November 12, 2008 REFERENCE: Response to RWDI Peer … · Markham, Ontario L3R 9R8 REFERENCE ... particulate emission rate for each fuel type was calculated ... heating value of 91.5

106-885 Don Mills Road, Toronto, Ontario M3C 1V9, Canada Phone: (416) 391-2527 Fax: (416) 391-1931

www.churchandtrought.com

November 12, 2008 Tom Jones Miller Group Inc. 505 Miller Avenue P.O. Box 4080 Markham, Ontario L3R 9R8 REFERENCE: Response to RWDI Peer Review of Environmental Noise

and Air Quality Studies, RWDI Project W08-5275A (dated July 31, 2008)

Proposed Miller Quarry Expansion CTI Project P3053b Dear Mr. Jones, Church & Trought Inc. (CTI) has reviewed the RWDI Peer Review, referenced above, and we have discussed the comments with Colin Welburn and Mike Lepage of RWDI. We provide this letter as a response to the peer review comments. Section 1.2 – Sources of Air Emissions A. Source Summary Table The table summarizing all sources of particulate used in the AERMOD assessment is included on the following page.

Comments on Peer Review of Environmental Noise and Air Quality Studies, RWDI Project W08-5275A

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B. Sample emission calculations demonstrating the application of assumptions and emission factors to develop the modelled emission rates shown in the table above: Point Sources (Stacks) Drum Mixer Baghouse The emissions from the No. 2 fuel oil-fired HMA drum mixer were calculated using the maximum AP42 Chapter 11.1 Hot Mix Asphalt Plant (March 2004) emission factors for a No. 2 fuel-oil fired drum mixer and a facility capacity of 150 MT/hr. Particulate emissions from the drum mixer were calculated in grams per second (g/s) using emission factors shown in the formula below:

AP42 emission factor, lb/ton x 0.5 (to convert to kg/MT) x 150 MT/hr x 1000 g/kg / 3600 s/hr

= 0.033 lb/ton * 0.5 * 150 MT/hr * 1000 g/kg / 3600s/hr = 0.688 g/s RMC Boiler The RMC boiler may operate on either natural gas or propane. To be conservative, the particulate emission rate for each fuel type was calculated and the maximum value selected. Natural gas emissions from the boiler were calculated from AP42 Chapter 1.4 Natural Gas Combustion (July 1998) for small industrial boilers <100 MMBTU/hr and propane emissions were calculated from AP42 Chapter 1.5 Liquefied Petroleum Gas Combustion (October 1996) for industrial boilers. A natural gas heating value of 1020 MMBTU/ million scf of natural gas and a propane heating value of 91.5 MMBTU/1000 gal of propane burned were used as suggested by respective AP42 Chapters. The boiler capacity was 2 MMBTU/hr. Particulate emissions from propane combustion were calculated using the formula below:

(AP42 emission factor, lb/1000 US gal of propane) * (1000 US gal of propane/ heating value MMBTU) * (boiler capacity, MMBTU/hr) * 454 g/lb * hr/3600s = (0.6 lb/1000 US Gal) * (1000 US gal/91.5 MMBTU) * 2 MMBTU/hr * (454 g / lb) * (1 hr/3600s) = 1.66 x 10-3 g/s

Particulate emissions from natural gas combustion were calculated using the formula below:


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(AP42 emission factor, lb/106 scf) / (106 scf of natural gas/heating value MMBTU) * (boiler capacity, MMBTU/hr) * 454 g/lb * hr/3600s = (7.6 lb/106 scf) * (106 scf /1020 MMBTU) * 2 MMBTU/hr * (454 g / lb) * (1 hr/3600s) = 1.88 x 10-3 g/s

Therefore the maximum value of 1.88 x 10-6 g/s is from natural gas combustion. Crusher Generator Particulate emissions from the crusher diesel generator were calculated using emission factors from AP42 Chapter 3.3 Gasoline and Diesel Industrial Engines (October 1996). The maximum generator capacity is 1135 kW/hour. Particulate emissions were calculated as shown below:

(AP42 emission factor, lb/hp-hour) * 0.608 (to convert to kg/kW-hour) * capacity of generator (kW/hour) * 1000 g/kg * 1 hr/3600s = 0.0022 lb/hp-hour * 0.608 * 1135 kW/hour * 1000 g/kg * 1 hr/3600s = 0.422 g/s

Line Sources (Roads) Vehicular traffic on paved and unpaved roads is potentially a significant source of dust emissions. As trucks travel they re-suspend particulate matter from the roadway. The property entrance and roadways to the HMA and RMC plants are paved (access roads). The internal roads in the quarry are unpaved. Emissions are estimated based on the average vehicle weight, the distance travelled per trip and the number of trips completed in a time period (e.g. per hour). The published emission factors do not take vehicle speed into account and this causes the estimated emission rate to be very conservative. Based on guidance provided in the Michigan Department of Environmental Quality Mineral Product Processes Emission Calculation Fact Sheet (November 2005, included in the following pages), the road dust emissions were reduced by a factor of 80% to account for control activities such as watering or the use of an approved surfactant.


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Paved Roads Particulate emissions from paved roads were calculated using emission factors from AP42 Chapter 13.2.1 Paved Roads (November 2006). The following assumptions were made regarding vehicle traffic on paved roads:

average weight (W) of trucks on paved roads is 15 ton (the average vehicle weight is set to the average of a fully loaded truck and an empty truck in view of the fact that each trip counted in the calculation of VKT includes a round trip)

if the HMA plant operated at a maximum capacity of 150 MT/hr (165 ton/hr) it would require approximately 6.5 trucks/hr to transport the HMA product offsite

each HMA truck would make 2 trips of approximately 405 m

if the RMC plant operated at a maximum capacity of 170 MT/hr (187 ton/hr) it would require approximately 7.5 trucks/hr to transport the RMC product offsite

each RMC truck would make 2 trips of approximately 222 m

a silt loading (sL) value of 8.8 g/m2 was used for the travel completed by HMA trucks (value representative for asphalt batching sites based on professional judgment)

a silt loading (sL) value of 12 g/m2 was used for the travel completed by RMC trucks (12 g/m2 is the mean value provided in AP42 Table 13.2.1-4 for concrete batching sites)

the particle size multiplier for PM30 (k = 24 g/vehicle km travelled) was used to estimate total particulate matter

a control factor of 80% was applied to account for control activities such as watering or use of an approved surfactant

The paved road emissions were calculated and modelled in various straight line segments (3 for the HMA only road, one for the RMC only road and one for the shared entrance). So, for example, for the RMC only road, the TSP emission rate (g/s) was calculated: E = k * (sL/2)0.65 * (W/3)1.5 = 24 * (12/2)0.65 * (15/3)1.5 = 859.9 g/VKT Vehicle kilometres travelled (VKT/hour) = # of trips * distance travelled per trip (km) = 15 * 0.057 km = 0.855 VKT/hour Assume 80% control of dust emissions, TSP emission rate = 859.9 g/VKT x 0.855 VKT/hour x 20% = 147 g/hour x 1 hour/3600 sec = 0.04 g/s


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Unpaved Roads Particulate emissions from unpaved roads were calculated using emission factors from AP42 Chapter 13.2.2 Unpaved Roads (November 2006). The following assumptions were made regarding vehicle traffic on unpaved roads:

average weight of trucks on paved roads is 15 ton (average of full and empty trucks)

if the crushing plant operated at a maximum capacity of 450 MT/hr (495 ton/hr) it would require approximately 20 trucks/hr to transport the crushed aggregate out of the quarry for use either onsite or transported offsite

each aggregate truck would make 2 trips of approximately 276 m

a silt content of 8.3% was used for the travel completed by aggregate trucks (8.3% is the average for stone quarrying and processing haul roads to and from the pit provided in AP42 Table 13.2.2-1)

the particle size multiplier for PM30 (k = 4.9 lb/vehicle mile travelled) was used to estimate total particulate matter; empirical constants of a = 0.7 and b = 0.45 were used

a control factor of 80% was applied to account for control activities such as watering or use of an approved surfactant

E = k * (s/12)a * (W/3)b = 4.9 * (8.3/12)0.7 * (15/3)0.45 = 7.81 lb/VMT = 7.81 lb/VMT * 454 g/lb * 0.621 mile/km = 2201.7 g/VKT Vehicle kilometres travelled (VKT/hour) = # of trips * distance travelled per trip (km) = (2*20) * 0.276 km = 11.04 VKT/hour Assume 80% control of dust emissions, TSP emission rate = 2201.7 g/VKT x 11.04 VKT/hour x 20% = 4861 g/hour x 1 hour/3600 sec = 1.35 g/s Volume / Area Sources (Storage Piles) HMA Silo and Loadout Emissions from HMA silo filling were calculated using emission factors from AP42 Chapter 11.1 using the formula below:


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For particulate matter emissions:

AP42 emission factor, where E = 0.000332 + 0.00105 (-V) * e(0.0251 * (T+460) - 20.43),

lb/ton V = asphalt volatility of -0.5 T = hot mix asphalt temperature of 315ºF

AP42 emission factor, lb/ton * 0.5 (to convert to kg/MT) * silo storage capacity, MT/hr * 1000 g/kg / 3600 s/hr = 5.30 x10-4 lb/ton * 0.5 * 150 MT/hr * 1000 g/kg / 3600 s/hr = 1.10 x10-2 g/s

Emissions from HMA loadout were calculated using emission factors from AP42 Chapter 11.1 using the formula below: For particulate matter emissions:

AP42 emission factor, where E = 0.000181 + 0.00141 (-V) * e(0.0251 * (T+460) - 20.43),

lb/ton V = asphalt volatility of -0.5 T = hot mix asphalt temperature of 350ºF

AP42 emission factor, lb/ton * 0.5 (to convert to kg/MT) * loadout capacity, MT/hr * 1000 g/kg / 3600 s/hr = 8.20 x10-4 lb/ton * 0.5 * 150 MT/hr * 1000 g/kg / 3600 s/hr = 1.71 x 10-2 g/s

Therefore, the total emission rate for silo filling and loadout is 1.10 x10-2 g/s + 1.71 x 10-2 g/s = 2.81 x 10-2 g/s HMA Storage Piles Emissions from storage piles are highest when the storage pile is disturbed and therefore emissions were estimated based on the amount of material transferred per hour. Estimates were prepared using the emission factor for uncontrolled open storage from the Michigan DEQ Mineral Product Processes Fact Sheet. For particulate matter emissions:


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Material transferred (ton/hour) * Emission factor (lb/ton product stored) * 454 g/lb * 1hour/3600 sec = 159 ton/hour * 0.12 lb/ton * 454 g/lb * 1 hour/3600 sec = 2.41 g/s Cement Silos #1 and #2 The maximum TSP emission rate from each cement silo fabric filter was calculated based on a TSP outlet concentration of 20 mg/m3 and an assumed exhaust flow rate of 0.31 m3/s (660 cfm). The TSP emission factor of 20 mg/m3 was recommended in the MOE Procedure Appendix C and, therefore, has an Above Average data quality.

TSP emissions from the cement supplement silos were calculated using the formula below:

g

mg 1000/

m

mg Loading,Outlet Maximum*

s

m Flowrate, Baghouse3

3

= 0.31 m3/s * 20 mg/m3 / 1000 mg/g = 6.23 x 10-3 g/s

Cold Feed Bin Emissions from the cold feed bin were calculated using emission factors from AP42 Chapter 11.2 Concrete Batching (June 2006), Table 11.12-1, using the formulas below: For particulate matter emissions from sand transfer: AP42 Emission factor (kg/tonne) * Maximum throughput, sand (tonne/hour) * 1000 g/kg * 1 hour/3600 seconds = 0.0011 kg/tonne * 60 tonne/hour * 1000 g/kg * 1 hour/3600 seconds = 0.018 g/s For particulate matter emissions from aggregate transfer: AP42 Emission factor (kg/tonne) * Maximum throughput, aggregate (tonne/hour) * 1000 g/kg * 1 hour/3600 seconds = 0.0035 kg/tonne * 79 tonne/hour * 1000 g/kg * 1 hour/3600 seconds = 0.077 g/s Therefore, the total cold feed bin emissions are 0.018 g/s + 0.077 g/s = 0.095 g/s Weigh Hopper Emissions from the weigh hopper were calculated using emission factors from AP42 Chapter 11.2 Concrete Batching (June 2006), Table 11.12-1, using the formula below:


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For particulate matter emissions: AP42 Emission factor (kg/tonne) * Maximum throughput, sand & aggregate (tonne/hour) * 1000 g/kg * 1 hour/3600 seconds = 0.0026 kg/tonne * 139 tonne/hour * 1000 g/kg * 1 hour/3600 seconds = 0.10 g/s RMC Storage Piles Emissions from storage piles are highest when the storage pile is disturbed and therefore emissions were estimated based on the amount of material transferred per hour. Estimates were prepared using the emission factor for uncontrolled open storage from the Michigan DEQ Mineral Product Processes Fact Sheet. For particulate matter emissions: Material transferred (ton/hour) * Emission factor (lb/ton product stored) * 454 g/lb * 1hour/3600 sec = 110 ton/hour * 0.12 lb/ton * 454 g/lb * 1 hour/3600 sec = 1.67 g/s Primary Crusher Emissions from the primary crusher were calculated using emission factors from AP42 Chapter 11.19.2 Crushed Stone Processing and Pulverized Mineral Processing, Table 11.19.2-2, using the formula below: For particulate matter emissions: AP42 Emission factor (lb/ton) * Capacity (ton/hour) * 454 g/lb * 1 hour/3600 seconds = 0.0012 lb/ton * 495 ton/hour * 454 g/lb * 1 hour/3600 seconds = 7.49 x 10-2 g/s Primary Screen Emissions from the primary screening were calculated using emission factors from AP42 Chapter 11.19.2 Crushed Stone Processing and Pulverized Mineral Processing, Table 11.19.2-2, using the formula below: For particulate matter emissions:


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AP42 Emission factor (lb/ton) * Capacity (ton/hour) * 454 g/lb * 1 hour/3600 seconds = 0.0022 lb/ton * 495 ton/hour * 454 g/lb * 1 hour/3600 seconds = 1.37 x 10-1 g/s Secondary Crusher Emissions from the secondary crusher were calculated using emission factors from AP42 Chapter 11.19.2 Crushed Stone Processing and Pulverized Mineral Processing, Table 11.19.2-2, using the formula below: For particulate matter emissions: AP42 Emission factor (lb/ton) * Capacity (ton/hour) * 454 g/lb * 1 hour/3600 seconds = 0.0012 lb/ton * 275 ton/hour * 454 g/lb * 1 hour/3600 seconds = 4.16 x 10-2 g/s Screen Plant Emissions from the screen plant include secondary screening and transfer from crushers to the storage pile by conveyor. Emissions were calculated using emission factors from AP42 Chapter 11.19.2 Crushed Stone Processing and Pulverized Mineral Processing, Table 11.19.2-2, using the formulas below: For particulate matter emissions from secondary screening: AP42 Emission factor (lb/ton) * Capacity (ton/hour) * 454 g/lb * 1 hour/3600 seconds = 0.0022 lb/ton * 275 ton/hour * 454 g/lb * 1 hour/3600 seconds = 7.63 x 10-2 g/s For particulate matter emissions from transfer: AP42 Emission factor (lb/ton) * Capacity (ton/hour) * 454 g/lb * 1 hour/3600 seconds = 0.00014 lb/ton * 275 ton/hour * 454 g/lb * 1 hour/3600 seconds = 4.86 x 10-3 g/s Therefore, total emissions from the screen plant are 7.63 x 10-2 g/s + 4.86 x 10-3 g/s = 8.12 x 10-2 g/s


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Crushing Storage Piles Emissions from storage piles are highest when the storage pile is disturbed and therefore emissions were estimated based on the amount of material transferred per hour. Estimates were prepared using the emission factor for uncontrolled open storage from the Michigan DEQ Mineral Product Processes Fact Sheet. For particulate matter emissions: Material transferred (ton/hour) * Emission factor (lb/ton product stored) * 454 g/lb * 1hour/3600 sec = 495 ton/hour * 0.12 lb/ton * 454 g/lb * 1 hour/3600 sec = 7.49 g/s Blasting Blasting emission factor was taken from Michigan DEQ Mineral Product Processes Fact Sheet. For particulate matter emissions: Capacity (ton/hour) * Emission factor (lb/ton) * 454 g/lb * 1hour/3600 sec = 714 ton/hour * 0.076 lb/ton * 454 g/lb * 1 hour/3600 sec = 6.85 g/s The blasting sources were modeled separately from the rest of the quarry sources since no quarry sources operated during blasting operations. Drilling Emissions from drilling were calculated using emission factors from AP42 Chapter 11.19.2 Crushed Stone Processing and Pulverized Mineral Processing, Table 11.19.2-2, using the formula below: For particulate matter emissions: AP42 Emission factor (lb/ton) * Capacity (ton/hour) * 454 g/lb * 1 hour/3600 seconds = 0.00008 lb/ton * 714 ton/hour * 454 g/lb * 1 hour/3600 seconds = 7.22 x 10-3 g/s


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C. Sample Output Files for Regulation 346 and AERMOD dispersion modelling runs Regulation 346 Dispersion Model Sample Output file (nitrogen oxides)

MAXIMUM GROUND LEVEL CONCENTRATION

VERSION 2.00

Date: Apr 30, 2007

Application No: P3053 Miller Braeside Quarry

Reviewer: CW

Title: NOx

Data from file: mbnox-3.stk

Point Sources

Number Height Emission Exit Diameter Temp X Y

Rate Velocity

m gm/s m/s m C m m

1 10.7 11.50 45.7 .8 149.0 -764. 168.

2 7.9 .100E-39 55.6 .2 370.0 -766. 179.

Virtual Sources

Number Height Emission Width Length Angle X Y

Rate

m gm/s m m deg m m

3 18.3 .100E-39 4.5 4.5 90.0 -782. 157.

4 4.0 .100E-39 3.0 3.5 -60.0 -672. -86.

5 20.0 .100E-39 15.0 18.0 30.0 -685. -55.

6 15.0 .100E-39 5.0 99.0 43.0 -371. -255.

Single Source Maximum Ground Level Concentrations

Source Stability Maximum Distance Wind Speed

Conc (ug/m3) (m) (m/sec)

1 C 288.43 219. 7.235

D 347.24 369. 7.735

2 C .13023E-37 152. 2.735

D .16095E-37 259. 2.735

3 C .11915E-36 3. 5.000

D .16912E-36 3. 5.000

4 C .81000E-36 2. 5.000

D .11623E-35 2. 5.000


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5 C .34149E-37 9. 5.000

D .47821E-37 9. 5.000

6 C .30841E-37 50. 5.000

D .58552E-37 50. 5.000

All Stacks Tested

Maximum off-property ground level concentration 347.24 ug/m3

Stability D

Wind direction 245.321 deg

Wind speed 7.735 m/s

Coordinates -917.9 -167.0 (m)

Maximum Concentration along the property line 347.24 ug/m3

Stability D

Wind direction 209.043 deg

Wind speed 7.735 m/s

Coordinates -1086. -11. (m)

Sample input file is available to RWDI. AERMOD Dispersion Model Sample Output File Input/output files for the runs are available to RWDI as separate PDF files. The .ain and .aou files are the AERMOD equivalent files. Section 1.3 – Air Dispersion Modelling Section 1.3 claims that the AERMOD model lumped all sources into a single source. This is not correct. All surface sources were individually modeled including detailed road segments. The sources within the Pit were modeled as a PIT source in AERMOD, which requires that all emissions of particulate within the pit be summed into a single value for use in specifying the PIT sources emission rate. Also in Section 1.6, the reviewer’s misunderstanding of the PIT source in the AERMOD model leads him to conclude that the AERMOD model did not consider the worst case situation, which is completely wrong. The CO2 emissions have no local consequence and should not be modeled for MOE compliance purposes. Section 1.4 – Interpretation of Air Dispersion Modelling Results Table 1 (Emission Summary Table) has been revised to account for the new or revised Standards issued since the publication of the Air Quality Assessment Report.


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Contaminant Name CAS#

Total

Facility

Maximum

Emission

Rate

(g/s)

Air

Dispersion

Model

Used

Max. POI

Concentration

(µg/m3)

Ave

ragin

g

Pe

riod

(hr)

POI Limit

(1/2-hr)

(µg/m3)

Limiting

Effect

Regulation Schedule # or

Alternate

Maximum

% of POI

Limit

1-Pentene 109-67-1 0.046 Reg 346 1.4 0.5 108 - Half-hour MOE JSL (3) 1%

2-Methyl-1-pentene 763-29-1 0.083 Reg 346 2.5 0.5 - - - -

2-Methyl-2-butene 513-35-9 0.012 Reg 346 0.37 0.5 318 - Half-hour MOE JSL (3) <1%

Benzene 71-43-2 0.0081 Reg 346 0.25 0.5 90 - Michigan (2) <1%

Benzo(a)pyrene 50-32-8 0.0000007 Reg 346 0.000066 0.5 0.0033 Health Guideline (1) 2%

n-Butane 106-97-8 0.014 Reg 346 0.42 0.5 22,800 - Half-hour MOE JSL (3) <1%

Carbon Dioxide 124-38-9 690 Reg 346 21000 0.5 63,000 - Half-hour MOE JSL (3) 33%

Carbon Monoxide 630-08-0 2.7 Reg 346 82 0.5 6,000 Health 1 1%

Ethylene 74-85-1 0.15 Reg 346 4.4 0.5 40 Vegetation Guideline (1) 11%

Formaldehyde 50-00-0 0.065 Reg 346 2 0.5 65Odour /

Irritation1 3%

Methane 74-82-8 0.26 Reg 346 8.4 0.5 - - - -

Naphthalene 91-20-3 0.014 Reg 346 0.41 0.5 36 Odour Guideline (1) 1%

NOx 10102-44-0 11 Reg 346 350 0.5 500 Health 1 69%

Silica 14808-60-7 0.062 Reg 346 8 0.5 15 Health Guideline (1) 53%

Sulphur Dioxide 7446-09-5 2.3 Reg 346 69 0.5 830 Health 1 8%

Particulate Matter TSP 0.97 Reg. 346 27 0.5 100 Visibility 1 27%

NOTES:

(3) JSL is the MOE 'Jurisdictional Screening Level' (February 2008)

(1) Taken from "Summary of Standards and Guidelines & Ambient to support Ontario Regulation 419, February 2008

(2) Taken from Michigan Department of Environmental Quality ITSL/IRSL Toxics Screening Level, January 2006

Section 1.6.1 Appendix A – Emission Rate Calculation Assumptions

A.2.5 RMC Truck Loading

No photos are available to support the applicability of the 50% control assumption. This is considered to be a conservative assumptionl.

A.4.1.1 Paved Road Dust

Michigan DEQ 2005 documentation is included in discussion of Section 1.2 (A.4.1). Additional supporting details on water suppressant are included in the following section (1.6.2). A silt loading of 8.8 g/m2 for HMA batching was used. The value in AP-42 Chapter 13.2.1, Table 13.2.1-4 of 120 g/m2 as listed is misleading. As shown in the associated supporting document for this section in Table A1-5 (page 1-7), the emission factor for asphalt batching paved roads is about half of the emission factor for concrete batching roads.

A.4.1.2 Unpaved Roads

The vehicle weight of 15 tons is set to the average of a fully loaded truck and an empty truck in view of the fact that each trip counted in the calculation of vehicle kilometres travelled includes a round trip


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Section 1.6.2 Appendix B – Dust Management Plan Summary A detailed Dust Management Plan that is to be implemented at the quarry is attached. When we have discussed these comments with RWDI for any necessary clarifications, we will incorporate them in a revised final report. Yours truly, Church & Trought Inc. (CTI)

John Trought Attach Cc Skelton Brumwell – Gary Bell

Documents

November 12, 2008 REFERENCE: Response to RWDI Peer … · Markham, Ontario L3R 9R8 REFERENCE ... particulate emission rate for each fuel type was calculated ... heating value of 91.5