Lehigh Hanson Materials Limited/Mateériaux Lehigh Hanson Limitée - Environmental Compliance Approval (air)

14 comments were received under EBR during the required posting period. In general, the commenters expressed concerns related to the potentially higher emissions from co-burning Alternative Low Carbon Fuels (ALCF), emission controls and reporting, and ALCF handling by the proponent.

Proposals for Environmental Compliance Approval for air and Noise (ECA) undergo detailed technical review to determine whether or not they comply with the requirements related to section 9 of the Environmental Protection Act (section 9 EPA). Approvals are only issued if all of these requirements are satisfied.

Submitted proposal satisfies requirements set in section 9 of EPA

Comments received were reviewed and where appropriate were considered in the Ministry's decision whether or not to proceed with this proposal. In this case, the comments are consistent with concerns within the Ministry and as a result terms and conditions have been added.

The terms and conditions do not represent all conditions in the ECA but are those related to the comments on the proposal.

Pollution control, emission monitoring and reporting requirements

The facility operates the typical continuous emission monitoring systems on the kiln stacks, such as nitrogen oxides, sulphur oxides and opacity. Additionally, the facility submitted (acceptable to the ministry) monitoring plan to ensure that proposed systems will produce reliable data on the continuous bases, therefore a compliance for the major contaminants can be verified at the actual operating time.

The facility is required to perform an annual source testing for other contaminants emitted from kiln stacks, including but not limited to metals, dioxin and furans, hydrochloric acid, etc., most likely associated with the production of clinker cement. The annual source testing should be performed when conventional fuels are fired only (base emissions) and when the ALCF are co-fired to establish influence (if any) of ALCF on the base emission rates. Any significant changes to the base emissions will require adjustment of ALCF types; or removal of the specific types of ALCF from the co-burning. The company is required to prepare an annual compliance report, including but not limited to summary of source testing, types of ALCF co-fired, etc., and make is public for examination and any future comments.

Also, should be noted that based on the available data and the company application, co-burning ALCF at the proposed burning rates and types of ALCF, should not significantly increase emissions from the kiln stacks when compared to the base emissions (firing the kiln by conventional fuels). The company is required to prepare an annual Compliance Report (available for examination by any person), including summary of operation and compliance.

Additionally, to better control emissions, the facility proposed to install the baghouse leak detection systems on the significant dust collectors and updated operation and maintenance procedure for the remaining baghouses to ensure better performance of the dust collectors leading to reduction of emissions.

The facility also updated the Best Management Practice Plan (BMPP) to reduce fugitive dust emissions from the site.

ALCF handling and co-burning

The submitted ALCF handling manual, includes a provision to return all ALCF out of the required specifications to the original owner at the owner expense. Additionally, the ECA requires that all accepted and stored ALCF at the site shall be combusted in the cement kiln.

The facility is required to perform source testing and assess compliance of emissions from co-firing any new mixtures of ALCF (including the first mixture) before co-firing them on the regular bases.