STRATEGY 4 INC. D-6 COMPATIBILITY ASSESSMENT...3267 Mainway, Burlington, Ontario WSP Canada Inc. was...

STRATEGY 4 INC.

D-6 COMPATIBILITY ASSESSMENT 3267 MAINWAY, BURLINGTON, ONTARIO

JANUARY 15, 2018

WSP Canada Inc.

D-6 COMPATIBILITY ASSESSMENT 3267 MAINWAY, BURLINGTON, ONTARIO

STRATEGY 4 INC. PROJECT NO.: 171-17445-00 DATE: JANUARY 15, 2018

WSP UNIT 2 126 DON HILLOCK DRIVE AURORA, ON, CANADA L4G 0G9 T: +1 905 750-3080 F: +1 905 727-0463 WSP.COM

WSP Canada Inc.

UNIT 2 126 DON HILLOCK DRIVE AURORA, ON, CANADA L4G 0G9 T: +1 905 750-3080 F: +1 905 727-0463 wsp.com

January 15, 2018

Strategy 4 Inc. 2620 Bristol Circle #1100 Oakville, Ontario L6H 6Z7

Attention: Jeff Kenny

Dear Sir:

Subject: D-6 Compatibility Assessment 3267 Mainway, Burlington, Ontario

WSP Canada Inc. was retained by Strategy 4 Inc. to complete a D-6 Compatibility Assessment for the proposed development located at 3267 Mainway in Burlington, Ontario as a result of the neighbouring residential and industrial facilities. It is understood that U-Haul International Inc. intends to develop the land for commercial purposes.

The study was conducted in accordance with the “Compatibility between Industrial Facilities and Sensitive Land Uses”, published by the Ontario Ministry of the Environment and Climate Change (MOECC) Guideline D-6.

This report summarizes the findings of the D-6 Compatibility Assessment of the surrounding area uses on the proposed development site.

Yours truly,

Paul Orchard Team Lead – Environment, Aurora

SC/nah WSP ref.: 171-17445-00

D-6 COMPATIBILITY ASSESSMENT Project No. 171-17445-00 Strategy 4 Inc.

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S I G N A T U R E S

PREPARED BY

Stephanie Clarke, B.A. Environmental Technician

REVIEWED BY

David Hofbauer, M.A.Sc., P.Eng. Senior Engineer - Environment

This report was prepared by WSP Canada Inc. for the account of Strategy 4 Inc., in accordance with the professional services agreement. The disclosure of any information contained in this report is the sole responsibility of the intended recipient. The material in it reflects WSP Canada Inc.’s best judgement in light of the information available to it at the time of preparation. Any use which a third party makes of this report, or any reliance on or decisions to be made based on it, are the responsibility of such third parties. WSP Canada Inc. accepts no responsibility for damages, if any, suffered by any third party as a result of decisions made or actions based on this report. This limitations statement is considered part of this report.

The original of the technology-based document sent herewith has been authenticated and will be retained by WSP for a minimum of ten years. Since the file transmitted is now out of WSP’s control and its integrity can no longer be ensured, no guarantee may be given with regards to any modifications made to this document.


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TABLE OF CONTENTS

1 INTRODUCTION ............................................. 1

2 PROPOSED DEVELOPMENT ........................ 1

2.1 Location .......................................................................... 1

2.2 Proposed On-Site Activities ......................................... 2

2.3 Industry Classification .................................................. 2

2.4 Minimum Separation Distance and Potential Area of Influence ......................................................................... 2

2.5 Meteorological Data ...................................................... 3

2.5.1 Prevailing Wind Direction ...................................................................... 4

2.5.2 Wind Direction from Site to Residential Receptors ............................... 4

3 EVALUATION OF SURROUNDING LAND USES .............................................................. 5

3.1 Existing Class I Facilities ............................................. 5

3.1.1 Lightning Fresh Ltd. ............................................................................... 5

3.1.2 Watson Building Supplies ...................................................................... 5

3.1.3 The Printing House ................................................................................ 6

3.1.4 Pell Insulation Drywall Ltd. .................................................................... 6

3.1.5 Taurus Industrial Sales Inc. ................................................................... 6

3.1.6 Allen Industrial Rubber Products 1988 Ltd. .......................................... 6

3.2 Existing Class II Facilities ............................................ 6

3.2.1 FibreCast Inc. ........................................................................................ 6

3.2.2 Thordon Bearings Inc. ........................................................................... 7

3.2.3 RPM Environment Ltd. .......................................................................... 7

3.2.4 L & A Diecrafts Ltd. ............................................................................... 7

3.2.5 McKellar Machine Products Ltd. ........................................................... 7

4 CONCLUSIONS AND RECOMMENDATIONS 7

5 REFERENCES ................................................ 9


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TABLES

TABLE 1-1 GUIDELINE D-6 RECOMMENDED MINIMUM SEPERATION DISTANCE AND POTENTIAL INFLUENCE AREAS FOR INDUSTRIAL LAND USES ................................................... 1

TABLE 2-1 WIND DATA FOR STATION #61587 .. 3 TABLE 2-2 PREVAILING WIND DATA 3267

MAINWAY, BURLINGTON .................. 4 TABLE 2-3 WIND DATA FROM SITE TO

RESIDENTIAL RECEPTORS .............. 4

FIGURES

FIGURE 1 ZONING MAP FIGURE 2 CONCEPTUAL SITE PLAN FIGURE 3 CLASS II RECOMMENDED

SEPARATION DISTANCES FIGURE 4 WINDROSE FIGURE 5 SUMMARY OF FACILITIES

APPENDICES

A INDUSTRIAL CLASS DEFINITIONS

B SUMMARY OF FACILITIES

C REGULATORY APPROVALS


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1 INTRODUCTION WSP was retained by Strategy 4 Inc. to prepare a D-6 Compatibility Assessment for the property located at 3267 Mainway in Burlington, Ontario (the ‘Site’).The proposed land use consists of an interior self storage warehouse and vehicle rental facility with ancillary uses. The ancillary uses include office with limited retail (sale of moving supplies), vehicle and trailer modification (installation of hitches occurring indoors) and propane dispensing. The existing building will be retrofit to accommodate these uses.The total site area is 3.35 ha (8.28 ac.).

The purpose of the study is to complete an Air Quality, Dust, and Odour Assessment of the proposed development and surrounding commercial and industrial land uses on the existing residential land uses. The study was conducted in accordance with the “Compatibility between Industrial Facilities and Sensitive Land Uses”, published by the Ontario Ministry of the Environment and Climate Change (MOECC) as Guideline D-6 (the ‘D-6 Guideline’).

This report describes the surrounding industrial and commercial facilities, specifically addressing the neighbouring businesses and industries within close proximity of the development site as having the highest potential to cause an adverse impact. Other surrounding facilities have been evaluated as part of this investigation and are outlined in the subsequent sections of this report. The assessment was based on readily available information (i.e. facility websites, environmental registry, aerial photography, etc.).

The objective of the D-6 Guideline is to prevent or minimize the encroachment of sensitive land use upon industrial land use and vice versa. These two land uses are generally accepted as being incompatible when in close proximity, due to possible adverse effects on sensitive land uses created by industrial operations. The D-6 Guideline categorizes industrial facilities into three classes according to their size, volume of operations, and nature of their emissions and defines sensitive land uses. The D-6 Guideline provides definitions and examples to illustrate the three Industrial Classes, provided in Appendix A. Facilities that do not meet the definition of any one of the three classes historically have little to no potential for creating nuisance issues that would give rise to complaints. The definitions and examples in the D-6 Guideline relevant to air quality concerns were used to characterize the nearby facilities. The D-6 Guideline defines a recommended minimum separation distance and potential influence area between industrial facilities and sensitive land uses for each class, presented in Table 1-1.

Table 1-1 Guideline D-6 Recommended Minimum Seperation Distance and Potential Influence Areas for Industrial Land Uses

INDUSTRY CLASSIFICATION RECOMMENDED MINIMUM SEPERATION DISTANCE (m)

POTENTIAL INFLUENCE AREA (m)

Class I – Light Industrial 20 70

Class II – Medium Industrial 70 300

Class III – Heavy Industrial 300 1000

2 PROPOSED DEVELOPMENT

2.1 LOCATION The proposed development is located at 3267 Mainway in Burlington, Ontario on the north side of Mainway between Northside Road and Pioneer Road. The zoning for the area of the development site is designated as general employment, and the area surrounding the proposed development is mixed use; including residential, general employment and open space. The total site area is 3.35 ha (8.28 ac.). A zoning map and site plan are shown as Figure 1 and Figure 2, respectively.


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2.2 PROPOSED ON-SITE ACTIVITIES The proposed land use consists of an interior self-storage warehouse and vehicle rental facility with ancillary uses. The ancillary uses include office with limited retail (sale of moving supplies), vehicle and trailer modification (installation of hitches occurring indoors) and propane dispensing. The office component of the property will serve both primary and ancillary uses on site. The self-storage warehouse comprises the largest use of gross floor area and is proposed to be located on the northeast side of the property. The self –storage warehouse will be open 24 h and will be accessible via key by customers who have rented a locker. The retail component of the development is proposed to be located on the south side of the property, north of Mainway and will include the retail sale of packing and moving supplies. A vehicle rental office will be located on the property along with a vehicle and equipment shunting lot on the west side of the property. The vehicle rental office will operate during daytime hours. The proposed development will also include a delivery and receiving area which will also serve as a vehicle bay for the modification of equipment such as trucks and trailers. A retail propane dispensing station is proposed to be located in the southwest corner of the property, north of Mainway, as close to the front of the property as the city by-law permits. The proposed propane dispensing station will serve the public to fill 20 lb BBQ propane cylinders, cylinders up to 100 lb, recreational vehicles, and automobiles. The annual throughput of propane is predicted to be 40 000 L per year. The proposed volume of propane is to be stored on site in one tank with a total capacity of 2000 US gal (water capacity).

2.3 INDUSTRY CLASSIFICATION Based on the proposed facility description the potential for air and noise impacts on the surrounding sensitive land uses exists. Sources of noise nuisance include vehicle traffic from customers accessing the retail, vehicle rental and propane dispensing station components of the proposed development during daytime hours. There is also potential for noise nuisance outside of daytime hours from vehicle traffic as a result of the self-storage warehouse being accessible by customers 24 h a day. Additional sources of potential noise nuisance include vehicle traffic from larger vehicles such as moving trucks and delivery trucks accessing the vehicle bay and equipment shunting area. Potential sources of air nuisance includes the propane dispensing station which has the potential to emit odour when in operation and vehicle emissions. According to the D-6 Guidelines, a Class II facility is one which noise outputs are occasionally audible off property, odour is frequent and occasionally intense, outside storage is permitted and the movement of products is frequent with the majority of movements occurring during the daytime hours. As a result, the proposed land use at 3267 Mainway in Burlington, Ontario has been classified as a Class II facility for the purpose of this study.

2.4 MINIMUM SEPARATION DISTANCE AND POTENTIAL AREA OF INFLUENCE

Based on the D-6 Guidelines for a Class II facility, the recommended minimum separation distance for air and noise sources is 70 m and the potential area of influence is 300 m. These recommended separation distances are shown in Figure 3. The existing portion of the proposed development is located approximately eight metres from the nearest residential receptor. Based on the proposed on-site activities and site plan, the area of potential air and noise sources is located on the west side of the property. This area of the proposed development will include the retail propane dispensing station, equipment shunting area and parking lots. The propane dispensing station is proposed to be located in the south corner of the property approximately 136 m southeast of the nearest residential receptor. As a result, the proposed location of the propane dispensing station meets the recommended minimum separation distance. The equipment shunting area is proposed to be located on the west side of the property approximately 30 m southeast of the nearest residential receptor. A parking lot to the west of the equipment shunting area has also been proposed for the property. This parking lot is located approximately 47 m southeast of the nearest residential receptor. Based on the D-6 Guidelines, the equipment shunting area and parking lot to the west do not meet the recommended minimum separation distance of 70 m for a Class II facility. An additional parking lot, referred to as


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‘Lot 3’ in the conceptual site plan, is located approximately 77 m southeast of the nearest residential receptor. Based on the recommended minimum separation distance of 70 m, this parking area does meet the minimum separation distance. Based on the recommended minimum separation distance of 70 m and the potential area of influence of 300 m, the proposed development has the potential to impact residential developments to the north, northwest, west, and southwest.

2.5 METEOROLOGICAL DATA Based on the proposed on site operations, the main odour impacts arise from the propane dispensing station and vehicle emissions located within the 300 m potential area of influence. The propane dispensing station is proposed to be located outside the recommended minimum separation distance. The equipment shunting area and one parking lot is proposed to be located inside the recommended minimum separation distance. Dust generators associated with the property are expected to be limited, and controlled by vehicle speed limits and paved parking areas and laneways.

Wind data averaged from 1996 - 2000 compiled from the Toronto Station (Station 61587) was analyzed and applied to the area in order to determine the frequency that the wind could contribute to nuisance issues such as fugitive dust and odour as potential concerns for the proposed development. A ‘blowing from’ wind rose was produced for the aforementioned years, the approximated data is included in Table 2-1. The ‘blowing from’ wind rose plot is included in this report as Figure 4.

Table 2-1 Wind Data for Station #61587

WIND BLOWING FROM FREQUENCY (%)

APPROXIMATE EQUIVILENT DAYS PER

YEAR

WSW 4.2 15

SW 3.1 11

SSW 2.0 7

S 1.8 7

SSE 2.7 10

SE 2.2 8

ESE 2.2 8

E 2.6 9

ENE 1.5 5

NE 1.2 4

NNE 1.3 5

N 4.3 16

NNW 5.3 19

NW 3.9 14

WNW 3.9 14

W 4.6 17

CALM 53.2 196


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2.5.1 PREVAILING WIND DIRECTION

According to Figure 4, the prevailing winds in the area of the proposed development are blowing from the north, north northwest, northwest, west northwest, west and west southwest. This area is comprised of residential developments which are located within the recommended minimum separation distance and potential area of influence.

Table 2-2 Prevailing Wind Data 3267 Mainway, Burlington



YEAR

N 4.3 16

NNW 5.3 19

NW 3.9 14

WNW 3.9 14

W 4.6 17

WSW 4.2 15

TOTAL 26.2 95

According to Table 2-2, the prevailing winds blow from the residential developments adjacent to the proposed development towards the Site 26.2 % of the time or 95 equivalent days per year. Based on the meteorological data, the location of the facility and the nature of the onsite operations, the facility is expected to have limited impact on the surrounding residential developments.

2.5.2 WIND DIRECTION FROM SITE TO RESIDENTIAL RECEPTORS

Table 2-3 Wind Data from Site to Residential Receptors



YEAR

S 1.8 7

SSE 2.7 10

SE 2.2 8

ESE 2.2 8

E 2.6 9

ENE 1.5 5

NE 1.2 4

TOTAL 14.2 51


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According to Table 2-3, the winds blow from the proposed development towards the adjacent residential receptors 14.2 % of the time or 51 equivalent days per year. Based on the meteorological data, which is based on 24 h periods for an entire year, the location of the facility and the nature of the onsite operations, the facility is expected to have limited impact on the surrounding residential developments. Impacts would be limited to when on site sources would operate, and when meteorological conditions could transport emissions from those sources (controlled speed, paved laneways and parking areas) to the receptors.

3 EVALUATION OF SURROUNDING LAND USES

Industrial facilities and sensitive land uses are typically incompatible due to possible adverse effects on sensitive land uses created by the industrial operations. In order to prevent or minimize the encroachment of the sensitive land uses the D-6 Guideline categorizes industrial facilities into three classes according to their size, volume of operations, and nature of their emissions and defines sensitive land uses.

The guideline outlines a recommended minimum separation distance and potential influence area between industrial facilities and sensitive land uses for each class as shown in Table 1-1. The minimum separation distance is the distance (property line to property line) between the incompatible development and the sensitive land use, wherein industry has the potential to adversely affect those contained in the area. The potential area of influence is a greater distance in which the industrial operations may have limited potential to adversely affect those contained in the area, depending on onsite operations. Additionally, the facilities that lie outside of their Class’s respective recommended minimum separation distance and potential area of influence are expected to have no potential for creating nuisance issues that would give rise to complaints.

In this assessment facilities of potential concern were analysed based on their on-site operations, proximity to nearby residential receptors, as well as any pertinent EASR or ECA. The approximate locations of these facilities is shown in Figure 5.

3.1 EXISTING CLASS I FACILITIES To determine the impact of the Site on the residential receptors, it is important to understand what other facilitates operate in the area and their current impacts. This section outlines other Class I facilities that operate in close proximity to the existing residential development.

3.1.1 LIGHTNING FRESH LTD.

Lightning Fresh Ltd. is a cleaning service specializing in the sanitation of sports equipment and is located at 1233 Northside Road in Burlington, Ontario. The facility is Class I for air and is located approximately 45 m from the nearest residential receptor, outside the recommended minimum separation distance but within the potential area of influence. As a result the facility may have limited impact on the existing residential development.

3.1.2 WATSON BUILDING SUPPLIES

Watson Building Supplies is a building materials supplier located at 3191 Mainway in Burlington, Ontario. On site activities at the facility include significant outdoor storage and operations The facility is Class I for air and noise and is located approximately 42 m from the nearest residential receptor, outside the recommended minimum separation distance but within the potential area of influence. As a result the facility may have limited impact on the existing residential development.


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3.1.3 THE PRINTING HOUSE

The Printing House is a commercial printing service located at 3285 Mainway in Burlington, Ontario and is a Class I facility for noise. The facility is located approximately nine meters from the nearest residential receptor, within the recommended minimum separation distance and potential area of influence and thus may have the potential to impact the existing residential development.

3.1.4 PELL INSULATION DRYWALL LTD.

Pell Insulation Drywall is a drywall contractor located at 3295 Mainway in Burlington, Ontario and is a Class I facility for air and noise. The facility is located approximately five meters from the nearest residential receptor, within the recommended minimum separation distance and potential area of influence. As a result, the facility may have potential to impact the existing residential development.

3.1.5 TAURUS INDUSTRIAL SALES INC.

Taurus Industrial Sales Inc. is a facility which distributes industrial machinery, equipment, supplies and hardware. The facility is located at 3327 Mainway in Burlington, Ontario and is a Class I facility for noise. The facility is located approximately five meters from the nearest residential receptor, within the recommended minimum separation distance and potential area of influence. As a result the facility may have the potential to impact the existing residential development.

3.1.6 ALLEN INDUSTRIAL RUBBER PRODUCTS 1988 LTD.

Allen Industrial Rubber Products 1988 Ltd. is a manufacturer of rubber, PTFE, and metallic gaskets. The facility is located at 3333 Mainway in Burlington, Ontario and is a Class I facility for air and noise. The facility is located approximately five meters from the nearest residential receptor, within the recommended minimum separation distance and potential area of influence. As a result, the facility may have the potential to impact the existing residential development.

3.2 EXISTING CLASS II FACILITIES To determine the impact of the Site on the residential receptors, it is important to understand what other facilitates operate in the area and their current impacts. This section outlines other Class II facilities that operate in close proximity to the existing residential development.

3.2.1 FIBRECAST INC.

FibreCast Inc. is a manufacturer refractory and clay building materials and provide to industrial sectors such as iron and steel, petrochemical, power generation, ceramic and glass, cement, and fabricators and contractors. The facility located at 3264 Mainway in Burlington is considered to be a Class II facility with respect to air and noise. It is located approximately188m from the nearest residential receptor, outside the recommended minimum separation distance, but within the potential area of influence. As a result, the facility may have an impact on the existing residential development.


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3.2.2 THORDON BEARINGS INC.

Thordon Bearings Inc. is a manufacturer of high performance bearings used for marine, pump, hydro-turbine, oil and other industries. Thordon Bearings Inc. is located at 3225 Mainway in Burlington, Ontario. The facility is considered a Class II facility for air and noise and is located approximately 13 m from the nearest residential receptor. The facility is located within the recommended minimum separation distance and potential zone of influence, thus may have the potential to impact the existing residential development. Thordon Bearings Inc. operates under an ECA for mixing and casting, adhesive bonding and curing, welding, and painting processes. A copy of the ECA for this facility is provided in Appendix C.

3.2.3 RPM ENVIRONMENT LTD.

RMP Environment Ltd. is a recycling facility specializing in the reuse of plastic containers such as drums, empty oil containers, pesticide containers, fertilizer containers, and paint containers which have been contaminated by hydrocarbons. Facility processes include receipt, sorting, grinding, washing and packaging. The facility is located at 3166 Mainway in Burlington, Ontario. It is a Class II facility for air and noise and is located approximately 200 m from the nearest residential receptor. The facility is located outside the minimum separation distance, however it is located within the potential area of influence and may have an impact on the existing residential development. RPM Environment Ltd. operates under an ECA and EASR. A copy of the ECA and EASR is provided in Appendix C.

3.2.4 L & A DIECRAFTS LTD.

L & A Diecrafts Ltd. is a manufacturer specializing in die cutting. The facility is located at 3179 Mainway in Burlington, Ontario. It is a Class II facility for air and noise and is located approximately 115 m from the nearest residential receptor, outside the recommended minimum separation distance but within the potential area of influence. As a result the facility may impact the existing residential development.

3.2.5 MCKELLAR MACHINE PRODUCTS LTD.

McKellar Machine Products Ltd. is a manufacturer specializing in turned product, screws, nuts, rivets and bolts. The facility is located at 3291 Mainway in Burlington, Ontario. It is a Class II facility for air and noise and is located approximately nine meters from the nearest residential receptor, within the recommended minimum separation distance and potential area of influence. As a result the facility may have potential to impact the existing residential development.

4 CONCLUSIONS AND RECOMMENDATIONS

Based on the proposed development at the Site and existing surrounding facilities the following conclusions and recommendations are outlined below:

— As outlined in Section 2.4 the proposed development is a Class II facility for air and noise. Based on the D-6 Guideline recommended minimum separation distance and potential area of influence the facility may have the potential to impact the existing residential developments to the north, northwest, west, and southwest;

— Based on the conceptual site plan, the proposed locations of the propane dispensing station and ‘Lot 3’ do meet the recommended minimum separation distance of 70 m. The proposed locations of the equipment shunting area and parking lot to the west do not meet the recommended minimum separation distance.


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— Thordon Bearings Inc. and McKellar Machine Products Ltd. are Class II facilities located within the recommended minimum separation distance and potential area of influence and may have the potential to already impact the surrounding residential development. FibreCast Inc., RPM Environment, and L & A Diecrafts Ltd. are Class II facilities located outside the recommended minimum separation distance but within the potential area of influence and may have potential to impact the surrounding residential developments. Currently there are no public issues with this area, suggesting that residential dwellings remain unaffected by existing facilities;

— The Printing House, Pell Insulation Drywall Ltd., Taurus Industrial Sales Inc. and Allen Industrial Rubber Products 1988 Ltd. are Class I facilities located within the recommended minimum separation distance and potential area of influence. These facilities may have potential to impact on the surrounding residential development. Lightning Fresh Ltd. and Watson Building Supplies are Class I facilities located outside the recommended minimum separation distance but within the potential area of influence. Based on their operations, these facilities are expected to have limited impacts on the surrounding residential development. Currently there are no public issues with this area, suggesting that residential dwellings remain unaffected by existing facilities;

Based upon the foregoing analysis, the proposed development is not anticipated to have an adverse impact on the residential dwellings as existing facilities do not have a publicly known impact. For residential dwellings located adjacent to the Site it is recommended that:

— A speed limit of 20 km/h be posted and enforced on paved parking areas and laneways to reduce off site impacts due to vehicle traffic;

— Propane refuelling operations be conducted by trained staff who are aware of procedures to prevent odour from being released from distribution/fuelling operations; and,

— The location of the equipment shunting area and parking lot to the west be relocated such that they meet the recommended minimum separation distance of 70 m from the nearest residential receptor property line.


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5 REFERENCES — Guideline D-6 (formerly 07-09), Compatibility Between Industrial Facilities and Sensitive Land Uses

FIGURES

WRPLOT View - Lakes Environmental Software

WIND ROSE PLOT:

COMMENTS:

Toronto Station #61587AERMET Version 14134

COMPANY NAME:

WSP

MODELER:

Carolyn Ropp

DATE:

12/13/2017

PROJECT NO.:

171-17445-00

NORTH

SOUTH

WEST EAST

1.2%

2.4%

3.6%

4.8%

6%

WIND SPEED (m/s)

>= 11.10

8.80 - 11.10

5.70 - 8.80

3.60 - 5.70

2.10 - 3.60

0.50 - 2.10

Calms: 0.00%

TOTAL COUNT:

43758 hrs.

CALM WINDS:

0.00%

DATA PERIOD:

Start Date: 1/1/1996 - 00:00End Date: 12/31/2000 - 23:59

AVG. WIND SPEED:

3.97 m/s

DISPLAY:

Wind SpeedDirection (blowing from)

Figure 4: Windrose Plot3267 Mainway, Burlington

APPENDIX

A INDUSTRIAL CLASS DEFINITIONS

wsp.com

DEFINITIONS OF CLASSES FROM GUIDELINE D-6

CLASS I INDUSTRIAL FACILITY

A place of business for a small scale, self-contained plant or building which produces and/or stores a product which is contained in a package and has a low probability of fugitive emissions for any of the following: noise, odour, dust, and/or vibration. There are daytime operations only, with infrequent movement of products and/or heavy trucks and no outside storage.

CLASS II INDUSTRIAL FACILITY

A place of business for medium scale processing and manufacturing with outdoor storage of wastes or material (i.e. it has an open process) and/or there are periodic outputs of minor annoyance. There are occasional outputs of either point source or fugitive emissions of any of the following: noise, odour, dust, and/or vibration, and low probability of fugitive emissions. Shift operations are permitted and there is frequent movement of products and/or heavy trucks during daytime hours.

CLASS III INDUSTRIAL FACILITY

A place of business for large scale manufacturing or processing, characterized by: large physical size, outside storage of raw and finished products, large production volumes and continuous movement of products and employees during daily shift operations. It has frequent outputs of major annoyance and there is a high probability of fugitive emissions.

APPENDIX

B SUMMARY OF FACILITIES

Table C-1: Summary of Facilities

ID# Facility Address Description of OperationsPotential

Issues

MOECC D-6IndustrialClass #

Approximate MinimumDistance from Site(Property Line to

Property Line) (m)

Approximate MinimumDistance from Residential

Area(Property Line to

Property Line) (m)

MOECC D-6Recommended

Minimum SeparationDistance (m)

MOECC D-6Potential

Area of Influence(m)

A1 FibreCast Inc. 3264 Mainway Manufacturer Air, Noise II 22 188 70 300A2 Thordon Bearings Inc. 3225 Mainway Manufacturer Air, Noise II 0 13 70 300A3 RPM Environment 3166 Mainway Plastic Recycling Facility Air, Noise II 290 200 70 300A4 Lightning Fresh Ltd. 1233 Northside Road Sports Equipment Cleaner Air I 210 45 20 70A5 L & A Diecrafts Ltd. 3179 Mainway Manufacturer Air, Noise II 212 115 70 300A6 WSB Titan 3191 Mainway Building Materials Supplier Noise I 115 42 20 70A7 McKellar Machine Products Ltd. 3291 Mainway Manufacturer Air, Noise II 9 9 70 300A8 The Printing House 3285 Mainway Commercial Printing Noise I 48 9 20 70A9 Pell Insulation Drywall Ltd. 3295 Mainway Contractor Air, Noise I 108 5 20 70A10 Taurus Industrial Sales Inc. 3327 Mainway Distribution Centre Noise I 108 5 20 70A11 Allen Industrial Rubber Products 1988 Ltd. 3333 Mainway Manufacturer and Distribution Air, Noise I 108 5 20 70

APPENDIX

C REGULATORY APPROVALS

Content Copy Of Original

Ministry of the Environment and Climate Change Ministère de l’Environnement et de l’Action en matière de changement

climatique

AMENDMENT TO ENVIRONMENTAL COMPLIANCE APPROVAL NUMBER 6922-96UNVK

Notice No. 1 Issue Date: February 8, 2017

RPM Environnement Ltée 50 Marius-Warnett St, No. 101 Blainville, Quebec J7C 5P9

Site Location: RPM Environment Ltd. 3166 Mainway Burlington City, Regional Municipality of Halton

You are hereby notified that I have amended Approval No. 6922-96UNVK issued on May 13, 2013 for 0.4 ha waste disposal site (transfer/processing) to be used for the transfer and processing of thefollowing types of waste: municipal special waste limited to empty oil and antifreeze containers and other containers; andresidual oil and antifreeze waste class no. 254 as per conditions of this Approval , as follows:

I. The following Definition is hereby added: " Other Containers " mean empty plastic containers (drums, totes and other types) having reachedtheir end of life and are accepted at the Owner's Burlington facility and transferred to the Owner'sQuebec facility. Those containers will come from a variety of recuperation centres of plastic andprogram's like : Stewardship Ontario box program, RTQ, Safety Kleen, Terrapure, Clean Farms andGFL. All containers are empty and clean of original content. II. The following Conditions are hereby revoked and replaced with: Financial Assurance 7.0 Within twenty (20) days of issuance of this Approval, the Owner shall submit to the Director financial assurance as defined in Section 131 of the EPA, in the amount of $2,450.00 for the totalFinancial Assurance of $19,450.00 . This financial assurance shall be in a form acceptable to theDirector and shall provide sufficient funds for the analysis, transportation, Site clean-up, monitoringand disposal of all quantities of waste on the Site at any one time. 7.1 Commencing on March 31, 2020 and at intervals of three (3) years thereafter, the Owner shallsubmit to the Director, a re-evaluation of the amount of financial assurance to implement the actionsrequired under Condition 7.0. The re-evaluation shall include an assessment based on any newinformation relating to the environmental conditions of the Site and shall include the costs of additionalmonitoring and/or implementation of contingency plans required by the Director upon review of theclosure plan and annual reports. The financial assurance must be submitted to the Director withintwenty (20) days of written acceptance of the re-evaluation by the Director. 7.2 Commencing on March 31, 2018, the Owner shall prepare and maintain at the Site an updatedre-evaluation of the amount of financial assurance required to implement the actions required under

Condition 7.0 for each of the intervening years in which a re-evaluation is not required to be submittedto the Director under Condition 7.1. The re-evaluation shall be made available to the Ministry uponrequest. 7.3 The amount of financial assurance is subject to review at any time by the Director and may beamended at his/her discretion. If any financial assurance is scheduled to expire or notice is received,indicating Financial Assurance will not be renewed, and satisfactory methods have not been made toreplace the financial assurance at least sixty (60) days before the financial assurance terminates, thefinancial assurance shall forthwith be replaced by cash. Approved Waste Types, Quantities and Activities 11.0 This Site is approved for the receipt, transfer and processing of the following types of waste: (a) municipal special waste limited to empty oil and antifreeze containers and Other Containers ; and (b) residual oil and antifreeze waste class no. 254 as described in the Ministry of the Environment's"New Ontario Waste Classes" document dated January 1986, as amended from time to time. 11.4 The Owner shall ensure that: (a) the maximum amount of waste accepted at the Site shall not exceed 20 tonnes per day; (b) the maximum amount of waste ( unprocessed waste, processed waste ) stored on Site shall notexceed 90 tonnes at any one time;

(c) the maximum amount of residual oil and antifreeze waste stored or be present at the Site shall notexceed 10,000 litres at any one time. III. The following items are hereby added to Schedule "A":

5. Application for an amendment to ECA No. 6922-96UNVK (Waste Disposal Site) dated September12, 2016 and signed by Dominic Payette, President, RPM Environnement Ltée including Design andOperations Report dated August 9, 2012 and all supporting information. 6. Revised Design and Operations Report dated December 2016, updated floor plan and financialassurance calculation received by emails on December 14, 2016 and December 19, 2016 fromChristian Lauzon, General Manager, RPM Environnement Ltée. 7. Updated FA calculation received by email dated December 21, 2016 from Christian Lauzon,General Manager, RPM Environnement Ltée.

The reasons for this amendment to the Approval are as follows: The reason for Conditions 11.0 and 11.4 is to update waste types and waste amounts accepted at thesite based on the Owner’s application and supporting documentation. The reason for Conditions 7.0, 7.1, 7.2 and 7.3 is to ensure that sufficient funds are available to theMinistry to clean up the Site in the event that the Owner is unable or unwilling to do so.

This Notice shall constitute part of the approval issued under Approval No. 6922-96UNVK dated May 13, 2013.

In accordance with Section 139 of the Environmental Protection Act, you may by written Notice servedupon me, the Environmental Review Tribunal and in accordance with Section 47 of the EnvironmentalBill of Rights, 1993 , S.O. 1993, c. 28 (Environmental Bill of Rights), the Environmental Commissioner,within 15 days after receipt of this Notice, require a hearing by the Tribunal. The EnvironmentalCommissioner will place notice of your appeal on the Environmental Registry. Section 142 of theEnvironmental Protection Act provides that the Notice requiring the hearing shall state: 1. The portions of the environmental compliance approval or each term or condition in theenvironmental compliance approval in respect of which the hearing is required, and; 2. The grounds on which you intend to rely at the hearing in relation to each portion appealed. Pursuant to subsection 139(3) of the Environmental Protection Act, a hearing may not be required withrespect to any terms and conditions in this environmental compliance approval, if the terms andconditions are substantially the same as those contained in an approval that is amended or revoked bythis environmental compliance approval. The Notice should also include: 3. The name of the appellant; 4. The address of the appellant; 5. The environmental compliance approval number; 6. The date of the environmental compliance approval; 7. The name of the Director, and; 8. The municipality or municipalities within which the project is to be engaged in. And the Notice should be signed and dated by the appellant. This Notice must be served upon:

The Secretary* Environmental ReviewTribunal 655 Bay Street, Suite1500 Toronto, Ontario M5G 1E5

AND

The EnvironmentalCommissioner 1075 Bay Street, Suite605 Toronto, Ontario M5S 2B1

AND

The Director appointed for thepurposes of Part II.1 of theEnvironmental Protection Act Ministry of the Environment andClimate Change 135 St. Clair Avenue West, 1stFloor Toronto, Ontario M4V 1P5

* Further information on the Environmental Review Tribunal’s requirements for an appeal canbe obtained directly from the Tribunal at: Tel: (416) 212-6349, Fax: (416) 326-5370 orwww.ert.gov.on.ca This instrument is subject to Section 38 of the Environmental Bill of Rights, 1993, that allows residentsof Ontario to seek leave to appeal the decision on this instrument. Residents of Ontario may seekleave to appeal within 15 days from the date this decision is placed on the Environmental Registry. Byaccessing the Environmental Registry at www.ebr.gov.on.ca , you can determine when the leave toappeal period ends. The above noted activity is approved under s.20.3 of Part II.1 of the Environmental Protection Act.

DATED AT TORONTO this 8th day of February, 2017Dale Gable, P.Eng. Director appointed for the purposes of Part II.1 ofthe Environmental Protection Act

MC/ c: District Manager, MOECC Halton-Peel Patrice Frechette, RPM Environnement Ltée

Ministère de l'Environnement et de l'Action en matière de changement climatique

Division des opérations

RPM Environnement

3166 MAINWAY

BURLINGTON ON L7M 1A5

3166 MAINWAY BURLINGTON ON L7M 1A5

Les renseignements liés à l’activité fournis à l’enregistrement sont inclus dans la confirmation de l’enregistrement comme annexe 'A'.

Vous avez enregistré, conformément à l’alinéa 20.21(1)(a) de la Loi sur la protection de l'environnement , l’utilisation, l’exploitation, l’établissement, la

modification, engagement ou l’extension ou le remplacement d’un système de gestion des déchets au service de la province de l’Ontario. le Système de

gestion des déchets parc de stockage lié à cet enregistrement est situé au

en date du mai 19, 2016

Directeur

Direction de l’accès aux autorisations environnementales et de l’intégration des services


135, avenue St. Clair Ouest, rez-de-chaussée

Toronto (Ontario) M4V 1P5

Veuillez adresser toute question liée à cet enregistrement et au Registre environnemental des activités et des secteurs aux coordonnées suivantes:


Représentant du service à la clientèle

Téléphone : 416 314-8001

Direction de l’accès aux autorisations environnementales et de l’intégration des services

Sans frais : 1 800 461-6290

Confirmation de l'enregistrement

Numéro de la version: 001

Numéro de l'enregistrement: R-004-2595900467

Date de l'enregistrement: mai 19, 2016 10:43:16 AM

Monsieur/Madame,

Veuillez prendre note que le Système de gestion des déchets est assujetti aux dispositions applicables du O.Reg 245/11 et O. Reg. 351/12.

Annexe 'A'

Partie 3 . Renseignements sur les activités

3.1 Le présent formulaire doit être utilisé pour enregistrer des activités liées à l'utilisation, à l'exploitation, àla mise en place, à la modification, à la prolongation ou au remplacement d'un système de gestion desdéchets qui est un système de transport des déchets. Veuillez confirmer que vous exercerez une ouplusieurs de ces activités.

Oui Non

3.2 Pour le système de gestion des déchets qui est assujetti au présent enregistrement, veuillez confirmer que TOUTES les affirmationssuivantes s.appliquent :

(a) Le système de gestion des déchets s'occupe seulement de la collecte, de la manutention, du transportet du transfert des déchets par un véhicule de transport des déchets (camion).

Oui Non

(b) Le système de gestion des déchets ne s'occupe pas du traitement des déchets sur camion. Oui Non

3.3 Le système de gestion des déchets s'occupe-t-il de la gestion de l'un ou l'autre des types de déchets suivants (tels qu'ils sont définis ausens du Règlement 347 de la Loi sur la protection de l'environnement, ou dans le cas des déchets biomédicaux ou de déchetsbiomédicaux traités, des Lignes directrices C-4 du ministère de l'Environnement . Gestion des déchets biomédicaux en Ontario)?

(a) Déchets dangereux* Oui Non

(b) Déchets industriels liquides Oui Non

(c) Déchets biomédicaux ou déchets biomédicaux traités Oui Non

(d) Déchets d'amiante Oui Non

* Veuillez noter qu.il faut interpréter comme étant des déchets dangereux les déchets qui étaient des déchets caractéristiques, mais qui ontété traités de sorte qu'ils ne sont plus des déchets caractéristiques, à condition que lesdits déchets ne puissent pas être éliminés par miseen décharge en vertu du paragraphe 79(1) du règlement 347 des Règlements refondus de l'Ontario de 1990 pris en application de la Loi.

3.4 Veuillez choisir dans le tableau ci-dessous toutes les catégories de déchets qui seront transportés par le système. Notez que lesréponses données à la question 3 ci-dessus doivent être véridiques pour l'une ou l'autre des catégories de déchets choisis.

(a) Matières recueillies au moyen des boîtes bleues

(b) Ordures ménagères

(c) Matériaux collectés à l'occasion du nettoyage des puisards

(d) Déchets provenant des opérations de préparation / de transformation des aliments

(e) Feuilles / résidus de jardin

(f) Pneus

(g) Déchets commerciaux

(h) Déchets de bois

(i) Eaux usées de lavage

(j) Déchets industriels solides non dangereux

(k) Sol contaminé

(l) Déchets organiques transformés

(m) Eaux d.égout transportées

of 5Page 31005E (2012/10)

(n) Matériel de nettoyage des déversements non dangereux

(o) Décrivez les autres types de déchets gérés par le système, le cas échéant :

3.5 Les déchets seront-ils conservés ou transférés à un parc de remisage de camions ou à un autreemplacement dans le cadre de l'exploitation du système de gestion des déchets?

Oui Non

3.6 (a) Combien de véhicules de transport des déchets (camions) compte le système de gestion desdéchets?

3

(b) Le système de gestion des déchets s'occupe-t-il du transport des déchets à l.intérieur ou à l.extérieurde l'Ontario?

Oui Non

(c) Veuillez indiquer le territoire de compétence à partir duquel le ou les véhicules de transport des déchets entrent / sortent normalementde l'Ontario.Veuillez cocher toutes les cases applicables :

Québec Entrée du Sortie vers

Manitoba Entrée du Sortie vers

New York Entrée du Sortie vers

Michigan Entrée du Sortie vers

Minnesota Entrée du Sortie vers

(d) Veuillez énumérer tous les territoires de compétence dans lesquels les déchets sont transférés vers un site d.entreposage oud'élimination à l'extérieur de l'Ontario.Veuillez cocher toutes les cases applicables :

Alberta Colombie-Britannique Manitoba Nouveau-Brunswick Terre-Neuve

Nouvelle-Écosse Territoires du Nord- Nunavut Île-du-Prince-Édouard Québec

Saskatchewan Yukon Alaska Alabama Arkansas

Arizona Californie Colorado Connecticut Delaware

Floride Géorgie Iowa Idaho Illinois

Indiana Kansas Kentucky Louisiane Massachusetts

Maryland Maine Michigan Minnesota Missouri

Mississippi Montana Caroline du Nord Dakota du Nord Nebraska

Nevada New Hampshire New Jersey Nouveau-Mexique New York

Ohio Oklahoma Oregon Pennsylvanie Rhode Island

Caroline du Sud Dakota du Sud Tennessee Texas Utah

Virginie Vermont Washington Wisconsin Virginie-Occidentale

Wyoming Hawaii

of 5Page 41005E (2012/10)

Content Copy Of Original

Ministry of the Environment Ministère de l’Environnement

ENVIRONMENTAL COMPLIANCE APPROVAL NUMBER 6182-9MPGAN

Issue Date: March 26, 2015

Thomson-Gordon Group Inc. 3225 Mainway Dr. Burlington, Ontario L7M 1A6

Site Location: 3225 Mainway Dr. Burlington City, Regional Municipality of Halton L7M 1A6

You have applied under section 20.2 of Part II.1 of the Environmental Protection Act , R.S.O. 1990, c.E. 19 (Environmental Protection Act) for approval of: Description Section

A non-metallic liquid cast elastomer products and speciality lubricant products manufacturing facility,consisting of the following processes and support units:

- Mixing and casting;

- Adhesive bonding and curing;

- Welding and painting;

including the Equipment and any other ancillary and support processes and activities, operating at aFacility Production Limit of up to 453,592 kilograms of finished products per year discharging tothe air as described in the Original ESDM Report.

For the purpose of this environmental compliance approval, the following definitions apply: 1. " Acceptable Maximum Ground Level Concentration" means a concentration accepted by theMinistry, as described in the Guide to Applying for Approval (Air & Noise), for a Compound of Concernlisted in the Original ESDM Report that: (a) has no Ministry Point of Impingement Limit and no Jurisdictional Screening Level, or (b) has a concentration at a Point of Impingement that exceeds the Jurisdictional Screening Level.2. "Acoustic Assessment Report" means the report, prepared in accordance with Publication NPC-233 and Appendix A of the Basic Comprehensive User Guide, by Corey Kinart P.Eng., of HGCEngineering and dated January 31, 2013 submitted in support of the application, that documents allsources of noise emissions and Noise Control Measures present at the Facility and includes all up-dated Acoustic Assessment Reports as required by the Documentation Requirements conditions ofthis Approval to demonstrate continued compliance with the Performance Limits following theimplementation of any Modification.

3. "Acoustic Assessment Summary Table" means a table prepared in accordance with the BasicComprehensive User Guide summarising the results of the Acoustic Assessment Report, up-dated as

required by the Documentation Requirements conditions of this Approval.

4. "Air Standards Manager" means the Manager, Human Toxicology and Air Standards Section,Standards Development Branch, or any other person who represents and carries out the duties of theManager, Human Toxicology and Air Standards Section, Standards Development Branch, as thoseduties relate to the conditions of this Approval.

5. "Approval" means this entire Environmental Compliance Approval and any Schedules to it.

6. "Basic Comprehensive User Guide" means the Ministry document titled "Basic ComprehensiveCertificates of Approval (Air) User Guide” dated March 2011, as amended.

7. "Company" means Thomson-Gordon Group Inc. that is responsible for the construction or operationof the Facility and includes any successors and assigns in accordance with section 19 of the EPA.

8. "Compound of Concern" means a contaminant that, based on generally available information, maybe discharged to the air in a quantity from the Facility that: (a) is non-negligible in accordance with section 26(1)4 of O. Reg. 419/05 in comparison to the relevantMinistry Point of Impingement Limit; or (b) if a Ministry Point of Impingement Limit is not available for the compound, may cause an adverseeffect at a Point of Impingement based on generally available toxicological information.

9. "Description Section" means the section on page one of this Approval describing theCompany's operations and the Equipment located at the Facility and specifying the Facility ProductionLimit for the Facility.

10. "Director" means a person appointed by the Minister pursuant to section 5 of the EPA.

11. "District Manager" means the District Manager of the appropriate local district office ofthe Ministry, where the Facility is geographically located.

12. "Emission Summary Table" means the most updated table contained in the ESDM Report, which isprepared in accordance with section 26 of O. Reg. 419/05 and the Procedure Document listing theappropriate Point of Impingement concentration for each Compound of Concern from the Facility andproviding comparison to the corresponding Ministry Point of Impingement Limit orMaximum Concentration Level Assessment, or Jurisdictional Screening Level.

13. "Environmental Assessment Act" means the Environmental Assessment Act, R.S.O. 1990, c.E.18,as amended.

14. "EPA" means the Environmental Protection Act, R.S.O. 1990, c.E.19, as amended.

15. "Equipment" means equipment or processes described in the ESDM Report, this Approval and inthe Schedules referred to herein and any other equipment or processes.

16. "Equipment with Specific Operational Limits" means any Equipment related to the thermaloxidation of waste or waste derived fuels, fume incinerators or any other Equipment that is specificallyreferenced in any published Ministry document that outlines specific operational guidance that must beconsidered by the Director in issuing an Approval.

17. "ESDM Report" means the most current Emission Summary and Dispersion Modelling Report thatdescribes the Facility. The ESDM Report is based on the Original ESDM Report, is prepared after theissuance of this Approval in accordance with section 26 of O. Reg. 419/05 and the ProcedureDocument by the Company or its consultant.

18. "Facility" means the entire operation located on the property where the Equipment is located.

19. "Facility Production Limit" means the production limit placed by the Director on the main product(s)or raw materials used by the Facility.

20. "Jurisdictional Screening Level" means a screening level for a Compound of Concern that is listedin the Ministry publication titled "Jurisdictional Screening Level (JSL) List, A Screening Tool for OntarioRegulation 419: Air Pollution - Local Air Quality", dated February 2008, as amended.

21. "Log" means the up-to-date log that is used to track all Modifications to the Facility since the dateof this Approval as required by the Documentation Requirements conditions of this Approval.

22. "Maximum Concentration Level Assessment" means the Maximum Concentration LevelAssessment for the purposes of an Approval, described in the Basic Comprehensive UserGuide, prepared by a Toxicologist using currently available toxicological information, thatdemonstrates that the concentration at any Point of Impingement for a Compound of Concern thatdoes not have a Ministry Point of Impingement Limit is not likely to cause an adverse effect as definedby the EPA.

23. "Ministry" means the ministry of the government of Ontario responsible for the EPA and itsregulations and includes all officials, employees or other persons acting on its behalf.

24. "Ministry Point of Impingement Limit" means the applicable Standard set out in Schedule 2 or 3 ofO.Reg. 419/05 or a limit set out in the Ministry publication titled "Summary of Standards andGuidelines to support Ontario Regulation 419: Air Pollution - Local Air Quality (including Schedule 6 ofO. Reg. 419 on Upper Risk Thresholds)", dated April 2012, as amended.

25. "Modification" means any construction, alteration, extension or replacement of any plant, structure,equipment, apparatus, mechanism or thing, or alteration of a process or rate of production at theFacility that may discharge or alter the rate or manner of discharge of a Compound of Concern to theair or discharge or alter noise or vibration emissions from the Facility.

26. "Noise Control Measures" means measures to reduce the noise emissions from the Facility and/orEquipment including, but not limited to, silencers, acoustic louvres, enclosures, absorptive treatment,plenums and barriers.

27. "O. Reg. 419/05" means the Ontario Regulation 419/05, Air Pollution – Local Air Quality, asamended.

28. "Original ESDM Report" means the Emission Summary and Dispersion Modelling Report whichwas prepared in accordance with section 26 of O. Reg. 419/05 and the Procedure Document byORTECH Environmental and dated January 31, 2013 submitted in support of the application, andincludes any changes to the report made up to the date of issuance of this Approval.

29. "Performance Limits" means the performance limits specified in Condition 3.2 of this Approval titledPerformance Limits.

30. "Point of Impingement" has the same meaning as in section 2 of O. Reg. 419/05.

31. "Point of Reception" means Point of Reception as defined by Publication NPC-205.

32. "Procedure Document" means Ministry guidance document titled "Procedure for Preparing anEmission Summary and Dispersion Modelling Report" dated March 2009, as amended.

33. "Processes with Significant Environmental Aspects" means the Equipment which, during regularoperation, would discharge a contaminant or contaminants into the air at an amount which is notconsidered as negligible in accordance with section 26(1)4 of O. Reg. 419/05 and the ProcedureDocument.

34. "Publication NPC-205" means the Ministry Publication NPC-205, “Sound Level Limits for

Stationary Sources in Class 1 & 2 Areas (Urban)”, October, 1995, as amended.

35. "Publication NPC-207" means the Ministry draft technical publication “Impulse Vibration inResidential Buildings”, November 1983, supplementing the Model Municipal Noise Control By-Law,Final Report, published by the Ministry, August 1978, as amended.

36. "Publication NPC-233" means the Ministry Publication NPC-233, "Information to be Submitted forApproval of Stationary Sources of Sound", October, 1995, as amended.

37. "Schedules" means the following schedules attached to this Approval and forming part of thisApproval namely: Schedule A - Supporting Documentation;

38. "Toxicologist" means a qualified professional currently active in the field of risk assessment andtoxicology that has a combination of formal university education, training and experience necessary toassess contaminants.

39. "Written Summary Form" means the electronic questionnaire form, available on theMinistry website, and supporting documentation, that documents the activities undertaken at theFacility in the previous calendar year that must be submitted annually to the Ministry as required by thesection of this Approval titled Reporting Requirements.

You are hereby notified that this environmental compliance approval is issued to you subject to theterms and conditions outlined below: TERMS AND CONDITIONS 1. GENERAL1.1 Except as otherwise provided by this Approval, the Facility shall be designed, developed, built,operated and maintained in accordance with the terms and conditions of this Approval and inaccordance with the following Schedules attached hereto:

Schedule A - Supporting Documentation

2. LIMITED OPERATIONAL FLEXIBILITY2.1 Pursuant to section 20.6(1) of the EPA and subject to Conditions 2.2 and 2.3 of thisApproval, future construction, alterations, extensions or replacements are approved in this Approval ifthe future construction, alterations, extensions or replacements are Modifications to the Facility that:

(a) are within the scope of the operations of the Facility as described in the Description Section of thisApproval;

(b) do not result in an increase of the Facility Production Limit above the level specified in theDescription Section of this Approval; and

(c) result in compliance with the Performance Limits.

2.2 Condition 2.1 does not apply to:

(a) the addition of any new Equipment with Specific Operational Limits or to the Modification of anyexisting Equipment with Specific Operational Limits at the Facility; or

(b) Modifications to the Facility that would be subject to the Environmental Assessment Act.

2.3 Condition 2.1 of this Approval shall expire ten (10) years from the date of this Approval, unless thisApproval is revoked prior to the expiry date. The Company may apply for renewal of Condition 2.1 ofthis Approval by including an ESDM Report and an Acoustic Assessment Report that describes theFacility as of the date of the renewal application.

3. REQUEST FOR MAXIMUM CONCENTRATION LEVEL ASSESSMENT AND PERFORMANCELIMITS

3.1 REQUEST FOR MAXIMUM CONCENTRATION LEVEL ASSESSMENT

3.1.1 If the Company proposes to make a Modification to the Facility, the Company shall determine ifthe proposed Modification will result in:

(a) a discharge of a Compound of Concern that was not previously discharged; or

(b) an increase in the concentration at a Point of Impingement of a Compound of Concern.

3.1.2 If a proposed Modification mentioned in Condition 3.1.1 will result in the discharge of aCompound of Concern that was not previously discharged, the Company shall submit a MaximumConcentration Level Assessment to the Director for review by the Air Standards Manager in thefollowing circumstances:

(a) The Compound of Concern does not have a Ministry Point of Impingement Limit or a JurisdictionalScreening Level.

(b) The Compound of Concern does not have a Ministry Point of Impingement Limit and theconcentration at a Point of Impingement will exceed the Jurisdictional Screening Level.

(c) Prior to the proposed Modification, a contaminant was discharged in a negligible amount and theproposed Modification will result in the discharge of the contaminant being considered a Compound ofConcern and the Compound of Concern does not have a Ministry Point of Impingement Limit or aJurisdictional Screening Level.

(d) Prior to the proposed Modification, a contaminant was discharged in a negligible amount and theproposed Modification will result in the discharge of the contaminant being considered a Compound ofConcern. Additionally, the Compound of Concern does not have a Ministry Point of ImpingementLimit and the concentration at a Point of Impingement will exceed the Jurisdictional Screening Level.

3.1.3 If a proposed Modification mentioned in Condition 3.1.1 will result in an increase in theconcentration at a Point of Impingement of a Compound of Concern, the Company shall submit aMaximum Concentration Level Assessment to the Director for review by the Air Standards Manager inthe following circumstances:

(a) The Compound of Concern does not have a Ministry Point of Impingement Limit or a JurisdictionalScreening Level and the concentration at a Point of Impingement will exceed the Acceptable MaximumGround Level Concentration.

(b) The Compound of Concern does not have a Ministry Point of Impingement Limit or a JurisdictionalScreening Level and the concentration at a Point of Impingement will exceed the most recentlyaccepted Maximum Concentration Level Assessment submitted under Condition 3.1.2 or thisCondition.

(c) The Compound of Concern does not have a Ministry Point of Impingement Limit and theconcentration at a Point of Impingement will exceed the Jurisdictional Screening Level and theAcceptable Maximum Ground Level Concentration.

(d) The Compound of Concern does not have a Ministry Point of Impingement Limit and the

concentration at a Point of Impingement will exceed the Jurisdictional Screening Level and the mostrecently accepted Maximum Concentration Level Assessment submitted under Condition 3.1.2 or thisCondition.

(e) The Compound of Concern does not have a Ministry Point of Impingement Limit, AcceptableMaximum Ground Level Concentration or a Maximum Concentration Level Assessment and theconcentration at a Point of Impingement will exceed the Jurisdictional Screening Level.

3.1.4 Subject to the Operational Flexibility set out in Condition 2 of this Approval, the Company maymake the Modification if the submission of a Maximum Concentration Level Assessment underCondition 3.1.2 or 3.1.3 is not required.

3.1.5 A Company that is required to submit an assessment under Condition 3.1.2 or 3.1.3 shall submitthe assessment at least thirty (30) days before the proposed Modification occurs.

3.1.6 The Ministry shall provide to the Company written confirmation of the receipt of the assessmentunder Condition 3.1.2 or 3.1.3.

3.1.7 If an assessment is submitted under Condition 3.1.2 or 3.1.3, the Company shall not modify theFacility unless the Ministry accepts the assessment.

3.1.8 If the Ministry notifies the Company that it does not accept the assessment submitted underCondition 3.1.2 or 3.1.3, the Company shall:

(a) revise and resubmit the assessment; or

(b) notify the Ministry that the Company will not be modifying the Facility.

3.1.9 The re-submission under Condition 3.1.8 (a) is considered by the Ministry as a new submission.

3.2. PERFORMANCE LIMITS

3.2.1 Subject to Condition 3.2.2, the Company shall, at all times, ensure that all Equipment that is asource of a Compound of Concern is operated to comply with the following Performance Limits:

(a) for a Compound of Concern that has a Ministry Point of Impingement Limit, the maximumconcentration of that Compound of Concern at any Point of Impingement shall not exceed thecorresponding Ministry Point of Impingement Limit;

(b) for a Compound of Concern that has an Acceptable Maximum Ground Level Concentration and noMaximum Concentration Level Assessment, the maximum concentration of that Compound ofConcern at any Point of Impingement shall not exceed the corresponding Acceptable MaximumGround Level Concentration; and

(c) for a Compound of Concern that has a Maximum Concentration Level Assessment, the maximumconcentration of that Compound of Concern at any Point of Impingement shall not exceed the mostrecently accepted corresponding Maximum Concentration Level Assessment.

3.2.2 If the Company has modified the Facility and was not required to submit a MaximumConcentration Level Assessment with respect to a Compound of Concern under Condition 3.1.2 or3.1.3, the Company shall, at all times, ensure that all Equipment that is a source of the Compound ofConcern is operated such that the maximum concentration of the Compound of Concern shall notexceed the concentration listed for the Compound of Concern in the most recent version of the ESDMReport.

3.2.3 The Company shall, at all times, ensure that the noise emissions from the Facility comply withthe limits set out in Ministry Publication NPC-205.

3.2.4 The Company shall, at all times, ensure that the vibration emissions from the Facility comply with

the limits set out in Ministry Publication NPC-207.

3.2.5 The Company shall ensure that all Noise Control Measures identified in the AcousticAssessment Report are incorporated at the Facility within six (6) months of the date of this Approval.

3.2.6 The Company shall ensure that the Noise Control Measures are properly maintained andcontinue to provide the acoustical performance outlined in the Acoustic Assessment Report.

3.2.7 The Company shall, at all times, operate any Equipment with Specific OperationalLimits approved by this Approval in accordance with the Original ESDM Report and Conditions in thisApproval.

4. DOCUMENTATION REQUIREMENTS

4.1 The Company shall, at all times, maintain documentation that describes the current operations ofthe Facility, including but not limited to:

(a) an ESDM Report that demonstrates compliance with the Performance Limits for the Facility;

(b) an Acoustic Assessment Report that demonstrates compliance with the Performance Limits forthe Facility;

(c) an up-to-date Log that describes each Modification to the Facility; and

(d) a record of the changes to the ESDM Report and the Acoustic Assessment Report that documentshow each Modification is in compliance with the Performance Limits.

4.2 The Company shall, during regular business hours, make the current Emission SummaryTable and Acoustic Assessment Summary Table available for inspection at the Facility by anyinterested member of the public.

4.3 Subject to Condition 4.5, the Company shall prepare and complete no later than March 31 of eachyear documentation that describes the activities undertaken at the Facility in the previous calendaryear, including but not limited to:

(a) a list of all Compounds of Concern for which a Maximum Concentration Level Assessment wassubmitted to the Director for review by the Air Standards Manager pursuant to Condition 3.1.2 or 3.1.3of this Approval;

(b) if the Company has modified the Facility and was not required to submit a Maximum ConcentrationLevel Assessment with respect to a Compound of Concern under Condition 3.1.2 or 3.1.3, a list andconcentration level of all such Compounds of Concern;

(c) a review of any changes to Ministry Point of Impingement Limits that affect any Compounds ofConcern emitted from the Facility; and

(d) a table of the changes in the emission rate of any Compound of Concern and the resultant increaseor decrease in the Point of Impingement concentration reported in the ESDM Report.

4.4 Subject to Condition 4.5, the Company shall, at all times, maintain the documentation described inCondition 4.3.

4.5 Conditions 4.3 and 4.4 do not apply if Condition 2.1 has expired.

4.6 The Company shall, within three (3) months after the expiry of Condition 2.1 of this Approval,update the ESDM Report and the Acoustic Assessment Report such that they describe the Facility asit was at the time that Condition 2.1 of this Approval expired.

5. REPORTING REQUIREMENTS

5.1 Subject to Condition 5.2, the Company shall provide the Ministry and the Director no later thanMarch 31 of each year, a Written Summary Form that shall include the following:

(a) a declaration of whether the Facility was in compliance with section 9 of the EPA, O.Reg.419/05 and the conditions of this Approval;

(b) a summary of each Modification that took place in the previous calendar year that resulted in achange in the previously calculated concentration at the Point of Impingement for any Compound ofConcern or resulted in a change in the sound levels reported in the Acoustic Assessment SummaryTable at any Point of Reception.

5.2 Condition 5.1 does not apply if Condition 2.1 has expired.

6. OPERATION AND MAINTENANCE6.1 The Company shall prepare and implement, not later than three (3) months from the date of thisApproval, operating procedures and maintenance programs for all Processes with SignificantEnvironmental Aspects, which shall specify as a minimum:

(a) frequency of inspections and scheduled preventative maintenance;

(b) procedures to prevent upset conditions;

(c) procedures to minimize all fugitive emissions;

(d) procedures to prevent and/or minimize odorous emissions;

(e) procedures to prevent and/or minimize noise emissions; and

(f) procedures for record keeping activities relating to the operation and maintenance programs.

6.2 The Company shall ensure that all Processes with Significant Environmental Aspects are operatedand maintained at all times in accordance with this Approval, the operating procedures andmaintenance programs.

7. COMPLAINTS RECORDING PROCEDURE

7.1 If at any time, the Company receives any environmental complaints from the public regarding theoperation of the Equipment approved by this Approval, the Company shall respond to thesecomplaints according to the following procedure:

(a) the Company shall record and number each complaint, either electronically or in a log book, andshall include the following information: the time and date of the complaint and incident to which thecomplaint relates, the nature of the complaint, wind direction at the time and date of the incident towhich the complaint relates and, if known, the address of the complainant;

(b) the Company, upon notification of a complaint, shall initiate appropriate steps to determine allpossible causes of the complaint, and shall proceed to take the necessary actions to appropriatelydeal with the cause of the subject matter of the complaint; and

(c) the Company shall complete and retain on-site a report written within one (1) week of the complaintdate, listing the actions taken to appropriately deal with the cause of the subject matter of thecomplaint and any recommendations for remedial measures, and managerial or operational changesto reasonably avoid the recurrence of similar incidents.

8. RECORD KEEPING REQUIREMENTS

8.1 Any information requested by any employee in or agent of the Ministry concerning the Facility and

its operation under this Approval, including, but not limited to, any records required to be kept by thisApproval, shall be provided to the employee in or agent of the Ministry, upon request, in a timelymanner.

8.2 The Company shall retain, for a minimum of five (5) years from the date of their creation, except asnoted below, all reports, records and information described in this Approval and shall include but notbe limited to:

(a) If the Company has updated the ESDM Report in order to comply with Condition 4.1(a) of thisApproval, a copy of each new version of the ESDM Report;

(b) If the Company has updated the Acoustic Assessment Report, in order to comply with Condition4.1(b) of this Approval, a copy of each new version of the Acoustic Assessment Report;

(c) supporting information used in the emission rate calculations performed in the ESDM Reports andAcoustic Assessment Reports to document compliance with the Performance Limits(supersededinformation must be retained for a period of three (3) years after Modification);

(d) the Log that describes each Modification to the Facility;

(e) all documentation prepared in accordance with Condition 4.3 of this Approval;

(f) copies of any Written Summary Forms provided to the Ministry under Condition 5.1 of this Approval;

(g) the operating procedures and maintenance programs, including records on the maintenance, repairand inspection of the Equipment related to all Processes with Significant Environmental Aspects; and

(h) the complaints recording procedure, including records related to all environmental complaints madeby the public as required by Condition 7.1 of this Approval.

9. REVOCATION OF PREVIOUS APPROVALS

9.1 This Approval replaces and revokes all Certificates of Approval (Air) issued under section 9EPA and Environmental Compliance Approvals issued under Part II.1 EPA to the Facility in regards tothe activities mentioned in subsection 9(1) of the EPA and dated prior to the date of this Approval.

SCHEDULE A

Supporting Documentation

(a) Application for Approval (Air & Noise), dated February 1, 2013, signed by Terry McGowan andsubmitted by the C ompany;(b) Emission Summary and Dispersion Modelling Report, prepared by ORTECH Environmental anddated January 31, 2013;

(c) Revised air emissions and modelling information provided by ORTECH Environmental and datedJuly 29, 2014.

(d) Acoustic Assessment Report entitled "Acoustic Assessment Report Thomson-Gordon GroupBurlington, Ontario", dated January 31, 2013, created and signed by Corey Kinart, P.Eng., of HGCEngineering.

The reasons for the imposition of these terms and conditions are as follows:

GENERAL1. Condition No. 1 is included to require the Approval holder to build, operate and maintain theFacility in accordance with the Supporting Documentation in Schedule A considered by the Director inissuing this Approval.

LIMITED OPERATIONAL FLEXIBILITY, REQUEST FOR MAXIMUM CONCENTRATION LEVELASSESSMENT AND PERFORMANCE LIMITS

2. Conditions No. 2 and 3 are included to limit and define the Modifications permitted by thisApproval, and to set out the circumstances in which the Company shall submit a MaximumConcentration Level Assessment prior to making Modifications. The holder of the Approval isapproved for operational flexibility for the Facility that is consistent with the description of theoperations included with the application up to the Facility Production Limit. In return for the operationalflexibility, the Approval places performance based limits that cannot be exceeded under the terms ofthis Approval. Approval holders will still have to obtain other relevant approvals required to operate theFacility, including requirements under other environmental legislation such as the EnvironmentalAssessment Act.

DOCUMENTATION REQUIREMENTS

3. Condition No. 4 is included to require the Company to maintain ongoing documentation thatdemonstrates compliance with the Performance Limits of this Approval and allows the Ministry tomonitor on-going compliance with these Performance Limits. The Company is required to have an upto date ESDM Report and Acoustic Assessment Report that describe the Facility at all times and makethe Emission Summary Table and Acoustic Assessment Summary Table from these reports availableto the public on an ongoing basis in order to maintain public communication with regard to theemissions from the Facility.

REPORTING REQUIREMENTS

4. Condition No. 5 is included to require the Company to provide a yearly Written Summary Form tothe Ministry, to assist the Ministry with the review of the site’s compliance with the EPA, the regulationsand this Approval.

OPERATION AND MAINTENANCE

5. Condition No. 6 is included to require the Company to properly operate and maintain the Processeswith Significant Environmental Aspects to minimize the impact to the environment from theseprocesses.

COMPLAINTS RECORDING PROCEDURE

6. Condition No. 7 is included to require the Company to respond to any environmental complaintsregarding the operation of the Equipment, according to a procedure that includes methods forpreventing recurrence of similar incidents and a requirement to prepare and retain a written report.

RECORD KEEPING REQUIREMENTS

7. Condition No. 8 is included to require the Company to retain all documentation related to thisApproval and provide access to employees in or agents of the Ministry, upon request, so that theMinistry can determine if a more detailed review of compliance with the Performance Limits isnecessary.

REVOCATION OF PREVIOUS APPROVALS

8. Condition No. 9 is included to identify that this Approval replaces all Section 9 Certificate(s) of

Approval and Part II.1 Approvals in regards to the activities mentioned in subsection 9(1) of theEPA and dated prior to the date of this Approval.

In accordance with Section 139 of the Environmental Protection Act, you may by written Notice servedupon me, the Environmental Review Tribunal and in accordance with Section 47 of the EnvironmentalBill of Rights, 1993 , S.O. 1993, c. 28 (Environmental Bill of Rights), the Environmental Commissioner,within 15 days after receipt of this Notice, require a hearing by the Tribunal. The EnvironmentalCommissioner will place notice of your appeal on the Environmental Registry. Section 142 of theEnvironmental Protection Act provides that the Notice requiring the hearing shall state: 1. The portions of the environmental compliance approval or each term or condition in theenvironmental compliance approval in respect of which the hearing is required, and; 2. The grounds on which you intend to rely at the hearing in relation to each portion appealed. The Notice should also include: 3. The name of the appellant; 4. The address of the appellant; 5. The environmental compliance approval number; 6. The date of the environmental compliance approval; 7. The name of the Director, and; 8. The municipality or municipalities within which the project is to be engaged in. And the Notice should be signed and dated by the appellant. This Notice must be served upon: The Secretary* Environmental ReviewTribunal 655 Bay Street, Suite1500 Toronto, Ontario M5G 1E5

AND

The EnvironmentalCommissioner 1075 Bay Street, Suite605 Toronto, Ontario M5S 2B1

AND

The Director appointed for thepurposes of Part II.1 of theEnvironmental Protection Act Ministry of the Environment 2 St. Clair Avenue West, Floor12A Toronto, Ontario M4V 1L5

* Further information on the Environmental Review Tribunal ’s requirements for an appeal canbe obtained directly from the Tribunal at: Tel: (416) 212-6349, Fax: (416) 314-4506 orwww.ert.gov.on.ca This instrument is subject to Section 38 of the Environmental Bill of Rights, 1993, that allows residentsof Ontario to seek leave to appeal the decision on this instrument. Residents of Ontario may seekleave to appeal within 15 days from the date this decision is placed on the Environmental Registry. Byaccessing the Environmental Registry at www.ebr.gov.on.ca , you can determine when the leave toappeal period ends. The above noted activity is approved under s.20.3 of Part II.1 of the Environmental Protection Act.

DATED AT TORONTO this 26th day of March, 2015Ian Greason, P.Eng.

Director appointed for the purposes of Part II.1 ofthe Environmental Protection Act

SA/ c: District Manager, MOE Halton-Peel Kathleen Spence, ORTECH Environmental

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