Ministry Ministère Order Issued Pursuant to s.35(14) of of the de O. Reg. 419/05Environment l’Environnement and Climate et de l’Action en Change matière de

changement climatique

Benzene Order Number: 202-17-order-rv0 Reference Number: 7856-9VDPSR

Issue Date: November 21, 2017 Expiry Date: November 21, 2022

Order Issued to: Ruetgers Canada Inc.

Site Location: 725 Strathearne Ave. North Hamilton, Ontario L8H 5L3

Part 1: Legal Authority and Reasons

1.1 Pursuant to subsection 35 (14) of O. Reg. 419/05 if the Director sets a site-specific standard under subsection 35 (1) of the Regulation, he or she may make an order requiring a person to whom the site-specific standard applies to take steps specified by the order, not later than the dates specified in the order, that are related to complying with section 20, having regard to subsection 35 (4) of the Regulation.

1.2 Ruetgers Canada Inc. (the Company) is the owner, or is in occupation of, or has charge, management, or control of the operations known as the Ruetgers Canada Inc. with the street address of 725 Strathearne Ave. North Hamilton, Ontario L8H 5L3

1.3 On April 1, 2015, the Company submitted the Request pursuant to s. 35(1) of O. Reg. 419/05 (see Part 2 for the definition of the Request).

1.4 Information provided in the Request indicates that the following benzene site-specific standards for an annual averaging period would result in the difference between the standard with an annual averaging period set out in Schedule 3 of the Regulation and the site-specific standard being the minimum difference necessary to enable the Company to comply with section 20 of the Regulation with respect to benzene:

(a) From the date of issuance of the site-specific standard approval to June 30,2018: 27.7 µg/m3

(b) From July 1, 2018 to the expiry date of the site-specific standard approval:12.7 µg/m3

1.5 A site-specific standard of 27.7 µg/m3 (annual averaging period) from the date of site-specific standard approval to June 30, 2018 and of 12.7 µg/m3 (annual averaging period) from July 1, 2018 up to the expiry date of the site-specific standard approval, was set for the Facility for benzene by the Director on November 21, 2017. This Order is being made under subsection 35(14) of the Regulation and directs the Company to undertake the necessary steps that are related to complying with section 20 of the Regulation, having regard to subsection 35(4) of the Regulation.

Part 2: Definitions and Application

Ruetgers Canada Inc. – Benzene "This is not an original copy."

Order having regard to a Site-specific Air Standard Approval Order Number: 202-17-order-rv0

Reference Number: 7856-9VDPSR Issue Date: November 21, 2017

2.1 For the purpose of this Order, the following definitions apply:

”Action Plan for Benzene” has the same meaning as Action Plan in the Approval;

"Approval" means the site-specific standard approval for Benzene number 202-17-rv0, reference number 7856-9VDPSR issued November 21, 2017;

“Benzene” means benzene with a chemical abstract system (CAS) number of 71-43-2;

“Company” means Ruetgers Canada Inc.;

“Director” means a person in the Ministry, appointed under section 35 of the Regulation under the Environmental Protection Act;

“District Manager” means the District Manager of the Ministry’s Hamilton District Office;

“Drill and tap leak repair” means a method of repairing a leaking valve by drilling a hole into the valve packing gland, tapping the gland so that a small valve and fitting can be attached to the gland, and pumping new packing material into the gland;

”EMT” means the Environmental Monitoring Team that the Company is required by Item 4.1 to establish;

“Facility” means the Company facility referred to as Ruetgers Canada Inc. and located at 725 Strathearne Ave. North Hamilton, Ontario L8H 5L3;

“Fixed leak detection system” means a permanently located system of sensors that are electrically linked to an analyzer and an electronic data acquisition system. For example, a fixed leak detection system may be located near a component, sample the air at regular time intervals and analyze and record the concentration of VOCs discharged to the air from the leaking component;

“Inaccessible component” means a component that is located, (a) at least two metres above a permanently available support surface,(b) in such a manner that scaffolding or a harness is required in order to access the

component, or(c) in such a manner that the component is made inaccessible by a protective cover or

insulation;

“Ministry” means the Ontario Ministry of the Environment and Climate Change;

“OGI instrument” means an instrument that makes emissions, that may otherwise be invisible to the naked eye, visible through the use of optical gas imaging;

“Order” means this order number 202-17-order-rv0 issued under subsection 35(14) of the Regulation in conjunction with Approval number 202-17-rv0;

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Order having regard to a Site-specific Air Standard Approval Order Number: 202-17-order-rv0 Reference Number: 7856-9VDPSR

Issue Date: November 21, 2017

“Portable gas detector” means a handheld instrument that, when passed over a leaking component, measures the concentration of the gas leaking from the component;

“Regulation” means Ontario Regulation 419/05: Air Pollution – Local Air Quality under the Environmental Protection Act as amended from time to time;

“Request” has the same meaning as in the Approval;

“SDB Director” means the Director of the Ministry’s Standards Development Branch;

“unsafe component” means a component that, if assessed for leaks, is likely to, (a) expose personnel performing the assessment to imminent hazard from temperature,

pressure or explosive process conditions; or(b) lead to other dangerous circumstances as defined by the Occupational Health and

Safety Act; and

“Volatile organic compound” (“VOC”) means an organic compound the composition of which makes it possible for the compound to evaporate under normal atmospheric conditions of temperature and pressure.

2.2 For the purpose of this Order, a component is in heavy liquid service if the component contains a fluid,

(a) that is not in a gaseous state at operating conditions; and(b) in which the percentage of pure organic compounds that have a vapour pressure of

greater than 0.3kPa at 20oC is less than 20 per cent by weight.

Part 3. Leak Measurement Instrumentation

For the purposes of this Order, the Company shall ensure that, (a) if this Order requires the use of a portable gas detector, the detector meets the criteria set

out in section 2 of Appendix “A” and is used in a manner set out in section 3 of Appendix“A”;

(b) if this Order requires the use of an OGI instrument, the OGI instrument used meets thecriteria set out in section 1 of Appendix “B” and is used in a manner set out in section 2 ofAppendix “B” and

(c) if this Order requires the use of a fixed leak detection system, the fixed leak detectionsystem meets the criteria set out in section 1 of Appendix “C”.

Part 4: Work Ordered

The Company shall take steps related to compliance with section 20 of the Regulation having regard to the site-specific standard referred to in Item 1.5 above. Pursuant to s. 35 (14) of the Regulation, I hereby order the Company to, commencing on the compliance date set out in each Item below, take all steps necessary to do the following:

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Order having regard to a Site-specific Air Standard Approval Order Number: 202-17-order-rv0 Reference Number: 7856-9VDPSR

Issue Date: November 21, 2017

ENVIRONMENTAL MONITORING TEAM (EMT)

Item 4.1 Compliance Date: Commencing two months after the date the Order was issued

1. The Company shall establish, maintain and participate in an Environmental MonitoringTeam to serve as a forum for dissemination, consultation, review and exchange ofinformation regarding the operation of the Facility, environmental issues such as airmonitoring, analysis of relevant monitored data, status of the Action Plan implementationand any need for new approvals or amendments to existing approvals.

2. The EMT required by paragraph 1 shall include at least one representative from theCompany, one representative from the Ministry and at least three representatives fromthe community.

3. Subject to paragraph 6, the Company shall ensure that the EMT meets at least one timein every three month period, outside the Facility at a publicly accessible location.

4. The Company shall ensure that each member of the EMT is notified of each meeting ofthe EMT at least 30 days prior to the meeting.

5. The first EMT meeting shall occur no later than two months after the date that thisOrder was issued.

6. After June 30, 2018, the frequency of EMT meetings can be reduced to a frequency of noless than one time in every six month period if a vote is taken at an EMT meeting and allpersons attending the meeting vote in favour of the change in frequency.

ENVIRONMENTAL MANAGEMENT SYSTEM AND COMMUNITY ENGAGEMENT REPORT

Item 4.2 Compliance Date: Commencing April 1, 2018

1. By March 31 of each year, the Company shall prepare an annual report titled“Environmental Management System and Community Engagement Report” that sets outthe following information with respect to the preceding calendar year:

i. Documentation of all complaints received by the Company relating to airemissions and the resolution of those complaints;

ii. A written summary of the actions taken each calendar year to implement theAction Plan for Benzene, including a description of each action taken, the date ofimplementation of each action taken and dates for the implementation of actionsyet to be taken; and

iii. The minutes of the EMT meetings held during the calendar year and any relatedfollow-up actions.

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Order having regard to a Site-specific Air Standard Approval Order Number: 202-17-order-rv0 Reference Number: 7856-9VDPSR

Issue Date: November 21, 2017

2. The Company shall make a copy of the report required by paragraph 1 available forpublic inspection at the Facility during office hours and available on the Company’swebsite no later than March 31 of the year following the calendar year that the reportwas prepared for.

3. The Company shall present the report required by paragraph 1 to the EMT at the nextmeeting of the EMT following the date that the report is prepared.

LEAK DETECTION AND REPAIR PROGRAM

Item 4.3 Component identification Compliance Date: Two months after the date the Order was issued

1. Subject to paragraph 3, the Company shall make a written record of each of thefollowing components at the Facility if the component is in benzene service:

i. A compressor.ii. A pump.iii. A valve.iv. A pressure relief device.v. A sample point.vi. An instrumentation system.vii. An agitator.viii. A connector.

2. A component is in benzene service for the purposes of this Item if the component maycontain or come in contact with a liquid or gas that contains at least 1 per cent benzeneby weight.

3. The following components do not need to be included in the record required byparagraph 1:

i. A pump that is equipped with,A. a dual mechanical seal; andB. a system that alerts the operator when the seal or barrier fluid has failed.

ii. A valve or connector with a nominal diameter of less than 1.875 centimetres or ¾of an inch.

4. Each component required to be recorded under paragraph 1 shall be listed in a singleelectronic record with associated fields setting out the following information:

i. The name and model number of the component.ii. The name of the manufacturer of the component.iii. The serial number of the component.

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Order having regard to a Site-specific Air Standard Approval Order Number: 202-17-order-rv0 Reference Number: 7856-9VDPSR

Issue Date: November 21, 2017

iv. The purpose of the component.v. The process unit of which the component is part.vi. Whether the component is in heavy liquid service.vii. The date the component was installed.viii. If the component replaced a component, the period of time the replaced

component was in service.ix. Whether the component is an inaccessible component or an unsafe component

5. No later than 30 days after a change is made at the Facility that would affect theinformation in the record required by this Item, the Company shall ensure that the recordis updated to reflect the change.

Item 4.4 Inaccessible and unsafe components record

Compliance Date: Two months after the date the Order was issued

1. The Company shall make a written record of each component at the Facility that is aninaccessible component or an unsafe component and the reason that the component isan inaccessible component or an unsafe component.

2. The record required by paragraph 1 shall be certified as complete and accurate by thehighest ranking individual regularly present at the Facility who has managementresponsibilities relating to the Facility.

3. No later than 30 days after a change is made at the Facility that would affect theinformation in the record required by this Item, the Company shall ensure that the recordis updated to reflect the change.

Item 4.5 Component leak survey – general Compliance Date: Commencing April 1, 2018

1. The Company shall ensure that a component leak survey is performed in accordancewith this section.

2. A component leak survey shall be completed, at least three times each calendar yearwith at least one component leak survey being completed during each of the followingperiods,

i. the period starting April 1 and ending June 30,ii. the period starting July 1 and ending September 30, andiii. the period starting October 1 and ending December 31.

3. A component leak survey required by this Item shall assess each component required tobe recorded under Item 4.3 to determine if the component is leaking.

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Order having regard to a Site-specific Air Standard Approval Order Number: 202-17-order-rv0 Reference Number: 7856-9VDPSR

Issue Date: November 21, 2017

4. Despite paragraph 3 a component does not need to be included in a component leaksurvey if the component is identified in the record required by Item 4.4 as inaccessible oras an unsafe component.

5. No later than March 1 each year, the Company shall ensure that the Director and theDistrict Manager are given a written summary of the dates on which component leaksurveys are anticipated to occur during the calendar year and ensure thatrepresentatives of the Ministry are given an opportunity to witness the survey.

Item 4.6 Component leak survey – Compliance Date: Commencing April 1, 2018

Assessment and measurement of leaks 1. The Company shall ensure that a component leak survey required by Item 4.5 is

performed in accordance with this Item.2. Subject to paragraph 3, each component that is part of a component leak

survey required by Item 4.5 shall be assessed using one of thefollowing methods:

i. A portable gas detector shall be used to assess for a gaseous leakand to measure the concentration of VOCs discharged to air from aleaking component.

ii. An OGI instrument shall be used to assess for a gaseous leak.iii. A fixed leak detection system shall be used to assess for a gaseous

leak and to measure the concentration of VOCs discharged to airfrom a leaking component.

3. At least one time in each 12-month period, a method set out in subparagraph 2 i or iiishall be used to assess and measure each component mentioned in paragraph 2.

4. Each component that is part of a component leak survey required by Item 4.5 that maycontain a liquid shall be assessed for a liquid leak using an audio or visual method tomeasure the leak rate of liquid discharged from each leaking component. The liquid leakrate shall be measured in number of drops per minute.

5. The Company shall ensure that a person who is required to perform a component leaksurvey receives training on the leak assessment methods mentioned in paragraphs 2and 4 by a person with experience in the relevant method.

6. No later than seven days after a leak is identified using an OGI instrument, theconcentration of VOCs discharged to air from the leaking component shall be,

i. measured using a portable gas detector; orii. determined using an accessory device to the OGI instrument.

7. A determination made under subparagraph 6 ii is deemed to be a measurement of theconcentration of VOCs discharged to air from a leaking component.

8. The leak rate mentioned in paragraph 4 shall be measured in accordance with thefollowing rules:

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Order having regard to a Site-specific Air Standard Approval Order Number: 202-17-order-rv0 Reference Number: 7856-9VDPSR

Issue Date: November 21, 2017

i. Observe the component for at least one minute and count thenumber of drops seen or heard.

ii. Repeat the observation required by subparagraph i three times in aperiod of no more than ten minutes.

iii. Calculate the average of the leak rates observed under subparagraphsi and ii.

Item 4.7 Component leak survey plan Compliance Date: Commencing April 1, 2018

1. The Company shall ensure that a component leak survey plan that meets therequirements in this Item is prepared prior to the initial component leak survey requiredby Item 4.5.

2. A component leak survey plan shall be in electronic form and shall include thefollowing information:

i. A general description of the planned component leak surveyincluding a description of,

A. the components that are to be part of the component leaksurvey,

B. the location of each component that will be part of thecomponent leak survey,

C. the method that will be used to assess each component forleaks,

D. the percent by weight of benzene anticipated in leaks, basedon the percentage of benzene by weight to whichcomponents in a process unit are exposed, and

E. the training and experience of theindividuals performing the component leak survey.

ii. If an OGI instrument will be used to perform the component leaksurvey, the number of view angles from which images will be takenfor each component.

iii. A checklist of things to check or tasks to perform at the start ofeach day on which a component leak survey is performed,including,

A. if a portable gas detector will be used to perform thecomponent leak survey, determining and recording theresponse factor, the calibration precision and the responsetime of the portable gas detector in accordance Appendix A,

B. if an OGI instrument will be used to perform the componentleak survey, confirmation that the date and time settings ofthe OGI instrument are correct, and

C. if a fixed leak detection system will be used to perform anypart of the component leak survey, an automated check forany malfunctioning sensors.

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Order having regard to a Site-specific Air Standard Approval Order Number: 202-17-order-rv0 Reference Number: 7856-9VDPSR

Issue Date: November 21, 2017

3. No later than March 1 each year, the Company shall update the component leak surveyplan required by this Item so that the information required in the plan is accurate for thesurveys to be performed in the calendar year.

4. If the information required in the component leak survey plan required by this Itemchanges after March 1 of a year, the Company shall ensure that the plan is updated sothat it is accurate.

5. If a change mentioned in paragraph 4 affects the dates on which component leaksurveys are anticipated to occur during the calendar year as set out under paragraph 5of Item 4.5, the Company shall ensure that the Director and the District Manager arenotified as soon as practicable of the change in dates.

Item 4.8 Additional leak measurements - Compliance Date: Commencing two months after the date the Order was issued

Pumps, compressors and pressure relief devices

1. The Company shall ensure that a pump, compressor or pressure relief valve required tobe recorded under Item 4.3 is observed visually and audibly to identify gaseous andliquid leaks at least one time in every 12-hour period.

2. The Company shall ensure that the liquid leak rate from a leaking component ismeasured in accordance with the rules set out in paragraph 8 of Item 4.6 as soon aspracticable after a liquid leak is identified under paragraph 1.

3. No later than seven days after a gaseous leak is identified under paragraph 1, theCompany shall ensure that the concentration of VOCs discharged to air from the leakingcomponent is measured using,

i. a portable gas detector; orii. a fixed leak detection system.

Item 4.9 Leaks – repair Compliance Date: Commencing the earlier of April 1, 2018 and two months after the Order was issued

1. The Company shall ensure that repairs are made in accordance with paragraph 2 if one ormore of the following criteria are met:

i. A measurement required by the Order indicates that the concentration ofVOCs discharged to air from a leaking component is greater than or equal to 500 ppm by volume.ii. A measurement required by the Order indicates that a component has a liquid leak rate of three drops per minute or greater.

2. Subject to paragraph 3, the repairs required by paragraph 1 include, 9

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Order having regard to a Site-specific Air Standard Approval Order Number: 202-17-order-rv0 Reference Number: 7856-9VDPSR

Issue Date: November 21, 2017

i. no later than five days after taking a measurement mentioned inparagraph 1, making all repairs to prevent, minimize or reducethe leak that can feasibly be made in the five-day period such as,

A. if the component is a pump, tightening the packing glandnuts and ensuring that the seal flush is operating at designpressure and temperature, and

B. if the component is a valve, tightening the bonnet bolts,replacing the bonnet bolts, tightening the packing gland nuts,and injecting a lubricant into lubricated packing; and

ii. if the measurement is in the range set out in Column 1 of Table 1, repairing thecomponent within the repair period set out opposite the range in Column 2 of Table 1so that,

A. the concentration of VOCs discharged to air from the component is lessthan 500ppm by volume, or

B. the liquid leak rate is zero drops per minute.

3. A component does not need to be repaired within the applicable repair period set outin subparagraph 2 ii if,

i. the component is taken out of service no later than the last day in the repairperiod set out in Column 2 of Table 1, or

ii the component is placed on a delay of repair list in accordance with Item 4.10. 4. The Company shall ensure that a component mentioned in subparagraph 3 i isrepaired so that concentration of VOCs discharged to air from the component is lessthan 500 ppm by volume before the component is put back into service.

TABLE 1: Leak Repair

Item Column 1 Measurement Range

Column 2 Repair Period

1 500ppm – less than 1,000 ppm of VOCs by volume

The 60-day period commencing the date the leak is measured.

2 Greater than 1,000 ppm of VOCs by volume

The 30-day period commencing the date the leak is measured.

3 Greater than three drops per minute

The 7-day period commencing the date the leak is measured.

Item 4.10 Delay of repair list

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Order having regard to a Site-specific Air Standard Approval Order Number: 202-17-order-rv0 Reference Number: 7856-9VDPSR

Issue Date: November 21, 2017

Compliance Date: Commencing the earlier of April 1, 2018 and two months after the Order was issued

1. The Company shall ensure that the following information is recorded with respect toeach component at the Facility that is placed on the delay of repair list:

i. The name of the component, the component identifier, and the serial numberof the component.

ii. The process unit of which the component is part.iii. The estimated fraction of benzene, by volume, that the component

is exposed to.iv. The reason that the component could not be repaired within the

applicable repair period set out in Item 4.9.v. The concentration of VOCs leaking from the component as

measured under Items 4.6 or 4.8.vi. The calculated concentration of benzene leaking from the

component, calculated as the product of the values set out insubparagraphs iii and v.

vii. A description of any repairs made to the leaking component.viii. The date and time of the next anticipated shut-down of the process

unit of which the component is part.

2. A component may only be placed on the delay of repair list if one or more of thefollowing criteria are met:

i. The process unit in which the component is located must be shut down in orderto repair the component.

ii. The component is a valve and the only repair that could be made to the valvewithout shutting down the process unit in which the valve is located is a drill andtap leak repair.

3. The Company shall ensure the concentration of benzene recorded under subparagraph1 vi for each component on the delay repair list is summed.

4. At least one time in each six-month period of each year the Company shall ensure thata report that contains the following information is signed by the highest-rankingindividual regularly present at the Facility who has management responsibilities relatingto the Facility and submitted to a provincial officer:

i. Each component on the delay repair list.ii. The length of time each component on the delay of repair list has been on

the list.iii. For each component on the delay of repair list, the concentration of

benzene leaking from the component calculated in accordance withsubparagraph 1 vi.

iv. The sum determined under paragraph 3.v. Each component that was set out in the previous report that is not

set out in the report.vi. For each component mentioned in subparagraph v, the results of the

measurement required by section 4.10 following the repair to thecomponent.

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Order having regard to a Site-specific Air Standard Approval Order Number: 202-17-order-rv0 Reference Number: 7856-9VDPSR

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vii. A comparison of the number of components set out in the report tothe number of components set out in the previous report.

viii. A comparison of the sum mentioned in sub-paragraph iv to the sum setout in the previous report.

5. The Company shall ensure that the next time a process unit is shut down, eachcomponent on the delay of repair list that is part of the process unit is repaired so thatthe concentration of VOCs discharged to air from each component is less than 500 ppmby volume.

6. Subject to paragraph 7, if a component on the delay of repair list is a valve, theCompany shall ensure that the next time the process unit in which the valve is located isshut down, the valve is replaced with a low emission valve or repacked with lowemission valve packing that meets the criteria set out in paragraph 2 of Item 4.12.

7. Paragraph 6 does not apply with respect to a valve for which there is no low-emissionreplacement or low emission packing if the registered person notifies the Director, inwriting, no later than 30 days after the date that the process unit in which the valve islocated is shut down that there is no low-emission replacement or low emission packingfor the valve.

8. The notification required by paragraph 7 shall include the followinginformation:

i. The date of the shut-down of the process unit in which the component islocated.

ii. A description of the component.iii. An explanation of why there is no low-emission replacement.iv. A description of how the component was repaired instead of

replaced.

9. No later than six months after a component on the delay of repair list is repaired,the Company shall submit the following information, in writing, to a provincial officer:

i. The date of the shut-down of the process unit in which the component islocated.

ii. The date the component was repaired.iii. A description of how the component was repaired.iv. The concentration of VOCs leaking from the component after the

repair was made.

Item 4.11 Re-measurement following component repair or replacement Compliance Date: Commencing the earlier of April 1, 2018 and two months after the Order was issued

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Order having regard to a Site-specific Air Standard Approval Order Number: 202-17-order-rv0 Reference Number: 7856-9VDPSR

Issue Date: November 21, 2017

1. After a component is required to be repaired in accordance with Item 4.9 or 4.10 orreplaced in accordance with Item 4.12, the Company shall make the followingmeasurements no later than the dates set out in paragraph 2:

i. One of the following methods is used to measure the concentrationof VOCs discharged to air from the component that was required tobe repaired or replaced,

A. a portable gas detector, orB. a fixed leak detection system.

ii. The liquid leak rate from the component required to be repaired orreplaced is measured in accordance with the rules set out inparagraph 8 of Item 4.6.

2. The measurements required by paragraph 1 shall be made,i. if the component is required to be repaired in accordance with

paragraph 2 of Item 4.9, no later than the last day in the repair period setout in Column 2 of Table 1, as applicable;

ii. if the component is required to be repaired in accordance withparagraph 4 of Item 4.9, no later than seven days after the component isput back into service;

iii. if the component is required to be repaired in accordance withparagraph 5 of Item 4.10, no later than 30 days after the date that theprocess unit in which the component is located is placed back intoservice; and

iv. if the component is required to be replaced in accordance withItem 4.12, no later than seven days after the component isreplaced.

Item 4.12 Component replacement Compliance Date: Commencing the earlier of April 1, 2018 and two months after the Order was issued

1. The Company shall ensure that a component required to be recorded under Item 4.3 isreplaced with a new component if the component has been repaired two times in a 24-month period so that the concentration of VOCs discharged to air from the component isless than 500 ppm by volume and is required to be repaired a third time in the period.

2. Subject to paragraph 3, if the component mentioned in paragraph 1 is a valve, the valveshall be replaced with a low emission valve or repacked with low emission valve packingthat meets the following criteria:

i. The valve or valve packing has been tested by the manufacturer todetermine the concentration of VOCs discharged from the valve orvalve packing.

ii. The maximum concentration of VOCs determined under subparagraph ishall not be greater than 500 ppm by volume.

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Order having regard to a Site-specific Air Standard Approval Order Number: 202-17-order-rv0 Reference Number: 7856-9VDPSR

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iii. The average concentration determined under subparagraph i shall not begreater than 100 ppm by volume.

3. Paragraph 2 does not apply with respect to a valve for which there is no low-emissionreplacement or low emission packing if the Company notifies the Director, in writing, nolater than 30 days after the date that the process unit in which the valve is located isshut down that there is no low-emission replacement or low emission packing for thevalve.

4. The notification required by paragraph 3 shall include the following information:i. The date of the shut-down of the process unit in which the component is

located.ii. A description of the component.iii. An explanation of why there is no low-emission replacement.iv. A description of how the component was repaired instead of

replaced.

5. Subject to paragraph 6, the Company shall ensure that a componentrequired to be replaced under paragraph 1 is replaced with a newcomponent no later than the last day in the repair period associated with the third repairmentioned in paragraph 1 set out in Column 2 of Table 1.

6. Paragraph 5 does not apply to the replacement of a component if thecomponent is taken out of service no later than the last day in the applicablereplacement period set out in paragraph 5.

7. The Company shall ensure that a component mentioned in paragraph 6 isreplaced before the component is put back into service.

Item 4.13 Records - component leak survey Compliance Date: Commencing April 1, 2018

1. The Company shall ensure that for each component required to be recorded underItem 4.3 the following is recorded in the electronic record with respect to eachcomponent leak survey required by Item 4.5:

i. The date the component was assessed for leaks.ii. The position title of the personnel who assigned an individual to

assess the component for leaks and the date the individualreceived the training required by paragraph 5 of Item 4.6.

iii. The method used to assess the component for leaks, inaccordance with Item 4.6, including,A. if a portable gas detector or OGI instrument is used to

assess the component, the unique identifier of the detectoror instrument used,

B. if a fixed leak detection system is used to assess thecomponent, the distance from the component assessed by

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the fixed leak detection system to each sensor that assessed the component for leaks.

iv. The result of the assessment required by Item 4.6, including, if aleak is identified,A. if the assessment indicated that VOCs were being

discharged to air in a concentration of 500 ppm by volumeor greater, the measured concentration of VOCs,

B. if an OGI instrument was used to assess the component andthe follow-up measurement required by paragraph 6 of item 4.6indicated that VOCs were being discharged to air in aconcentration of 500 ppm by volume or greater,I. the method used to perform the follow-up measurementrequired by paragraph 6 of Item 4.6,II. copy of the image or images produced by the OGIinstrument and the time that the images were taken,

III. the wind speed that is published by Environment andClimate Change Canada for the area in the vicinity of theFacility on the date that the component was assessed forleaks,andIV. an indication of whether it was sunny or overcast at thetime that the component was assessed for leaks,

C. if the assessment indicated that the component had a liquidleak rate of three drops per minute or greater, the measuredliquid leak rate.

v. If a concentration indicated in accordance with sub-subparagraphs 1 iv Aor B is 500 ppm by volume or greater, the estimated mass emissionrate of benzene, in grams per second, and a description of how themass emission rate was estimated.

vi. A description of each action taken to repair the leak, including thedate each action was taken.

vii. The position title of the personnel who assigned an individual tomake the repair.

viii. The likely cause of the leak.ix. The date that measurements required by Item 4.11 were made.x. The method used to make to take the measurements required by

Item 4.11.xi. The result of the measurements required by Item 4.11, including the

concentration of VOCs or liquid leak rate measured.

2. After the completion of each component leak survey performed at the Facility, theCompany shall ensure that a record of the following information is made:

i. The start date and end date of the component leak survey.ii. A summary of the methods used in the component leak survey.iii. The percentage of leaking components, calculated in accordance

with paragraph 3.iv. An indication of whether the operating conditions at the Facility were

normal on each day of the component leak survey.v. An indication of the weather conditions at the Facility on each day of the

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component leak survey. vi. If a fixed leak detection system was used for any part of the

component leak survey, for each fixed leak detection system used,A. the number of sensors used to assess components for leaks,B. the manufacturer and model number of each sensor,C. the type of each analyser linked to each sensor,D. the manufacturer and model number of each analyser,E. the year each sensor was installed,F. the year each analyser was installed, andG. a record of any sensors that malfunctioned during the

automated checks required by sub-subparagraph 2 iii C ofItem 4.7.

vii. If a portable gas detector was used for any part of the componentleak survey,A. the manufacturer and model number of each portable gas

detector, andB. for each day on which part of a component leak survey was

performed using a portable gas detector,I. the unique identifier of each portable gas detector

used on the day,II. the concentration of calibration gas used to determine the

response factor and calibration precision of eachportable gas detector used on the day,

III. the response factor, calibration precision and responsetime of each portable gas detector used on the daydetermined in accordance with Appendix A .

viii. If an OGI instrument was used for any part of the component leaksurvey, the manufacturer, model number and unique identifier ofeach OGI instrument.

3.The percentage of leaking components shall be calculated in accordance with thefollowing formula:

RT / CT * 100 where, RT= the total number of components that require repair under Items 4.9 and

4.10. CT= the total number of components assessed in the component leak

survey required by Item 4.5.

Item 4.14 Records – additional leak measurements Compliance Date: Commencing two months after the Order was issued

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1. If a measurement required by Item 4.8 identifies that the concentration of VOCsdischarged to air from a leaking component is greater than or equal to 500 ppm byvolume or that a component has a liquid leak rate of three drops per minute or greater,the Company shall ensure that the following information is recorded with respect to theleaking component in the electronic record required by Item 4.3:

i. The date the component was identified as leaking.ii. The name of the individual who identified the component as leaking.iii. The concentration of VOCs discharged to air from the component or liquid leak

rate measured as required by Item 4.8.iv. The date that the liquid leak rate or concentration of VOCs discharged to air from

the component was measured.v. The name of the individual who measured the liquid leak rate or concentration of

VOCs discharged to air from the component.vi. The method used to measure the liquid leak rate or concentration of VOCs

discharged to air from the component.vii. If the concentration mentioned in subparagraph iii was measured using a

portable gas detector,A. the unique identifier of the portable gas detector,B. the concentration of calibration gas used to determine the

response factor and calibration precision of the portable gas detector,C. the response factor, calibration precision and response time of the

portable gas detector determined in accordance with Appendix A.viii. If the leak is a gaseous leak, the estimated mass emission rate of benzene, in

grams per second, and a description of how the mass emission rate wasestimated.

ix. A description of each action taken to repair the leak, including the date eachaction was taken.

x. The position title of the personnel who assigned an individual to make the repair.xi. The likely cause of the leak.xii. The date that measurements required by Item 4.11 were made.xiii. The result of the measurements required by Item 4.11, including the

concentration of VOCs or liquid leak rate measured, as applicable.

BENZENE MONITORING

Item 4.15 Compliance Date: Two months after the date the Order was issued

1. The Company shall develop and submit for approval to the District Manager, an airquality monitoring plan for the measurement of Benzene at locations near the boundaryof the Facility as approved by the District Manager.

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Item 4.16 Compliance Date: Two months after the plan required by Item 4.15 is approved

1. The Company shall install a monitoring station for monitoring Benzene at eachlocation identified in the plan approved by the District Manager under Item 4.15.

Item 4.17 Compliance Date: Commencing three months after the plan required by Item 4.15 is approved

1. The Company shall measure Benzene at each monitoring station identified in the planapproved by the District Manager under Item 4.15, in accordance with the approvedmonitoring plan.

Item 4.18 Compliance Date: Commencing one month after starting measuring as per Item 4.17

1. The Company shall prepare a written summary of the measurements of Benzene takenat each monitoring station identified in the plan approved by the District Manager underItem 4.15 during each calendar month, in a format acceptable to the District Manager,and including the following information:

i. Identification of each location at which a measurement was taken;ii. For each location mentioned in item 4.15 the concentration of each

measurement taken; andiii.The date and time each measurement mentioned in item 4.16 was taken.

2. The Company shall submit an electronic copy of the summary required by paragraph 1to the District Manager no later than the twentieth of each month following the calendarmonth that is being summarized.

3. The Company shall make a copy of the summary required by paragraph 1 availablefor public inspection at the Facility during office hours and on the Company’swebsite no later than no later than the twentieth of each month following the calendarmonth that is being summarized.

WRITTEN SUMMARY OF ACTION PLAN

Item 4.19 Compliance Date: Commencing April 1, 2018

1. The Company shall prepare a written summary of the actions taken each calendar yearto implement the Action Plan for Benzene, including a description of each action taken,

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the date of implementation of each action taken, and dates for the implementation of actions yet to be taken.

2. The Company shall submit an electronic copy of the summary required by paragraph 1to both the District Manager and the SDB Director no later than March 31 of each yearfollowing the calendar year that is being summarized.

3. The Company shall make a copy of the summary required by paragraph 1 available forpublic inspection at the Facility during office hours and on the Company’s website nolater than March 31 of each year following the calendar year that is being summarized.

Part 5: General

5.1 All orders are issued in the English language and may be translated into the French language. In the event that there should be a conflict between the English original and the French translation, the English original shall prevail.

5.2 The requirements of this order are severable. If any requirement of this order or the application of any requirement to any circumstance is held invalid, the application of such requirement to other circumstances and the remainder of the order shall not be affected thereby.

5.3 Any request to change a requirement in this order shall be made in writing to the Director and District Manager with reasons for the request, at least 14 days prior to any compliance date for that requirement.

5.4 The requirements of this order are minimum requirements only and do not relieve you from: (a) complying with any other applicable order, statute, regulation, municipal, provincial

or federal law; and(b) obtaining any approvals or consents not specified in this order.

5.5 Subsection 19(1) of the EPA provides that an order of the Director is binding upon the successor or assignee of the person to whom it is directed.

5.6 Subsection 186(2) of the EPA provides that non-compliance with the requirements of this order constitutes an offence.

5.7 An obligation set out in this Order may be adjusted in a manner defined by the Director, in consultation with the District Manager, if he or she is of the opinion that a party to this Order is rendered unable to perform or comply with the obligation because of: (a) natural phenomena of an exceptional, inevitable or irresistible nature, or

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(b) strikes, lockouts, or other industrial disturbances, or(c) inability to obtain materials or equipment for reasons beyond the control of the

company, or(d) any other cause whether similar to or different from the foregoing beyond the

reasonable control of the parties,

5.8 To obtain an adjustment mentioned in Item 5.7, the party must notify the Director immediately of any of the occurrences set out in that Item, providing details that demonstrate that no practical alternatives are feasible in order to meet the compliance dates in question.

Part 6: Expiry and appeals

6.1 The Company was provided a copy of a draft version of this Order on September 28, 2017. The Director considered the comments of the Company as well as other public comments before deciding to issue this order.

6.2 This order expires on November 21, 2022.

6.3 Pursuant to section 140 of the EPA, the Company may require a hearing before the Environmental Review Tribunal (the Tribunal) if, within 15 days after service upon the Company of a copy of this Order, the Company serves written notice upon the Director and the Tribunal as set out in Item 6.5.

6.4 Pursuant to section 142 of the EPA, the notice requiring the hearing must include a statement of the portions of the Order for which the hearing is required and the grounds on which the Company intends to rely at the hearing. Except by leave of the Tribunal, the Company is not entitled to appeal a portion of the Order or to rely on grounds of appeal that are not stated in the notice requiring the hearing.

6.5 Written notice requiring a hearing should be served personally or by mail upon:

Secretary Director Environmental Review Tribunal Standards Development Branch 2300 Yonge Street, Suite 2100 Ministry of the Environment and Climate Change Toronto, Ontario 40 St. Clair Avenue West, 7th Floor

M4P 1E4 Toronto, Ontario M4V 1M2

Where service is made by mail, the service shall be deemed to be made on the fifth day after the day of mailing and the time for requiring a hearing is not extended by choosing service by mail.

6.6 If you commence an appeal before the Tribunal, under section 47 of the Environmental Bill of Rights (EBR), you must give notice to the public in the EBR registry. The notice must include a brief description of this Order (sufficient to identify it) and a brief description of the grounds of appeal. The notice must be delivered to the Environmental Commissioner who will place it on the EBR Registry. The notice must be delivered to the Environmental Commissioner at 605-1075 Bay Street, Toronto, Ontario, M5S 2B1, by the earlier of:

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6.6.1 2 days of commencing the appeal before the Tribunal; and

6.6.2 15 days after service of this Order.

6.7 Pursuant to subsection 47(7) of the EBR, the Tribunal may permit any person to participate in the appeal, as a party or otherwise, in order to provide fair and

adequate representation of the private and public interests, including governmental interests, involved in the appeal.

6.8 For your information, under section 38 of the EBR, any person resident in Ontario with an interest in this Order may seek leave to appeal the Order. Under section 40 of the EBR, the application for leave to appeal must be made to the Tribunal by the earlier of:

6.8.1 15 days after notice of this Order is given in the EBR registry; and

6.8.2 if you appeal, 15 days after your notice of appeal is placed in the EBR registry by the Environmental Commissioner.

To ascertain whether or not an application for leave to appeal this Order has been made by any person, you may wish to periodically check the EBR registry up to a few business days after the period mentioned in Items 6.8.1 and 6.8.2 above. Information about how to access the EBR registry is available from your local library or by calling the Ministry of the Environment at (416) 325-4000.

ISSUED at Toronto this 21st day of November, 2017.

______________________________________ Sarah Paul, Director Ontario Regulation 419/05, s. 35 (14)

cc. Mili New, Director, West-Central Region Paul Widmeyer, District Manager(Acting), Hamilton District Office Kathleen O’Neill, Director, Environmental Approvals Branch/R. Wan, Supervisor L. Hussain, Manager, Local Air Quality Section, Standards Development Branch

"Originally Signed By"

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Appendix “A”: Portable Gas Detector - Methodology and Instrumentation

1. Definitions(1) For the purpose of this Appendix “A”,

“calibration gas” means a VOC used to adjust an instrument meter reading to a knownvalue;

“calibration precision” means the degree of agreement between a known concentrationand an instrument’s measurements of a known concentration;

“cylinder calibration gas” means a calibration gas that is packaged in a cylinder;“component interface” means the surface of a component where a leak may occur;“response factor” means the ratio of the known concentration of a VOC to an instrument’smeasurements of a known concentration;

“response time” means the time from introducing a VOC to an instrument to the time atwhich 90 percent of the corresponding final value is reached as displayed on the instrument readout meter;

“zero gas” means a gas containing less than 10 ppmv VOCs that is used for the calibrating the zero point of an instrument.

(2) For the purposes of the procedures set out in this Appendix, the calibration gas used shallbe a VOC of a concentration that is no less than 500 ppm by volume and no more than3,000 ppm by volume.

2. VOCs Leak Measurement - Instrument Requirements(1) A portable gas detector used for the purposes of this Order shall meet the following criteria:

1. The portable gas detector shall be designed to detect VOCs. The portable gasdetector may use, for example, catalytic oxidation, flame ionization, infraredabsorption, or photoionization technologies to detect VOCs.

2. The portable gas detector shall be capable of measuring concentrations of VOCsthat are as low as 100 parts per million by volume.

3. The scale of the portable gas detector meter shall be readable to at least ±2.5percent of 100 parts per million by volume.

4. The probe of the portable gas detector shall be fitted with a glass wool plug orfilter to prevent plugging of the portable gas detector.

5. The portable gas detector shall be equipped with an electrically-driven pump toensure that a sample is provided to the detector at a constant flow rate. Thenominal sample flow rate, as measured at the sample probe tip, shall be between0.10 and 3.0 litres per minute.

6. The portable gas detector shall be equipped with a probe, probe extension orsampling system not to exceed 6.4 mm (1/4in) in outside diameter, with a singleend opening for admission of sample.

7. The portable gas detector shall be intrinsically safe for operation in explosiveairs.

8. The response factor of the portable gas detector, determined in accordance withsubsection (2), shall be less than 10.

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9. The calibration precision of the portable gas detector, determined in accordancewith subsection (3), shall be equal to or less than 10 per cent of the calibrationgas value.

10. The response time of the portable gas detector, determined in accordance withsubsection (4), shall be equal to or less than 30 seconds.

(2) The response factor of the portable gas detector shall be determined by recording aresponse factor published for the portable gas detector or by taking the following steps:

1. Introduce a calibration gas to the probe of the portable gas detector and recordthe observed meter reading.

2. Introduce a zero gas to the probe of the portable gas detector until a stablereading is obtained.

3. Repeat the steps set out in paragraphs 1 and 2 two more times for a total ofthree repetitions.

4. Calculate the response factor for each repetition by dividing the knownconcentration of the calibration gas by the concentration observed underparagraph 1.

5. Determine the response factor of the portable gas detector by taking the averageof the three values calculated under paragraph 4.

(3) The calibration precision shall be determined by taking the following steps:1. Introduce a calibration gas to the probe of the portable gas detector and record

the observed meter reading.2. Introduce a zero gas to the probe of the portable gas detector until a stable

reading is obtained.3. Repeat the steps set out in paragraphs 1 and 2 two more times for a total of

three repetitions.4. Calculate the average algebraic difference between the three meter readings

taken under paragraph 1 and the known concentration of the calibration gas.5. Divide the average difference mentioned in paragraph 4 by the known

concentration of the calibration gas mixture and multiply the result by 100.

(4) The portable gas detector response time shall be determined by taking the following steps:1. Introduce zero gas to the probe of the portable gas detector.2. When the meter reading for the zero gas has stabilized, quickly introduce a

calibration gas to the probe of the portable gas detector.3. After introducing the calibration gas, measure and record the time required for

the portable gas detector to attain a reading of 90 percent of the knownconcentration of the calibration gas.

4. Repeat the steps set out in paragraphs 1, 2 and 3 two more times for a total ofthree repetitions.

5. Determine the response time of the portable gas detector by taking the averageof the three values recorded under paragraph 4.

(5) A cylinder calibration gas shall not be used for the purposes of this section unless,(a) the concentration of the cylinder calibration gas has been certified by the

manufacturer of the gas to be accurate within two per cent, and

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(b) the date is earlier than the expiry date set out on the label of the cylindercalibration gas.

3. VOCs Leak Measurement - Methodology(1) A portable gas detector used for the purposes of this Order shall be used in the following

manner:1. At the beginning of each day on which a portable gas detector is used, the following

steps shall be taken:i. Assemble a portable gas detector that meets the criteria set out in subsection 2

(1) of this Appendix.ii. Warm up the portable gas detector according to the manufacturer’s instructions.iii. Determine and record,

A. the response factor of the portable gas detector, in accordance withsubsection 2 (2) of this Appendix,

B. the calibration precision of the portable gas detector, in accordance withsubsection 2 (3) of this Appendix, and

C. the portable gas detector response time, in accordance with subsection 2(4) of this Appendix.

iv. Perform a zero internal calibration procedure for the portable gas detector, andthen introduce the calibration gas into the portable gas detector sample probe.

v. Adjust the portable gas detector meter readout to correspond to the calibrationgas value. If the meter readout cannot be adjusted to the proper value,corrective actions shall be taken before using the portable gas detector.

vi. If a cylinder calibration gas was used for any of the steps in subparagraphs iii tov, record the manufacturer of the cylinder calibration gas.

2. To assess a component for leaks, the following steps shall be taken:i. Place the probe of the portable gas detector at the component interface.ii. Move the probe along the component interface periphery, placing the probe as

close as possible to the component interface periphery, while observing theportable gas detector readout.

iii. If an increased meter reading is observed, slowly sample the componentinterface until the maximum meter reading is obtained.

iv. Leave the probe at this maximum reading location for approximately two timesthe portable gas detector response time.

v. Record the maximum concentration of VOCs detected by the portable gasdetector.

(2) If the component is a valve, for the purpose of subparagraph 2 i of subsection (1) place theprobe at the component interface where the stem exits the packing gland and sample thestem circumference. Also, place the probe at the component interface of the packing glandtake-up flange seat and sample the periphery. In addition, sample valve housings ofmultipart assembly at the surface of all component interfaces where a leak could occur.

(3) If the component is a connector, for the purpose of subparagraph 2 i of subsection (1),place the probe at the outer edge of the flange-gasket component interface and samplethe circumference of the flange. Sample other types of non-permanent joints (suchas threaded connections) in a similar manner.

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(4) If the component is a pump or compressor, for the purpose of subparagraph 2 iof subsection (1), move the probe around the circumference of the outer surface ofthe pump or compressor shaft and seal component interface. If sampling a rotating shaft,position the probe within one centimetre of the shaft-seal component interface. If thehousing configuration prevents a complete traverse of the shaft periphery, sample allaccessible portions. Sample all other joints on the pump or compressor housing whereleakage could occur.

(5) If the component is a pressure relief device that is equipped with an enclosed extension orhorn, for the purpose of subparagraph 2 i of subsection (1), place the probe inlet atapproximately the centre of the exhaust area to the air.

(6) If the component is an open-ended valve, for the purpose of subparagraph 2 i of subsection(1), place the probe inlet at approximately the centre of the opening to the air.

(7) If the component is a sample point, instrumentation system or agitator, for the purposes ofsubparagraph 2 i of subsection (1), move the probe around the circumference of the outersurface of the component.

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Appendix “B”: Optical Gas Imaging - Methodology and Instrumentation

1. Optical Gas Imaging– OGI Instrument Requirements(1) An OGI instrument used for the purposes of this Order shall meet the following criteria:

1. The OGI instrument must be designed to make visible VOC air emissions thatwould normally be invisible to the naked eye.

2. The OGI instrument must be portable.3. The OGI instrument must function in weather conditions that occur at the Facility

in the spring, summer, fall and winter.4. The OGI instrument must be capable of recording and storing images.5. The OGI instrument must record the date, time and an identifier code for each

image taken by the instrument.6. The OGI instrument must be able to be used with a tripod.

(2) The following information must be present at the Facility where the OGI instrumentmentioned in subsection (1) is used: 1. An operating manual that enables the OGI instrument to be used with minimal

training.2. A written record of operating specifications that identify limits outside of which the

OGI instrument may not be used, including,i. acceptable operating temperatures of the OGI instrument,ii. maximum wind speed over which the OGI instrument must not be used,iii. minimum and maximum ambient air temperature outside of which the OGI

instrument must not be used, andiv. minimum and maximum ambient air humidity outside of which the OGI

instrument must not be used.3. A written record of the detection limits of the OGI instrument for methane,

propane, hexane and benzene.4. A written record of the maximum image storage capacity of the OGI equipment.

2. Optical Gas Imaging– Methodology(1) An OGI instrument used for the purposes of this Order shall be used in a manner that

meets the requirements set out in this section.

(2) Before first using an OGI instrument on a day, the instrument shall be calibrated, inaccordance with the operating manual.

(3) An OGI instrument used in the performance of a component leak survey shall operateproperly.

(4) Subject to subsection (5), a tripod support shall be used when an OGI instrument is used.

(5) Subsection (4) does not apply if using a tripod support would lead to unsafe circumstancesand a record is made setting out why using a tripod would lead to unsafe circumstances.

(6) If an OGI instrument is capable of determining the concentration of VOCs, the concentrationshall be determined accurately.

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Appendix “C”: Fixed Leak Detection System - Methodology and Instrumentation

1. Fixed leak detection system – Instrument RequirementsA fixed leak detection system used for the purposes of this Order shall meet the following criteria:

1. The fixed leak detection system shall be located close enough to a component to measurethe concentration of VOCs discharged from the component.

2. The fixed leak detection system shall be located no farther from a component mentionedin paragraph 1 than the distance set out in the operating and maintenance manualprovided by a manufacturer or supplier of fixed leak detection systems.

3. The fixed leak detection system shall be capable of sampling the air at least one timeevery 60 minutes.

4. The results of the sampling and analysis shall be stored in an electronic data acquisitionsystem.

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