFGGEN1 Landfill Gas-Fired Generator Set LFGGEN1 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647193 4777839 1.12E-01 24 EF Above-Average 16% PM LFGGEN2 Landfill Gas-Fired Generator Set LFGGEN2 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647193 4777833 1.12E-01 24 EF Above-Average 16% PM LFGGEN3 Landfill Gas-Fired Generator Set LFGGEN3 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647194 4777828 1.12E-01 24 EF Above-Average 16% PM LFGGEN4 Landfill Gas-Fired Generator Set LFGGEN4 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647194 4777824 1.12E-01 24 EF Above-Average 16% Carbon Monoxide 630-08-0 LFGGEN1 Landfill Gas-Fired Generator Set LFGGEN1 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647193 4777839 1.09E+00 0.5 EF Above-Average 25% 630-08-0 LFGGEN2 Landfill Gas-Fired Generator Set LFGGEN2 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647193 4777833 1.09E+00 0.5 EF Above-Average 25% 630-08-0 LFGGEN3 Landfill Gas-Fired Generator Set LFGGEN3 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647194 4777828 1.09E+00 0.5 EF Above-Average 25% 630-08-0 LFGGEN4 Landfill Gas-Fired Generator Set LFGGEN4 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647194 4777824 1.09E+00 0.5 EF Above-Average 25% Sulphur Dioxide 7446-09-5 LFGGEN1 Landfill Gas-Fired Generator Set LFGGEN1 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647193 4777839 1.06E-01 1, 24 EF Above-Average 25% 7446-09-5 LFGGEN2 Landfill Gas-Fired Generator Set LFGGEN2 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647193 4777833 1.06E-01 1, 24 EF Above-Average 25% 7446-09-5 LFGGEN3 Landfill Gas-Fired Generator Set LFGGEN3 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647194 4777828 1.06E-01 1, 24 EF Above-Average 25% 7446-09-5 LFGGEN4 Landfill Gas-Fired Generator Set LFGGEN4 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647194 4777824 1.06E-01 1, 24 EF Above-Average 25% Hydrogen Sulfide 7783-06-4 LFGGEN1 Landfill Gas-Fired Generator Set LFGGEN1 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647193 4777839 1.63E-03 0.17, 24 ST Highest 25% 7783-06-4 LFGGEN2 Landfill Gas-Fired Generator Set LFGGEN2 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647193 4777833 1.63E-03 0.17, 24 ST Highest 25% 7783-06-4 LFGGEN3 Landfill Gas-Fired Generator Set LFGGEN3 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647194 4777828 1.63E-03 0.17, 24 ST Highest 25% 7783-06-4 LFGGEN4 Landfill Gas-Fired Generator Set LFGGEN4 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647194 4777824 1.63E-03 0.17, 24 ST Highest 25% 1,1,2-Trichloroethane 79-00-5 LFGGEN1 Landfill Gas-Fired Generator Set LFGGEN1 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647193 4777839 1.86E-05 24 ST Highest 25% 79-00-5 LFGGEN2 Landfill Gas-Fired Generator Set LFGGEN2 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647193 4777833 1.86E-05 24 ST Highest 25% 79-00-5 LFGGEN3 Landfill Gas-Fired Generator Set LFGGEN3 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647194 4777828 1.86E-05 24 ST Highest 25% 79-00-5 LFGGEN4 Landfill Gas-Fired Generator Set LFGGEN4 Point CoGen 21.2 490 1.52 11.64 15.5 9.1 647194 4777824 1.86E-05 24 ST Highest 25% Nitrogen Oxides 10102-44-0 Total Total of all listed sources 1.78E+01 100% Particulate Matter PM Total Total of all listed sources 7.08E-01 100% Carbon Monoxide 630-08-0 Total Total of all listed sources 4.37E+00 100% Sulphur Dioxide 7446-09-5 Total Total of all listed sources 4.25E-01 100% Hydrogen Sulfide 7783-06-4 Total Total of all listed sources 6.52E-03 100% 1,1,2-Trichloroethane 79-00-5 Total Total of all listed sources 7.43E-05 100% 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.

6-1 Dispersion Modelling Input Summary Table RWDI Project 1100778 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 6.1.1 in the report. A meteorological data set consisting of five years (1996-2000) 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 6.1.2 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 6.1.3 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 6.1.4 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 6.1.5 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.

647250 647500 647750 648000! 4778550! 4778550! 4778050 4778050 4778300 4778300 4778800 4778800 BOIL5&6!( 4777800 LFGGEN1 LFGGEN2 LFGGEN3 LFGGEN4! BOIL1 BOIL2 BOIL3 BOIL4!(!(!(!(!(!(!(!(! 4777800!!!!!! 4777550 Legend!( Sources 4777550 Building Property Boundary Service Layer Credits: First Base Solutions Web Mapping Service - Niagara Region, 2010 0 50 100 150 m 647250 647500 647750 648000 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 #1100750 [ Drawn by: DJH Fig: 6-1a Approx. Scale: 1:4,000 Date Revised: Dec. 21, 2016

647100 647200 647300 647400 647500 647600 647700 647800 4778100 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 4778100 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 4778000 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 4778000 4777900 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 4777900 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 4777800 Legend!(!(!(!( HT=12.47m HT=10.01m HT=12.22m HT=4m 4777800!( Sources Building Property Boundary Service Layer Credits: First Base Solutions Web Mapping Service - Niagara Region, 2010 HT=4m 0 50 100 150 m 647100 647200 647300 647400 647500 647600 647700 647800 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 #1100750 True North Drawn by: [ Approx. Scale: DJH Fig: 1:2,000 6-1b Date Revised: Dec. 21, 2016

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

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 1.1.3 and 2.19, Schedule D, and Appendices 16.1.1 to 16.1.4). ** **

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 1.1.3 and 2.19, Schedule D, and Appendices 16.1.1 to 16.1.4). **

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

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 11. - 22 -

City of St. Catharines Zoning By-law December 16, 2013 4.2 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 -

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 -

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 -

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 -

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) 4.2.1 Footnote to Section 4.2 Uses and Zones a) Only permitted as an accessory use. - 27 -

City of St. Catharines Zoning By-law December 16, 2013 4.3 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 R1-1-14 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 14. - 28 -

sectton 5 ZONES

City of Thorold Gomprehensive Zoninq Bv-law 2140ß71 SEGTION 5: ZONES 5.1 Establishment of Zones 5.1.1 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 9 10 11 12 13 14 15 16 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 17 18 18A 19 20 21 22 INDUSTRIAL ZONES Prestige Office Zone Prestige lndustrial Zone Light lndustrial Zone Heavy lndustrialzone Dry lndustrialzone PO PI LI HI DI 23 24 25 26 27 INSTITUTIONAL ZONE lnstitutional Zone 28 OPEN SPACE ZONE Open Space Zone Environmental Conservation Zone OS EC 29 30 41

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-R3 31 314 318 31C 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 5.1.2 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. 5.1.3 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

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. 5.1.4 Holding zones are hereby established by the use of the symbol (H) as a suffix to the zone symbols in Sections 5.1.1 and 5.1.3. 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 7.15.1 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. 5.2 5.2.1 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 412 5.2.2 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: 5.3.1 Zone boundaries are indicated by heavy black lines 5.3.2 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

Citu of Thorold Comorehensive Zonino Bv-law 2140ß71 5.3.3 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. 5.3.4 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. 5.3.5 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. 5.3.6 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. 5.3.7 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. 5.3.8 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. 5.3.9 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. 5.3.10 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

Citv of Thorold Comprehensive Zoninq Bv-law 2140(97) 5.3.11 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 5.4.1 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

GM Facility to the Southwest