Appendix 1. Air Quality Management Plan

Appendix 1 Air Quality Management Plan

Air Quality Management Plan This Air Quality Management Plan (AQMP) has been developed for the Giscome Quarry and Lime Plant Project (the Project). The AQMP is a living document and will be updated as appropriate during the life of the Project. 1.0 PURPOSE AND SCOPE The purpose of the AQMP is to mitigate the potential impacts of air emissions generated during construction, operation, closure and post-closure phases of the Project. The plan will work in conjunction with other component environmental management plans. The plan has been developed in accordance with Condition 15 of the Environmental Assessment Certificate, as indicated in the table below. EAC Condition Number 15 EAC Condition The Holder must retain a QP to develop a plan for Air Quality Management. The plan must be developed in consultation with MOE, MEM, NHA and LTFN. The plan must include, at a minimum, the means by which the following will be addressed: Emissions monitoring and control; Ambient air quality monitoring: o Including, but not limited to, monitoring at sensitive receptor sites as determined in consultation with MOE; Meteorological monitoring; and Fugitive dust monitoring and mitigation. The plan must include at least the following: Documentation of specific mitigation measures and pollutionprevention strategies, and specific triggers and actions for the above plan components; Community engagement to report annually on air quality parameters and receive community feedback through the Community Advisory Committee; and The means by which monitoring and mitigation for metal contamination in fugitive dust for the purpose of protecting public health will be implemented including, but not limited to: o Those metals in Table B-1 of Appendix B in the Giscome Project Human Health Risk Assessment (PGL, July 2016); o Baseline monitoring; o A rationale for selection of ambient air quality thresholds used to determine protection of human health; and o Impacts of air emissions on harvested vegetation on and off the Project area. The Holder must provide the plan to EAO, MEM, NHA and MOE for review a minimum of 60 days prior to the planned commencement of Construction. The plan, and any amendments thereto, must be implemented throughout Construction and Operations under the supervision of a QP and to the satisfaction of EAO. Notes: EAO Environmental Assessment Office LTFN Lheidli T enneh First Nation MEM Ministry of Energy and Mines NHA Northern Health Authority MOE Ministry of Environment QP Qualified Professional Plan Reference Section 6.0 Effectiveness Monitoring Section 1.2 Community Engagement Section 5.0 Potential Sources and Project- Specific Mitigation Section 3.0 Performance Thresholds Page A1 1

1.1 Consultation As part of Graymont s ongoing consultation for the Project, Graymont has engaged with local community members, business people, recreationalists, First Nations and others to ensure that the Project meaningfully considers the potential for impacts on First Nations and stakeholders. Graymont initially consulted with a wide range of local and regional stakeholder groups in 2007 prior to the project being put on hold. In 2013, preliminary discussions were undertaken with the Regional District of Fraser Fort George (RDFFG) officials prior to finalization of the draft Project Description document. A community newsletter and public meetings in Willow River and Prince George in June 2013 introduced the project to local residents and led to a number of one-on-one meetings with local residents that were held in July and August 2013, prior to finalization of the draft Application Information Requirements. Public Consultation continued through the Application Review phase in accordance with Public Consultation Plan Graymont submitted to the Environmental Assessment Office under Section 11 Order. Additional information on the consultation process completed as part of the environmental assessment process are provided in: Lheidli T enneh First Nation Consultation Plan for the Proposed Giscome Quarry and Lime Plant: Submitted to the Environmental Assessment Office under Section 11 Order by Graymont Western Canada Ltd. December 10, 2013; Public Consultation Plan for the Proposed Giscome Quarry and Lime Plant: Submitted to the Environmental Assessment Office under Section 11 Order by Graymont Western Canada Ltd. December 10, 2013; First Nations Consultation Report, Giscome Quarry and Lime Plant, Giscome BC, September 2015; and Public Consultation Report, Giscome Quarry and Lime Plant, Giscome BC, September 2015 Draft versions of the management and monitoring plans were submitted to the Lheidli T enneh First Nation as part of the Environmental Assessment process for review and comment. Responses to comments are provided in the EAO s tracking table. 1.2 Community Engagement Graymont will develop a Community Advisory Committee in accordance with Condition 15 of the Environmental Assessment Certificate. The Committee will be: Comprised of at least three Graymont and three community representatives, and Formed at least 30 days prior to the start of Construction. The Committee will: Establish a terms of reference for the Committee prior to the start of Construction; Meet at least once per year during Construction and the first three years Operations. Subsequent meeting frequency must be determined by the terms of reference and agreed upon by all representatives; Receive Project related environmental performance information including but not limited to air quality, groundwater and surface water quality, wildlife interactions, visual mitigations, public access management, and noise management; and Provide a venue to address community concerns with a public grievance mechanism to track and revolve issues. Page A1 2

Graymont will include information discussed with the Community Advisory Committee and report on environmental performance as described above on a Project-specific webpage established at least 30 days prior to the start of Construction, updated at least annually and maintained throughout Project Construction, Operations, and Decommissioning. 2.0 REGULATORY REQUIREMENTS AND GUIDELINES Relevant guidance includes federal and provincial legislation and industry-standard best management practices (BMPs). Legislated measures are generally mandatory, whereas BMPs may be superseded by project-specific mitigation approaches that are tailored to the local circumstances. 2.1 Federal Federal legislation related to the protection and management of air quality relevant to this AQMP is described below. 2.1.1 Canadian Environmental Protection Act The Canadian Environmental Protection Act (CEPA) forms the basis for federal ambient air quality objectives. CEPA is aimed at preventing pollution and protecting the environment and human health and includes provisions to regulate vehicle, engine and equipment emissions. 2.2 Provincial Provincial legislation related to the protection and management of air quality relevant to this AQMP is described below. 2.2.1 Environmental Management Act The Environmental Management Act (BC EMA) forms the basis for provincial ambient air quality objectives. The BC EMA provides an authorization framework to protect human health and the quality of water, land and air in BC. Under BC EMA, Waste Discharge Regulations set forth the requirements for any industry, trade, business, activity, and operation to obtain authorization before introducing waste into the environment. British Columbia Ambient Air Quality Objectives (BC AQOs) are developed under BC EMA. The BC AQOs are non-statuary limits following Provincial Air Quality Objectives, the former Pollution Control Objectives (PCOs), National Ambient Air Quality Objectives (NAAQOs), Canadian Ambient Air Quality Standards (CAAQS) and Guidance on Application of Provincial Interim Air Quality Objectives for nitrogen dioxide (NO2) and sulphur dioxide (SO2) (last updated October 2014). Although the BC AQOs are non-statuary limits, the objectives for fine particulate (PM2.5), NO2 and SO2 are set to take consideration for protecting human health. 1 The Open Burning Smoke Control Regulation sets limits and describes practices for open burning of debris, including wood debris. However, no open burning will be permitted as part of the Project. 1 According to the New Ambient Air Quality Criteria for PM2.5: Development Process, available at http://www.bcairquality.ca/regulatory/pm25-development.html; and the interim Provincial AQOs available at: http://www.bcairquality.ca/reports/pdfs/interim-no2-so2aqos-implement-on-guide.pdf Page A1 3

2.3 Best Management Practices Guidelines and BMPs for air quality that will be considered for this Project include the following: Best Practices for the Reduction of Air Emissions from Construction and Demolition Activities (Cheminfo, 2005); Aggregate Operators Best Management Practices Handbook for British Columbia. Volume II Best Management Practices (BC MEM, 2002); Federal and Provincial Air Quality Objectives and Standards - Air Quality Objectives and Standards for British Columbia and Canada; and Pits and Quarries Guidance from Environment Canada (Environment Canada, 2015) 3.0 PERFORMANCE THRESHOLDS Background concentrations and BC Air Quality Objectives are shown below in Table 1 and the WHO guideline for mercury in Table 2. Table 1: BC Air Quality Objectives and Background Measurements for the Giscome Quarry and Lime Plant Pollutant Averaging Period BC AQ Objective Background 2 (µg/m 3 ) (µg/m 3 ) Dustfall 1 month Lower 1.7mg/(dm 2 -d) Upper 2.9mg/(dm 2 -d) - TSP 24-hour MDL 120 B 200 43.6 C 260 TSP Annual A 60 B 70 14.4 C 75 PM10 24-hour 50 27.1 PM2.5 3 24-hour 25 16.3 PM2.5 Annual 8 5.5 NO2 5, 1-hour 188 67.5 NO2 c, Annual 60 19.2 SO2 c 1-hour 200 2.1 CO 1-hour A 14,300 B 28,000 870 C 35,000 CO 8-hour A 5,500 B 11,000 C 14,300 815 Table 2: WHO Guideline 4 Pollutant Averaging Period WHO Guideline (µg/m3) Hg Annual 1 2 The background concentrations are presented in Table 1. 3 The PM 2.5 24-hour standard is assessed based on the annual 98th percentile value. The NO 2 1-hour standard is assessed based on the annual 98th percentile of daily 1-hour maximum values, and the SO 2 1-hour standard is assessed based on the annual 99th percentile of daily 1-hour maximum values. 4 Background concentrations for mercury are expected to be minimal; therefore, a background concentration was not requested by BC MOE (Trinity, 2015). Page A1 4

4.0 PERMITS AND APPROVALS The Project will require a Waste Discharge Authorization Air, under the BC EMA, which authorizes construction and operational discharges of air emissions into the environment. During construction, wood waste will not be disposed of by burning, therefore no permits under the EMA for open burning will be required. 5.0 POTENTIAL SOURCES AND PROJECT-SPECIFIC MITIGATION During construction, the main sources of air emissions will include ground disturbance, transportation of heavy construction equipment and other construction activities including operation of diesel-driven equipment. Common construction activities that result in combustion emissions contributing to greenhouse gases include mobile and stationary diesel and gas power equipment such as drills, excavators, crawler tractors, loaders, graders, cranes, concrete trucks, dump trucks, generators and welding equipment. Construction materials will also be transported to the site by rail. Locomotive emissions in Canada are regulated by Transport Canada and Environment Canada. Federal regulations require locomotives to use ultra-low-sulphur diesel fuel (less than 15mg/kg sulphur content). Primary pollutants expected from the construction phase are coarse particulate matter such as total suspended particulates (TSP) and particulate matter up to 10 micrometers in size (PM10), i.e. fugitive dust. Additionally, lesser levels of SO2, nitric oxide and nitrogen dioxide (NOX), volatile organic compounds (VOCs), and carbon monoxide (CO) emissions are expected from diesel fired equipment (greenhouse gases). Vegetation/slash burning can also contribute to poor air quality; however, there will be no open burning of vegetation during the Project s construction phase. Construction related impacts to air quality are generally short-term in duration, but may still contribute to poor air quality. Project construction is expected to be up to 18-24 months following issuance of permits. During operation the main source of air contaminants will be from point sources at the processing plant (e.g. sources emitting from a stack such as lime kilns and generators). The vertical kiln technology selected for the Project will make it one of the most efficient lime-producing facilities in the country, with an associated low emission intensity. Sources of air contaminants during operation will also include stationary and mobile diesel and gas powered equipment primarily associated with the operation of the quarry. During closure and post-closure the main sources of air emissions will be similar to those during the construction phase described above. This primarily includes diesel and gas powered equipment required to decommission the Project and carry out reclamation activities. To mitigate the impacts of greenhouse gas during construction, operation, closure and post closure, measures that will be implemented include: 1. Ensuring fleet vehicles and equipment are maintained according to manufacturer s guidelines. Vehicles and equipment will be inspected on a regular basis and maintained, as required. During construction the Independent Environmental Monitor (IEM) will inspect equipment for presence of emission control measures. 2. Using modern machinery and commercially available low sulphur fuels. 3. Minimizing engine idling. Page A1 5

4. Minimizing land clearing. 5. Implementing speed limits for mobile diesel equipment (refer to Traffic Management Plan (Appendix 12)). 6. Optimizing trucking loads to reduce the number of trips between the source and destination. Measures to eliminate or minimize fugitive dust are discussed below in the Section 5.1 Fugitive Dust Management. 5.1 Fugitive Dust Management Common activities that result in fugitive dust emissions include: excavation, pile driving, clearing, grubbing, aggregate handling, stockpiling, crushing, grading, compacting, paving, demolition of existing structures, and the use of vehicles and equipment. Fugitive dust is expected to originate from a number of sources including: Traffic along unpaved roads; Soil movement including grubbing, grading and re-contouring activities; and Wind erosion of soil stockpiles. During the construction, operation, closure and post closure phases of the Project fugitive dust will be managed by: 1. Using dust suppressants for dust control. Dust will be controlled for the duration of the construction phase a dust suppressant approved by Fisheries and Oceans Canada (DFO) and the Ministry of Environment. Oil will not be used as a dust suppressant. 2. Implementing speed limits to reduce the generation of fugitive dust emissions. 3. Covering vehicle loads of fine grained material, particularly on windy days, to minimize windblown dispersal. Several additional mitigation measures are proposed specifically for the operation phase: Dust collection systems will be installed at the crusher located at the quarry that will be equipped with pick-up points to collect any dust generated at various material handling points; Crushing, screening, and transfers at the limestone crushing process will be either partially enclosed or fully enclosed; Operations at the quarry will generally be limited to daylight working hours. This limitation will improve air concentrations from quarry operations, due to typically poor nighttime meteorological conditions; A baghouse will be installed at the crushing and screening facilities to further reduce dust emissions; A covered overland conveyor system was selected to move crushed limestone to the plant site rather than using haul trucks, to further reduce the generation of fugitive dust. Dust suppressant will be applied, as deemed necessary, on gravel roads within the quarry road system and at the plant site. Truck traffic (for onsite loading) will be kept to defined traffic lanes and these traffic lanes will be paved with asphalt over a two to three year period, which will minimize the generation of fugitive dust associated with traffic. Page A1 6

6.0 EFFECTIVENESS MONITORING During operation, an air quality monitoring program will be implemented and will include a continuous opacity monitoring system or a bag leak detection system at the lime kilns to ensure operational controls are in place. Both systems would operate continuously to ensure that particulate emissions from the baghouse stack do not exceed a given emission rate. A Project-wide ambient air monitoring program is also proposed to ensure that dust mitigation measures are effective. The monitoring program will include a PM2.5 monitor and a meteorological (MET) station to evaluate particulate data. A location for the PM2.5 monitor and the MET station has not been determined; however, a site at or near the Giscome Elementary School is currently being evaluated. The program will be initiated in conjunction with the installation of the first kiln and be maintained for a period of up to five years. Effectiveness monitoring will also partially rely on compliance with recommended mitigation measures or other commitments made by Graymont with respect to air quality management. Other commitments may include those outlined in the Environmental Assessment Certificate s Table of Conditions, or permit conditions. The IEM or operations supervisor will be responsible for documenting the measures used, as well as indicating where there are deficiencies. Visual dust events will be immediately acted upon by stopping the specific activity or applying dust suppressants. The air quality data from the air quality monitoring program will allow for the measurement of trends and the effectiveness of fugitive dust management measures. The IEM or operations supervisor is expected to monitor the mitigation measures implemented regularly and to communicate compliance or non-compliance, and or incidents with the appropriate regulatory authorities as may be necessary. 6.1 Communication During construction, the construction schedule and timing of specific construction activities will be communicated with adjacent land owners and regulatory agencies, as necessary. Communications will facilitate awareness of upcoming activities, and allow the local community and regulatory agencies to plan activities as appropriate. With respect to air quality, if a complaint is received and deemed legitimate and if it can be addressed immediately by safely stopping the specific activity or applying dust suppressants then this will be done under the direction of the construction manager or the operations supervisor. 7.0 GREENHOUSE GAS MONITORING The Project will result in an increase in Greenhouse Gas (GHG) emissions within the lime sector and increased provincial, and federal totals during all phases of the Project, despite the mitigation measures proposed. The BC Ministry of Environment requires reporting of GHG emissions over the 10 kilotonnes threshold per year. The Project GHG emissions will be monitored on an annual basis and reported to the MOE as required. A GHG Inventory Management Plan (IMP) will be developed specifically for the operation phase of the Project. The IMP will allow the quantification and reporting of GHG emissions inventories in accordance with the GHG accounting principles of completeness, consistency, comparability, transparency and accuracy and do so in a manner that is verifiable. Page A1 7

The IMP will provide details on: The identification of GHG emission sources from stationary and mobile fuel combustion and process-related activities at the Giscome plant; Various estimation approaches that are used to estimate the Giscome plant facility s GHG emissions and tools to help select the appropriate method for the Giscome plant; The GHG-related database management and retrieval systems specific to the Giscome plant facility; Aspects of uncertainty; Quality assurance / quality control (QA/QC); Verification; and Reporting of emissions information. The GHG IMP developed for the Project will be compliant with the British Columbia Greenhouse Gas Reduction (Cap and Trade) Act (GGRCTA) and follow the principles of the Western Climate Initiative (WCI), or Environment Canada (EC) guidelines where no WCI methods exist. 8.0 REFERENCES BC MEM [Ministry of Energy and Mines], 2002. Aggregate Operators Best Management Practices Handbook for British Columbia. Volume II Best Management Practices. April 2002. BC MOE [Ministry of Environment], 2009. Federal and Provincial Air Quality Objectives and Standards - Air Quality Objectives and Standards for British Columbia and Canada BC MOE [Ministry of Environment], 2015. BC Air Quality Accessed from: http://www.bcairquality.ca/topics/rail-emissions.html Cheminfo, 2005. Best Practices for the Reduction of Air Emissions from Construction and Demolition Activities (March, 2005). Available from: http://www.bieapfremp.org Environment Canada, 2015. Pits and Quarries Guidance from Environment Canada. Accessed from: https://www.ec.gc.ca/inrp-npri/ Trinity, 2015. Giscome Quarry and Lime Plant Project, Application for an Environmental Assessment Certificate, Section 8.2 Air Quality. Trinity, 2015. US Environmental Protection Agency, Emissions Factors & AP 42, Fifth Edition Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources Page A1 8