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February 5, 2016

ENVIRONMENTAL SCREENING REPORT

Evaluation of Low Carbon Fuels – Project 1, Considerations for Permanent Use

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Report Number: 13-1151-0041

Distribution:

1 copy - Lafarge Canada Inc. 1 copy - Golder Associates Ltd. 1 copy - Township of Champlain 2 copies - Ministry of Environment and Climate Change

Submitted to:Mr. Robert Cumming Lafarge Canada Inc. P.O. Box 160 / 6501 Bath Road Bath, Ontario K0H 1G0

EVALUATION OF LOW CARBON FUELS - PROJECT 1, CONSIDERATIONS FOR PERMANENT USE

February 5, 2016 Report No. 13-1151-0041 i

EXECUTIVE SUMMARY With their partners, Lafarge Canada Inc. (Lafarge), Canada’s largest diversified supplier of construction

materials, has undertaken a broad initiative to improve the sustainability of their Bath cement manufacturing

plant by the year 2020, termed the Cement 2020 Initiative. Under this initiative, working in Partnership with

Queen’s University, environmental non-government organizations and various levels of government, Lafarge is

reducing its imported fossil fuel use, and so lowering its Green House Gas (GHG) emissions, through the use of

local and/or regional, sustainable, Low Carbon Fuels (LCF). Under the sustainability model adopted by the

Project team, to be considered a sustainable fuel, they must be environmentally sound, socially responsible and

economically viable.

The purpose of this Project is to assess the potential environmental effects (both beneficial effects and potential

adverse effects) of using construction and demolition (C&D) materials, asphalt shingles, and weathered treated

wood (such as railway ties and utility poles) as LCFs in the cement manufacturing process. Doing so would

reduce imported fossil fuel use, lowering GHG emissions, and make use of local and/or regional, and

sustainable, LCF sources that would otherwise be directed to landfills.

Lafarge is proposing to receive and process up to 135,000 tonnes of LCF per year. A maximum of 250 tonnes of

LCF per day, corresponding to about a third of the plant’s daily fuel needs, would be used as fuel in the cement

plant, with another 125 tonnes of LCF per day processed on-Site and shipped off-Site to third party users.

The estimated maximum number of trucks transporting LCFs to and from the Site in a single day is 21 (15 trucks

delivering LCF to the Site, and 6 trucks leaving the Site with processed LCF destined for third party consumers)

or residual wastes (destined for recycling/disposal). Although the facility will be open continuously 365 days per

year, Lafarge’s experience is that the vast majority of truck traffic will be Monday to Friday, during daylight hours,

due to commercial practicalities. In addition, rail shipments will be scheduled as much as practical to deliver

LCFs to the Site.

LCFs, either processed or partially processed (shredded), or unprocessed (whole), will be supplied from a

variety of suppliers, or directly from waste generators, as determined by market availability. Prior to use as fuel

through the primary fuel combustion system, the LCFs must be finely shred into a consistent size suitable for

injection with the pulverized coal and petroleum coke currently used in the cement kiln. Lafarge has learned

during the course of completing this environmental review, over the first year of the Low Carbon Fuel

Demonstration Project, that access to LCFs is improved if they can provide the shredding services. This allows

the plant to have a more consistent supply of LCFs, and to exercise better quality control over the materials.

Lafarge is using an Environmental Screening Process (ESP), as per Ontario’s Regulation 101/07 under the

Environmental Assessment Act, to assess the potential environmental effects (including benefits) of using

C&D materials, weathered treated wood, and asphalt shingles as LCFs. As per the Ministry of Environment

and Climate Change’s Guide to Environmental Assessment Requirements for Waste Management Projects

(MOECC 2007), a Screening Criteria Checklist is completed at the beginning of the process. This checklist is a

comprehensive list of potential effects, and proponents must review these criteria to assess which ones are

applicable to the Project. Mitigation measures cannot be taken into account when addressing the Screening

Criteria. This means that any effects, both positive and negative, that may be possible are identified, to ensure

they are included in the ESP.


February 5, 2016 Report No. 13-1151-0041 ii

The components of the environment identified in the Screening Criteria Checklist as having the potential to be

affected by the Project, as identified by the Project team and validated at a public meeting, were surface and

groundwater, air and noise, and land-use and socio-economics. These environmental and social criteria were

assessed to determine if they would be affected by the Project, and if that effect was anticipated to be significant.

Water (Groundwater and Surface Water) No adverse effects to groundwater quality, quantity and flow, or to surface water quality, quantity and flow to the

Stormwater Management Pond (the regulated discharge point on Site), are predicted as a result of the Project.

Mitigation measures to control runoff of waters in contact with LCFs include: implementation of a

Best Management Practice Plan (BMPP) for dust control and housekeeping at all areas where LCF materials are

processed or handled; storage of only unprocessed weathered or hydrophobic materials outdoors and

uncovered, other non-hydrophobic unprocessed materials and all processed fuels to be stored under cover to

minimize the opportunity for contact with rainwater and snowmelt; a covered structure to be installed in LCF 1

(identified in Figure 4-1) to minimize the opportunity for processed fuels to come into contact with rainwater and

snowmelt; and re-grading LCF 1 area and constructing a geomembrane lined runoff collection pond to reduce

impacts from dust during the LCF processing operations. There may be a moderate effect to surface water

quantity and flow to the West Drainage Channel, but this effect is not considered significant; further

investigations to the drainage patterns to the west of the plant will be undertaken to confirm assumptions made

in the assessment.

Air Quality (including Dust and Odour) No adverse effects to air quality are predicted as a result of the Project. LCF will not be introduced in the kiln

until conditions that promote good combustion are established, with emissions controlled by an electrostatic

precipitator on the kiln stack. RWDI states in the 2015 ESDM report that maximum air emissions from the kiln

during the LCF condition showed no statistical significant variation from the existing baseline conditions, and an

independent study by Queens University researchers concludes there are no deleterious influences on the

emissions after the introduction of LCF (Davis and Chandler 2014).

No adverse effects to greenhouse gas (GHG) emissions are predicted as a result of the Project. Emissions of

reportable carbon dioxide (CO2) equivalents are reduced with the use of LCF and a Life Cycle Analysis

confirmed an overall reduction in GHG’s compared to fossil fuels when considering the supply chain – and also

indicated an indirect GHG reduction from diverting these materials from landfill.

No adverse effects to dust or odour are predicted as a result of the Project. A dust BMPP and housekeeping

plan will be developed and implemented at all areas of the Site where LCF materials are processed or handled.

In addition, all processed fuels will be stored under cover to minimize windblown debris.

A cumulative effects assessment on air quality was completed by RWDI to include the ambient air background

conditions, the emissions from the Lafarge Bath Plant (without [Base Case] and with [Future Case] the inclusion

of the LCF systems), and the emissions from five industrial sources within 30 km of the Project Site in the

prevailing upwind direction and within 20 km in the prevailing downwind direction. The results of RWDI’s study

conclude the Project will not significantly change the cumulative effects assessment from the Base Case.

Further, the report states that in consideration of the conservatisms built into the assessment and the limited

area and frequency that predicted concentrations are above the Ambient Air Quality Criteria, the predicted levels

of all contaminants are considered to be acceptable and well within typical results under the Future case.


February 5, 2016 Report No. 13-1151-0041 iii

Noise Emissions No adverse effects to noise emissions are predicted as a result of the Project. As of January 2015, the date of

the most recent noise monitoring, equipment from the LCF delivery systems was operational, but the LCF

processing equipment has not yet been purchased. Consequently, for this noise assessment, HGC based sound

emissions from the proposed LCF processing equipment on measurements of similar equipment. With the

addition of the LCF equipment, the modelling analysis conducted by HGC Engineering (HGC) indicated that the

total sound power level of all sources at the site increased by 0.2 dBA. Consequently, the predicted likely effect

of noise emissions from the LCF processing and delivery systems on neighbouring receptors is considered to be

negligible.

In response to community questions, a cumulative effects assessment was also completed by HGC to include

the estimated noise emissions from the proposed TransCanada Energy Ltd. Napanee Generating Station (NGS).

Although the sound level limits of the Ministry of Environment and Climate Change (MOECC) do not apply to the

combined sound levels of two separate, independent facilities, it may be noted that the combined predicted

sound levels of the NGS and Lafarge Bath Plant are less than the MOECC daytime/nighttime limits for both

Class 2 (semi-urban) and Class 3 (rural) areas. Based on HGC’s study findings, the predicted cumulative effect

of noise emissions from the Lafarge Bath Plant and NGS on neighbouring receptors is considered to be

negligible.

Land Use and Socio-Economics (including Traffic) No adverse effects to land-use and socio-economic indicators are predicted. The Project is expected to

contribute to the local economic base, create approximately 20 new permanent jobs in the local and/or regional

area, and support a transition towards a low carbon economy that benefits the region as a whole. While this

represents a positive contribution to the local economy, it will have a negligible effect on the local economic base

at the Project level.

A conservative estimate of 21 additional trucks per day on local roadways is anticipated as a result of the

Project. This may result in increased visibility of traffic, and potentially LCF material and litter on transportation

routes. Consistent with the current haul route designations within the area, primary routes to be used by Project-

related trucks will be east-west along Highway 33 and north-south along County Road 4. Based on the predicted

2019 and 2024 traffic conditions, GHD Inc. (GHD) concluded a minimal effect to traffic is predicted since all

individual movements on the local roadways are expected to operate at acceptable levels of service, with no

critical movements and no queuing issues. Mitigation measures to minimize the aesthetic and traffic-related

effects include: the transportation of LCFs in fully enclosed trailers, tarped dump trucks, or railcars; sorting of

LCF materials inside a covered structure as much as practical; and compliance with Lafarge’s Site safety and

insurance requirements and the 2015 ‘Trucking, Bulk Carriers, Transport and Dump Trailer’ policy.

In response to community questions, a cumulative effects assessment was also completed by GHD to include

the estimated traffic from the proposed NGS. Based on the study’s findings, the predicted cumulative effect of

increased levels of traffic from the Project and NGS in the community is considered to be negligible.


February 5, 2016 Report No. 13-1151-0041 iv

Conclusions In conclusion, the Project is expected to have an overall positive affect on the environment and benefit the

community-at-large. Through the use of local and/or regional, and sustainable, LCF sources, Lafarge can reduce

its imported fossil fuel use (with a current goal of a 30% reduction of fossil fuel use by the year 2020) and

thereby reduce their emissions of greenhouse gases (specifically CO2). The use of LCFs is also expected to

create immense spin-off benefits to the community and Ontario, bringing new, direct and indirect, economic

opportunities.

Lafarge and its other project partners are committed to working with the community, specifically through their

Community Liaison Committee, to ensure the community-at-large as well as Lafarge benefit from this Project.

Mitigation measures have been put in place to reduce or eliminate any potential adverse effects from the Project

to surface and groundwater, air quality and dust, aesthetics and traffic in the community. Thus, the advantages

of the Project significantly outweigh any potential disadvantages.


February 5, 2016 Report No. 13-1151-0041 v

Table of Contents

1.0 INTRODUCTION ............................................................................................................................................................... 1

2.0 RATIONALE FOR THE PROJECT (ESP STEP 2) ........................................................................................................... 1

2.1 Problem and Opportunity Statement ................................................................................................................... 1

2.2 Canada and World-Wide Fuel Substitution .......................................................................................................... 2

2.3 Purpose of the Project ......................................................................................................................................... 3

2.4 Project Background ............................................................................................................................................. 4

2.5 Project Location ................................................................................................................................................... 5

2.6 Project Proponent ................................................................................................................................................ 6

3.0 GUIDING PRINCIPLES AND LEGISLATIVE FRAMEWORK .......................................................................................... 7

3.1 Statement of Environmental Values .................................................................................................................... 7

3.2 Precautionary Principle ........................................................................................................................................ 8

3.3 Ontario Environmental Assessment Act .............................................................................................................. 8

3.4 Permits and Approvals....................................................................................................................................... 10

3.5 Air Emissions Standards .................................................................................................................................... 12

4.0 PROJECT DESCRIPTION (ESP STEP 3) ...................................................................................................................... 14

4.1 Service Areas and Fuel Types ........................................................................................................................... 14

4.1.1 Construction and Demolition Materials ........................................................................................................ 15

4.1.2 Weathered Treated Wood ............................................................................................................................ 16

4.1.3 Asphalt Shingles .......................................................................................................................................... 16

4.2 Project Phases .................................................................................................................................................. 17

4.2.1 Construction ................................................................................................................................................. 17

4.2.2 Operations ................................................................................................................................................... 17

4.2.3 Retirement ................................................................................................................................................... 17

4.3 Low Carbon Fuel Transport ............................................................................................................................... 17

4.4 Fuel Staging/Processing System ....................................................................................................................... 18

4.4.1 Sorting Operations ....................................................................................................................................... 18

4.4.2 Shredding Operations .................................................................................................................................. 19

4.5 Fuel Delivery System ......................................................................................................................................... 20


February 5, 2016 Report No. 13-1151-0041 vi

4.5.1 Fuel Off-Loading System ............................................................................................................................. 20

4.5.2 Fuel Storage System ................................................................................................................................... 21

4.5.3 Fuel Injection System ................................................................................................................................... 21

4.6 Low Carbon Fuel Efficiency ............................................................................................................................... 21

4.7 Low Carbon Fuel Storage .................................................................................................................................. 22

4.8 Relevant Bath Operations Activities .................................................................................................................. 23

4.8.1 Water Usage Relevant to the LCF Operations ............................................................................................. 23

4.8.2 Water Discharge to the Environment ........................................................................................................... 23

4.8.3 Ash Production/Disposal .............................................................................................................................. 23

5.0 ENVIRONMENTAL SCREENING CHECKLIST TO IDENTIFY POTENTIAL ENVIRONMENTAL EFFECTS

(ESP STEPS 3 & 4) ........................................................................................................................................................ 24

5.1 Screening Criteria and Evaluation Approach ..................................................................................................... 28

5.2 Surface and Groundwater .................................................................................................................................. 29

5.3 Land .................................................................................................................................................................. 30

5.4 Air and Noise ..................................................................................................................................................... 30

5.4.1 Emissions ..................................................................................................................................................... 30

5.4.2 Dust and Odour ............................................................................................................................................ 31

5.4.4 Light ............................................................................................................................................................. 31

5.5 Natural Environment .......................................................................................................................................... 32

5.6 Resources ......................................................................................................................................................... 32

5.7 Socio-Economic ................................................................................................................................................. 33

5.8 Heritage and Culture ......................................................................................................................................... 33

5.9 Aboriginal ........................................................................................................................................................... 33

5.10 Other.................................................................................................................................................................. 34

6.0 CONSULTATION AND ENGAGEMENT (ESP STEPS 1, 5, 8 & 12) .............................................................................. 34

6.1 Public Consultation Process Overview .............................................................................................................. 34

6.2 Public and Agencies .......................................................................................................................................... 35

6.3 First Nations and Aboriginal Communities ......................................................................................................... 37

7.0 EFFECTS ASSESSMENT APPROACH ......................................................................................................................... 38

7.1 Identify the Spatial and Temporal Boundaries of the Assessment ..................................................................... 39

7.2 Characterize the Existing Environment .............................................................................................................. 39


February 5, 2016 Report No. 13-1151-0041 vii

7.3 Characterize Environmental and Social Effects ................................................................................................. 39

7.3.1 Identify Potential Effects .............................................................................................................................. 39

7.3.2 Implement Mitigation Measures ................................................................................................................... 39

7.3.3 Determine Residual Effects .......................................................................................................................... 40

7.4 Evaluate the Significance of Residual Effects .................................................................................................... 40

7.5 Identify Follow up Monitoring ............................................................................................................................. 40

7.6 Evaluate Cumulative Effects .............................................................................................................................. 40

8.0 ASSESSMENT OF POTENTIAL EFFECTS AND DEVELOPMENT OF IMPACT MANAGEMENT MEASURES

(ESP STEPS 6, 7 & 9) .................................................................................................................................................... 41

8.1 Water (Surface Water and Groundwater) .......................................................................................................... 41

8.1.1 Existing Environment ................................................................................................................................... 41

8.1.2 Potential Environmental Effects ................................................................................................................... 42

8.1.3 Impact Management Measures .................................................................................................................... 44

8.1.4 Net Effects and Significance ........................................................................................................................ 44

8.1.5 Monitoring Commitments ............................................................................................................................. 46

8.1.6 Cumulative Effects ....................................................................................................................................... 47

8.2 Air Quality (including Dust and Odour) .............................................................................................................. 47







8.3 Noise Emissions ................................................................................................................................................ 59







8.4 Land Use and Socio-Economics (including Traffic) ........................................................................................... 64


February 5, 2016 Report No. 13-1151-0041 viii


8.4.2 Potential Environmental and Social Effects ................................................................................................. 71





9.0 SUMMARY OF ADVANTAGES AND DISADVANTAGES OF PROJECT AND CONCLUSIONS ................................. 77

10.0 REFERENCES ................................................................................................................................................................ 81

TABLES

Table 2-1: Project Proponent ............................................................................................................................................. 6

Table 3-1: Emission Limits from Schedule C of ECA #7984-8YYR75 .............................................................................. 11

Table 3-2: Emission Limits of O. Reg. 194/05 and the Federal Base Level Industrial Emission Requirements Program .......................................................................................................................................................... 14

Table 4-1: Composition of Typical Bin of Construction and Demolition Material .............................................................. 15

Table 4-2: Key Physical/Chemical Parameters of Coal vs. Construction and Demolition Materials ................................. 15

Table 4-3: Key Physical/Chemical Parameters of Coal vs. Railway Ties ......................................................................... 16

Table 4-4: Key Physical/Chemical Parameters of Coal vs. Asphalt Shingles ................................................................... 16

Table 4-5: Low Carbon Fuel Storage Areas ..................................................................................................................... 22

Table 5-1: Screening Criteria Checklist ............................................................................................................................ 24

Table 6-1: Mandatory Consultation Activities ................................................................................................................... 35

Table 6-2: Summary of Key Concerns Raised and How Addressed ................................................................................ 36

Table 8.1-2: Monitoring Commitments for Surface and Groundwater ................................................................................. 46

Table 8.2-1: Summary of Representative Background Air Quality Concentrations ............................................................. 49

Table 8.2-2: Net Effects to Air Quality ................................................................................................................................. 53

Table 8.2-3: Monitoring Commitments for Air Quality .......................................................................................................... 53

Table 8.2-4: Large Industrial Sources in the Vicinity of the Lafarge Bath Plant ................................................................... 55

Table 8.2-5: Comparison in Cumulative Effects Air Concentrations .................................................................................... 57

Table 8.3-1: Applicable Sound Level Limits at Selected Points of Reception ..................................................................... 61

Table 8.3-2: Predicted Sound Emissions of Lafarge Bath Plant at Selected Points of Reception ....................................... 61

Table 8.3-3: Net Effects to Noise Emissions ....................................................................................................................... 63

Table 8.3-4: Monitoring Commitments for Noise Emissions ................................................................................................ 63

Table 8.3-5: Predicted Sound Levels, LEQ [dBA], of Napanee Generating Station and Lafarge Bath Plant ........................ 64

Table 8.4-2: Population (2001 to 2011) ............................................................................................................................... 67


February 5, 2016 Report No. 13-1151-0041 ix

Table 8.4-3: Top Employers ................................................................................................................................................ 69

Table 8.4-4: Summary of Land Use and Socio-economic Effects Assessment ................................................................... 75

FIGURES

Figure 2-1: Site Location Plan

Figure 4-1: Site Layout and Fuel Management

Figure 4-2: Low Carbon Fuel Management Process

Figure 4-3: Low Carbon Fuel Delivery System

APPENDICES

APPENDIX A Maps

APPENDIX B Comparison of Air Emission Standards across Jurisdictions

APPENDIX C Consultation Report

APPENDIX D1 Groundwater Technical Study

APPENDIX D2 Surface Water Technical Study

APPENDIX E1 Background Air Quality & Cumulative Effects Analysis

APPENDIX E2 Emission Summary and Dispersion Modelling Report

APPENDIX E3 Source Testing Report

APPENDIX E4 Life Cycle Assessment of LCFs

APPENDIX F1 Acoustic Assessment Report

APPENDIX F2 Acoustic Assessment Briefing

APPENDIX G1 Land Use and Socio-Economic Baseline and Effects Assessment Report

APPENDIX G2 Traffic Impact Study


February 5, 2016 Report No. 13-1151-0041 x

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February 5, 2016 Report No. 13-1151-0041 xi

LIST OF ABBREVIATIONS 3Rs Reduction, Reuse and Recycling

% Percent

AAQC Ambient Air Quality Criteria

AAR Acoustic Assessment Report

ANSI Areas of Natural or Scientific Interest

BLIERs Base Level Industrial Emission Requirements

BMP Best Management Practices

BMPP Best Management Practices Plan

C&D Construction and Demolition

C of A Certificate of Approval

CCME Canadian Council of Ministers of the Environment

CLC Community Liaison Committee

CO2 Carbon Dioxide

CSA Component Study Area

d Day

dBA A-weighted Decibel

dBAI A-weighted Decibel Impulse

EAA Environmental Assessment Act

ECA Environmental Compliance Approval

EMS Emergency Medical Services

EPA Environmental Protection Act

ESA Endangered Species Act

ESDM Emission Summary and Dispersion Modelling

ESP Environmental Screening Process

GHD GHD Inc.

GHG Green House Gas

GJ Gigajoule

HGC Howe Gastmeier Chapnik Limited (HGC Engineering)

Hr Hour

kg Kilogram

km Kilometre

L Litre

LCA Life Cycle Assessment

LCF Low Carbon Fuel

LEQ Equivalent Continuous Level


February 5, 2016 Report No. 13-1151-0041 xii

LSA Local Study Area

m Metre

m2 Metre Squared

m3 Cubic Metre

M4 Extractive Industrial Zone

masl Metres Above Sea Level

mg Milligram

mm Millimetre

MOECC Ministry of Environment and Climate Change

NGS Napanee Generating Station

NOx Nitrogen Oxides

O. Reg. Ontario Regulation

OWRA Ontario Water Resources Act

pg Picogram

PM2.5 Particulate Matter Less Than 2.5 µm in Diameter

PM10 Particulate Matter less than 10 µm in diameter

POI Point of Impingement

POR Point of Reception

ppb Parts Per Billion

ppmdv Parts Per Million by Volume, Dry Basis

PTTW Permit To Take Water

R Corrected to 11% Oxygen, 25˚ Celsius, 1 Atmosphere

RSA Regional Study Area

RWDI RWDI Air Inc.

SEV Statement of Environmental Values

SO2 Sulphur Dioxide

SPM Total Suspended Particulate Matter

SSA Site Study Area

SWM Stormwater Management

t Tonne

TransCanada TransCanada Energy Ltd.

TSS Total Suspended Solids

µg Microgram


February 5, 2016 Report No. 13-1151-0041 1

1.0 INTRODUCTION Lafarge Canada Inc. (Lafarge), Canada’s largest diversified supplier of construction materials, has undertaken a

broad initiative to improve the sustainability of their Bath cement manufacturing plant by the year 2020, termed

the Cement 2020 Initiative. Under this initiative, and working in Partnership with Queen’s University,

environmental non-government organizations and various levels of government, Lafarge is reducing its imported

fossil fuel use, and so lowering its Green House Gas (GHG) emissions, through the use of local and/or regional,

sustainable, Low Carbon Fuels (LCF). Lafarge is currently approved to use virgin biomass (crops such as switch

grass and oat hulls) as fuel in the cement manufacturing process and has a pilot study underway to assess the

use of mixed biomass or otherwise lower carbon materials as fuels. The first mixed biomass LCFs proposed for

permanent use, based on the results of the pilot study, are construction and demolition materials, asphalt

shingles, and weathered treated wood (such as railway ties and utility poles), Lafarge is using an Environmental

Screening Process (ESP) to assess the potential environmental effects (including benefits) of using these LCFs

(“Project 1”).

2.0 RATIONALE FOR THE PROJECT (ESP STEP 2)

2.1 Problem and Opportunity Statement There is more concrete sold per year than all other building materials combined. Concrete is made from

aggregates (gravel and sand), cement, and water and is much in demand for its building material qualities, and

superior life cycle and environmental performance. However, cement, the active ingredient, requires thermal

energy to produce. Traditionally, this thermal energy is obtained from fossil fuels such as coal, natural gas, and

petroleum and its by-products. However, worldwide, fossil fuel alternatives (derived from fossil sources, biomass

and mixtures of the two) have been a growing source of energy for cement manufacturing due to their better

ranking from a sustainability perspective. Further, with the emerging global need to reduce GHG emissions to

mitigate the impacts from climate change, the need for lower carbon fuels – a subset of fossil fuel alternatives –

is growing urgent.

Lafarge is amongst many members in the cement sector assessing fossil fuel alternatives, related technologies,

and their optimum use. In Ontario, the Lafarge Bath Plant Cement 2020 initiative aims to identify broad

measures for improved sustainability (e.g., energy, water, economics, emissions, biodiversity) and extend the

findings to the rest of the sector. One of the key focus areas of the Cement 2020 initiative is to reduce imported

fossil fuel use by 30% by the year 2020, and so lower GHG emissions and other emissions, through the use of

local and/or regional, and sustainable, LCF sources. Under the sustainability model adopted by the Project team,

to be considered a sustainable fuel, they must be environmentally sound, socially responsible and economically

viable.

The Ontario Ministry of Environment and Climate Change (MOECC, formerly called the Ontario Ministry

of Environment) defines alternative LCFs in the new Alternative Low Carbon Fuels Regulation 79/15

(O. Reg. 79/15) as “a fuel that has a carbon dioxide emission intensity that is less than the carbon dioxide

emission intensity of the coal or petroleum coke in the place of which the fuel is combusted and that meets one

of the following descriptions:



1) The fuel,

i) is not derived from or composed of any material set out in Schedule 1 (of O. Reg. 79/15);

ii) is wholly derived from or composed of materials that are biomass or municipal waste or a combination

of both; and

iii) unless the fuel is wholly derived from or composed of materials that are solid biomass, has a high heat

value of at least 10,000 mega joules per tonne.

2) The fuel is wholly derived from or composed of organic matter, not including peat or peat derivatives,

derived from a plant or micro-organism and grown or harvested for the purpose of being used as a fuel."

Lafarge has adopted the MOECC definition of alternative LCFs for this project.

There is great potential for adoption of LCFs within North America, where there are approximately 115 operating

cement kilns. Much of the 2 million tonnes of fossil fuels used every year by the Canadian cement industry is

imported and enabling the industry to receive local LCFs will create immense local spin-off benefits; bringing

new, direct and indirect, economic values well in excess of $100 million per year while preserving the existing

cement industry’s competitiveness. In addition, the business models being developed can be readily replicated

and the science readily adapted to other facilities. Other large energy users such as electricity and steel can

build on the in-depth science produced to adopt LCFs as may be appropriate for their sector.

The vision of the Cement 2020 initiative is to achieve 30% substitution of the traditional fuel sources currently in

use at the Bath Plant with practical, sustainable LCF alternatives by the year 2020, and to continue developing

LCFs and related technologies to reach ever higher replacement rates in the future.

In addition, there are a number of social benefits that are expected from the sustainability model adopted.

By working in a Partnership comprised in part of local entities, local employment and educational opportunities

are maximized. Each partner brings expertise and values that synergistically ensure the community values are

integrated, including transparency, the precautionary principle, and local enrichment. Through a series of

communications efforts and events, the Project team ensures that the local public is offered the opportunity to

engage with the team and to participate in the program. The skills developed by working on this Project will

prepare the team members to contribute to other local and non-local development projects.

It is anticipated that this Project will create new jobs as imported fuels are replaced with local and/or regionally1

produced fuels. This Project will decrease the amount of material destined for landfill and extend landfill life

spans. Including all Project partners, over 20 new permanent jobs will be created and with higher levels in the

future as the program expands. These jobs include unskilled and skilled work opportunities.

2.2 Canada and World-Wide Fuel Substitution Alternative fuels have been used by the cement industry worldwide since the 1970s. Globally, the average

substitution rate of alternative fuels for coal and/or petroleum coke in cement plants is approximately 14%,

with Europe at a remarkable level of 36% (Zhang and Mabee 2015a). The alternative fuels used as a substitute

include fossil-based fuels (such as tires and tire-derived fuels, waste solvents, plastics and used oils),

1 Alternative fuels may be sourced from Ontario, Quebec or New York State, depending on availability.



and renewable biomass-based fuels (such as sewage sludge, meat and bone meal, agricultural plants and wood

wastes). The most common alternative fuel used globally in cement plants is used oil, representing 50% of all

alternative fuels (Zhang and Mabee 2015a).

In Canada, five provinces (British Columbia, Alberta, Ontario, Quebec, and Nova Scotia) have operating

Portland cement plants, with an average alternative fuel substitution rate of approximately 11% (Zhang et al

2015). The substitution rates (calculated by weight) vary between provinces, from 0% in Alberta to over 34% in

Quebec. In Ontario, the fuel substitution rate is approximately 5% (Zhang et al 2015). Many of Ontario’s cement

plants have considered or are testing alternative fuels under a pilot study, but only one is approved to

permanently use alternative fuels in their plant and is actively doing so.

The Government of Ontario promotes the reduction, reuse and recycling (3Rs) of waste to keep these materials

out of landfills for environmental reasons (i.e., save scarce resources and reduce GHGs), and also because

these materials have tremendous value and potential to generate new investment, new factories, new jobs,

and new Ontario-made products. To achieve its vision of a ‘zero-waste’ society the government has proposed a

new Resource Recovery and Circular Economy Act (the draft bill was posted on the ON Environmental Registry

for public comment on November 26, 2015) to hold individual producers responsible for recovering resources

and reducing waste associated with their products and packaging, and establish a strategy and identify actions

to increase resource recovery and waste reduction in Ontario. In a parallel initiative, a new Alternative

Low Carbon Fuel Regulation (O. Reg. 79/15) was passed in Ontario in May 2015 that recognizes the beneficial

uses of alternative fuels, specifically to energy intensive manufacturing facilities such as cement plants and steel

producers, and places the use of alternative fuels in a greenhouse gas reduction policy framework. Under this

new regulation, fuel use will target materials that are currently not-recycled. The use of alternative fuels supports

the government’s GHG and waste reduction policies.

2.3 Purpose of the Project The purpose of this Project is to assess the potential environmental effects (both beneficial effects and potential

adverse effects) of using construction and demolition materials, asphalt shingles, and weathered treated wood

(such as railway ties and utility poles) as LCFs in the cement manufacturing process. Doing so would reduce

imported fossil fuel use, lowering GHG emissions, and make use of local and/or regional, and sustainable,

LCF sources that would otherwise be directed to landfills.

The direct GHG emissions are reduced through the use of LCF because the thermal energy is from a biological

(plant) based source rather than a fossil fuel. When purpose grown biomass or other wood products are used for

energy, carbon is released into the atmosphere in the form of carbon dioxide (CO2). These carbon (specifically

CO2) emissions are quickly taken back up by plant material that is grown to replace the material used for

energy. Conversely, when fossil fuels are used for energy, an increase in the atmospheric carbon concentrations

results as there is no short term mechanism to remove the CO2 from the atmosphere and sequester the carbon

outside of the natural carbon cycle. The carbon cycle for biological (plant) based sources of energy is

acknowledged in the Environment Canada guidelines for reporting GHG emissions (Environment Canada 2014).

Lafarge is using an environmental assessment, specifically an Environmental Screening Process (ESP), to

assess the potential effects of using LCFs in the cement manufacturing process. Once the Environmental

Screening Process is complete, Lafarge will apply for a permanent Environmental Compliance Approval (ECA)

to add these specific types of LCFs to the currently approved list of fuels in their cement plant.



2.4 Project Background In 2010, the Lafarge Bath Plant undertook its first LCF testing program. The Energy Farm Demonstration Project

evaluated several forms of locally-grown virgin biomass for suitability as a LCF: the tested mix included maize,

millet, hemp, oat hulls, and switch grass. The study concluded that these types of materials were not currently

economically viable; results are summarized in a public report submitted to the MOECC and currently available

on the www.cement2020.org website (Hyndman & Associates 2011). This phase of the project was funded in

part by a Biomass Research grant from Natural Resources Canada.

Building upon this success and lessons learned, the Project team expanded the scope of its research to find

other LCFs that meet all three requirements under the Project team’s sustainability approach (environmentally

sound, socially responsible and economically viable). This search was funded in part by an Asia Pacific

Partnership grant and built on the knowledge gained in previous years. The Cement 2020 initiative commenced,

in its current form, in 2011.

There were two main elements of relevance to this next phase of the LCF program. The first was a call to the

local business community to identify LCF sources that appear to have merit under the sustainability approach.

A second process, undertaken in parallel, was to engage a multi-stakeholder expert panel to develop a protocol

tool for use in assessing the relative environmental and social benefits of candidate fuels. That is, to develop a

transparent tool to quantify two of the three sustainability requirements recognizing that economics can be

readily assessed. This protocol was called the Greener Fuel Protocol (the “Protocol”). The Task Force panel

included members from Loyalist Township, World Wildlife Fund Canada, Queen’s University, New Energy

Project, Cement Association of Canada, Kingston Environmental Advisory Forum, Kingston Greens, Lafarge,

and the local community. While the Protocol included specific social measures, the team based development of

the Protocol itself was a major element of meeting the social component. This Protocol was then used in its draft

form to assess the local LCF proposals – in addition to an economic analysis – and as a result a number of fuel

types were put forward for additional development. These fuels included: forest and agricultural production by-

products and waste, construction and demolition materials, asphalt shingles, railway ties, pulp and paper by-

products, fibre based industrial discards, and post-consumer fibre based materials that are not readily

recoverable through existing recycling systems.

The next phase of the LCF program, currently underway, is to validate the Protocol’s performance prediction for

these fuels at full scale. The Low Carbon Fuel Demonstration Project will evaluate potential fuel management

systems for the dedicated injection of LCFs into the main cement kiln combustion system. A detailed

air emission testing program forms a key component of this project (Golder 2012a). Its aim is to assess the

expected positive results (or negative changes, if any), to the air quality from the stack emissions.

Further information on the project can be found in the Design and Operations Report (Golder 2012b).

Under the Cement 2020 initiative, a series of environmental approval and assessments activities have or will be

undertaken, for the use of LCFs in the cement manufacturing process. These activities are briefly discussed

below.



Round 1 of environmental approval activities was completed in 2009 for the Energy Farm Demonstration

Project. A Pilot Project Environmental Compliance Approval (ECA #1202-7UTPZJ) was issued by the MOECC in

November 2009 to use/assess virgin biomass (including switch grass, Miscanthus, sorghum, hemp and willows)

in the cement manufacturing process.

Round 2 was completed for the Permanent Low Carbon Fuel Project (formerly called the Energy Farm

Demonstration Project) in December 2012.

Lafarge received approval (ECA #3610-8Y9NVD) to permanently use virgin biomass as a supplemental fuel

in their cement manufacturing process based on its successful demonstration in 2010.

Lafarge also received approval in this same ECA to permanently operate the LCF fuel management

system. This includes the LCF fuel staging/processing system (shredding, blending, mixing and grinding the

fuel) and fuel delivery system (off-loading, storage and injection into the kiln). This approval grants ‘limited

operational flexibility’ to allow the plant to optimize the staging and delivery systems, as determined through

the Low Carbon Fuel Demonstration Project. This system is approved on an ongoing basis for virgin

biomass fuels (see above) and on a temporary basis for use in the Pilot Project (see below).

Round 2 also included activities completed in December 2012 for the Low Carbon Fuel Demonstration Project.

Pilot Project ECAs (#7984-8YYR75 and #9606-8Z7S9Z)) were issued by the MOECC to use/assess mixed

biomass LCFs in the cement manufacturing process for a period of 3 years (with the opportunity for two 1-

year extensions). These ECAs specifically address the handling and storage requirements for the LCF

material, and source and emission monitoring requirements.

Round 3 is underway for the Evaluation of Low Carbon Fuels - Project 1. Lafarge is conducting an

environmental assessment (specifically an Environmental Screening Process) of the potential environmental

effects of using specific types of LCFs in their cement manufacturing process. These specific types of LCFs are

described further in Section 4.1 of this report and were selected through the “Greener Fuel Protocol” process

described above. Once the Environmental Screening Process is complete, pending successful results, Lafarge

will apply for a permanent ECA to use these specific types of LCFs indefinitely in their cement plant.

Pending the outcome of Round 3, subsequent Rounds will seek approval for the use of a broader range of LCFs

in the cement manufacturing process.

2.5 Project Location The Lafarge Bath Plant is situated on a 1,089 hectare property located on the north side of Highway No. 33,

approximately 3 kilometres west of the Village of Bath, Ontario in Loyalist Township (the “Site”). Bath is located

approximately 25 kilometres west of the City of Kingston. The legal address for the Site is Concession 1, Broken

Front Lot 4 to 6 and Lot 7 to 8 Part Lot plus open allowance, Loyalist Township, County of Lennox & Addington.

The mailing address is 6501 Highway 33 / PO Box 160, Bath, Ontario, K0H 1G0. The location of the Site is

shown in Figure 2-1.

The Site is bordered to the north, east, and west, by residential and agricultural properties. The majority of the

south limit of the Site is bounded by Highway No.33 and further to the south by lands owned by Lafarge and

water lots (Lake Ontario).



The Loyalist Township Official Plan (Cumming Cockburn Limited 2014) designates the Site as Aggregate,

providing for a range of aggregate related operations. This includes, but is not limited to, blasting, crushing,

screening, blending, storage and aggregate recycling. The Site is also situated in an Aggregate Specific Policy

Area and is therefore subject to additional requirements, such as the requirements of the Aggregate Resources

Act, and requirements outlined in an agreement signed by Lafarge Canada Inc. on May 27th, 1992. Land use

mapping for the Site and adjacent properties is included in Appendix A.

According to the Loyalist Township Zoning By-Law 2001-38 (Cumming Cockburn Limited 2001), as amended,

the Site is located within an Extractive Industrial (M4) Zone. Permitted uses for the M4 zoning designation are

diverse, and include aggregate processing plants. Based on an exception provision within By-Law 2001-38

(Extractive Industrial Exception Two – M4-2 Zone) the Site is also situated in a zone which permits the

establishment and use of a cement plant. This zoning also allows the cement plant to receive and use fuels,

including LCFs. Lands surrounding the Bath Plant are a mixture of M4, rural, prime agricultural and open space

designated zones. A zoning designation map indicating zone classification for the Site and surrounding areas as

per By-Law 2001-38 is also provided in Appendix A.

2.6 Project Proponent The name of the designated Project is “Evaluation of Low Carbon Fuels – Project 1, Considerations for

Permanent Use”. Contact information for the proponent is provided in Table 2.1 below.

Table 2-1: Project Proponent

The proponent is:

Lafarge Canada Inc.

P.O. box 160 / 6501 Bath Road

Bath, Ontario K0H 1G0

The primary contact person is:

Mr. Robert Cumming

Director Environment, Canada

[email protected]

1-613-352-7711 x185



3.0 GUIDING PRINCIPLES AND LEGISLATIVE FRAMEWORK The Ontario government and Lafarge Canada are both guided by principles meant to protect the environment in

a sustainable and accountable fashion. A summary of these principles is provided in Sections 3.1 and 3.2.

The Lafarge Bath Plant is subject to a number of regulatory acts, permits and approvals, and emission

standards. A summary of these regulatory requirements is provided in Sections 3.3 to 3.5.

3.1 Statement of Environmental Values Each provincial ministry subject to the Ontario Environmental Bill of Rights has a framework called a “Statement

of Environmental Values” (SEV) to be used when the environment may be affected by a ministry decision.

The SEV are a means for each ministry to record their commitment to the environment and to be accountable for

ensuring the environment is considered in decision-making. The MOECC applies the principles of their

SEV when developing Acts, regulations and policies, such as the Ontario Environmental Assessment Act (EAA),

to protect the environment and human health. Principles of the MOECC SEV require that the Ministry

(MOECC 2015):

adopt an ecosystem approach to environmental protection and resource management;

consider the cumulative effects on the environment; the interdependence of air, land, water and living

organisms; and the relationships among the environment, the economy and society;

consider the effects of decisions on current and future generations, consistent with sustainable

development principles;

use a precautionary, science-based approach in decision-making;

place priority on preventing pollution and minimizing the creation of pollutants that can adversely affect the

environment within their environmental protection strategy;

has the perpetrator of pollution pay for the cost of clean-up and rehabilitation consistent with the polluter

pays principle;

ensure that the environment is rehabilitated to the extent feasible where significant environmental harm is

caused;

strive for continuous improvement and effectiveness in planning and management for environmental

protection through adaptive management;

support and promote a range of tools that encourage environmental protection and sustainability

(e.g., stewardship, outreach, education); and

encourage increased transparency, timely reporting and enhanced ongoing engagement with the public as

part of environmental decision making.



The purpose of the Project is to assess the potential environmental effects of using sustainable LCF’s in the

cement manufacturing process to reduce imported fossil fuel use and lower GHG emissions. To be considered a

sustainable fuel, the LCF must be environmentally sound, socially responsible and economically viable. As these

fuels would otherwise be destined for landfill, the principles of sustainability, minimizing the creation of pollutants,

and consideration for current and future generations, form the basis of the Project.

In addition to the principles of the MOECC SEV listed above, social considerations must be taken into account

when a decision could affect the environment. It is also necessary to consult with the public as per the Ontario

Environmental Bill of Rights, which provides the public the right to participate in environmental decision-making.

This includes opportunities for involvement of Aboriginal peoples who may be affected. These additional

considerations are requirements of the environmental assessment process and discussed in Section 6.

3.2 Precautionary Principle The principles listed in Section 3.1 apply to environmental assessments and other project approvals under the

mandate of the MOECC. An environmental assessment is a forward-looking planning tool used in the early

stages of project development to encourage decision makers to take actions that promote sustainable

development and thereby achieve or maintain a healthy environment and a healthy economy. To ensure that

projects are considered in a careful and precautionary manner, the environment assessment process is based

on a precautionary and science-based approach, which is a principle of the MOECC SEV. The precautionary

approach is guided by judgement, based on values, and is intended to address uncertainties in the assessment.

This approach is consistent with Principle 15 of the 1992 Rio Declaration on Environment and Development and

the Canadian government’s framework for applying precaution in decision-making processes (Canadian Privy

Council Office 2003).

The approach used for assessing the Project, as documented in this Environmental Screening Report, supports

the philosophy of environmental assessment as a planning and decision-making process. The assessment

characterizes and assesses the effects of the Project in a thorough, traceable, step-wise manner, proposes

impact management measures to mitigate potential negative environmental effects and predicts whether there

will be likely significant net environmental effects after impact management measures are implemented.

Furthermore, the Project is the next step under Lafarge’s Cement 2020 Initiative to assess the use of mixed

biomass LCFs as a fossil fuel alternative. Through this Project, Lafarge will verify and evaluate the fuel

combustion properties of the LCFs, and assess any potential impacts from the use of LCFs to the environment,

before a broader introduction into the process. They will also extend the findings of the Project to others within

the cement sector also assessing the use of fossil fuel alternatives.

3.3 Ontario Environmental Assessment Act Ontario’s Environmental Assessment Act (EAA) provides for the protection, conservation and wise management

of Ontario’s environment by establishing a responsible and accountable process for decision-making before a

project is undertaken. The EAA applies to undertakings (i.e., enterprises, activities, proposals, plans or

programs) by provincial ministries and agencies, municipalities and public bodies, such as conservation

authorities and the Ontario Energy Commission. Under the EAA, Waste Management Projects Regulation

101/07 (O. Reg. 101/07) was promulgated in 2007 with the intent of standardizing the approvals required for

waste management projects. Taking into account the varying complexity of waste management projects,



O. Reg. 101/07 classifies waste management projects (and their corresponding environmental assessment

requirements) into three process streams. These include:

1) Individual Environmental Assessment – for major projects with the potential for significant environmental

effects;

2) Environmental Screening Process (ESP) – for projects that have predictable environmental effects that can

be readily mitigated; and

3) Undesignated / EAA Approval Not Required – for projects that are expected to have minimal environmental

effects.

The MOECC (2007) document, Guide to Environmental Assessment Requirements for Waste Management

Projects (the “Guide”), provides guidance with respect to the classification of waste management projects as set

out in O. Reg. 101/07. As the Evaluation of Low Carbon Fuels – Project 1 is the expansion of an existing thermal

treatment site at a manufacturing facility that uses petroleum coke as a fuel, it is subject to the ESP. Further, due

to earlier testing results, the effects (including benefits) from this Project are considered to be predictable and

readily mitigated.

As per the Guide, projects subject to an ESP follow 14 prescribed steps. These include:

Step 1 – notice of commencement of a screening;

Step 2 – identify problem or opportunity and provide project description;

Step 3 – apply screening criteria checklist to identify potential environmental effects;

Step 4 – describe the potential environmental effects, concerns and/or issues to be addressed;

Step 5 – consult with interested persons, including Aboriginal communities and government agencies to

identify any issues or concerns on Steps 1 - 4;

Step 6 – conduct studies and assessment of potential environmental effects;

Step 7 – develop impact management measures (including mitigation measures);

Step 8 – consult with interested persons, including Aboriginal communities and government agencies to

identify any issues or concerns on Steps 1 – 7;

Step 9 – determine significance of any net effects (if any) and resolve of concerns;

Step 10 – conduct additional studies and assessment of effects and mitigation measures (if required);

Step 11 – prepare Environmental Screening Report;

Step 12 – publish notice of completion of Environmental Screening Report;

Step 13 – address elevation requests (if any); and

Step 14 – submission of statement of completion to the Ministry (i.e., MOECC).



An ESP is a comprehensive and environmentally sound planning procedure that incorporates public consultation

with a wide variety of stakeholders. Lafarge has expressed a strong desire to involve the community and

interested stakeholders in the ongoing Cement 2020 low carbon fuel initiative, and the ESP is an excellent,

formal means of doing so.

3.4 Permits and Approvals In addition to requirements under the EAA, Lafarge must obtain and/or amend existing permits and approvals

prior to the permanent use of the LCFs. Applicable permits and approvals contain terms and conditions that are

in place to protect the environment; the conditions are designed to reduce, control or eliminate, and monitor

potential effects, and are legally enforceable.

The following is a summary of the Permits and Approvals, relative to the Project activities, which are currently

held by Lafarge or will be required prior to the permanent use of the LCFs.

Environmental Compliance Approvals

Under the Environmental Protection Act (EPA) and Ontario Water Resources Act (OWRA), approval or

registration must be obtained from the MOECC where a project or activity is expected to emit/discharge

contaminants to the environment, or store, transport or dispose of waste. In 2011 amendments to the EPA and

OWRA created the Environmental Compliance Approval (ECA) process, which is a legal document (instrument)

issued by MOECC to regulate specific plants and/or specific components of a manufacturing site.

This instrument of approval replaces the previously existing Certificates of Approval (C of A) process. Conditions

of an ECA provide operating rules that are based on information about the proponent, the location of the

project/activity and site-specific details.

Lafarge has been issued numerous C of As and ECAs for the Site that cover operating and maintenance

requirements, training and record keeping, administrative legal conditions, and related items. These approvals

apply emission or discharge limits for air, noise, and water from the plant.

In December 2012, Lafarge obtained two Pilot Project ECAs (#7984-8YYR75 and #9606-8Z7S9Z) to use/assess

mixed biomass LCFs in the Bath Plant’s cement manufacturing process. These ECAs outline the requirements

for LCF material handling and storage, as well as source and emission monitoring. The Site-specific emission

limits, based on Guideline A-7, are listed in Schedule C of the plant’s ECA #7984-8YYR75, and are provided in

Table 3-1. Ontario Guideline A-7 (MOECC 2010) is used by the MOECC to help set site-specific air emission

limits in ECAs reflecting the capabilities of emission control equipment, standards from other jurisdictions,

and the site-specific nature of cement plant operations. When the Guideline A-7 limits are written into ECAs,

they become legally enforceable limits. It is important to note that, in practice, Guideline A-7 results in

significantly lower limits than those associated with the health-based limits.

Guideline A-7 recognizes that in several respects, cement plant emissions are not dominated by the fuels in use

but rather by the raw materials and by the technical capabilities of the cement plant equipment (MOECC 2010).

Where a facility meets the listed emission limit in its local, baseline context, the limit is normally applied to the

site’s ECA unless other regulations are in force. Where the existing site’s baseline emissions are higher than the

Guideline’s published levels, a site-specific emission limit is established. The goal is to ensure that the use of

LCFs, or other waste-based fuels, does not result in an unacceptable increase in emissions as compared to the



baseline. Where emissions, such as Nitrogen Oxides (NOx) and Sulphur Dioxide (SO2), are already separately

regulated, the existing regulations are typically applied.

Details regarding Lafarge’s air emissions are provided in Section 8.2. Upon successful conclusion of this

Environmental Screening Process, Lafarge intends to apply for a permanent ECA to use these proven LCFs in

their cement plant.

Table 3-1: Emission Limits from Schedule C of ECA #7984-8YYR75

Compound Maximum Limit

Hydrogen Chloride 18 ppmdv(a)

Total Particulate Matter 50 mg/Rm3

Mercury 20 ug/Rm3

Cadmium 7 ug/Rm3

Lead 60 ug/Rm3

Dioxins and Furans 80 pg/Rm3

a) ppmdv = parts per million by volume, dry basis.

R = corrected to 11% oxygen, 25˚ Celsius, 1 atmosphere.

In December 2012, Lafarge also received approval (ECA #3610-8Y9NVD) to permanently operate the LCF fuel

management system. This includes the LCF fuel staging/processing system (shredding, blending, mixing and

grinding the fuel) and fuel delivery system (off-loading, storage and injection into the kiln). This system is

approved on an ongoing basis for virgin biomass fuels (see above) and on a temporary basis for use in the Pilot

Project. This ECA requires the implementation of noise control measures at the Site, as detailed in the Plant’s

Acoustic Assessment Report (prepared by HGC in September 2015, attached in Appendix F1), and that noise

emissions from the facility comply with the MOECC regulatory limits. Details regarding Lafarge’s noise emissions

are provided in Section 8.3.

In addition, Lafarge has an existing stormwater management pond located on the south end of the Site that is

regulated under ECA #3466-6G6PMQ. Under this approval, Lafarge must monitor the pond on a weekly basis

and all measured parameters must meet the stipulated regulatory criteria in the ECA, including toxicity testing,

and Ontario Effluent Monitoring and Effluent Limits – Industrial Minerals Sector Regulation 561/94

(O. Reg. 561/94) prior to releasing the water to Lake Ontario. Pending a successful conclusion of this

Environmental Screening Process, Lafarge intends to apply for an ECA, or an amendment to the existing ECA,

to include the new lined collection pond in LCF 1, and to address potential increases in water volume or changes

to water quality (both thought to be negligible) in the stormwater management pond. Further details on water

management for the Project are provided in Section 8.1.

Permit to Take Water

To ensure that water is conserved, protected, managed and used wisely in Ontario, the taking of water is

governed by the OWRA and Water Taking and Transfer Regulation 387/04. The OWRA establishes that no

person shall take more than 50,000 L/d of water, with some exceptions, from a lake, stream, river, pond or

groundwater source unless in accordance with a Permit to Take Water (PTTW) from the MOECC. The PTTW

process is a mechanism to implement Ontario’s water quality management policy, which is based on the



principles of reasonable use, environmental protection, cumulative consideration, risk management and public

consultation. A risk-based approach is used by the MOECC when issuing a PTTW. Also, the permit holder is

required to submit daily water taking volumes on an annual basis to the MOECC as a condition of the permit.

Lafarge has two active PTTW for relevant Site activities currently underway; water taking from on-site quarry

pumps (PTTW #6713-9QJJU9) and from Lake Ontario (PTTW #4454-9ABRLX). These permits specify the

maximum rate and amount of water that can be taken from the identified source per day over a certain period of

time, as well as monitoring requirements.

3.5 Air Emissions Standards In addition to the limits enforced through the ECA, including those guided by Guideline A-7 (MOECC 2010),

there are several regulations and other regulatory tools that control air emissions. In some cases the regulations

apply to all industries, in others the emission limits apply only to the cement industry. A comparison of Ontario’s

air emission standards to other jurisdictions is provided in Appendix B.

Ontario’s Ambient Air Quality Criteria and Emission Modeling

One of the foundations of the MOECC regulatory structure is the establishment of ambient air quality criteria for

a wide range of compounds. As of 2012, 334 compounds have been assigned ambient air quality criteria by the

MOECC and apply to all industries in Ontario (MOECC 2012). These criteria are designed to be protective of

human health and the environment and are reviewed and updated periodically based on the best science

available and compared to other jurisdictions. Typically they are expressed in terms of concentration in air,

for example, micrograms of a compound per cubic meter of ground level air (µg/m3). They are “established at

concentrations that are protective against adverse effects that may occur during continuous lifetime exposure”

according to MOECC officials (MOECC n.d.).

Under the MOECC’s approach, there are two distinct uses for these criteria, 1) assessing air quality in various

Ontario regions regardless of the source of the emissions; and 2) as a level, that if you are below, the MOECC

considers acceptable for operations – an evaluation carried out through Ontario Air Pollution – Local Air Quality

Regulation 419/05 (O. Reg. 419/05). The O. Reg. 419/05 limits may be numerically the same as the criteria,

but they are used differently. When used in assessing specific industrial sites under O. Reg. 419/05, the second

use noted above, these criteria help the MOECC to determine which compounds are of greatest concern in the

local context and when a facility’s emissions may result in ground level concentrations that are above acceptable

limits.

To determine how ground level concentrations near a facility are established, it is necessary to estimate (through

measurement or calculations) the amount of various compounds emitted from the site and to determine, using

advanced, MOECC-approved models, what the maximum concentration in the natural environment will be at full

production. The MOECC requires that plants model both the normal (average) emissions as well as worst case

emissions. These predicted concentrations (referred to as point of impingement [POI] concentrations) are

compared to the O. Reg. 419/05 criteria in order to assess the compliance of the facility, but also to prioritize

which compounds are of greatest concern. This program is described in detail in Lafarge’s Emission Summary

and Dispersion Modeling (ESDM) report (prepared by RWDI in April 2015, attached in Appendix E2).



Lafarge’s ESDM report has been submitted to the MOECC as part of the approval process for various ECA

amendments and is publically available on Lafarge’s www.Cement2020.org website. Further details on the

ESDM report are provided in Section 8.2.

Although studies have found that approximately 90% of the air pollution in some regions of Ontario comes from

outside of the Province (MOECC 2005), O. Reg. 419/05 requires comparison of a site’s emissions to the limits;

it does not require inclusion of other local airshed sources in the site’s model. However, Lafarge has received

recommendations in previous programs that a cumulative effects approach should be adopted so that other

site’s emissions can be included in the model, as well as an assessment of actual air quality levels. Lafarge has

voluntarily done a separate cumulative effects report to implement this recommendation. Further details of the

cumulative effects study are provided in Section 8.2. Therefore, Lafarge considers both distinct uses of Ontario’s

Ambient Air Quality Criteria, as identified above, at the Site.

Ontario Regulation 194/05 and Federal Base Level Industrial Emission Requirements Program

In 2005, MOECC instituted a “cap and trade” program for NOx and SO2 emissions under Industry Emissions –

Nitrogen Oxides and Sulphur Dioxide Regulation 194/05 (O. Reg. 194/05) for the power, cement, steel,

and other sectors. Under this Program, the amounts of NOx and SO2 in metric tonnes that can be emitted are to

be reduced over time. For the cement industry, the emission caps are expressed as kilograms (kg) per tonne of

clinker, where clinker is the intermediate product produced directly from kiln operations. Clinker is subsequently

ground with gypsum to form cement, the final product. The MOECC issues free “allowances” for NOx and SO2

emissions based on the regulated amount of emissions. As an illustrative example, if the limit is 2 kg/tonne of

clinker and a million tonnes of clinker are produced by the cement plant, MOECC will issue the plant

2,000 allowances with each allowance representing a tonne of either NOx or SO2. The actual methodology of

issuing allowances is much more complex; for example, MOECC uses 3-year rolling average production levels

to calculate “deemed production”.

If the plant emits more than 2000 tonnes in the above example, allowances saved up from previous years must

be “retired”. If the plant does not have enough allowances from previous years, allowances from other

participating facilities must be purchased (traded). Alternatively, if the plant emits less than the allowable

2,000 tonnes, then the plant can bank the allowances for future use or can sell the allowances to another plant.

This is how typical “cap and trade” programs work and a similar program is being developed for greenhouse gas

emissions. The amount of Lafarge Bath Plant allowances is publicly available on the Ontario Emissions Trading

Registry (http://www.oetr.on.ca/oetr/index.jsp). Lafarge has a cap under this program that is unique to the plant

and is lowered over time to reduce the overall emissions.

In contrast to the O. Reg. 194/05 program, which is an example of a “cap and trade” regulatory approach,

the proposed Federal Base Level Industrial Emission Requirements (BLIERs) program is known as a “hard cap”

program. Emitters that are regulated under the BLIERs must comply with the capped limits; they cannot trade

allowances to meet the cap. The BLIERs have been negotiated between the Provinces and the Federal

government under the Canadian Council of Ministers of the Environment (CCME) and are a joint

Federal-Provincial regulation. This regulation is still required to be passed into law by the Federal Government.

When it becomes legally in force the plant will need to meet the new limits identified in Table 3-2, expressed as

kilograms per tonne of clinker, for the 2019 reporting year. Both the BLIERs and O. Reg. 194/05 will continue to



apply in parallel. Details regarding Lafarge’s air emissions, both existing conditions and with the use of LCFs,

are provided in Section 8.2.

Table 3-2: Emission Limits of O. Reg. 194/05 and the Federal Base Level Industrial Emission Requirements Program

Regulation / Reporting Year Limit Oxides of Nitrogen (NOx)

(kg/tonne clinker) Limit Sulphur Dioxide (SO2)

(kg/tonne clinker)

O. Reg. 194/05(a) (2006) 5.4 4.2

O. Reg. 194/05(a) (2007 to 2009) 4.2 3.6

O. Reg. 194/05(a) (2010 to 2014) 3 3

O. Reg. 194/05(a) (2015 +) 2 2.2

BLIERs (2019)(a,b) 2.55 3

Notes:

a) The O. Reg. 194/05 limits shown above are under an Ontario “cap and trade” program and are specific to the Bath Cement plant whereas the Federal BLIERs “hard cap” limits are applied equally to all cement plants across Canada.

b) Total Particulate Matter is also regulated by BLIERs and is set to 50 mg/Rm3 for long dry kilns (like the Bath cement plant). This matches the ECA limit described in Table 3-1.

4.0 PROJECT DESCRIPTION (ESP STEP 3) The proposed LCF types, handling and processing systems, and storage requirements are described in further

detail below. The Bath Plant layout, specifically outlining the areas to be used for the LCF operations,

is illustrated in Figure 4-1, and a schematic of the LCF Management System layout is shown in Figure 4-2.

4.1 Service Areas and Fuel Types As discussed in Section 2.4, Lafarge has regulatory approval (ECAs #7984-8YYR75 and #9606-8Z7S9Z) to run

a Pilot Project to use/assess a broad range of mixed biomass LCFs in the cement manufacturing process.

For this Project, Evaluation of Low Carbon Fuels – Project 1, three (3) types of mixed biomass LCF materials

have been chosen from the longer list to undergo the current environmental approval and assessment process

(Round 3); these fuels are Construction and Demolition (C&D) materials, weathered treated wood, and asphalt

shingles. None of these materials are deemed ‘hazardous waste’ under the Ontario Environmental Protection

Act, General – Waste Management Regulation 347.

The materials will be generated from within a service area comprised of the provinces of Ontario and Quebec

and the state of New York, U.S.A. Local materials meeting the three sustainability criteria will be preferentially

sourced; materials from Quebec and New York will be used as necessary to ensure a constant source of fuel to

the plant based on commercial realities. The three fuel types selected for Round 3 were so chosen due to their

availability in sufficient quantities to afford a regular supply.

All of these LCF types have been assessed in a preliminary manner by the ‘Greener Fuel Protocol’ (referred to in

Section 2.4) and all are expected to perform well as fuels, to reduce emissions, to reduce greenhouse gases

directly and indirectly, and to provide local opportunities for economic development – all while meeting the

economic criteria necessary to justify capital expenditures. Further details on each of the proposed LCF types

are provided in the following sections.



4.1.1 Construction and Demolition Materials

C&D is widely used to refer to any waste material that is generated from the construction and/or demolition of

various types of civil infrastructure. This type of fuel is generally a renewable biomass mix, including materials

such as wood (i.e., skids, untreated lumber, plywood), other wood waste (pressure treated, painted), engineered

wood composites, rugs, vinyl, and non-recyclable packaging. To get some local data, in November 2014 a bin of

C&D material was provided by a local supplier. Queen’s University students completed an inventory of the

contents; results are presented in Table 4-1 below.

Table 4-1: Composition of Typical Bin of Construction and Demolition Material

Component Examples Mass (kg)

Composition(%)

Wood Wood Waste Green Wood Waste (high moisture content)

776 31

Fuel Grade Wood Painted/stained Wood Treated Wood Mixed Demolition Wood

591 23

Engineered Wood Wood Composites 891 35

Miscellaneous Other materials including sand, gravel and other aggregates 284 11

Key physical and chemical parameters for C&D materials, as compared to coal, are provided in Table 4-2 below.

Table 4-2: Key Physical/Chemical Parameters of Coal vs. Construction and Demolition Materials

Parameter Coal C&D Materials

Density (kg/m3) 640 239

Moisture Content (%) 1.6 23

Heating Value (GJ/t) 26-30 14

Ash (%) 13 10

Carbon (%) 80 352

Note: Information sourced from testing conducted by Lafarge under the Cement 2020 initiative.

2 Of this, approximately 90% is derived from plant biomass and part of the natural carbon cycle.



4.1.2 Weathered Treated Wood

This type of fuel is a wood that has been treated/preserved with an organic compound and has been used

outdoors (i.e., weathered) for many years. Examples of this type of wood are railway ties and utility poles.

Railway ties are widely available across Canada, with over 24 million railway ties replaced each year (equivalent

to approximately 1.3 million tonnes). Railway companies stockpile the old ties during maintenance and then

transport them via rail to processing or disposal sites, or to fuel users such as Lafarge.

Railway ties are commonly treated with creosote, an organic compound derived from coal, to preserve the wood.

Key physical and chemical parameters for railway ties, as compared to coal, are provided in Table 4-3 below.

Table 4-3: Key Physical/Chemical Parameters of Coal vs. Railway Ties

Parameter Coal Railway Ties


Moisture Content (%) 1.6 13


Ash (%) 13 3

Carbon (%) 80 48


4.1.3 Asphalt Shingles

This type of fuel is a special example of C&D materials; shingles are widely used roofing covers in North

America. Typically, shingles are removed by roofing contractors and taken to local waste management sites; in

the United States of America, approximately 11 million tonnes of shingles are landfilled annually.

Asphalt shingles are made with a base layer of organic materials or fiberglass, and then saturated with asphalt

(also known as bitumen) to make it waterproof. Key physical and chemical parameters for asphalt shingles, as

compared to coal, are provided in Table 4-4 below.

Table 4-4: Key Physical/Chemical Parameters of Coal vs. Asphalt Shingles

Parameter Coal Asphalt Shingles


Moisture Content (%) 1.6 6.5


Ash (%) 13 28

Carbon (%) 80 45




4.2 Project Phases For this Project, Evaluation of Low Carbon Fuels – Project 1, three distinct phases of project development have

been identified: construction, operations and retirement. A discussion of each phase is provided below.

4.2.1 Construction

As discussed in Section 2.4, Lafarge has received approval (ECA #3610-8Y9NVD) to construct and permanently

operate the LCF fuel management system. This includes the LCF fuel staging/processing system (shredding,

blending, mixing and grinding the fuel) and fuel delivery system (off-loading, storage and injection into the kiln).

Consequently, no potential construction-related effects for the fuel platform were assessed for this Project.

Lafarge proposes to re-grade and re-surface the area identified as LCF 1 on Figure 4-1 and construct a covered

structure to store processed LCFs. This structure will be temporary in nature, similar to a large hoop tent,

installed directly on the aggregate surface (no flooring), with electricity and water supplied from the cement plant.

In addition, a small, shallow lined collection pond is proposed in LCF 1 to collect surface runoff from the graded

aggregate pad. Further details on this infrastructure are provided in Section 4.4.2. No other construction

activities have been identified for this Project. Any potential environmental or socio-economic effects related to

the covered structure and lined collection pond in LCF 1 are included in the assessment of the operations phase

of the Project.

4.2.2 Operations

For this Project, Lafarge is proposing to receive and process up to 135,000 tonnes of LCF per year. A maximum

of 250 tonnes of LCF per day would be used as fuel in the cement plant, with another 125 tonnes of LCF per day

processed on-Site and shipped off-Site to third party users. Further details on the operations phase of the

Project are provided in Sections 4.3 through 4.8.

4.2.3 Retirement

All LCFs stored on Site will be fully used or will be removed from the Site and shipped to other approved fuel

users or to an approved waste management facility for disposal or other uses. Remaining equipment will be

dismantled and removed from the Site. No residual impacts from this Project are expected.

The Bath Plant has quarry reserves representing over 100 years of operation and there is a Quarry

Rehabilitation Plan in place that describes the eventual closure of the quarry operations and cement plant.

4.3 Low Carbon Fuel Transport The Pilot Project ECAs (#7984-8YYR75 and #9606-8Z7S9Z) allow for a maximum of 1,200 tonnes of LCF to be

received at the Site per day, via fully enclosed trailers, tarped dump trucks, or by railcar. For Evaluation of Low

Carbon Fuels – Project 1, no additional increase in maximum LCF tonnage received at the Site per day is

required.

The LCFs are both low-density (e.g., C&D) and high-density (e.g., shingles), with bulk densities of approximately

0.3 tonne/m3 and 0.6 tonne/m3, respectively. A truck trailer, holding low-density fuel, has a storage capacity of

approximately 20 to 25 tonnes; a dump truck, holding high-density fuel, has a total capacity of approximately

50 tonnes. LCF material is typically shipped to the processing site(s) on a campaign basis, due to the

commercial realities of material availability. The estimated maximum number of trucks transporting LCFs to and



from the Site in a single day is 21 (15 trucks delivering LCF to the Site, and 6 trucks leaving the Site with

processed LCF destined for third party consumers) or residual wastes (destined for recycling/disposal).

All haulers delivering LCF will be required to comply with Lafarge’s transportation program. This includes

instructions around using public roadways, remaining within approved traffic routes, refraining from the use of

engine brakes, complying with Site safety & insurance requirements, and to be cognizant of the concerns of the

local community. Although the facility will be open continuously 365 days per year, Lafarge’s experience is that

the vast majority of truck traffic will be Monday to Friday, during daylight hours, due to commercial practicalities.

A railway gondola car can hold approximately 60 tonnes of high-density fuel, and the Site railway spur can

accommodate approximately 10 to 16 gondola cars, dependent on their length. This equates to a maximum

shipment of 600 tonnes. Typically, rail shipments will be scheduled to arrive subsequent to completion of the

previous shipment. Thus, up to 600 tonnes of rail delivered LCF material will be unloaded and stockpiled, prior to

the new shipment arriving.

4.4 Fuel Staging/Processing System Lafarge currently holds a permanent ECA (#3610-8Y9NVD) for the operation of the Low Carbon Fuel

staging/processing system, for activities including sorting, shredding, blending, screening, magnetic separation

and grinding. A brief description of the LCF staging/processing system is provided below. Further details of the

system can be found in the Design and Operations Report (Golder 2012b), and on the sorting and shredding

operations in Sections 4.4.1 and 4.4.2 below.

Deliveries of LCFs are booked in advance through the Lafarge Site Manager (or designate) or an authorized and

trained third party operator designated by Lafarge. All LCF suppliers are required to submit and have approved a

Fuel Data Sheet, prior to scheduling, for each type of LCF. The Fuel Data Sheet includes a detailed description

of the material types expected in the LCF load and associated testing required.

Characterization of the LCFs includes analyses of combustion properties (e.g., lower heating value, ash content,

moisture content, and volatile matter), chemical contents (e.g., carbon, hydrogen, sulphur, chlorine, nitrogen,

oxygen, and metals), and density. Further testing details can be found in the Low Carbon Fuel Demonstration

Project Testing Plan (Golder 2012a). Lafarge has internal Quality Assurance and Quality Control standards that

must be contractually met in order for the fuels to be accepted at Site.

4.4.1 Sorting Operations

Lafarge has learned during the first year of the Low Carbon Fuel Demonstration Project that it cannot rely solely

on third party suppliers to provide LCF materials for the plant in a suitable form. To facilitate a continuous flow

of materials and manage supply fluctuations, Lafarge must be prepared to accept unprocessed (whole)

LCF materials (as approved under their permits) directly from waste generators as well.

Materials that come directly from waste generators would require further processing, to prepare the fuel for

shredding. The fuels would require sorting to segregate the desired LCFs from unsuitable materials (such as

bricks or metal). This sorting process would provide the Quality Control that Lafarge requires: namely that the

materials destined for the shredding and fuel delivery systems are of high quality for cement production and

meet the Lafarge approval requirements. All rejected materials would be shipped off-Site to the municipal landfill,

recycling depot, or licensed disposal facility (dependent on the type of reject material), or reused for another

purpose. Lafarge proposes to sort the LCFs brought to the Site in the area identified as LCF 1 in Figure 4-1.



Most sorting activities would take place inside a covered structure to protect the fuels from the elements

(e.g., rain/snow).

In addition to the sorting process described above, a screening process for small metals (e.g., nails) takes place

during the fuel off-loading system (see Section 4.5.1 for more information).

4.4.2 Shredding Operations

Prior to use as fuel through the primary fuel combustion system, the LCFs must be finely shred into a consistent

size suitable for injection with the pulverized coal and petroleum coke currently used in the cement kiln.

Under the Site’s permanent ECA, shredding operations may be conducted by Lafarge or a third party – either

on-Site or off-Site – with shredded fuel product either used at Site in the cement manufacturing process or

shipped off-Site to other regional fuel users.

LCFs, either processed or partially processed (shredded), or unprocessed (whole), will be supplied from a

variety of suppliers, or directly from waste generators, as determined by market availability. Lafarge has learned

during the first year of the Low Carbon Fuel Demonstration Project that access to LCFs is improved if they can

provide the shredding services. This allows the plant to have a more consistent supply of LCFs, and to exercise

better quality control over the materials. Consequently, Lafarge proposes to shred weathered treated wood (such

as railway ties and utility poles), C&D materials and asphalt shingles at the Site, in the area identified as LCF 1

in Figure 4-1. This area is ideal for the shredding activities as it allows for unprocessed LCF materials to be

brought to the Site by railcar (a rail spur that can accommodate from 10 to 16 gondola type rail cars, dependent

on their length, is adjacent to LCF 1) or truck. LCF 1 is approximately 2.1 hectares in size.

The equipment at LCF 1 to be used for the shredding operations has not yet been purchased. It is expected that

mobile equipment (such as a hydraulic excavator or ‘grappler’) would be used to transfer the raw materials

arriving on the railway cars to either a temporary storage pile or directly to the shredding equipment. A typical

shredding machine, for an operation of this magnitude, would be a portable machine with a cutting adjustment to

allow the raw materials to be processed into two sizes. Generally, the raw materials would be shred in a two-step

process, from course (larger particle size) to fine (smaller size), to ensure a consistent quality fuel. Other mobile

equipment, such as a front end loader or trailer, would be used to transfer the processed fuels into temporary

storage piles or directly to the fuel delivery system. LCFs would be shred in batches, dependent on material

availability and cement plant requirements, with shredding activities taking place on and off over the cement

plant operating hours (24 hours a day, 7 days a week) as required.

Shredding machines generally come equipped with water sprays and light gauge metal enclosures and hoods

over the conveyors to minimize the production of dust and keep any dust in close proximity to the shredders.

In addition, to control the dispersion of dust and fine particles, Lafarge would limit the operations of the shredding

equipment during high winds. These measures are anticipated to control dust generated from the shredding

operations. The Site housekeeping program would also be amended to include the shredding operations, so that

the area is kept in an orderly and clean manner.

A covered structure, approximately 20 m wide by 40 m long, will be installed in LCF 1 to store processed

fuels prior to use in the plant and protect them from the elements (e.g.; rain and wind). On occasion,

shredded materials could be stored outdoors, under temporary cover such as tarps, for short periods of time to

facilitate material handling and storage activities.



A grading plan has been completed for the LCF 1 area, with the uppermost layers of the pad consisting of a

0.4 m thick layer of compacted Granular B (Type 2) sand and gravel overlain by 0.15 m of compacted

Granular A. A collection sump with a 45 mil (1 mm) thick ethylene-propylene-diene-terpolymer geomembrane

liner is designed to capture surface water runoff from the area for sedimentation control and use as dust control.

The lined sump is shallow (0.5 m maximum water depth at the permanent pool elevation) due to the shallow

depth to bedrock, and has a volume capacity (at the permanent pool elevation) of 530 m3. The pond also has an

extended detention capacity of 670 m3 that can hold up to the runoff volume produced by a 24-hour, 10-year

return period rainfall event. It is anticipated that for most of the year the lined sump would be dry. However,

in the rare event that excess water exists, overflow from the pond would be directed to the main quarry sump

and managed with the quarry’s surface water management system.

To control surface runoff laden with dust and fine particles at LCF 1 area, activities would be limited during

intense rain events and snow would be removed from working areas prior to commencement of shredding

operations.

4.5 Fuel Delivery System Lafarge currently holds a permanent ECA (ECA #3610-8Y9NVD) for the operation of the Low Carbon Fuel

delivery system. For the Pilot Project approval (ECA #9606-8Z7S9Z), a maximum of 75 tonnes of LCF may be

subjected to thermal treatment per day. For this Project, Evaluation of Low Carbon Fuels – Project 1,

a maximum of 250 tonnes per day is proposed for the listed LCFs; this represents approximately 30% of the

annual fuel usage and matches the stated goal of the Cement 2020 initiative. Currently, fuel types used for

the cement manufacturing process (i.e., coal, petroleum coke, virgin biomass) are listed in the existing ECAs

without limit, other than practical fuel demand requirements.

A brief description of the LCF delivery system is provided below. A schematic of the delivery system is illustrated

in Figure 4-3. Further details of the system can be found in the Design and Operations Report (Golder 2012b).

The System has three distinct phases or sub-systems, as follows:

Fuel Off-Loading System;

Fuel Storage System; and

Fuel Injection System.

4.5.1 Fuel Off-Loading System

The Fuel Off-Loading System transfers prepared LCF into the Fuel Storage System for subsequent controlled

injection into the kiln burner by the Fuel Injection System. The Fuel Off-Loading System is located east of the

cement storage dome.

Fuel is typically transported to the Fuel Off-Load System in self-unloading tractor trailer trucks (e.g., walking

floor). The trucks back up to a stationary bunker where the prepared LCF is unloaded into a receiving hopper.

The fuel is subsequently transferred via a conveyor to the screening station. The presence of nails and other

metal components can result in damage to conveyance systems and, if in high enough amounts, can create a

risk of product contamination. Magnetic separation is a common material processing step and the number of

magnetic separation stages and the type of system will vary depending on the likelihood of metal contamination



in the fuel source material and the nature of the contamination. The screening station, in a series of steps,

removes oversized LCF materials and detects and removes small metal materials. These residual wastes

(e.g., tramp metal, off-spec material, and materials arising from maintenance activities on equipment) will be

removed from the LCF off-loading system and collected in bins for transport to a recycling/disposal facility.

After screening, the prepared LCF is transported via conveyor to a 3-way diverter valve in the Fuel Holding

System. LCF material is separated into one of two bulk storage bins, depending on the type of fuel, or it can

bypass the Fuel Storage System and go directly to the Fuel Injection System.

4.5.2 Fuel Storage System

The Fuel Storage System acts as the buffer between the Fuel Off-Load System and the Fuel Injection System

and, where both bulk storage bins and/or the bypass are in use, affords the opportunity to blend different types

of LCFs. Typically, the Fuel Storage System controls the unloading of material from the truck trailers.

The Fuel Storage System is comprised of two (2) bulk storage bins to hold the off-loaded prepared LCFs.

These bins can store up to an estimated 150 tonnes each. Two (2) discharge conveyors transport the fuel from

each bin to the Fuel Injection System. These conveyors operate independently, allowing different ratios or

blends of fuel to be transported. The blends of fuels will differ, dependent on the fuel availability at the time.

For the October 2014 stack test, the blend of LCFs was 40% railway ties, 30% asphalt shingles and 30% C&D

materials.

4.5.3 Fuel Injection System

From the Fuel Holding System, LCFs are transported via conveyor to the second screening station. Oversized

materials, or LCFs that have clumped together, are separated and directed to the grinder (or shredder) for

further processing. All materials are then transported via a long conveyor up to the burner floor in the mill

building into the kiln metering bin.

Using a series of conveyors, the fuel is transported to the air lock. The air lock is a rotary valve that keeps air

from entering the LCF conveying system. The kiln feed blower moves the fuel from the air lock to the injection

point and ultimately into the kiln. The flow rate of traditional and low carbon fuels is controlled to achieve a

uniform delivery and to ensure that minimum temperatures in the kiln are maintained. The average temperature

in the combustion zone is 1,450 degrees Celsius (the flame is significantly hotter); the residence time at

temperatures in excess of 1000 degrees Celsius is over 10 seconds. These temperatures are well in excess of

the temperatures necessary to ensure efficient combustion of the fuels used in the process and any products in

the fuels such as creosote.

4.6 Low Carbon Fuel Efficiency The Site will generate on average 17 gigajoules of thermal energy output from every tonne of LCF used. In a full

production year of 7400 hours of operation, this equates to approximately 400 terajoules of energy from LCF for

every 10% co-fire (substitution of traditional fuel with LCF) increase.



4.7 Low Carbon Fuel Storage The Pilot Project ECA (#9606-8Z7S9Z) allows for a maximum of 2,910 tonnes of LCF to be stored at the Site at

any one time. This includes unprocessed (whole) LCFs, partially and fully processed LCFs, and residual waste.

Lafarge is proposing to increase the maximum storage value to 45,000 tonnes, which represents 6 months of

LCF capacity (250 tonnes per day processed at Site for 180 days). This storage volume was derived based on

advice from stakeholders. Storage of LCF is critical to the operation of the plant to facilitate a continuous flow of

materials and manage seasonal supply fluctuations (for example, asphalt shingles would only be available in the

summer during the roofing season). Storage areas associated with the LCF are illustrated in Figure 4-1 and are

described in Table 4-5.

Table 4-5: Low Carbon Fuel Storage Areas

LCF Area Number

Description Type of Storage

LCF 1

2.1 hectare area situated west of the existing Bath Plant Solid Fuel Storage Area and abutting a section of the on-Site railway spur

LCF staging and processing operations will take place here. Short term storage of self-unloading trailers and dump trucks of unprocessed, partially and fully processed LCFs will be present. Temporary working stockpiles of unprocessed LCFs will be stored uncovered on the ground; stockpiles of partially and fully processed LCFs will be stored under a covered structure. On occasion, processed LCFs could be stored outdoors, under temporary cover such as tarps, for short periods of time to facilitate material handling and storage activities.

LCF 2 Repurposed former “Bunker C” building located near rail spur to west of cement storage silos

Short term storage of self-unloading trailers and dump trucks of unprocessed, partially and fully processed LCFs will be present.

LCF 3

Fuel Delivery system, located east of cement storage dome and south of kiln burner system, at grade and at the kiln burner elevation

Trailers, or storage with walking floor bins, of processed LCFs.

LCF 4 “LSI” building and storage hall Temporary working stockpiles of partially and fully processed LCFs. This storage is inside a building.

LCF 5 10 hectare area located east of the storage hall

Short term storage of self-unloading trailers and dump trucks of unprocessed, partially and fully processed LCFs will be present.

FF 1 Existing stockpile area for marine shipments of fossil fuels, gypsum, and slag

Unprocessed, partially and fully processed high density LCFs may be stockpiled here temporarily, in addition to fossil fuels. Non-hydrophobic fuels, or otherwise unsuitable for outdoor storage, will be covered.



4.8 Relevant Bath Operations Activities The Bath cement plant has been in operation for over 40 years, and has continually sought to improve the

efficiency of its operations and promote an environmentally sustainable business. The use of LCFs at the Bath

plant has been under consideration for many years, with the benefits/impacts to the plant’s sustainability

approach (environmentally sound, socially responsible, and economically viable) carefully evaluated. Operational

activities that have been considered are water usage, water discharge to the environment, and ash disposal.

4.8.1 Water Usage Relevant to the LCF Operations

Freshwater is supplied from Lake Ontario for dust control and, if necessary, fire protection at the cement plant in

accordance with the Permit to Take Water (PTTW) No. 4454-9ABRLX, dated August 7, 2013. Water is also

obtained from the on-Site quarry sumps in accordance with PTTW No. 6713-9QJJU9, dated January 19, 2015.

No changes to water usage or amendments to these permits are anticipated from the use of LCFs.

Surface water runoff from the staging/processing area (LCF 1) will be contained as much as practical in a lined

collection pond and used for dust control during the fuel shredding process. Water from the plant and/or the

quarry may be used to supplement the runoff water, if necessary, for dust control; however, the volume of water

is expected to be minimal.

4.8.2 Water Discharge to the Environment

The Bath plant currently has a stormwater management pond on the south end of the Site. This pond is

regulated by the Ontario government under ECA No. 3466-6G6PMQ, dated Sept 27, 2005. Under that regulatory

approval, Lafarge must monitor the pond on a weekly basis; all measured parameters must meet the stipulated

regulatory criteria prior to releasing the water to Lake Ontario.

No changes to the water quality in the stormwater management pond are anticipated from the processing and

use of LCFs; see Sections 5.2 and 8.1 for further details. Should monitoring in the lined sump at LCF 1 indicate

otherwise, Lafarge is committed to implementing mitigation measures to correct the issue, and if necessary,

treating the water prior to release to the environment.

4.8.3 Ash Production/Disposal

In a conventional combustion system, ash is produced from the non-combustible portion of fuel which consists of

ceramics, salts, metals, and minerals. The Bath Plant does not produce ash. As fuels are injected directly into

the kiln during the cement manufacturing process, and thus come into contact with the raw materials, the ash

components get incorporated into the final product.

Ash from other combustion sites is a valuable raw material; the Bath plant has historically recycled ash from

power plants as a raw material. This process of incorporating ash into the final product will not change with the

use of LCFs.



5.0 ENVIRONMENTAL SCREENING CHECKLIST TO IDENTIFY POTENTIAL ENVIRONMENTAL EFFECTS (ESP STEPS 3 & 4)

As discussed in Section 3, Lafarge is using an Environmental Screening Process (ESP) to assess the potential

environmental effects (including benefits) of using C&D materials, weathered treated wood (such as railway ties

and utility poles), and asphalt shingles as LCFs. The ESP is a multi-step process. Step 3 requires a Screening

Criteria Checklist be completed. This checklist is a comprehensive list of potential effects, and proponents must

review these criteria to assess which ones are applicable to the Project. Step 4 then requires a description of the

potential (i.e., screened in) negative effects to be addressed in the ESP.

As per Step 3 of the ESP, a draft of the Screening Criteria Checklist was presented at a public meeting in

October 2013. At that time Lafarge sought feedback from all interested stakeholders on the proposed Project,

and potential negative effects to be addressed. No further criteria or studies were identified by the stakeholders

in addition to the ones proposed by Lafarge and the research team. Further details on the public consultation

events are presented in Section 6 below.

The Screening Criteria Checklist is provided in Table 5-1. The following Sections discuss the preliminary

screening and assessment approach and provide the rationale for each of the Screening Criteria responses.

Table 5-1: Screening Criteria Checklist

Might the project… Yes NoAdditional Information / Potential Studies or Assessments

1. Surface and Ground Water

1.1 cause negative effects on surface water quality, quantities or flow?

Y

There is the potential for negative effects on surface water quality from LCF materials stored outdoors and uncovered, or from dust generated from the LCF shredding operations at LCF 1. Surface water runoff could contain low levels of contaminants. A surface water study was undertaken to assess the potential impacts. See Sections 5.2 and 8.1 for further details.

1.2 cause negative effects on groundwater quality, quantity or movement?

Y

There is the potential for negative effects on groundwater quality from LCF materials stored outside and uncovered leaching contaminants into the water table. A groundwater study was undertaken to assess the potential impacts. See Sections 5.2 and 8.1 for further details.

1.3 cause significant sedimentation or soil erosion or shoreline or riverbank erosion on or off site?

Y A surface water study was completed to assess potential impacts. See Sections 5.2 and 8.1 for further details.

1.4 cause negative effects on surface or ground water from accidental spills or releases (e.g., leachate) to the environment?

Y Surface water run-off and leachate risks are addressed in Points 1.1 and 1.2 above.





2. Land 2.1 cause negative effects on residential,

commercial, institutional or other sensitive land uses within 500 metres from the site boundary?

Y A land use and socio-economic study was completed to assess potential impacts. See Sections 5.3 and 8.4 for further details.

2.2 not be consistent with the Provincial Policy Statement, provincial land use or resource management plans?

N See Section 5.3 for further details.

2.3 be inconsistent with municipal land use policies, plans and zoning bylaws (including municipal setbacks)?


2.4 use lands not zoned as industrial, heavy industrial or waste disposal?


2.5 use hazard lands or unstable lands subject to erosion?


2.6 cause negative effects related to the remediation of contaminated land?


3. Air and Noise 3.1 cause negative effects on air quality due to

emissions (for parameters such as temperature, thermal treatment exhaust flue gas volume, nitrogen dioxide, sulphur dioxide, residual oxygen, opacity, hydrogen chloride, suspended particulates or other contaminants)?

Y

All thermal treatment facilities release emissions to the environment. While beneficial (or no) effects are expected, there is a potential for negative effects on air quality due to the emission of standard parameters (e.g., nitrogen dioxide, sulphur dioxide) and/or greenhouse gases (e.g., carbon dioxide) from the combustion of the LCF materials. A testing program evaluated the potential environmental effects to air quality. See Sections 5.4.1 and 8.2 for further details.

3.2 cause negative effects from the emission of greenhouse gases (e.g., carbon dioxide, carbon monoxide, methane)?

Y

3.3 cause negative effects from the emission of dust or odour?

Y

There is the potential for a localized odour while shredding LCF materials. This situation will be monitored. Dust from the shredding of LCF materials may cause a potential negative effect; fugitive dust control procedures will be revised. See Sections 5.4.2 and 8.2 for further details.

3.4 cause negative effects from the emission of noise?

Y

There is a potential for noise levels at the plant to increase due to the processing and combustion of LCF materials. Sound emissions will be analyzed to ensure compliance with applicable MOECC limits. See Sections 5.4.3 and 8.3 for further details.

3.5 cause light pollution from trucks or other operational activities?

N See Section 5.4.4 for further details.





4. Natural Environment 4.1 cause negative effects on rare (vulnerable),

threatened or endangered species of flora or fauna or their habitat?


4.2 cause negative effects on protected natural areas such as, ANSIs, ESAs or other significant natural areas?


4.3 cause negative effects on designated wetlands?


4.4 cause negative effects on wildlife habitat, populations, corridors or movement?


4.5 cause negative effects on fish or their habitat, spawning, movement or environmental conditions (e.g., water temperature, turbidity, etc.)?


4.6 cause negative effects on locally important or valued ecosystems or vegetation?


4.7 increase bird hazards within the area that could impact surrounding land uses (e.g., airports)?


5. Resources 5.1 result in practices inconsistent with waste

studies and/or waste diversion targets (e.g., result in final disposal of materials subject to diversion programs?


5.2 result in generation of energy that cannot be captured and utilized?


5.3 be located a distance from required infrastructure (such as availability to customers, markets and other factors)?


5.4 cause negative effects on the use of Canada Land Inventory Class 1-3, specialty crop or locally significant agricultural lands?


5.5 cause negative effects on existing agricultural production?






6. Socio-Economic

6.1 cause negative effects on neighbourhood or community character?


6.2 result in aesthetics impacts (e.g., visual and litter impacts)?

Y

Litter from the transportation, shredding and storage of LCF materials may cause a potential negative effect; the Site Housekeeping Program will be revised to include LCFs. See Sections 5.7 and 8.4 for further details.

6.3 cause negative effects on local businesses, institutions or public facilities?


6.4 cause negative effects on recreation, cottaging or tourism?

Y A land use and socio-economic study was completed to assess potential impacts. See Sections 5.7 and 8.4 for further details..

6.5 cause negative effects related to increases in the demands on community services and infrastructure?


6.6 cause negative effects on the economic base of a municipality or community?


6.7 cause negative effects on local employment and labour supply?


6.8 cause negative effects related to traffic? Y

LCF materials will be delivered to the Site in trucks using public roadways. There is the potential for increased traffic and other negative effects on the roadways. A traffic study was undertaken to assess the potential impacts. See Sections 5.7 and 8.4 for further details.

6.9 be located within 8 km of an aerodrome/airport reference point?


6.10 interfere with flight paths due to the construction of facilities with height (i.e., stacks)?


6.11 cause negative effects on public health and safety?






7. Heritage and Culture 7.1 cause negative effects on heritage buildings,

structures or sites, archaeological sites or areas of archaeological importance, or cultural heritage landscapes?


7.2 cause negative effects on scenic or aesthetically pleasing landscapes or views?


8. Aboriginal 8.1 cause negative effects on land, resources,

traditional activities or other interests of Aboriginal communities


9. Other 9.1 result in the creation of non-hazardous

waste materials requiring disposal? N See Section 5.10 for further details.

9.2 result in the creation of hazardous waste materials requiring disposal?


9.3 cause any other negative environmental effects no covered by the criteria outlined above?


5.1 Screening Criteria and Evaluation Approach As per the MOECC (2007) document, Guide to Environmental Assessment Requirements for Waste

Management Projects, potential effects of a Project are subdivided into nine (9) criterion categories.

These criterion categories are:

1) Surface and Ground water;

2) Land;

3) Air and Noise;

4) Natural Environment;

5) Resources;

6) Socio-Economic;

7) Heritage and Culture;

8) Aboriginal; and

9) Other.



Each category is then divided into a number of Screening Criteria that, as per the ESP, must be answered yes or

no on the Screening Criteria Checklist. Mitigation measures cannot be taken into account when addressing the

Screening Criteria. This means that any effects, both positive and negative, that may be possible are identified,

to ensure they are included in the ESP.

For this Project, the Screening Criteria were evaluated using a generalized risk assessment approach.

This approach considers the potential for a ‘source of contamination/effect’, ‘receptor that may be impacted’

and ‘exposure pathway’. Examples for each are provided below:

‘Source of contamination/effect’ could include a material leaching into the ground and/or groundwater,

a chemical parameter being emitted into the air, or a negative effect on a local business.

‘Receptor that may be impacted’ could include an aquatic or terrestrial animal, a specific habitat or

ecosystem, or a human being.

‘Exposure pathway’ is the means by which a contaminant can be transported to a receptor, and it must be

complete (in that it goes from A to B) to have a potential negative effect. This could include surface water

runoff flowing to the lake or increased machinery noise levels in proximity to public areas.

For a negative effect to be possible there must be a source, receptor and complete exposure pathway.

If there is the potential for a negative effect to occur, the Screening Criterion is indicated by a yes. If further

information must be obtained prior to responding yes or no, the Screening Criterion is also indicated by a yes

(until all of the information is known, there is still a ‘potential’ for a negative effect). If there is no anticipated

negative effect, the Screening Criterion is indicated by a no.

5.2 Surface and Groundwater This Project may negatively affect Surface and Groundwater Criteria.

Unprocessed LCF materials considered for this Project that may potentially be stored outdoors and uncovered

are, by their nature, pre-weathered (e.g., railway ties, utility poles and asphalt shingles). While there is a risk that

surface run-off water may be contaminated by these materials, or from dust generated from the processing of

the LCF materials, therefore a potential source of contamination, the risk is considered low. Other LCF materials

considered for this Project (e.g., unprocessed C&D materials), and processed or partially processed

LCF materials, will be stored in enclosed trailers or under cover so that the materials remain dry and protected

from the elements (e.g., rain, wind). A surface water study was undertaken to assess potential impacts to water

quality; a summary of the findings is presented in Section 8.1.

As part of the Site surface water management system, water is regulated through a stormwater management

pond and monitored as per provincial legislation. This system allows the Site to react to any emergency situation

and also minimizes the potential for contaminated water releases to the environment. The surface water study

identified potential exposure pathways for the Project, and confirmed that water from the LCF Management

Areas will be directed to the existing surface water management system. The surface water study assessed the

potential impacts to the surface water drainage system, including water quantity, flow, and sedimentation or

erosion; a summary of the findings is presented in Section 8.1.



Unprocessed LCF materials stored outdoors and uncovered, or dust generated from the processing of LCF

materials, also has the potential to leach contaminants (i.e., to be a potential source of contamination) into the

groundwater, although the risk of negative effects to groundwater quantity or flow is considered low.

A groundwater study was undertaken to assess baseline conditions for groundwater quality and potential

impacts to groundwater quality, quantity and flow; a summary of the findings is presented in Section 8.1.

Contingencies, such as accidental spills or releases, and emergency response procedures, are documented in

the approved Design and Operations Report (Golder 2012b) for the Low Carbon Fuel Demonstration Project.

Any negative effects on surface water or groundwater quality from accidental spills or releases are addressed by

the surface water and groundwater studies described above.

5.3 Land This Project may negatively affect Land Criteria.

Sensitive land uses can include any building or associated amenity area (i.e., residences, senior citizen homes,

schools, day care facilities, hospitals, churches and other similar institutional uses, or park campgrounds) which

is not directly associated with the industrial use, where humans or the natural environment may be adversely

affected. A land use and socio-economic study was completed and verified that there are no sensitive land uses

(receptors) within 500 metres of the Site boundary; further details of the land use study are presented in

Section 8.4.

This Project will be conducted in accordance with the Provincial Policy Statement, and provincial and municipal

land use policies, plans and zoning bylaws. This project is conducted on lands zoned as Aggregate, in an

Aggregate Specific Policy Area and Extractive Industrial Zone, which permits the establishment and use of an

aggregate processing plant and cement plant (see Section 2.5 for further details). This zoning also allows the

Site to receive and use fuels, including LCFs. There will be no use of hazard lands (or unstable lands subject to

erosion), nor will the Project cause negative effects to lands subject to remediation.

5.4 Air and Noise This Project may negatively affect Air and Noise Criteria.

5.4.1 Emissions

There is the potential for the use of LCF materials to change the air emissions from the cement manufacturing

process.

A number of studies were conducted to assess the potential effects on air quality due to the emission of products

of combustion (e.g., nitrogen dioxide, sulphur dioxide, hydrogen chloride, suspended particulates or other

contaminants) and greenhouse gases (e.g., carbon dioxide, methane). These products constitute ‘sources of

contamination’ to air quality that were evaluated by emission testing.

Notably, based on the “Greener Fuel Protocol”, described in Section 2.4, the selected LCFs were expected to be

cleaner in general than the current traditional fuels used (i.e., coal and petroleum coke); no new compounds of

concern were predicted and reductions in greenhouse gases (e.g., carbon dioxide, methane) were anticipated.

This was based on a whitepaper produced prior to commencing the project, which arose from the

recommendations received from the Lafarge Bath Plant Community Liaison Committee (CLC). During initial

discussions of the LCF program the CLC recommended the development of a “white paper” on the use of LCFs



with a particular emphasis on railway ties. This report, prepared by Chandler and Associates (2012), entitled

“Technical Backgrounder: Low Carbon Fuels, Guidelines for the Safe and Beneficial Use of Mixed Fossil &

Biomass Fuel Sources in the Cement Industry with a Focus on Railroad Ties”, was intended to aid in the

community’s understanding of proper combustion and expected performance of LCFs. The report concludes that

railway ties, and other LCFs, can be used safely to fuel cement plants. Eleven recommendations for the use of

LCFs were developed and all have been incorporated by Lafarge as part of the LCF program.

A summary of the findings of the various air studies, verifying the air quality predictions, is presented in

Section 8.2.

5.4.2 Dust and Odour

There is the potential for negative effects from dust or odour. However, these impacts have been addressed

through the Low Carbon Fuel Demonstration Project’s Environmental Compliance Approval (ECA) process

(ECAs #7984-8YYR75 and #9606-8Z7S9Z). It should be noted that no dust or odour studies were required

under this approval process.

The Site currently operates under a Fugitive Dust Best Management Practices Plan (BMPP) that has been

approved and enforced by the MOECC. While potential dust emissions from the shredding of LCF materials is

much less significant that the existing operations, this Fugitive Dust BMPP will be revised to include potential

dust from the LCF shredding operations.

No significant odours associated with the LCFs are anticipated. The LCF materials to be received will be made

up of weathered or stable organic (e.g., treated wood) and other inert inorganic materials (e.g., asphalt shingles),

which are not anticipated to result in odours. LCFs that have been shredded will be contained in enclosed trailers

or under cover to keep the materials dry. The shredding of treated wood may release a localized odour.

5.4.3 Noise

There is the potential for negative effects from noise. However, these impacts have been addressed through the

Permanent Low Carbon Fuel Project’s ECA process (ECA #3610-8Y9NVD).

An Acoustic Assessment Report (AAR) prepared in 2012 demonstrated that the Site is capable of operating in

accordance with the MOECC Noise Guidelines (MOECC 2013) and that noise levels associated with the

processing and combustion of LCFs would be a negligible contributor to the overall Site noise levels. This report

takes into account noise abatement measures and equipment maintenance programs implemented at the Site

over the past few years.

The AAR was updated by HGC in September 2015 (attached in Appendix F1) to include equipment from the

LCF delivery system (measured) and processing system (estimated). The results demonstrated that the Site

continues to operate in accordance with the MOECC Noise Guidelines; see Section 8.3 for further details.

5.4.4 Light

As this Project is located within a currently operating cement plant and quarry, there is no anticipated increase in

light emissions from trucks or other operational activities.



5.5 Natural Environment There are no anticipated negative effects from this Project to Natural Environment Criteria.

As this Project is located within a currently operating cement plant and quarry, there are no anticipated effects to

wildlife habitat, populations, corridors or movement. A small lined collection pond is proposed south of the quarry

at LCF 1; however, as this water body is located in the center of the Site, is expected to be dry for most of the

year, and is negligible in size in relation to Lake Ontario just south of the Site, it is not anticipated that birds or

other wildlife will be attracted to it. There are also no anticipated increases in bird hazards that could impact

surrounding land uses (i.e., airports).

Negative effects to fish or their habitat, spawning, movement or environmental conditions are not anticipated.

Surface water run-off has the potential to be contaminated from LCF materials when stored outdoors and

uncovered, or from dust generated from the LCF shredding operations at LCF 1; consequently surface water

may act as potential exposure pathway to receptors in the natural environment. However, the surface water

study undertaken for the Project confirmed that water from the LCF Management Areas will be directed to the

main quarry sump and ultimately to the existing stormwater management pond. This pond is regulated by the

Ontario government under ECA No. 3466-6G6PMQ, dated Sept 27, 2005, and no water may be discharged to

Lake Ontario without meeting regulatory discharge limits. Further details on the surface water study are

presented in Section 8.1.

As the Project areas are relatively small and highly disturbed by vehicles and other industrial activities, the

presence of or effects to rare (vulnerable), threatened or endangered species of flora or fauna or their habitat are

not anticipated. There are also no anticipated effects to locally important or valued ecosystems or vegetation.

Within the Project area, no protected natural areas such as Areas of Natural or Scientific Interest (ANSI), areas

protected by the Endangered Species Act (ESA), other significant natural areas, or designated wetlands have

been identified.

5.6 Resources There are no anticipated negative effects from this Project to Resources Criteria.

This Project will be conducted in a manner that is consistent with local waste studies and/or waste diversion

targets. As discussed in Section 2.2, the Government of Ontario promotes the reduction, reuse and recycling

(the 3 “R”s) of waste to keep these materials out of landfills. To achieve its vision of a ‘zero-waste’ society the

government has proposed a new Resource Recovery and Circular Economy Act (the draft bill was posted on the

ON Environmental Registry for public comment on November 26, 2015) to hold individual producers responsible

for recovering resources and reducing waste associated with their products and packaging, and establish a

strategy and identify actions to increase resource recovery and waste reduction in Ontario. While the LCFs

targeted under this Project (i.e., C&D materials, asphalt shingles, and weathered treated wood) are not currently

recycled, a number of municipal thermal treatment facilities across Canada have demonstrated that the use of

alternative fuels complements existing recycling and composting programs and can help to improve recycling

rates (Pollution Probe 2014). It is also important to note that Ontario produces approximately 12.5 million tonnes

of waste per year (OWMA 2015). For this Project, the maximum estimated usage of LCFs per year is 135,000

tonnes; this represents approximately 1% of the waste materials produced in the province being diverted from

disposal in landfills. Consequently, the use of LCFs at the Lafarge Bath Plant supports the government’s waste

reduction policy.



The LCF material will be received, processed and stored within the Site’s boundaries. These materials are being

utilized to generate heat in place of traditional fuels with the thermal energy being used in the cement

manufacturing process. Consequently, this Project will not result in a change in the generation of energy that

cannot be captured and utilized.

This Project is not expected to negatively affect Canada Land Inventory Class 1-3, specialty crops or locally

significant agricultural lands. These lands are not directly located on the Site, and as discussed in Section 5.4.1,

emissions from LCFs are expected to be cleaner than traditional fuels; a summary of the air studies, verifying the

air quality predictions, is presented in Section 8.2.

5.7 Socio-Economic This Project may negatively affect Socio-Economic Criteria.

Increased truck traffic on the public roadways from the delivery of LCF material to and from the Site could cause

negative effects on local traffic. A traffic study was conducted to assess the potential effects; a summary of the

findings are presented in Section 8.4.

There is a potential for the Project to cause aesthetic impacts (e.g., visual and litter) from the transportation,

shredding and storage of LCFs. A land use and socio-economic study was conducted to assess the potential

impacts; a summary of the findings is presented in Section 8.4.

There are no anticipated negative effects on community character, local businesses, institutions or public

facilities, recreation or tourism. No increases in demands on community services and infrastructure are

anticipated or negative effects on the economic base of the municipality or community, or local employment and

labour supply. In fact, there are a number of social benefits expected from the Project, including the creation of

new permanent jobs, educational opportunities, and a decrease in the amount of material destined for landfill.

A land use and socio-economic study was completed to assess the potential impacts to verify these predictions;

a summary of the findings is presented in Section 8.4.

This Project will not be located within 8 km of an aerodrome/airport, nor will any equipment or infrastructure

interfere with flight paths. There are no anticipated negative effects on public health and safety.

5.8 Heritage and Culture There are no anticipated negative effects from this Project to Heritage and Culture Criteria.

This Project is located within a currently operating cement plant and quarry. There are no heritage buildings,

structures or sites, archaeological sites or areas of archaeological importance within the Site, and no effects to

cultural heritage landscapes, or scenic or aesthetically pleasing landscapes or views are anticipated.

5.9 Aboriginal There are no anticipated negative effects from this Project to Aboriginal Criteria.

No negative effects on land, resources, traditional activities or other interests have been identified by Aboriginal

communities. A summary of consultation and engagement activities with Aboriginal communities is provided in

Section 6.3.



5.10 Other There are no anticipated negative effects from this Project to Other Criteria.

This Project will not result in the creation of non-hazardous or hazardous waste materials. Non-combustible

fractions of LCF (i.e., ash) are recycled into cement as part of the cement production process. Some materials in

the LCFs may be rejected in the fuel staging and processing system and require disposal or recycling (for

example, nails in the construction boards will be sent for recycling). However, this waste is minor with respect to

the total volume of LCF material, and this waste would have otherwise gone straight to the landfill for disposal.

6.0 CONSULTATION AND ENGAGEMENT (ESP STEPS 1, 5, 8 & 12) Consultation with the public and Aboriginal communities is a key aspect of an environmental assessment.

Consultation with interested and potentially affected parties provides an opportunity for meaningful input into the

process. The consultation program undertaken for this Project was guided by the Consultation Plan developed

by the Project Team based on the Guide to Environmental Assessment Requirements for Waste Management

Projects (MOECC 2007), the core values of the International Association of Public Participation and best

practices for meaningful consultation, and incorporating feedback from participants on how best to engage them

in the process. A high level overview of the consultation program demonstrating how the regulatory requirements

have been met is provided in Sections 6.1 to 6.3. A detailed account of the Consultation Plan and consultation

program completed for the Project is provided in the Consultation Report in Appendix C.

6.1 Public Consultation Process Overview As detailed in the Guide to Environmental Assessment Requirements for Waste Management Projects (MOECC

2007), there are four (4) mandatory consultation activities with government agencies, interested persons and

Aboriginal communities. These consultation activities and their dates of completion for this Project are provided

below in Table 6-1.



Table 6-1: Mandatory Consultation Activities

Consultation Activity

Date Completed / Details Relevant Section(s) of Consultation Report (Appendix C)

Notice of Study Commencement (ESP Step 1)

September 17, 2013 and October 1, 2013

The Notice of Study Commencement and Notice of First Public Meeting contained all required information and was distributed to the stakeholder list and posted in the Kingston Whig Standard.

Section 2.1 and Section 3.3

Public Meeting #1 (ESP Step 5)

October 8, 2013 at the Loyalist Golf & Country Club from 7:00 pm to 9:00 pm.

The public meeting was held in an Open House format with display boards arranged around the room and Project Team members on hand to answer questions from participants.

The public meeting was attended by 28 people and 13 comment forms were completed.

Section 3.6

Public Meeting #2 (ESP Step 8)

June 9, 2015 at the Loyalist Golf & Country Club from 7:00 pm to 9:00 pm.

The public meeting was also held in an Open House format with Project team members on hand to answer questions from participants.

The public meeting was attended by 43 people and 5 comment forms were completed.

Section 3.10

Notice of Completion (ESP Step 12)

The Notice of Completion will contain all required information and will be distributed to the stakeholder list and posted in the Kingston Whig Standard.

Section 4.0

6.2 Public and Agencies Prior to issuing the Notice of Commencement for this Project Lafarge and Golder met with representatives of the

MOECC in Kingston Ontario to provide an overview of the Project and review the Draft Screening Criteria

Checklist, Draft Consultation Plan and proposed Project timelines. In addition, prior to the First Public

Open House, Lafarge attended the Loyalist Township Council’s Administration Committee meeting to discuss

the Cement 2020 initiative and the LCF Project. The MOECC and the Loyalist Township have continued to be

consulted with throughout the Project; additional details on all correspondence and meetings with these

stakeholders are provided in Section 3 of the Consultation Report (Appendix C).

Prior to finalizing the technical studies, draft reports of all air quality, noise, water (surface water and

groundwater) and socio-economic (including traffic) studies in support of the Project were provided to the

MOECC for review and comment. The comments provided by the MOECC technical reviewers and

the responses from Lafarge were organized by discipline and presented in a comment response table.

This comment response table is provided in Appendix G of the Consultation Report (Appendix C).



The Lafarge Community Liaison Committee (CLC) meets several times a year with representatives from different

sectors of the community, including local businesses, residents associations, community groups, nearby city

councils, and regulatory bodies such as the MOECC and the local Health Unit. The CLC is a key point of contact

between Lafarge and the community, designed to facilitate an exchange of information and the opportunity for

the community and stakeholder groups to provide feedback. The CLC met several times throughout the Project

to discuss the progress of the LCF program. In addition, Lafarge met with or provided information regarding the

Project to many individual members of the public, non-government organizations, and local community groups.

Further information on the CLC meetings, and other communications with the public, is available in Section 3 of

the Consultation Report (Appendix C).

Two public meetings were held throughout the Project, in accordance with the Guide to Environmental

Assessment Requirements for Waste Management Projects (MOECC 2007). The first meeting was held on

October 8, 2013 and provided an overview of the Project and presented a draft of the Screening Criteria

Checklist. The second meeting was held on June 9, 2015 and provided a summary of the technical studies

completed for the Project. In addition, Lafarge held open houses at their Bath Plant on October 5, 2013, in

celebration of their 40th anniversary, and October 9, 2014 providing tours of the Site, including the LCF fuel

delivery platform, and information on the Project and the air emissions stack testing program. Further information

on the public meetings and open houses is available in Section 3 of the Consultation Report (Appendix C).

Table 6-2 below provides a summary of key concerns raised by the public through the consultation program and

how those concerns were addressed. Detailed information on individual concerns raised and how Lafarge

responded are provided in Appendix E of the Consultation Report (Appendix C).

Table 6-2: Summary of Key Concerns Raised and How Addressed

Concern How Addressed

Concerns about air quality

Lafarge is committed to rigorous emissions testing and evaluation as part of this Project, and as required by the MOECC’s Environmental Compliance Approval. Air studies conducted for the Project verify that the LCF materials have a neutral to beneficial effect on air emissions. A summary of the findings of the various air studies is provided in Section 8.2.

Concerns about noise

Noise levels have been addressed through the Permanent Low Carbon Fuel Project’s ECA process (ECA #3610-8Y9NVD). An Acoustic Assessment Report (AAR) prepared in 2012 demonstrated that the Site is capable of operating in accordance with the MOECC Noise Guidelines and that noise levels associated with the processing and combustion of LCFs would be a negligible contributor to the overall Site noise levels. This report takes into account noise abatement measures and equipment maintenance programs implemented at the Site over the past few years. The AAR was updated by HGC in September 2015 (attached in Appendix F1) and demonstrated that the Site continues to operate in accordance with the MOECC Noise Guidelines; see Section 8.3 for further details.



Table 6-2: Summary of Key Concerns Raised and How Addressed

Concern How Addressed

Concerns about water quality

Unprocessed LCF materials considered for this Project that may potentially be stored outdoors and uncovered are, by their nature, pre-weathered (e.g., railway ties, utility poles and asphalt shingles). While there is a risk that surface run-off water, and ultimately groundwater, may be contaminated by these materials, or from dust generated from the processing of the LCF materials, and therefore a potential source of contamination, the risk is considered low.

A surface water study was undertaken to assess potential impacts to water quality and the surface water drainage system, including water quantity, flow, and sedimentation or erosion; a summary of the findings is presented in Section 8.1. A groundwater study was undertaken to assess potential impacts to groundwater quality, quantity and flow; a summary of the findings is presented in Section 8.1.

Concerns about increased traffic and haul routes

Increased truck traffic on the public roadways from the delivery of LCF material to and from the Site could cause negative effects on local traffic. The haul routes are designated by Lennox & Addington County and Lafarge is required to use these designated haul routes. Lafarge has a traffic management plan and it is a contract requirement for all hauling companies working with the Bath plant to comply with the requirements in this plan.

A traffic study was conducted to assess the potential effects of increased traffic on the public roadways; a summary of the findings is presented in Section 8.4.

6.3 First Nations and Aboriginal Communities On August 30, 2013 the MOECC provided Lafarge with a list of Aboriginal communities that may be interested in

the Project. This list of Aboriginal communities included:

Alderville First Nation;

Curve Lake First Nation;

Hiawatha First Nation;

Mississaugas of Scugog Island First Nation;

Kawartha Nishnawbe First Nation;

Mohawks of the Bay of Quinte;

High Lands and Waters Métis Council; and

Métis Nation of Ontario.



The identified Aboriginal communities were provided with the following Project information on September 10,

2013:

Letters introducing the Project and the ESP;

The Notice of Commencement and First Public Meeting;

A copy of the Draft Project Description Report; and

A copy of the Draft Screening Criteria Checklist.

A letter with the Notice of the Second Public Meeting was provided to the Aboriginal communities on May 8,

2015. Curve Lake First Nation, in a letter dated May 20, 2015, suggested that Lafarge contact the Williams

Treaty First Nation Claims Coordinator. Lafarge reached out to the Williams Treaty First Nations Claims

Coordinator on June 23, 2015 providing a letter introducing the Project and inviting comments.

None of the Aboriginal communities contacted identified concerns with the Project. No archaeological impacts or

negative environmental impacts on Treaty or Aboriginal rights were identified for this Project. A detailed account

of all communications with Aboriginal communities is provided in Section 2.0 of the Consultation Report

(Appendix C).

7.0 EFFECTS ASSESSMENT APPROACH Components of the environment identified in the Screening Criteria Checklist (Section 5) as having the potential

to be affected by the Project were assessed to determine if they would be affected by the Project, and if that

effect was anticipated to be significant. The effects assessment for each environmental or social component

consisted of the following steps:

1) identify the spatial and temporal boundaries of the assessment;

3) characterize the existing environment;

4) characterize environmental and social effects;

a) identify potential effects;

b) implement mitigation measures;

c) determine residual effects;

5) evaluate the significance of residual effects (if any);

6) identify follow up monitoring (if necessary); and

7) evaluate cumulative effects.

These steps are explained further in the following sections.



7.1 Identify the Spatial and Temporal Boundaries of the Assessment Spatial boundaries define the geographical extent(s) within which the assessment is carried out. The boundaries

encompass the environment that can reasonably be expected to be affected by the Project. The environmental

assessment component studies consider potential effects at two spatial scales:

The Site Study Area (SSA) is the same for each component. It is defined as the area housing all facilities,

buildings, and infrastructure associated with the Project.

The Component Study Area (CSA) is unique for each component. In general terms, the CSA includes that

area existing outside the SSA where there is reasonable potential for immediate effects due to either

ongoing normal activities or accidents or malfunctions. The CSAs for each component are defined in the

various subheadings under Section 8.0 of this report.

The temporal boundary considered for this assessment was solely the operations phase of the Project.

This phase is expected to last for the duration of the Bath quarry operations, anticipated for another 100 years.

A construction phase was not evaluated as Lafarge has approval (ECA #3610-8Y9NVD) to construct and

permanently operate the LCF fuel management system. The retirement phase was also not evaluated, as there

is a Quarry Rehabilitation Plan in place that describes the eventual closure of the Site. Further details on the

Project phases are provided in Section 4.2.

7.2 Characterize the Existing Environment Depending on the environment or social component, various methods are used to characterize the existing

environment. The characterization of the existing environment forms the baseline against which potential

changes in environmental or social conditions are evaluated and effects are assessed.

7.3 Characterize Environmental and Social Effects 7.3.1 Identify Potential Effects

Potential effects identified in the Screening Criteria Checklist are further assessed using information obtained

from additional studies and the characterization of the existing environment. Project activities are evaluated to

identify Project-Environment interactions and determine if the Project will cause a measurable change to the

environment. Descriptions of the potential effects are based on both qualitative and quantitative assessments.

Specific assessment criteria are applied to evaluate the importance of each effect according to provincial or

federal limits and/or criteria; if not available, then studies from peer-reviewed scientific journals and/or

professional judgments are employed. When determining the potential for an effect, elements inherent in the

design of the Project are considered.

7.3.2 Implement Mitigation Measures

When a measurable change or effect is predicted, mitigation measures are developed to avoid, minimize or

eliminate the effect. These measures can include design modifications, alternatives, and/or operational

modifications.



7.3.3 Determine Residual Effects

If the effects assessment concludes that a potential effect cannot be fully mitigated (i.e., the potential effect is

below the relevant approval or permit limits or is determined to be negligible) then a residual “net” effect is

identified. All residual adverse effects are carried forward for an assessment of significance.

7.4 Evaluate the Significance of Residual Effects For those residual effects that were identified, an assessment is completed to determine if those residual effects

could be considered significant adverse effects. In determining whether a significant adverse effect is likely to

occur, some or all of the following criteria are considered:

Magnitude: the size or degree of the effect compared with existing conditions;

Geographic Extent: the area over or throughout which the effects are predicted to occur;

Duration: the time period for which it is expected that the effect will last;

Frequency: the probable rate of reoccurrence of the effect (or conditions causing the effect);

Degree of Reversibility: the degree to which the effect may be reversed (typically as measured by the time it will take to restore the environmental feature);

Ecological Context: the resilience of the receptor to the potential adverse effects of the Project; and

Social Context: the resiliency or vulnerability to change.

7.5 Identify Follow up Monitoring A follow up monitoring program will be developed should monitoring be required for any component to verify

predictions made in the effects assessment and/or confirm that mitigation measures are effective. The program

will include the frequency and location of sampling, parameters to be monitored, and criteria to be evaluated

against.

7.6 Evaluate Cumulative Effects In addition to the assessment of environmental or socio-economic effects of the Project by itself, an assessment

was completed for residual effects of the Project in combination with those from other projects and activities that

have been, or will be, carried out, and which may interact with the effects of the Project both temporally and

spatially. Regarding future projects and activities, attention is focused on those that are certain to proceed

(e.g., approved) or are reasonably foreseeable, as well as related future development assumptions. Cumulative

effects may also include natural influences on biophysical and socio-economic components prior to, during and

after development of the Project (e.g., extreme rainfall events, periodic harsh and mild winters, economic

changes that are independent of the Project).



8.0 ASSESSMENT OF POTENTIAL EFFECTS AND DEVELOPMENT OF IMPACT MANAGEMENT MEASURES (ESP STEPS 6, 7 & 9)

Components of the environment identified in the Screening Criteria Checklist (Section 5) as having the potential

to be affected by the Project were assessed to determine if they would be affected by the Project, and if that

effect was anticipated to be significant. The effects assessment for each environmental or social component

followed the approach described in Section 7. The following sections provide a summary of the assessments for

the water, air, noise, and land use and socio-economics components.

8.1 Water (Surface Water and Groundwater) An assessment to address the potential environmental effects to surface and groundwater was completed for the

Project. These potential effects were identified on the Screening Criteria Checklist (Section 5) based on the

following questions:

Might the Project:

1.1 cause negative effects on surface water quality, quantities or flow?

1.2 cause negative effects on groundwater quality, quantity or movement?

1.3 cause significant sedimentation or soil erosion or shoreline or riverbank erosion on or off site?

1.4 cause negative effects on surface or ground water from accidental spills or releases

(e.g., leachate) to the environment?

For effects to surface and groundwater, the CSA is defined as the area that either surface or groundwater

affected by the Project could reasonably be expected to flow or influence. For this Project, the CSA is confined to

the Site boundary as both surface and groundwater potentially affected by the Project are directed to a

Stormwater Management (SWM) pond and monitored/controlled prior to discharge to the natural environment.

A summary of the environmental assessment findings is provided in Sections 8.1.1 to 8.1.4. Water monitoring

commitments for the Project are summarized in Section 8.1.5.

8.1.1 Existing Environment

In general, the Lafarge Bath Plant is underlain by a thin overburden cover which in turn is underlain by Paleozoic

limestone bedrock. Based on existing records and visual inspection of the proposed LCF Staging/Processing

area at LCF 1, the geology in the area is as follows:

Overburden comprised predominantly of glaciolacustrine silts and clays that range in thickness from

approximately 0 m to 3 m;

Verulam Formation bedrock comprised of a light grey, microcrystalline, low porosity limestone with

thin/weak shale bedding planes. The uppermost 6 m of the bedrock is heavily weathered; however, bedrock

fracturing decreases significantly at depths greater than 6 m beneath the bedrock surface. The Verulam

Formation ranges in thickness from approximately 24 to 33 m;

Bobcaygeon Formation bedrock, approximately 3 m thick and comprised of dark grey to black shale

interbedded with calcareous limestone; and



Gull River Formation bedrock comprised of a bedded, light grey, medium to fine grained limestone.

Below the weathered bedrock zone, fracturing is predominantly associated with bedding planes; however, most

of the bedding plane fractures are not water-bearing. The weathered uppermost portion of the limestone bedrock

appears to represent the primary water bearing zone. Further details on the geology of LCF 1 are provided in the

Groundwater Technical Study completed for the Project, attached to this report in Appendix D1.

The existing active quarry extracts the full depth of the Verulam Formation bedrock down to the top of the

Bobcaygeon Formation bedrock. Groundwater level data indicates a groundwater level of approximately 73

metres above sea level (masl) in the vicinity of LCF 1. With lake levels estimated at 75 masl, it is likely that the

groundwater levels show the effect of drawdown from the quarry sump which is located 15 m north of LCF 1.

The groundwater in the overburden and bedrock is mineralized, and may be generally characterized as hard,

calcium, magnesium, bicarbonate and sulphate water, with trace concentrations of metals, which is typical of that

encountered in limestone aquifers. Further details on the existing groundwater conditions are provided in

Appendix D1.

A desktop analysis and site visit were undertaken to assess existing surface water conditions. Surface water

drainage from the Site ultimately discharges to Lake Ontario (located immediately south of the Site) via the

following two features:

Stormwater Management (SWM) Pond – The SWM pond is located south of the main plant buildings and

receives runoff from the plant building areas, as well as from the area northeast of the storage hall.

The SWM pond has a total volume of approximately 6,000 m3 and flows are directed to it via a network of

drainage ditches and storm sewers. The SWM pond is approved under ECA No. 3466-6G6PMQ and is also

regulated under O. Reg. 561/94.

West Drainage Channel – The channel is located to the west of the main plant area. Water is generally

conveyed from north to south along the length of the feature, ultimately draining to Lake Ontario through a

culvert at Highway 33. The West Drainage Channel is relatively small, grass-lined, and understood to

support ephemeral flows. There are currently no known erosion or sedimentation issues at the feature.

The West Drainage Channel is assumed to receive surface water runoff from the areas west of the main

plant buildings; however, it was not possible to define the catchment divide between the West Drainage

Channel and SWM Pond during the site visit. During the design and construction phase of the project,

the drainage to the west of the plant area will be further investigated and confirmed.

Further details on the existing surface water conditions are provided in the Surface Water Technical Study

completed for the Project, attached to this report in Appendix D2.

8.1.2 Potential Environmental Effects

Surface and Groundwater Quality

The handling, stockpiling and processing of LCF materials at the Site may result in contact between the LCF and

rainfall or snowmelt, with the potential for increased concentrations of one or more water quality parameters in

the surface water environment. This may occur where unprocessed and processed (shredded) LCF materials

are stored, assuming that unprocessed materials include whole pieces of weathered treated wood (such as

railway ties and utility poles), asphalt shingles, and C&D materials. However, all shredded LCF materials will be



stockpiled under a covered structure (at LCF 1) or delivered and stored in enclosed trailers apart from short term

staging operations. Unprocessed C&D materials will also be stored under cover (i.e., under tarps) at LCF 1 or in

enclosed trailers. The storage of processed (shredded) LCF materials and unprocessed C&D materials under

cover is anticipated to greatly decrease the opportunity for contact with rainwater and snowmelt, and has

co-benefits of keeping the fuel dry to maximize fuel quality. Unprocessed weathered treated wood (such as

railway ties and utility poles) and asphalt shingles will be stored uncovered; however, these materials have been

previously exposed outdoors for a long period of time, meaning that they have minimal potential to leach

chemical constituents to the surface water environment (Brooks 2004; Innovative Waste Consulting Services

2007; Townsend, 1998). Overall, the predicted likely effect of material/water contact (i.e., interaction between

LCF materials and rainfall or snowmelt generated runoff) on surface water quality conditions at the Site’s

discharge is expected to be negligible.

In addition, the handling of LCF material (relevant to all LCF areas) may result in dust generation, recognizing

that dust can settle on the ground and become entrained in rainfall or snowmelt runoff as total suspended solids

(TSS). To address these potential concerns, the Project will employ best management practices (BMPs) that

include a dust control and housekeeping plan at all areas where LCF materials are processed or handled.

At LCF 1 in particular, the potential for increased TSS concentrations will be further mitigated by re-grading the

area and constructing a geomembrane lined runoff collection pond west of the area. Runoff from the LCF 1 area

(including the LCF material storage cover) will be directed to the pond, which is intended to provide TSS settling

per MOECC guidelines (MOECC 2003), and a source of water for dust suppression purposes. Overall,

the predicted likely effect of dust on water quality conditions (from the potential leaching of chemical

constituents) at the Site’s discharge is expected to be negligible. Further details on the potential effects to

surface water quality are provided in Appendix D2.

Some surface water at LCF 1 may migrate over time through the constructed pad and fractured bedrock to the

groundwater environment. However, as stated above, the predicted likely effects to surface water quality are

expected to be negligible. In addition, groundwater in the vicinity of LCF 1 would flow to the main quarry sump

and subsequently be managed in accordance with the existing surface water handling procedures for the quarry.

Further details on the potential effects to groundwater quality are provided in Appendix D1.

Groundwater Quantity and Flow Direction

A review of MOECC water well records show that there are 41 off-Site private wells located within a 500 m

radius of the Bath Plant. Water supply for the surrounding village of Bath and the town of Greater Napanee is

obtained from intakes on Lake Ontario. The village of Bath is supplied by the Bath Drinking Water System and

the town of Greater Napanee is supplied by the Sandhurst Shores Drinking Water System.

There will be no taking of groundwater and no significant change to the groundwater flow regime in the vicinity of

the proposed LCF staging/processing area at LCF 1. Therefore, there will be no effects on groundwater quantity

obtained from the identified private wells as a result of the LCF Project. Further details on potential effects to

groundwater quantity and flow are provided in Appendix D1.

Surface Water Quantity and Erosion

The covered structure and re-graded area may result in increased peak flow volumes at LCF 1, as well as at the

downstream receiving watercourse. However, the proposed covered structure (with an approximate surface area

of 800 m2) represents only about 4% of the total area of LCF 1 (2.1 hectares). Moreover, peak flows from the



LCF 1 area will be attenuated by the runoff collection pond, recognizing that this feature will have a total storage

capacity of 1200 m3 (including the extended detention capacity of 670 m3) with the opportunity to hold up to the

volume of a 24-hour, 10-year return period rainfall event (62 mm). As such, any changes to surface water

quantity and erosion-sedimentation processes downstream of the LCF 1 area are expected to be negligible.

In addition, overflow from the runoff collection pond will be diverted to the quarry sump north of the LCF 1 area,

and ultimately to the SWM Pond (away from the West Drainage Channel where it is currently assumed to drain).

This alteration to local drainage patterns may result in changes to flow volumes at the downstream receivers.

However, the modification in drainage patterns and related catchment area represents an increase of

approximately 2.1 hectares or less than 5% to the total catchment area at the SWM Pond (104.8 hectares) and

an associated decrease of approximately 20% to the West Drainage Channel. As such, the predicted effect to

surface water quantity and erosion-sedimentation processes at, and in the area upstream of, the SWM pond is

expected to be negligible, while the corresponding effects on these considerations at the West Drainage

Channel is anticipated to be moderate.

It is important to mention that the peak flow rates from LCF 1 to the SWM Pond will be attenuated by the main

quarry sump, meaning that discharge from the quarry sump to the SWM Pond will be maintained at the existing

discharge rate. Further details on potential effects to surface water quantity and channel erosion are provided in

Appendix D2.

8.1.3 Impact Management Measures

Based on the results of the effects assessment, no additional mitigation measures are deemed applicable

beyond the measures already identified in the Project description (Section 4). The BMPs and mitigation

measures that were considered as part of the assessment include:

a dust control and housekeeping plan at all areas where LCF materials are processed or handled to

address any accidental spills of processed fuels in a timely manner;

storage of only unprocessed weathered or hydrophobic materials outdoors and uncovered; other non-

hydrophobic unprocessed materials and all processed fuels to be stored under cover to minimize the

opportunity for contact with rainwater and snowmelt;

a covered structure to be installed in LCF 1 to minimize the opportunity for processed fuels to come into

contact with rainwater and snowmelt; and

re-grading LCF 1 area and constructing a geomembrane lined runoff collection pond to reduce impacts

from dust during the LCF processing operations.

8.1.4 Net Effects and Significance

A summary of the predicted likely effects to groundwater and surface water associated with the identified project-

environment interactions is provided in Table 8.1-1. No residual adverse effects are predicted on groundwater

quantity and flow, and groundwater quality due to the handling, stockpiling and processing of LCF materials at

the Site.

In general, the residual adverse effects of the Project on surface water conditions are also anticipated to be

negligible. As an exception, the predicted likely effects on surface water quantity and flow at the West Drainage

Channel are expected to be measurably reduced by 20% and therefore considered moderate in magnitude.



Surface water flows reporting to the West Drainage Channel are ephemeral (i.e., the Channel is often

characterized by dry conditions), recognizing that upstream runoff largely infiltrates before reaching the

downstream portions of the Channel. For this reason, any potential effect to flow conditions and erosion-

sedimentation processes at the West Drainage Channel would be limited to larger rainfall or snowmelt events

(i.e., short duration and low frequency). Furthermore, the anticipated changes to streamflow and related

opportunities for erosion-sedimentation processes are not expected to adversely influence channel stability.

Consequently, the effect is considered minor or insignificant.

Table 8.1-1: Net Effects to Water

Criteria Potential Effects Mitigation Measures Residual Adverse Effect

Groundwater quantity and flow

Groundwater levels and/or flow at nearby off-site private wells affected by LCF staging/processing area

None None (no change)

Groundwater quality

Increase in concentrations of one or more water quality parameters due to contact between rainfall or snowmelt and LCF materials

Covered LCF material storage areas Groundwater in the vicinity of LCF 1 would flow to the main quarry sump and be managed in accordance with the existing surface water handling procedures for the quarry

None (Predicted likely effects are expected to be negligible)

Groundwater quality Leaching from dust generated particles

Dust control and housekeeping plan


Surface water quality

Increase in concentrations of one or more water quality parameters due to contact between runoff and LCF stockpiles

Covered LCF material storage areas Surface water flows from LCF staging/processing area would be directed to a lined collection pond; excess surface water volumes would be discharged to the quarry and managed in accordance with the existing surface water handling procedures for the quarry


Surface water quality

Increase in TSS from dust generation and mobilization when in contact with runoff at all LCF areas

Dust control and housekeeping plan and runoff collection pond at LCF 1




Table 8.1-1: Net Effects to Water


Surface water flow

Increase in peak flow volumes at LCF 1 due to the covered storage area and re-graded surface

Runoff collection pond at LCF 1


Surface water quantity and flow

Increase in drainage area and related flow volumes to the quarry sump (and ultimately to the SWM Pond)

None None (Predicted likely effects are expected to be negligible)

Surface water quantity and flow

Decrease in drainage area and related flow volumes to the West Drainage Channel

None

Moderate effect, but not significant (drainage patterns to the west of the plant area will be further investigated and confirmed during the construction of the LCF 1 grading pad)

8.1.5 Monitoring Commitments

The existing monitoring commitments for surface water at the SWM Pond are provided in Table 8.1-2.

In addition, a follow up monitoring program has been developed for the Project to verify the predictions from the

effects assessment for surface water and groundwater. The follow up monitoring program is outlined

in Table 8.1-2; further details of the monitoring programs for groundwater and surface water are provided in

Appendices C1 and C2, respectively.

Table 8.1-2: Monitoring Commitments for Surface and Groundwater

Media Activity Location Frequency of Sampling

Parameters to be Measured

Surface Water Effluent water quality monitoring as a requirement under O. Reg. 561/94

SWM Pond discharge

Weekly, Quarterly or Semi-Annually (as required)

TSS, pH, E. Coli, acute lethality (rainbow trout and Daphnia magna) and chronic toxicity (fathead minnow and Ceriodaphnia dubia)

Surface Water Water quality sampling to verify predictions made in the assessment

Runoff Collection Pond at LCF 1

Semi-annual

polycyclic aromatic hydrocarbons, semi-volatile hydrocarbons, total metals, and total phenols



Table 8.1-2: Monitoring Commitments for Surface and Groundwater



Surface Water Effluent water quality monitoring as a requirement under O. Reg. 561/94

SWM Pond discharge

Weekly, Quarterly or Semi-Annually (as required)

TSS, pH, E. Coli, acute lethality (rainbow trout and Daphnia magna) and chronic toxicity (fathead minnow and Ceriodaphnia dubia)

Groundwater Water quality sampling to verify predictions made in the assessment

Two new wells at LCF 1

Semi-annual

polycyclic aromatic hydrocarbons, semi-volatile hydrocarbons, dissolved metals, and dissolved phenols

8.1.6 Cumulative Effects

As discussed in Section 8.1, both surface and groundwater potentially affected by the Project are directed to a

SWM pond and monitored/controlled prior to discharge to the natural environment. No residual effects of the

Project to surface or groundwater would be expected to influence effects from other projects or activities;

consequently, no cumulative effects assessment was completed.

8.2 Air Quality (including Dust and Odour) An assessment to address the potential environmental effects to air quality, dust and odour was completed for

the Project. These potential effects were identified on the Screening Criteria Checklist (Section 5) based on the

following questions:

Might the Project:

3.1 cause negative effects on air quality due to emissions (for parameters such as temperature,

thermal treatment exhaust flue gas volume, nitrogen dioxide, sulphur dioxide, residual oxygen,

opacity, hydrogen chloride, suspended particulates or other contaminants)?

3.2 cause negative effects from the emission of greenhouse gases (e.g., carbon dioxide, carbon

monoxide, methane)?

3.3 cause negative effects from the emission of dust or odour?

For air quality, the CSA is a distance of 8 km of any emission source. This study area is consistent with the

MOECC requirements to obtain an Environmental Compliance Approval.

A summary of the environmental assessment findings is provided in Sections 8.2.1 to 8.2.4. Air monitoring

commitments for the Project are summarized in Section 8.2.5. In addition to answering the above questions,

an assessment of air quality effects of the Project in combination with those from other projects and activities

that have been, or will be, carried out, and which may interact with the effects of the Project was completed.



Potential emission sources within 30 km of the Project site in the prevailing upwind direction and within 20 km in

the prevailing downwind direction were considered. A summary of these findings is provided in Section 8.2.6.


In the vicinity of the Project Site, the general background air pollution levels are considered to be those pollution

levels that would remain if the effects of emissions from the Project and those from other significant emission

sources in the surrounding area were removed. The most practical way to characterize the general background

air quality is to use historical ambient air quality monitoring data that have been collected in land use settings

that are similar to the study area, but without the influence of significant local emission sources.

The ‘Background Air Quality & Cumulative Effects Analysis’ report, prepared by RWDI Air Inc. (RWDI) in 2015,

attached as Appendix E1, summarizes monitoring data taken from both the MOECC and Environment Canada

(EC) National Air Pollution Surveillance (NAPS) ambient air monitoring networks. The report identifies eight

monitoring stations to represent the contribution of the background sources as discussed above; the stations

chosen were either similar to the Project site location (rural, suburban or lakefront settings) with a sufficient

number of years of data, or were located in urban areas but were the only stations that have data available for

the compounds of interest.

The representative background air quality concentrations were compared against Ontario’s Ambient Air Quality

Criteria (AAQC), as defined by the MOECC (2012), or other relevant criteria where no Ontario AAQC

exists (such as the Canadian Ambient Air Quality Standards or World Health Organization Guideline);

further explanation of the criteria used in the data analysis are provided in Section 2.4 of RWDI’s ‘Background

Air Quality & Cumulative Effects Analysis’ report (Appendix E1). Results of the background air quality data

analysis, as reported by RWDI, are shown in Table 8.2-1.



Table 8.2-1: Summary of Representative Background Air Quality Concentrations

Compound

Representative Background Concentration[1] Averaging

Period Criteria

(µg/m³)[2]

Percent of

Criteria[4] 50th Percentile(µg/m³)

90th Percentile(µg/m³)

Criteria Air Contaminants

Total Suspended Particulate Matter (SPM)

9.3 30 24-hr 120 25%

9.8 — Annual 60 [3] 16%

Particulate Matter less than 10 µm in diameter (PM10)

6.6 19 24-hr 50 38%

9.2 — Annual 20 46%

Particulate Matter Less Than 2.5 µm in Diameter (PM2.5)

5.1 17 24-hr 28 61%

7.5 — Annual 10 75%

Nitrogen Dioxide

7.9 22 1-hr 400 6%

9.6 18 24-hr 200 9%

11 — Annual 40 28%

Sulphur Dioxide

2.8 5.5 1-hr 690 1%

2.2 5.4 24-hr 275 2%

2.4 — Annual 55 4%

Carbon Monoxide 241 374 1-hr 36,200 1%

241 363 8-hr 15,700 2%

Metals

Antimony 0.013 0.024 24-hr 25 0.1%

Barium 0.026 0.097 24-hr 10 1%

Cadmium 0.0073 0.011 24-hr 0.025 44%

0.0057 — Annual 0.005 114%

Calcium (as calcium oxide) 0.14 0.35 24-hr 10 4%

Chromium 0.0016 0.0032 24-hr 0.5 1%

Iron (as ferric oxide) 0.045 0.15 24-hr 4 4%

Lead 0.0080 0.015 24-hr 0.5 3%

Manganese 0.0063 0.011 24-hr 0.4 3%

Total Gaseous Mercury 0.0016 0.0019 24-hr 2 0%

Nickel 0.0086 0.012 24-hr 0.2 6%

0.00769 — Annual 0.04 19%

Selenium 0.00097 0.0034 24-hr 10 0.034%

Vanadium 0.00061 0.0031 24-hr 2 0.16%

Zinc 0.0059 0.020 24-hr 120 0.017%

Polycyclic Aromatic Hydrocarbons

Naphthalene 0.024 0.050 24-hr 22.5 0.22%

Phenanthrene 0.00083 0.0013 24-hr — —



Table 8.2-1: Summary of Representative Background Air Quality Concentrations

Compound

Representative Background Concentration[1] Averaging

Period Criteria

(µg/m³)[2]

Percent of

Criteria[4] 50th Percentile(µg/m³)

90th Percentile(µg/m³)

Volatile Organic Compounds

Benzene 0.029 0.53 24-hr 2.3 23%

0.30 — Annual 0.45 67%

Methylene Chloride 0.32 0.56 24-hr 220 0.25%

0.36 — Annual 44 1%

Polychlorinated Dibenzodioxins

Dioxins and Furans (in terms of toxic equivalence (TEQ))

1.0E-08 3.5E-08 24-hr 1.00E-07 35%

Notes:

Reproduced from RWDI’s 2015 ‘Background Air Quality & Cumulative Effects Analysis’ report; attached as Appendix E1

1) The background levels reflect 5 years of data from the most representative station.

2) Criteria are the AAQC as defined by the MOECC or other relevant criteria where no Ontario AAQC exists (Canadian Ambient Air Quality Standards or WHO Guideline).

3) AAQC is a geometric mean. The reported background level is also a geometric mean.

4) Based on 90th percentile value (or annual average, where applicable).

This assessment shows that the existing conditions in the Project site area are below the MOECC AAQC with

the exception of cadmium. There are limited stations that include monitoring for cadmium and the available data

is from urban areas that would have additional background sources that would not be present at the Project

location. For consistency and conservatism, the cadmium value is still carried forward to the cumulative effects

assessment.


Criteria Air Contaminants and Other Compounds of Interest

The emissions associated with the addition of LCF in the cement manufacturing process were assessed in the

April 2015 Emission Summary and Dispersion Modelling (ESDM) Report prepared by RWDI, attached as

Appendix E2. This ESDM report was prepared in accordance with the methodology and guidance contained in

O. Reg. 419/05, MOECC Guideline A10: Procedure for Preparing an Emission Summary and Dispersion

Modelling Report (MOECC 2009a), and MOECC Guideline A11: Air Dispersion Modelling Guideline for Ontario

(MOECC 2009b). This approach is required to obtain approve under Section 9 of the EPA.

Maximum emission rates from the kiln were compared from source testing programs that were conducted at the

facility in 2006, 2010, 2012 and 2014 while the kiln was operating at baseline operating conditions and during

LCF operations. The 2014 stack test results are provided in Appendix E3. RWDI states in the 2015 ESDM report

that maximum “air emissions from the kiln during the LCF condition showed no statistical significant variation

from the existing baseline conditions”, indicating that the addition of LCF to the kiln does not alter the emissions

profile of the facility. In an independent study by Queens University, researchers concluded there are no

deleterious influences on the emissions after the introduction of LCF into the kiln (Davis and Chandler 2014).



RWDI concludes in the 2015 ESDM report that the Project is capable of operating in compliance with Schedule 3

standards for suspended particulate matter (SPM) and with Schedule 2 standards for all other contaminants, as

required by Ontario Regulation 419/05. The 2015 ESDM report will be used to support the ECA application for

permanent LCF operations.

Greenhouse Gases

As stated in Section 2.3, one of the purposes of this Project is to assess the potential environmental impacts of

using LCFs as a replacement to fossil fuels. The premise behind using LCF is to lower GHG emissions, through

the use of local and/or regional, and sustainable, LCF sources. The direct GHG emissions are reduced through

the use of LCF because the thermal energy is from a biological based source rather than a fossil fuel. When

biomass or other wood products are used for energy, carbon is released into the atmosphere in the form of

Carbon Dioxide (CO2). These CO2 emissions are taken back up by new, growing plants and trees – this is often

referred to as the natural carbon cycle. Conversely, when fossil fuels are used for energy, an increase in the

atmospheric CO2 concentrations results as there is no associated short term mechanism to remove the CO2

from the atmosphere and sequester the carbon. The short carbon cycle for plant based sources of energy is

acknowledged in the Environment Canada guidelines for reporting GHG emissions (Environment Canada 2014).

In addition to the direct reduction in CO2 emissions, a Life Cycle Assessment (LCA) can be used to further

evaluate the potential environmental impacts by including the indirect GHG emissions associated with the

production, transportation, processing and use of LCF compared to the fossil fuels they replace and compared to

the default fate for the materials (e.g., landfill). LCAs quantify the energy and raw materials consumed

throughout the life of a product by tracking inputs (i.e., energy consumption) and outputs (i.e., emissions to air

and water). An LCA of the Project 1 LCF materials was documented by Queens University in April 2015; this

report is attached as Appendix E4.

The LCA revealed that the current fossil fuel burning operation at the Lafarge Bath Plant produces 1012 kg of

CO2-eq for every 1 tonne of clinker produced (including all GHGs from fuels and raw materials). Approximately

40% of this is sourced directly from the use of fossil fuels and indirectly from electricity production. According to

the Queens LCA, up to 38% of the total reported GHG releases can be reduced through the use of C&D

materials as opposed to fossil fuels (the project goal is to achieve 30% LCF usage by 2020). Significant GHG

reductions are also realized with the use of railway ties; the reductions are lower for asphalt shingles (but still

reduced compared to using fossil fuels).

The changes in the reported GHG emissions and the LCA demonstrate that the LCF will reduce impacts of the

cement manufacturing process on climate change.

Dust

The Site is currently a source of fugitive dust emissions from raw material handling and storage. The Site

operates under a Fugitive Dust Best Management Practices Plan (BMPP) that has been approved and enforced

by the MOECC. The LCF materials to be received will be made up of weathered or stable organic (e.g., treated

wood) and other inert inorganic materials (e.g., asphalt shingles), which are not anticipated to result in a

significant quantity of dust. LCFs that have been shredded will be contained in enclosed trailers or under cover

to limit wind erosion. While potential dust emissions from the shredding of LCF materials is much less significant

that the existing operations, the Fugitive Dust BMPP has been revised to include potential fugitive dust from the

LCF processing operations.



Odour

The Bath Plant is currently not a source of odour emissions and no significant odours associated with the LCFs

are anticipated. The LCF materials to be received will be made up of weathered or stable organic (e.g., treated

wood) and other inert inorganic materials (e.g., asphalt shingles), which are not anticipated to result in odours

beyond the immediate vicinity of the shredding operations. LCFs that have been shredded will be contained in

enclosed trailers or under cover to keep the materials dry.

The shredding of treated wood may release a localized odour and has been monitored during the LCF

Demonstration Project. These impacts were considered during the application for the Low Carbon Fuel

Demonstration Project’s ECA process (ECAs #7984-8YYR75 and #9606-8Z7S9Z); it should be noted that no

odour studies were required under this approval process. Operating experience has shown that odour

associated with railway ties and other LCF are only detectible within the immediate vicinity of the fuel process

and storage equipment – that is, not observed away from the Lafarge facility.


Based on the results of the effects assessment, no additional mitigation measures are deemed applicable

beyond the measures already identified in the Project description (Section 4). The BMPPs and mitigation

measures described below were considered as part of the assessment.

The Fugitive Dust BMPP approved and enforced by the MOECC. While potential dust emissions from the

shredding of LCF materials is much less significant that the existing operations, this Fugitive Dust BMPP

will be revised to include potential dust from the LCF shredding operations.

LCFs will only be introduced into the cement kiln when the kiln rotation is 0.3 rotations per minute or higher,

which is considered normal operating conditions. During normal operating conditions, the flow rate of the

current traditional fuels and LCFs will be adjusted to obtain the necessary operating temperatures

(averaging 1,450°C) for cement manufacturing. These temperatures, of necessity for cement

manufacturing, are well in excess of the temperatures required for complete combustion.

The emission controls in the kiln for the proposed LCFs are comprised of the existing emission control

components for the kiln. These controls have demonstrated robust compliance with regulatory limits when

using the current traditional fuels (coal, petroleum coke, natural gas and virgin biomass). The particulates

entrained in the kiln flue gases are collected through four (4) cyclones in parallel, treated in two (2)

conditioning towers and followed by two (2) electrostatic precipitators (aligned in two parallel paths) prior to

discharge through the kiln stack.




A summary of the potential effects to air associated with the Project are provided in Table 8.2-2. Given that no

residual effects have been identified, an evaluation of net effects and determination of significance is not

necessary.

Table 8.2-2: Net Effects to Air Quality


Air Quality

Changes in ambient air concentrations as a result of the addition of LCF to the kiln that result in exceedances of the AAQCs

LCF will not be introduced in the kiln until conditions that promote good combustion are established; emissions are controlled by an electrostatic precipitator on the kiln stack

None (Predicted likely effects have been demonstrated to remain in compliance with the AAQCs)

Emissions of Greenhouse Gases

Changes in the emissions of greenhouse gases as a result of the use of LCF as a replacement to fossil fuels

The emissions of GHG are reduced through the use of the LCF; therefore no mitigation measures are required

None (Releases of reportable CO2 equivalents are reduced with the use of LCF and an LCA demonstrated a reduction in overall GHG’s compared to fossil fuels)

Emissions of Dust

Changes in dust emissions Best Management Practices Plan for Fugitive Dust

None (Predicted likely effects are expected to be negligible )

Emissions of Odour

Odour from shredding LCFs

None None (Predicted likely effects are expected to be negligible )


The existing monitoring commitments for air quality related to the LCF operations are provided in Table 8.2-3.

No additional monitoring commitments are recommended.

Table 8.2-3: Monitoring Commitments for Air Quality



LCF Fuel Fuel analysis as a requirement under ECA 7984-8YYR75

NA Batch sampling

Moisture, ash, heating value, chlorine, sulphur, nitrogen, hydrogen, oxygen, metals

Hourly feed rate and proportions of LCF feeds

Air Quality Source testing as a requirement under ECA 7984-8YYR75

Kiln Stack Annual

Carbon Monoxide, Carbon Dioxide, particulates, hydrogen chloride, ammonia, organic matter, acrolein, phenol, methanol, propionaldehyde, acetaldehyde, metals, polycyclic organic matter, dioxin/furan isomers



Table 8.2-3: Monitoring Commitments for Air Quality



Air Quality

Continuous Emissions Monitoring as a requirement under O. Reg. 194/05 and ECA 7984-8YYR75

Kiln Stack Continuous Nitrogen Oxides, Sulphur Dioxide, Opacity


Since the Project is not expected to result in residual adverse effects on air quality, a cumulative effects

assessment was not required. However, given questions from the public regarding air quality, cumulative effects

on air quality were assessed in the 2015 ‘Background Air Quality & Cumulative Effects Analysis’ report, prepared

by RWDI, attached as Appendix E1.

The report followed a four-step process to assess the cumulative impacts of the Project including:

1) Summarizing the historical ambient air quality measurements described in Section 8.2.1 to represent the

ambient air background conditions without any local industrial activity;

2) Preparing emission estimates for significant industrial sources in the vicinity of the Lafarge Bath Plant using

publically available information;

3) Using the emission estimates summarized in the ESDM Report described in Section 8.2.2 to describe two

scenarios: the current plant operations and the addition of sources of emission associated with

LCF processing; and

4) Performing a conservative cumulative effects dispersion modelling assessment for the local emission

sources, the two Project Site scenarios, and the ambient air background conditions.

To assess the local conditions, the contribution of significant local industry must be added to the ambient air

background conditions described in Section 8.2.1. Therefore, the cumulative effects assessment developed a

screening process to identify the emissions from significant industrial sources within 30 km of the Project site in

the prevailing upwind direction and within 20 km in the prevailing downwind direction. Five facilities were

identified and included in the cumulative effects dispersion model, as listed in Table 8.2-4



Table 8.2-4: Large Industrial Sources in the Vicinity of the Lafarge Bath Plant

Facility Approximate Distance to

Lafarge Bath Plant [km]

Ontario Power Generation – Lennox Generating Station 4.5

TransCanada - Napanee Generating Station 5

Kingston CoGen Limited Partnership 8

Invista Company – Kingston Site 20

Essroc Canada - Picton 28

In order to compare the current operations, two cumulative effects dispersion modeling assessments were completed by RWDI in the 2015 ‘Background Air Quality & Cumulative Effects Analysis’ report: a Base Case and a Future Case. The Base Case scenario considered the current conditions at the Lafarge Bath Plant, with the kiln operating on normal fuel mix (ground coal and petroleum coke). This is consistent with the conditions described in the ESDM report, with the exception of the LCF related systems and resulting emissions. The Future Case includes the air emission from the LCF receiving, handling, processing, and storage. The emissions from the kiln also reflect the use of LCF, as described in the ESDM report.

Table 8.2-5, reproduced in part from Appendix D3 in RWDI’s 2015 ‘Background Air Quality & Cumulative Effects Analysis’ report, attached as Appendix E1, summarizes the cumulative predicted ambient air concentrations for both Base Case and Future Case after the addition of LCF. Predicted concentrations above the AAQC are bolded and shaded in the table. Ambient air concentrations for some of the compounds have increased; these include:

Total Suspended Particulate Matter (SPM), Particulate Matter Less Than 10 µm in Diameter (PM10) and

Particulate Matter Less Than 2.5 µm in Diameter (PM2.5) due to increased material handling as part of the

LCF processing, and

some metals due to the use of a higher estimate of silt loading on the paved surface at the plant.

Of the compounds that increase under the Future Case, all remain below the respective Ontario AAQC with the exception of PM10 and PM2.5, which are predicted to be above the AAQC values for both the Base and Future Cases.

As noted in Section 8.2.1, the limited monitoring data for cadmium resulted in a background air concentration above the AAQC. Cadmium emissions are not expected to increase under both the Base and Future Cases; however, due to the high background concentrations the cumulative air concentration for cadmium is also predicted to remain greater than the AAQC.






Table 8.2-5: Comparison in Cumulative Effects Air Concentrations

Compound

Maximum Concentration from Lafarge and Other Industries

RepresentativeBackground

Concentration(µg/m³)

Cumulative Predicted Concentration

AveragingPeriod

Percentage of AAQC

Change in Predicted Concentration from Base Case to Future Case Lafarge and

Other Industries

Cumulative Predicted

Concentrations

Base Case (µg/m³)

Future Case

(µg/m³)

Base Case(µg/m³)

Future Case(µg/m³)

Base Case (%)

Future Case (%)

Base Case (%)

Future Case (%)

Lafarge and Other Industries

(%)

Cumulative Predicted Concentrations

(%)

Criteria Air Contaminants

Total Suspended Particulate Matter (SPM) 81 87 30 111 117 24-hr 67 72 92 97 8 6

13 16 9.8 23 25 Annual 22 26 38 42 19 11

Particulate Matter less than 10 µm in diameter (PM10) 53 58 19 72 77 24-hr 107 117 145 155 9 7

5.9 7.4 9.2 15 17 Annual 29 37 75 83 25 10

Particulate Matter Less Than 2.5 µm in Diameter (PM2.5) 27 29 17 44 46 24-hr 90 96 146 153 7 4

2.6 3.1 7.5 10 11 Annual 26 31 101 106 16 4

Nitrogen Dioxide

245 245 22 267 267 1-hr 61 61 67 67 0 0

40 40 18 58 58 24-hr 20 20 29 29 0 0

4 4 11 15 15 Annual 11 11 38 38 0 0

Sulphur Dioxide

93 93 5.5 98 98 1-hr 13 13 14 14 0 0

13 13 5.4 19 19 24-hr 5 5 7 7 0 0

2.0 2.0 2.4 4.4 4.4 Annual 4 4 8 8 0 0

Carbon Monoxide 507 507 374 881 881 0.5-hr 1 1 2 2 0 0

152 152 363 515 515 8-hr <1 <1 3 3 0 0

Metals

Cadmium 0.0010 0.0010 0.011 0.012 0.012 24-hr 4 4 48 48 0 0

0.000056 0.000056 0.0057 0.0058 0.0058 Annual 1 1 115 115 0 0

Calcium 1.3 1.4 0.35 1.7 1.7 24-hr 13 14 17 17 4 3

Iron 0.17 0.45 0.15 0.32 0.60 24-hr <1 2 1 2 159 86

Lead 0.011 0.011 0.015 0.026 0.026 24-hr 2 2 5 5 0 0

Manganese 0.020 0.021 0.011 0.031 0.032 24-hr 5 5 8 8 8 5

Nickel 0.0079 0.0079 0.012 0.020 0.020 24-hr 4 4 10 10 0 0

0.00092 0.00092 0.0077 0.0086 0.0086 Annual 2 2 22 22 0 0

Volatile Organic Compounds

Benzene 0.0025 0.0025 0.30 0.30 0.30 Annual <1 <1 67 67 0 0

Polycyclic Aromatic Hydrocarbons

Phenanthrene 0.00040 0.00 0.0013 0.0017 0.00 24-hr - - - - 53 13

Polychlorinated Dibenzodioxins

Dioxins and Furans (in terms of toxic equivalence (TEQ)) 6.45E-10 6.45E-10 3.5E-08 3.56E-08 3.56E-08 24-hr <1 <1 <1 <1 0 0

Note: Reproduced from RWDI’s 2015 ‘Background Air Quality & Cumulative Effects Analysis’ report; attached as Appendix E1






Predicted cumulative concentrations of PM10 increased by 7% on a 24-hour basis, and 10% on an annual basis

from the Base to Future Case from non-stack sources. Predicted cumulative concentrations of PM2.5 increased

by 4% on both a 24-hour and annual basis from the Base to Future Case. The predicted cumulative air

concentrations above the AAQC are limited to a small number of modelled receptors immediately to the west of

the Project site entrance, surrounded on 3 sides by the Lafarge property, and front onto Highway 33.

The cumulative assessment values for the Future Case are below AAQC’s for receptors in the Town of Bath and

to the north and south of the Project Site. A conservative frequency analysis was conducted that held the

representative background concentrations constant at a conservative 90th percentile value and assessed the

variation in modelling results. Even with the conservative modeling approach coupled with high background

levels, the calculated frequency above the AAQC threshold was low. PM10 was predicted to exceed the 24-hour

threshold 3.4% of the time, at the most impacted modelled receptor location; PM2.5 was predicted to exceed the

24-hour threshold 4.0% of the time at the most impacted modelled receptor. The main Project Site source

contributors to the PM2.5 and PM10 results are emissions from the clinker cooler gravel bed filter (52%) and

fugitive emissions from the on-site roadways (26%). These emission sources are not affected by the Project

and are consistent in both the Base and Future Cases.

RWDI concludes in the 2015 “Background Air Quality & Cumulative Effects Analysis’ report that the Project will

not significantly change the cumulative effects assessment from the Base Case. Further, the report states that in

consideration of the conservatisms built into the assessment and the limited area and frequency that predicted

concentrations are above AAQC, the predicted levels of all contaminants are considered to be acceptable and

well within typical results under the Future case.

8.3 Noise Emissions An assessment to address the potential environmental effects to noise emissions was completed for the Project.

These potential effects were identified on the Screening Criteria Checklist (Section 5) based on the following

question:

Might the Project:

3.4 cause negative effects from the emission of noise?

For effects to noise emissions, the CSA is defined as the most potentially impacted point of reception (POR),

which is a location on a property where someone may be impacted by sound. For this Project, two single family

dwellings adjacent to the Bath Plant have been identified as the nearest PORs: these are:

An upper storey window of a two-story home 700 m west of the Site on the north side of Highway 33

(referred to as Receptor R1); and an outdoor location up to 30 m from this location in the direction of the

facility (referred to as Receptor R1a); and

An upper storey window of a two-story home 1340 m east of the Site on the north side of Highway 33

(referred to as Receptor R2); and an outdoor location up to 30 m from this location in the direction of the

facility (referred to as Receptor R2a).

A summary of the environmental assessment findings is provided in Sections 8.3.1 to 8.3.4. . Noise monitoring

commitments for the Project are provided in Section 8.3.5. In addition to answering the question above,

an assessment of noise emission effects of the Project in combination with those from other projects that have



been, or will be, carried out, and which may interact with the effects of the Project was completed. In response to

community questions, noise emission monitoring was also conducted to assess sound levels on the north shore

of Amherst Island. A summary of these findings is provided in Section 8.3.6.


HGC Engineering (HGC) has conducted site visits and monitored sound emissions at the Lafarge Bath Plant,

and specifically at the Project receptor locations, for the past several years during the following periods:

November/December 2007;

May/June 2008;

November/December 2011;

June/October 2012; and

January 2015.

During these site visits, HGC concluded that background sound in the vicinity of the plant was dominated

primarily by road traffic on Highway 33 during daytime hours and by natural sounds during nighttime hours.

HGC also noted that the Lafarge Bath plant is audible at both receptor locations between car pass-bys, and

during prolonged periods of low background sound.

The primary existing sound sources associated with the cement plant include building ventilation and process

exhausts, kiln drum cooling fans, open doors, dust collectors, emergency generators, onsite vehicle activity

(i.e., tractor trailers, front end loaders, rail shunter), the sand drying operation and ship loading/unloading

operations. A Sound Source Summary is included in the 2015 Acoustic Assessment Report (AAR) prepared by

HGC, attached as Appendix E1.

The limits for noise are site-specific and vary depending on the existing ambient background sound levels

(due to road traffic, neighbouring commercial/industrial activity, etc.) in the vicinity of the facility. For the

purposes of the assessment, using MOECC noise assessment guidelines (MOECC 2013), the plant and

surrounding lands have been characterized as a “Class 2” semi-urban area.

Sounds from stationary sources are categorized into two broad types: impulsive sounds and non-impulsive

sounds. An “impulse” is defined as a single pressure pulse or a single burst of pressure pulses (such as a

gunshot, hammering, or rail car switching). Non-impulsive sounds are those which continue for periods of time

longer than an instantaneous burst. The majority of sounds emanating from the Lafarge Bath Plant are

non-impulsive in nature (e.g., process exhausts, building ventilation, etc.). The details by which the sound level

limits were established for the assessment are provided in the 2015 AAR, attached as Appendix E1.

The applicable sound level limits are identified in Table 8.3-1.



Table 8.3-1: Applicable Sound Level Limits at Selected Points of Reception

Type of Sound Point of

Reception

Daytime

(07:00 – 19:00)

Evening

(19:00 – 23:00)

Nighttime

(23:00 – 07:00)

Non-Impulsive, dBA R1, R2 57 54 45

R1a, R2a 57 54 -

Impulsive, dBAI R1, R2 60 60 55

R1A, R2a 60 60 —

Note: dBA = A-weighted Decibel; dBAI = A-weighted Decibel Impulse.

Overall sound emissions from the Lafarge Bath Plant were evaluated under a predictable worst case operating

scenario, which is defined as an hour when typically busy operation of the stationary sources under

consideration could coincide with an hour of low background sound. The analysis conducted by HGC, using the

predictable worst case scenario and with the existing noise control measures described in Section 8.3.3 below,

concluded that noise emissions from the Lafarge Bath Plant comply with the applicable sound level limits.

Further details of the noise emission studies conducted at the Lafarge Bath Plant, including the locations of

all monitoring and receptor stations, measurement methods and instrumentation, modelling criteria and results,

and the acoustic assessment for emergency equipment, are provided in the 2015 AAR, attached as

Appendix E1. A summary of the predicted results at each of the receptor locations is provided in Table 8.3-2.

Table 8.3-2: Predicted Sound Emissions of Lafarge Bath Plant at Selected Points of Reception

Type of Sound Point of

Reception

Daytime

(07:00 – 19:00)

Evening

(19:00 – 23:00)

Nighttime

(23:00 – 07:00)

Non-Impulsive, dBA

R1 51 51 45

R1a 50 50 44

R2 42 42 41

R2a 38 38 36

Impulsive, dBAI

R1 45 45 45

R1a 46 46 46

R2 19 19 19

R2a 19 19 19

Note: dBA = A-weighted Decibel; dBAI = A-weighted Decibel Impulse.




Quantifying sound emissions from key equipment is generally straightforward for an existing facility, since it can

be measured directly, near each source. For proposed facilities (or expansions of existing facilities), sound

emissions from proposed equipment is based on manufacturer’s data (where available), predictions using

generic data from reference texts, or on measurements of similar equipment. The sound emission levels of the

equipment, measured or estimated, are then used as input to a 3-dimensional computational acoustical model in

order to determine the contribution of each source to the overall offsite sound levels at the neighbouring PORs.

As of January 2015, the date of the most recent noise monitoring, equipment from the LCF delivery systems was

operational, but the LCF processing equipment has not yet been purchased. Consequently, for this noise

assessment, HGC based sound emissions from the proposed LCF processing equipment on measurements of

similar equipment (ie a Peterson 4710B horizontal grinder).

With the addition of the LCF equipment, the modelling analysis conducted by HGC, as described in

Appendix E1, indicated that the total sound power level of all sources at the site increased by 0.2 dBA.

With regard to the PORs considered in this assessment, HGC predicted offsite sound levels increased by 1 dBA

during daytime/evening hours at R1, R2 and R2a (but remain well within the applicable limits); during nighttime

hours at R1, R2 and R2a, and during all hours of the day and night at R1a, the sound levels from the Lafarge

Bath Plant remain unchanged with the inclusion of the LCF equipment. Consequently, the predicted likely effect

of noise emissions from the LCF processing and delivery systems on neighbouring receptors is considered to be

negligible.

In addition to the monitoring activities described above, in response to public questions, HGC conducted sound

level measurements on January 12, 2015 on Amherst Island. While homes on the north shore of the island are

2.5 kilometres south of the Lafarge Bath Plant, sounds from the plant are audible given the low ambient sound

levels on the island. For a Class 3 rural acoustic environment, such as the island, the MOECC applicable noise

limits are 45 dBA during the daytime and 40 dBA at nighttime (MOECC 2013). HGC monitoring results indicated

sound levels on the island directly across from the Bath Plant were 33 LEQ dBA during the daytime, 12 dBA less

than the applicable limits. The predicted sound levels in HGC’s assessment are 35 dBA, which are 2 dBA higher

than the measured levels, indicating that the acoustical model is a conservative representation of Bath Plant

sound levels on Amherst Island. Further details of the noise monitoring on Amherst Island, including a figure of

the monitoring location, are provided in the 2015 Acoustic Assessment Briefing prepared by HGC, attached as

Appendix E2.


Based on the results of the effects assessment, no mitigation measures are deemed necessary for the

LCF-related equipment and Project activities. Noise control measures installed/constructed at the Lafarge Bath

Plant between 2008 and 2011 are deemed sufficient to manage any sound emissions from the Project.

These abatement measures included the installation of acoustical silencers/louvres and exhaust mufflers on

some equipment and the construction of a concrete composite noise barrier on the north side of the storage silos

(see Appendix E1 for further details).




A summary of the predicted likely effects to noise emissions from the Project is provided in Table 8.3-3. Given

that no residual effects have been identified, an evaluation of net effects and determination of significance is not

necessary.

Table 8.3-3: Net Effects to Noise Emissions

Criteria Potential Effects Mitigation Measures

Residual Adverse Effect

Noise Increase in sound levels at nearby receptors from LCF processing and delivery systems

None None (predicted effects are considered negligible)


The proposed monitoring program, outlined in Table 8.3-4, has been developed to verify the predictions in the

assessment that the effect of noise emissions from the LCF processing and delivery systems on neighbouring

receptors is considered negligible.

Table 8.3-4: Monitoring Commitments for Noise Emissions



Noise Follow up noise monitoring once the LCF processing and delivery systems are fully operational

Receptors R1, R1a, R2, and R2a

Once, to confirm predictions made in the assessment

Non-Impulsive and Impulsive Noise Emissions


Since the Project is not expected to result in residual adverse effects on noise emissions, a cumulative effects

assessment was not required. However, given questions from the public regarding sound levels in the

community, an assessment of noise emissions from the Lafarge Bath Plant in combination with the proposed

TransCanada Energy Ltd. (TransCanada) Napanee Generating Station (NGS) was conducted.

The cumulative effects for noise emissions were assessed in the 2015 Acoustic Assessment Briefing prepared

by HGC, attached as Appendix E2. Noise emissions from the Lafarge Bath Plant were assessed in combination

with the NGS, which is a proposed 970 MW natural gas-fuelled combined cycle generating station adjacent to

the existing Lennox Generating Station, approximately 3.7 kilometres southwest of the Lafarge Bath Plant.

In support of environmental approvals sought by TransCanada for the NGS, an Acoustic Assessment Report

was prepared by SENES Consultants in January 2014 which reported the predicted sound levels of the NGS at

neighbouring offsite PORs. HGC extracted the predicted sound levels from the NGS directly from that report to

complete this cumulative assessment.



Receptor locations potentially impacted by sound emissions from both the NGS and the Lafarge Bath Plant

include POR3/POR5, which represent homes located on the north side of Highway 33, approximately 2.3

kilometres southwest of the Lafarge Bath Plant, as well as POR4, which represents homes on Amherst Island,

approximately 3.1 kilometres south of the Lafarge Bath Plant. A figure of the monitoring locations is available in

the HGC report, attached as Appendix E2. Table 8.3-5, copied directly from HGC’s assessment provided in

Appendix E2, presents a summary of the sound levels reported for the NGS along with predicted sound levels of

the Lafarge Bath Plant at the same locations, and the cumulative sum.

Table 8.3-5: Predicted Sound Levels, LEQ [dBA], of Napanee Generating Station and Lafarge Bath Plant

Receptor ID Napanee Generating Station Lafarge Bath Plant NGS + Lafarge

Normal Ops Start-up Ops Daytime Nighttime Daytime Nighttime

POR3a 39 39 38 31 41 39

POR3b 38 39 38 31 41 39

POR4a 38 39 34 28 39 39

POR4b 36 37 32 26 37 37

POR5 39 40 39 32 42 40

Note: LEQ dBA = Equivalent Continuous Level A-weighted Decibel.

Although the sound level limits of the MOECC do not apply to the combined sound levels of two separate,

independent facilities, it may be noted that the combined sound levels of the NGS and Lafarge Bath Plant

tabulated above remain less than the MOECC daytime/nighttime limits for both Class 2 (semi-urban) and Class 3

(rural) areas. Based on HGC’s study findings, the predicted cumulative effect of noise emissions from the

Lafarge Bath Plant and NGS on neighbouring receptors is considered to be negligible.

8.4 Land Use and Socio-Economics (including Traffic) An assessment to address the potential environmental effects to land use and socio-economics, including traffic,

was completed for the Project. These potential effects were identified on the Screening Criteria Checklist

(Section 5) based on the following questions:

Might the Project:

2.1 cause negative effects on residential, commercial, institutional or other sensitive land uses

within 500 metres from the site boundary?

6.1 cause negative effects on neighbourhood or community character?

6.2 result in aesthetics impacts (e.g., visual and litter impacts)?

6.3 cause negative effects on local businesses, institutions or public facilities?

6.4 cause negative effects on recreation, cottaging or tourism?



6.5 cause negative effects related to increases in the demands on community services and

infrastructure?

6.6 cause negative effects on the economic base of a municipality or community?

6.7 cause negative effects on local employment and labour supply?

6.8 cause negative effects related to traffic?

For effects to land use and socio-economics, the CSA is defined as the area of influence in which physical land

use and socio-economic features may be affected. For this Project, the CSA is designated as the area within a

500 m radius of the SSA boundary for land use, and the area within a 1 km radius of the SSA boundary for

socio-economics screening criteria. A local and regional study area was also considered:

Local Study Area (LSA): represents lower-tier municipalities where direct Project effects could be expected.

The LSA comprises Loyalist Township (including the Village of Bath) and the Town of Greater Napanee.

Regional Study Area (RSA): represents the upper-tier municipality where direct or indirect Project effects could

be expected. The RSA comprises the County of Lennox and Addington, in which Loyalist Township and the

Town of Greater Napanee are located.

The study areas selected for each of the land use and socio-economics screening criteria are identified in

Table 8.4-1. Where selected, the CSA provides a more focused assessment of effects on land use, and

community services and infrastructure than available through use of the LSA and RSA. A summary of the

environmental assessment findings is provided in Sections 8.4.1 to 8.4.4.

Table 8.4-1: Study Areas for Land Use and Socio-Economics

Screening Criteria CSA LSA/RSA

Land Use Criteria

Residential, commercial, institutional and other sensitive land uses ✓

Socio-economic Criteria

Neighborhood and Community Character ✓ ✓

Aesthetics ✓

Businesses, Institutions and Public Facilities ✓

Recreation, Cottaging and Tourism ✓

Community Services and Infrastructure ✓

Economic Base ✓

Employment and Labour Supply ✓




This section of the report provides a summary of the existing land use and socio economic environment

potentially affected by the Project. Further details on land use and socio-economics are provided in the

Land Use and Socio-economic Baseline and Effects Assessment Report completed for the Project, attached to

this report in Appendix G1.

Residential, Commercial, Institutional and Other Sensitive Land Uses

Land use designations, policies and regulations of the SSA and CSA are governed by the Official Plans and

Zoning By-laws of Loyalist Township and the Town of Greater Napanee. As discussed in Section 2.5,

Schedule A of the Loyalist Township Official Plan (2014) designates the Project location as Aggregate land use,

within an Aggregate Specific Policy Area (Cumming Cockburn Limited 2014). The Loyalist Township Zoning

By-Law (By-Law 2001-38) identifies the Project location as an Extractive Industrial (M4) zone (Cumming

Cockburn Limited 2001), a zoning that permits aggregate processing plants. An exception provision within

By-Law 2001-38 (Extractive Industrial Exception Two – M4-2 Zone) permits the establishment and use of a

cement plant, including the receipt and use of LCF fuels.

Northeastern portions of the CSA within Loyalist Township are designated as agricultural lands (Cumming

Cockburn Limited 2014). Schedule A of the Town of Greater Napanee Official Plan (2014) designates the CSA

as agricultural land, aggregate and industrial lands (IBI Group 2014). The CSA also includes low density

residential areas, small commercial land use areas, a small aggregate area, and open space areas of the Village

of Bath (Cumming Cockburn Limited 2014).

Neighbourhood and Community Character

Neighborhood and community character refers to the way a community characterizes and defines themselves,

providing insight into aspects of the community deemed most important by its members. The historical

prominence of the LSA forms an important part of community identity, neighborhood architecture, and local

events. The LSA has been settled since 1784, and as a result, many towns and villages within the LSA, including

public buildings, dwellings and historic sites, are amongst the oldest in Ontario.

Communities of the LSA are described as having a strong agricultural background, with quaint urban centres

and peaceful, rural countryside (Loyalist Township 2013; County of Lennox and Addington 2013a, b, c, d).

Community character is also closely tied to natural amenities, and both Loyalist Township and the Town of

Greater Napanee identify themselves as lakefront communities that take pride in the recreational opportunities

available locally (County of Lennox and Addington 2013c, d). The picturesque, historic image and tourist

economy of the LSA is further supported by the abundance of artisans within the community (County of Lennox

and Addington, 2013b).

The LSA has a total population of 31,732, representing 0.2% of the provincial population. The population and

population growth between 2001 and 2011 in the Village of Bath, Loyalist Township, Town of Greater Napanee

and RSA are provided in Table 8.4-2. Population growth in the Town of Greater Napanee has been slower,

remaining far below the provincial average (Statistics Canada 2012b, 2007b). This may be attributed, in part, to

its aging population and low mobility rate.



Table 8.4-2: Population (2001 to 2011)

Year Village of Bath

Local Study Area Regional Study Area Province of

Ontario Loyalist Township

Town of Greater Napanee

County of Lennox and Addington

2011 1,042 16,221 15,511 41,824 12,851,821

2006 823(a) 15,062 15,400 40,542 12,160,282

2001 1,583(a) 14, 551 15,132 39,461 11,410,046

2001-2011 Change (%)

—(a) 11.5 2.5 6.0 12.6

Source: Statistics Canada 2012a, b, c, d, e; Statistics Canada 2007a, b, c, d; Statistics Canada 2001a, b, c, d, e

Notes: (a) Unable to make statistical comparison between the 2011 Census data and other Census data given that the geographic boundaries changed between Census periods.

The Ministry of Finance projects that the RSA will experience low levels of growth, rising by only 5.0% by 2021

and 6.9% by 2031 (Ministry of Finance 2012). Municipal planners predict that the population of Loyalist

Township will range between 18,024 and 23,551 in 2020 (Cumming Cockburn Limited 2010). In the Town of

Greater Napanee, the population is expected to range from 19,700 to 21,600 in 2021, suggesting high levels of

growth (Cumming Cockburn Limited 2002). Additional demographic information on age distribution, dependency

ratios and mobility rates in the LSA and RSA are provided in Appendix G1.

Aesthetics

Businesses, Institutions and Public Facilities

The CSA is dominated by the presence of Lafarge Bath Plant, agricultural landscapes, country residences and

small-town infrastructure (Loyalist Township 2013; Cumming Cockburn Limited 2014). The CSA is bordered by

Lake Ontario to the south, and is crossed by Highway 33, a scenic 40 km stretch of road along the lakefront that

boasts historic sites and tourist attractions (Loyalist Township 2013; County of Lennox and Addington 2013c).

Numerous institutions and public facilities in the western part of the Village of Bath fall within the CSA.

These include the Bath branch of the Lennox and Addington Public Library, a Canada Post office, the Bath

Masonic Hall, and two local churches (i.e., St. John’s Anglican Church and the Bath United Church).

Approximately 30 businesses are located within the CSA, involved in various activities and sectors (e.g., antique

and art dealing, food retail and hospitality, farming and irrigation, banking and accounting) (Village of Bath

2012a).

Given the local landscape and access to Lake Ontario, recreation, cottaging and tourism represents an important

component of community character within the CSA. Recreation opportunities within the CSA include the

Shoreline Route of the County of Lennox and Addington cycling trail, municipal parks, and athletic facilities.

In addition, several sites marketed to tourists are located within the CSA, including the Bath Museum (formerly

the Bath Old Town Hall), Layer Cake Hall, and the Bath Farmer’s Market. Tourists are also encouraged to visit

Bath’s shops and restaurants, and to drive the scenic Highway 33 (Village of Bath 2012b). In terms of temporary

accommodations, there are four bed and breakfasts and/or inns in the Village of Bath, none of which fall within

the CSA (Village of Bath 2012a).



Recreation, Cottaging and Tourism

Data regarding cottages in the CSA are not available through Loyalist Township, the Town of Greater Napanee

or the Ministry of Natural Resource and Forestry’s Land Information Ontario database. However, a small area of

land designated as shoreline residential within the Town of Greater Napanee may include some cottages and/or

other seasonal dwellings.

Community Services and Infrastructure

Public services and infrastructure are essential for any community, contributing to the safety, health and

well-being of its residents. Services and infrastructure features include:

traffic and transportation;

protection and emergency services (i.e., police, fire and emergency medical services [EMS]);

health and social services;

educational services;

water, wastewater and waste management services; and

housing.

The existing vehicular access to the Project is directly to Highway 33, approximately 4.9 km east of County Road

21 and 2.9 km west of County Road 7. A haul route connection between Highway 33 and Highway 401 is

provided by County Road 4. Two railway lines run north-south and east-west through the CSA. No aerodromes

or airports fall within the CSA. Existing traffic conditions are provided in the Traffic Impact Study completed for

the Project, attached to this report in Appendix G2.

Municipal fire protection is provided through Loyalist Township Emergency Services (Loyalist Township

Emergency Services 2013) operated out of the Bath Fire Hall located within the CSA. Police and EMS services

are provided by the Ontario Provincial Police and the County of Lennox and Addington Ambulance Services,

respectively; however, no police detachments or EMS infrastructure are located within the CSA. Additionally, no

hospitals or medical clinics are located within the CSA.

Social services, child services and social housing are available within the LSA. Prince Edward-Lennox and

Addington Social Services manage and deliver social service programs, and provide temporary financial

and employment assistance to LSA residents. It also offers 206 rent-to-income housing units in the LSA.

Child services are provided through Lennox and Addington Resources for Children, who are responsible for

daycare, preschool, and after-school children’s programming in the LSA. No seniors’ facilities are located within

the CSA.

The Limestone District School Board and the Algonquin and Lakeshore Catholic District School Board manage

education facilities in the LSA (County of Lennox and Addington 2013e). Bath Public School falls within the CSA

and offers Kindergarten through Grade 8 education to approximately 327 students (Government of Ontario

2011). No post-secondary educational institutions are located within the socio-economics study areas (County of

Lennox and Addington 2013e).



Loyalist Township manages one water treatment facility and one wastewater treatment facility in the Village of

Bath. However, no water, wastewater or waste management services are located within the CSA.

A low density residential area within the Village of Bath is located to the east of the SSA within the CSA. In 2011,

Loyalist Township maintained a high occupancy rate of 96.7%, with average housing values of $266,625

(Statistics Canada 2013a). Sixty-six percent of the community’s housing stock was built prior to 1980,

and consequently, 11.1% of dwellings require major repairs (Statistics Canada 2013a).

Economic Base

Loyalist Township’s and the Town of Greater Napanee’s economic base are supported predominantly by the

public sector, as presented in Table 8.4-3 (County of Lennox and Addington 2013m). Millhaven Institution, the

Limestone District School Board and Bath Institution represent the largest three employers in Loyalist Township.

In the private sector, Bombardier and Lafarge Canada employ the largest number of people, reflecting a strong

manufacturing base (County of Lennox and Addington 2013f). In the Town of Greater Napanee, Goodyear

Canada Inc. is the largest employer (with 685 employees), and public administration, utilities, correctional

services, education and health service providers represent eight of the ten largest organizations in the Town

(County of Lennox and Addington 2013f).

Table 8.4-3: Top Employers

Rank Name of Employer Sector (Approximate) Number

of Employees

Loyalist Township

1 Loyalist Township Public Administration 1,411

2 Millhaven Institution Correctional Services 400

3 Limestone District School Board Education 284

4 Bath Institution Correctional Services 275

5 Bombardier Transportation Manufacturing 215

6 Lafarge Canada Inc. Manufacturing 138

7 Stock Transport Buses – Charter & Rental 135

8 Doornekamp Construction Construction 55

9 H.R. Doornekamp Construction Construction 48

Town of Greater Napanee

1 Goodyear Canada Inc. Manufacturing 685

2 County of Lennox & Addington (a) Public Administration 415

3 Limestone District School Board Education 260

4 L&A County General Hospital Health Services 215

5 John M. Parrott Centre Long-term Care Facility 187

6 Quinte Regional Detention Centre Correctional Services 167

7 Lennox Generating Station Utilities 160



Table 8.4-3: Top Employers

Rank Name of Employer Sector (Approximate) Number

of Employees

8 Town of Greater Napanee Public Administration 159

9 Metro Retail 140

10 Algonquin & Lakeshore Catholic Dist. School Board (a)

Education 126

Source: County of Lennox and Addington 2013f.

Note: (a) Head office is in Greater Napanee. Employees work throughout the County of Lennox and Addington.

Employment and Labour Supply

Employment and labour supply are characterized by examining employment rates, occupation and industry

affiliations, and educational attainment. These characteristics are illustrative of the pool of local workers and

skillsets that may be available to support the Project.

In 2011, Loyalist Township maintained an experienced labour force of 8,435 workers with an unemployment rate

below County and Provincial levels at 7.7% (Statistics Canada 2013a, c, d). Over the same period, the Town of

Greater Napanee had a labour force of 7,305 workers with an unemployment rate of 7.9%. However,

the community’s employment rate was 7.2% below the Ontario average, representing a decrease of 5.3% since

2006 (Statistics Canada 2013b, d).

In 2011, occupational trends and industry characteristics were uniform across the LSA. In both Loyalist

Township and the Town of Greater Napanee, sales and service jobs represented the largest employment

sectors, providing jobs to approximately one quarter of the local labour force. In 2011, the retail trade sector was

the top employer in both communities and the RSA. The second largest industries for both communities were

health care and social assistance. Trades, transport and equipment operators comprised approximately 16%

the workforce in each community (Statistics Canada 2013a, b).

The level of education within a community reflects the potential skillsets available in the local labour pool.

In 2011, 62.4% of residents in Loyalist Township had obtained a post-secondary degree, with college and other

non-university degrees/diplomas most commonly held (Statistics Canada 2013a). An estimated 27.5% of

residents had completed high school only, and 10.1% of the population had no certificate, diploma or degree

(Statistics Canada 2013a). The Town of Greater Napanee demonstrated lower educational attainment levels

than Loyalist Township and the Province: 51.3% of residents had completed post-secondary education,

most commonly resulting in college and other non-university certificates/diplomas. Approximately 30.2% of

residents had completed high school only, and 18.5% had not completed any certificate, diploma or degree.

Further details on employment and labour supply in the LSA and RSA are provided in Appendix G1.



8.4.2 Potential Environmental and Social Effects

Potential environmental effects on land use and socio-economics consider the operational phase of the Project

only. A review of the Screening Criteria Checklist indicates that the Project has the potential to affect the land

use and socio-economics criteria described below.

Residential, Commercial, Institutional and Other Sensitive Land Uses

Project activities will occur within an area zoned primarily for aggregate/industrial extractive operations, which

permits the receipt and use of LCFs at the Lafarge Bath Plant. While the Project may result in changes to traffic,

land use designations/zoning will not be affected. Consequently, no effects on residential, commercial,

institutional and other sensitive land uses are predicted as a result of the Project.

Neighbourhood and Community Character

The Project will create approximately 20 new permanent jobs. These new jobs are expected to be sourced

locally and/or regionally. Therefore, effects to the “small-town feel” and historic, agricultural lakefront identity of

the LSA are considered to be negligible. The Project anticipates up to 21 trucks a day on local roadways.

Changes to traffic levels from the transportation of LCFs are also considered to be negligible (Appendix G2),

and is not expected to affect the quaint, historic countryside reputation of the area communities. Therefore, no

effects on neighborhood or community character are predicted as a result of the Project.

Aesthetics

The Project will result in increased visibility of traffic, and potentially LCF material and litter on transportation

routes within the SSA. Therefore, a potential effect on aesthetics as a result of the Project is predicted. However,

the effect on community viewscapes and views of the Lafarge Bath Plant are expected to be minimal since the

increase in traffic as a result of the Project is relatively small (i.e., transportation of materials by approximately

21 trucks a day). Impact management measures to avoid, minimize and eliminate the effect on aesthetics are

identified in Section 8.4.3.

Businesses, Institutions and Public Facilities

The Project is not expected to directly affect the activities of the numerous businesses, institutions and public

facilities located within the CSA. However, there is potential for Project-related traffic and noise to indirectly

affect these operations. Effects from changes to local traffic as a result of the Project is predicted to be negligible

(Appendix G2) and results of the noise assessment indicate that Project-related noise will not result in noise-

related effects at neighboring points of reception (Section 8.3). Consequently, no effects on businesses,

institutions and public facilities are predicted as a result of the Project.

Recreation, Cottaging and Tourism

The Project is not expected to directly affect recreation, cottaging or tourism activities within the CSA. While an

additional 21 vehicles per day may pass two municipal parks, tennis courts and the Loyalist Golf and Country

Club, these trucks are not expected to be noticeable to recreational users or cottage dwellers, nor are they

expected to reduce the local enjoyment of these recreational/cottage spaces. Local tourism establishments,

cottagers and recreational users are not expected to experience a noticeable increase in local traffic.



Potential indirect effects on recreation, cottaging and tourism could result from Project-related air and noise

emissions. Since no adverse effects on air and noise are predicted, as described in Sections 8.2 and 8.3,

respectively, no indirect effects on recreation, cottaging and tourism are anticipated. Therefore, no effects on

recreation, cottaging and tourism are predicted as a result of the Project.

Community Services and Infrastructure


Project. The additional Project-related traffic includes 15 trucks for delivery of unprocessed LCF materials to the

SSA and 6 trucks for delivery of processed LCF materials to third party customers. Consistent with the current

haul route designations within the area, primary routes to be used by Project-related trucks will be east-west

along Highway 33 and north-south along County Road 4. The Project-related traffic is estimated to increase the

existing two-way traffic during the morning and afternoon peak hour by 5.2% in the vicinity of the Lafarge Bath

Plant. In the vicinity of the Village of Bath, the additional trucks represent approximately 2.9% and 1.5% of the

existing traffic during the morning and afternoon peak hours, respectively. Based on the predicted 2019 and

2024 traffic conditions, a minimal effect to traffic is predicted since all individual movements are expected to

operate at acceptable levels of service, with no critical movements and no queuing issues. Impact management

measures to avoid, minimize and eliminate the effect on community services and infrastructure from Project-

related traffic are identified in Section 8.4.3.

Since the Project is not expected to affect the population of the LSA and RSA, or noticeably affect traffic and

transportation, no changes in the demand for local protection and emergency services, health and social

services, educational services, or housing are anticipated.

A storm water management pond is located on the south end of the SSA. No changes to the water quantity or

quality discharge from the storm water management pond are anticipated from the use of LCFs in the cement

plant, or fuel staging/processing operations. In addition, a collection sump will be used to capture runoff that can

be used for sediment and dust control. The Project will also use water from Lake Ontario and the on-site quarry

sumps for dust control and, if necessary, fire protection. Therefore, the Project will not result in a change of

demand on existing municipal water or wastewater infrastructure and no effects are predicted.

Lafarge has committed to conduct Project activities in a manner consistent with local waste studies and/or waste

management targets. A maximum of 1,200 tonnes of LCF materials will be received at the Site per day. Local

materials meeting the three sustainability criteria will be preferentially sourced; materials from Quebec and New

York will be used as necessary to ensure a constant source of fuel to the plant. Although no new hazardous or

non-hazardous waste will be created by the Project, some LCF materials may be rejected in the

staging/processing system and will require disposal or recycling. Overall however, less waste materials will be

received at local and regional waste disposal and landfill facilities as a result of the Project. It is unlikely that

Project-related changes in waste management will result in a substantive increase in the lifetime of any landfills

within the LSA or RSA; consequently, no effect on waste services or infrastructure in the LSA or RSA is

predicted.



Economic Base

The Project is strongly aligned with the existing economic base of the LSA and RSA, which includes of the key

economic sectors areas of manufacturing, logistics and distribution, and clean technology. The Project is

expected to contribute to the local economic base and support a transition towards a low carbon economy that

benefits the region as a whole. While this represents a positive contribution to the local economy, it will have a

negligible effect on local economic base at the Project level. Consequently, no effects on the local or regional

economic base are predicted as a result of the Project.

Employment and Labour Supply

The Project is expected to create approximately 20 new permanent jobs that will employ new workers locally

and/or regionally. While this represents a positive effect on employment, the number of employment

opportunities it presents is negligible (i.e., an increase of 0.1%) in terms of the overall employment of the LSA,

where the labour force numbers 15,740 workers. Therefore, no effects on employment or labour supply are

predicted as a result of the Project.


Based on the results of the effects assessment, additional mitigation measures beyond the measures identified

in the Project description (Section 4) are necessary to avoid, minimize and eliminate the predicted effects on

aesthetics and community services and infrastructure from Project-related traffic. Lafarge will:

require LCFs to be transported to SSA via fully enclosed trailers, tarped dump truck, or railcars;

sort LCF materials inside a covered structure as much as practical;

amend the existing Site Housekeeping Program to include the LCF staging and processing operations,

so that the SSA is kept clean and orderly; and

make sure that Project vehicles:

remain within the three approved traffic routes identified in Lafarge’s 2015 Trucking: Bulk Carriers,

Transport and Dump Trailer policy;

refrain from using engine breaks;

comply with the safety and insurance requirements of the Lafarge Bath Plant; and

comply with Lafarge’s 2015 Trucking: Bulk Carriers, Transport and Dump Trailer policy, which requires

that drivers “respect the quiet, pedestrian nature of the Village of Bath… do not exceed the posted

speed limit… respect weight restrictions, and must be aware of pedestrians with particular attention to

children” (Lafarge Canada Inc. 2015).

Following the application of these mitigation measures, no residual effects on aesthetics or community services

and infrastructure are predicted to result from the Project.




A summary of the predicted likely effects to land use and socio-economics with the identified project-

environment interactions is provided in Table 8.4-4. Given that no residual effects have been identified, an

evaluation of net effects and determination of significant is not necessary.



Table 8.4-4: Summary of Land Use and Socio-economic Effects Assessment

Criteria Potential Effect Mitigation Measures Residual Adverse

Effect

Residential, commercial, institutional and other sensitive land uses

No changes predicted to residential, commercial, institutional and other sensitive land uses as a result of existing land use designation/zoning compatibility

None None

Neighbourhood and community character

No changes predicted to community character as a result of the Project workforce, increased traffic levels or noise

None None

Aesthetics Changes to aesthetics as a result of increased visibility of traffic and LCF materials.

Lafarge will require LCFs to be transported to Site via fully enclosed trailers, tarped dump truck, or railcars

The sorting of LCF materials will generally take place inside a covered structure

Existing Site Housekeeping Program will be revised to include the LCF staging and processing operations to ensure the SSA appears clean and orderly

None

Businesses, institutions and public facilities

No change predicted to businesses, institutions or public facilities as a result of increased traffic levels or noise.

None None

Recreation, cottaging and tourism

No changes predicted to recreation, cottaging and tourism as a result of changes to air quality, noise or traffic levels.

None None

Community services and infrastructure

Changes to traffic and transportation are considered potential effects, while no changes are predicted to protection and emergency services, health and social services, educational services, water and wastewater, waste or housing.

The Project will use approved traffic routes consistent with current haul route designations within the Project study areas

Haulers will refrain from using engine breaks and comply with Site safety and insurance requirements, and Lafarge’s 2015 Trucking: Bulk Carriers, Transport and Dump Trailer policy

None



Table 8.4-4: Summary of Land Use and Socio-economic Effects Assessment

Criteria Potential Effect Mitigation Measures Residual Adverse

Effect

Economic base No changes predicted to the economic base as a result of new LCF activity

None None

Employment and labour supply

No changes predicted to local employment and labour supply as a result of the Project workforce

None None




Based on the results of the effects assessment, no monitoring specific to land use and socio-economics is

necessary.


Since the Project is not expected to result in residual adverse effects on land use and socio-economics,

a cumulative effects assessment was not required. However, due to questions from the public regarding the

potential increased levels of traffic in the community, an assessment of traffic effects from the Project in

combination with the proposed TransCanada NGS was completed.

The cumulative effect of increased levels of traffic was assessed in the 2014 Traffic Impact Study prepared by

GHD Inc. (GHD), attached as Appendix G2. Traffic related effects from the Project were assessed

in combination with the NGS, which is a proposed 970 MW natural gas-fuelled combined cycle generating

station adjacent to the existing Lennox Generating Station, approximately 3.7 kilometres southwest of the

Lafarge Bath Plant. In support of environmental approvals sought by TransCanada for the NGS, a Traffic

Planning and Assessment Study was prepared by Transplan Associates in October 2013. For this cumulative

assessment, as a worse-case scenario, GHD extracted and used the NGS 2016 peak construction traffic

estimates.

Under the predicted future 2019 and 2024 traffic conditions, considering traffic from both the Project and NGS,

GHD concluded that all individual movements at the study intersections are expected to operate at ‘acceptable’

levels of service with no critical movements and no queuing issues. Comparing with background 2019 and 2024

conditions, without traffic from either project, the incremental changes at the study intersections results in vehicle

delays of no more than +1 second and in volume to capacity rations of no more than +0.03, both indicators of

minimal and acceptable traffic impact. Further details of the cumulative assessment are available in the Traffic

Impact Study attached as Appendix G2. Based on the study’s findings, the predicted cumulative effect of


9.0 SUMMARY OF ADVANTAGES AND DISADVANTAGES OF PROJECT AND CONCLUSIONS

There is more concrete sold per year than all other building materials combined. Concrete is made from

aggregates (gravel and sand), cement, and water and is much in demand for its building material qualities,

and superior life cycle and environmental performance. However, cement, the active ingredient, requires thermal

energy to produce. Traditionally, this thermal energy is obtained from fossil fuels such as coal, natural gas,

and petroleum and its by-products. However, worldwide, fossil fuel alternatives (derived from fossil sources,

biomass and mixtures of the two) have been a growing source of energy for cement manufacturing due to their

better ranking from a sustainability perspective. Further, with the emerging global need to reduce GHG

emissions to mitigate the impacts from climate change, the need for lower carbon fuels – a subset of fossil fuel

alternatives – is growing urgent.

Lafarge is amongst many members in the cement sector assessing fossil fuel alternatives, related technologies,

and their optimum use. In Ontario, the Lafarge Bath Plant Cement 2020 initiative aims to identify broad

measures for improved sustainability (e.g., energy, water, economics, emissions, biodiversity) and extend the



findings to the rest of the sector. One of the key focus areas of the Cement 2020 initiative is to reduce imported

fossil fuel use by 30% by the year 2020, and so lower GHG emissions and other emissions, through the use of

local and/or regional, and sustainable, LCF sources. Under the sustainability model adopted by the Project team,

to be considered a sustainable fuel, they must be environmentally sound, socially responsible and economically

viable.

There is great potential for adoption of LCFs within North America, where there are approximately 115 operating

cement kilns. Canada is at only 9.3% fuel substitution nationally (Ontario is at approximately 5%), while the US is

only 1% better – but European Union plants range from 40 - 90% substitution (some of which is not LCF). Much

of the 2 million tonnes of fossil fuels used every year by the Canadian cement industry is imported and enabling

the industry to receive local LCFs will create immense local spin-off benefits; bringing new, direct and indirect,

economic values well in excess of $100 million per year while preserving the existing cement industry’s

competitiveness. In addition, the business models being developed can be replicated and the science readily

adapted to other facilities. Other large energy users such as electricity and steel can build on the in-depth

science produced to adopt LCFs as may be appropriate for their sector.

The Government of Ontario promotes the reduction, reuse and recycling (3Rs) of waste to keep these materials

out of landfills for environmental reasons, and also because these materials have tremendous value and

potential to generate new investment, new factories, new jobs, and new Ontario-made products. To achieve its

vision of a ‘zero-waste’ society the government has proposed a new Waste Reduction Act (2013), and most

recently the new Resource Recovery and Circular Economy Act (November 2015) to hold individual producers

responsible for waste reduction outcomes, increase support for existing municipal recycling programs, and

increase the recycling of a broader range of wastes (Pollution Probe 2014). LCFs targeted under this Project

(i.e., C&D materials, asphalt shingles, and weathered treated wood) are not recycled currently. While the use of

these materials for energy does not currently count towards Ontario’s proposed waste reduction targets,

a number of municipal thermal treatment facilities across Canada have demonstrated that the use of alternative

fuels complements existing recycling and composting programs and can help to improve recycling rates

(Pollution Probe 2014). It is also important to note that Ontario produces approximately 12.5 million tonnes

of waste per year (OWMA 2015). For this Project, the maximum estimated usage of LCFs per year is

135,000 tonnes; this represents approximately 1% of the waste materials produced in the province.

Consequently, the use of LCFs at the Lafarge Bath Plant supports the government’s waste reduction policy.

In addition, there are a number of social benefits that are expected from the sustainability model adopted.

By working in a Partnership comprised in part of local entities, local employment and educational opportunities

are maximized. Each partner brings expertise and values that synergistically ensure the community values are

integrated, including transparency, the precautionary principle, and local enrichment. Through a series of

communications efforts and events, the Project team ensures that the local public is offered the opportunity to

engage with the team and to participate in the program. The skills developed by working on this Project will

prepare the team members to contribute to other local and non-local development projects.

Lafarge used an Environmental Screening Process, as per Ontario’s Regulation 101/07 under the Environmental

Assessment Act, to assess the potential environmental effects (including benefits) of using C&D materials,

weathered treated wood, and asphalt shingles as LCFs. Aspects of the environment having the potential to be

affected by the Project, as identified by the Project team and validated at a public meeting, were surface and



groundwater, air and noise, and land-use and socio-economics. These environmental and social criteria were

assessed to determine if they would be affected by the Project, and if that effect was anticipated to be significant.

Water (Groundwater and Surface Water) No adverse effects to groundwater quality, quantity and flow, or to surface water quality, quantity and flow to the

Stormwater Management Pond (the regulated discharge point on Site), are predicted as a result of the Project.

Mitigation measures to control runoff of waters in contact with LCFs include: implementation of a BMPP for dust

control and housekeeping at all areas where LCF materials are processed or handled; storage of only

unprocessed weathered or hydrophobic materials outdoors and uncovered, other non-hydrophobic unprocessed

materials and all processed fuels to be stored under cover to minimize the opportunity for contact with rainwater

and snowmelt; a covered structure to be installed in LCF 1 (identified in Figure 4-1) to minimize the opportunity

for processed fuels to come into contact with rainwater and snowmelt; and re-grading LCF 1 area and

constructing a geomembrane lined runoff collection pond to reduce impacts from dust during the LCF processing

operations. There may be a moderate effect to surface water quantity and flow to the West Drainage Channel,

but this effect is not considered significant; further investigations to the drainage patterns to the west of the plant

will be undertaken to confirm assumptions made in the assessment.

Air Quality (including Dust and Odour) No adverse effects to air quality are predicted as a result of the Project. LCF will not be introduced in the kiln

until conditions that promote good combustion are established, with emissions controlled by an electrostatic

precipitator on the kiln stack. RWDI states in the 2015 ESDM report that maximum air emissions from the kiln

during the LCF condition showed no statistical significant variation from the existing baseline conditions, and an

independent study by Queens University researchers concludes there are no deleterious influences on the

emissions after the introduction of LCF.

No adverse effects to greenhouse gas (GHG) emissions are predicted as a result of the Project. Emissions of

reportable carbon dioxide (CO2) equivalents are reduced with the use of LCF and a Life Cycle Analysis

confirmed an overall reduction in GHG’s compared to fossil fuels when considering the supply chain – and also

indicated an indirect GHG reduction from diverting these materials from landfill.

No adverse effects to dust or odour are predicted as a result of the Project. A dust BMPP and housekeeping

plan will be developed and implemented at all areas of the Site where LCF materials are processed or handled.

In addition, all processed fuels will be stored under cover to minimize windblown debris.

A cumulative effects assessment on air quality was completed by RWDI to include the ambient air background

conditions, the emissions from the Lafarge Bath Plant (without [Base Case] and with [Future Case] the inclusion

of the LCF systems), and the emissions from five industrial sources within 30 km of the Project Site in the

prevailing upwind direction and within 20 km in the prevailing downwind direction. The results of RWDI’s study

conclude the Project will not significantly change the cumulative effects assessment from the Base Case.

Further, the report states that in consideration of the conservatisms built into the assessment and the limited

area and frequency that predicted concentrations are above the Ambient Air Quality Criteria, the predicted levels

of all contaminants are considered to be acceptable and well within typical results under the Future case.



Noise Emissions No adverse effects to noise emissions are predicted as a result of the Project. As of January 2015, the date of

the most recent noise monitoring, equipment from the LCF delivery systems was operational, but the LCF

processing equipment has not yet been purchased. Consequently, for this noise assessment, HGC based sound

emissions from the proposed LCF processing equipment on measurements of similar equipment (ie a Peterson

4710B horizontal grinder). With the addition of the LCF equipment, the modelling analysis conducted by HGC

indicated that the total sound power level of all sources at the site increased by 0.2 dBA. Consequently,

the predicted likely effect of noise emissions from the LCF processing and delivery systems on neighbouring

receptors is considered to be negligible.

In response to community questions, a cumulative effects assessment was also completed by HGC to include

the estimated noise emissions from the proposed TransCanada Energy Ltd. Napanee Generating Station (NGS).

Although the sound level limits of the MOECC do not apply to the combined sound levels of two separate,

independent facilities, it may be noted that the combined predicted sound levels of the NGS and Lafarge Bath

Plant are less than the MOECC daytime/nighttime limits for both Class 2 (semi-urban) and Class 3 (rural) areas.

Based on HGC’s study findings, the predicted cumulative effect of noise emissions from the Lafarge Bath Plant

and NGS on neighbouring receptors is considered to be negligible.

Land Use and Socio-Economics (including Traffic) No adverse effects to land-use and socio-economic indicators are predicted. The Project is expected to

contribute to the local economic base, create approximately 20 new permanent jobs in the local and/or regional

area, and support a transition towards a low carbon economy that benefits the region as a whole. While this

represents a positive contribution to the local economy, it will have a negligible effect on the local economic base

at the Project level.


Project. This may result in increased visibility of traffic, and potentially LCF material and litter on transportation

routes. Consistent with the current haul route designations within the area, primary routes to be used by Project-

related trucks will be east-west along Highway 33 and north-south along County Road 4. Based on the predicted

2019 and 2024 traffic conditions, GHD concluded a minimal effect to traffic is predicted since all individual

movements on the local roadways are expected to operate at acceptable levels of service, with no critical

movements and no queuing issues. Mitigation measures to minimize the aesthetic and traffic-related effects

include: the transportation of LCFs in fully enclosed trailers, tarped dump trucks, or railcars; sorting of LCF

materials inside a covered structure as much as practical; and compliance with Lafarge’s Site safety and

insurance requirements and the 2015 ‘Trucking, Bulk Carriers, Transport and Dump Trailer’ policy.

In response to community questions, a cumulative effects assessment was completed by GHD to include the

estimated traffic from the proposed NGS. Based on the study’s findings, the predicted cumulative effect of


In conclusion, the Project is expected to have an overall positive affect on the environment and benefit the

community-at-large. Through the use of local and/or regional, and sustainable, LCF sources, Lafarge can reduce

its imported fossil fuel use (with a current goal of a 30% reduction of fossil fuel use by the year 2020) and

thereby reduce their emissions of greenhouse gases (specifically CO2). The use of LCFs is also expected to



create immense spin-off benefits to the community and Ontario, bringing new, direct and indirect, economic

opportunities.

Lafarge and its other project partners are committed to working with the community, specifically through their

Community Liaison Committee, to ensure the community-at-large as well as Lafarge benefit from this Project.

Mitigation measures have been put in place to reduce or eliminate any potential adverse effects from the Project

to surface and groundwater, air quality and dust, aesthetics and traffic in the community. Thus, the advantages

of the Project significantly outweigh any potential disadvantages.

10.0 REFERENCES

Brooks, K.M. 2004. Polycyclic aromatic hydrocarbon migration from creosote-treated railway ties into ballast and adjacent wetlands. Research Paper FPL-RP-617. U.S. Department of Agriculture, Forest Service, Forest Products Laboratory. Available at: http://www.woodcenter.org/docs/fpl_rp617.pdf.

Canadian Privy Council Office. 2003. A Framework for the Application of Precaution in Science-based Decision Making about Risk. ISBN 0-662-67486-3 Cat. no. CP22- 70/2003. Available at: http://www.pco-bcp.gc.ca/docs/information/publications/precaution/precaution-eng.pdf.

Chandler, A.J. and Associates (with contributions from Lafarge). 2012. Technical Backgrounder: Low Carbon Fuels, Guidelines for the Safe and Beneficial Use of Mixed Fossil & Biomass Fuel Sources in the Cement Industry, with a Focus on Railroad Ties. March 15, 2012. Available at: http://www.cement2020.org.

County of Lennox and Addington. 2013a. Loyalist Township. Available at: http://www.lennox-addington.on.ca/about-l-and-a/loyalist-township.html. Accessed on August 9, 2013.

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County of Lennox and Addington. 2013c. Loyalist Township. Available at: http://www.lennox-addington.on.ca/things-to-do/explore-towns-a-villages/loyalist-township.html.

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County of Lennox and Addington. 2013e. Education. Available at: http://www.lennox-addington.on.ca/services/education.html.

County of Lennox and Addington. 2013f. Top Employers. Available at: http://www.lennox-addington.on.ca/stats/top-employers.html.

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Davis, J. and J. Chandler. 2014. Draft. A Comparison of the Stack Emissions at the Lafarge Bath Cement Plant from the Combustion of Fossil Fuels versus a mixture of Low Carbon Fuels and Fossil Fuels. Department of Mechanical and Materials Engineering, Queens University. January 16, 2014. Available at http://www.cement2020.org.

Environment Canada. 2014. Facility Greenhouse Gas Emissions Reporting, Techncial Guidance on Reporting Greenhouse Gas Emissions. October 2014. Available from: http://www.ec.gc.ca/ges-ghg/47B640C5-8056-423D-89DA-57CF71D676A8/GHGRP%20Technical%20Guidance.pdf

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Statistics Canada. 2013b. Greater Napanee, T, Ontario (Code 3511015) (table). National Household Survey (NHS) Profile. 2011 National Household Survey. Statistics Canada Catalogue no. 99-004-XWE. Ottawa. Released September 11, 2013. Available at: http://www12.statcan.gc.ca/nhs-enm/2011/dp-pd/prof/index.cfm?Lang=E. Accessed December 6, 2013.

Statistics Canada. 2013c. Lennox and Addington, CTY, Ontario (Code 3511) (table). National Household Survey (NHS) Profile. 2011 National Household Survey. Statistics Canada Catalogue no. 99-004-XWE. Ottawa. Released September 11, 2013. Available at: http://www12.statcan.gc.ca/nhs-enm/2011/dp-pd/prof/index.cfm?Lang=E. Accessed December 6, 2013.

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Statistics Canada. 2012b. Greater Napanee, Ontario (Code 3511015) and Alberta (Code 48) (table). Census Profile. 2011 Census. Statistics Canada Catalogue no. 98-316-XWE. Ottawa. Released October 24, 2012. Available at: http://www12.statcan.gc.ca/census-recensement/2011/dp-pd/prof/index.cfm?Lang=E. Accessed December 6, 2013.

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Zhang, L. and W.E. Mabee. 2015a. Alternative fuel usage in the world cement industry. Poster presented by Queen’s University at the Lafarge Canada Inc. open house in Bath, ON, June 2015.

Zhang, L. and W.E. Mabee. 2015b. Life Cycle Assessment of the Utilization of Low Carbon Fuels for the Cement Industry – An Interim Report for the Lafarge-Queen’s Low Carbon Fuel Project. Available at: Available at http://www.cement2020.org.


February 5, 2016 Report No. 13-1151-0041

Report Signature Page

GOLDER ASSOCIATES LTD.

Rachel Lee Gould, M.Sc. Sean Capstick, B.A.Sc., P.Eng. Senior Project Manager Principal

RLG/FSC

Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.

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Golder Associates Ltd.

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ENVIRONMENTAL SCREENING REPORT …lccra.ca/wp-content/uploads/1311510041-Main-Report-Lafarge-LCF... · ENVIRONMENTAL SCREENING REPORT Evaluation of Low Carbon ... injection with the