sulphur handling terminal alberta environment 28102005

APPLICATION FOR APPROVAL

Alberta Sulphur Terminals Ltd. –

Sulphur Management Facility

Bruderheim, Alberta

Located within:

Sec 35-055-20 W4M

Submitted to:

Alberta Environment

In Accordance with the Environmental Protection and Enhancement Act

Submitted by:

Alberta Sulphur Terminals Ltd., a division of Hazco Environmental Services Ltd.

October 19, 2005 Revised

TABLE OF CONTENTS

SECTION 1: GENERAL INFORMATION................................................................................1

1.1 DATE OF APPLICATION: .................................................................................................... 1 1.2 NAME OF APPLICANT: ....................................................................................................... 1 1.3 CONTACT PERSON:. .......................................................................................................... 1 1.4 ADDRESS OF APPLICANT: .................................................................................................. 1 1.5 TELEPHONE NUMBER:....................................................................................................... 1 1.6 FAX NUMBER:................................................................................................................... 1 1.7 NAME OF FACILITY: .......................................................................................................... 1 1.8 LOCATION OF FACILITY:.................................................................................................... 1 1.9 PURPOSE OF APPLICATION:............................................................................................... 1 1.10 CORPORATE INFORMATION: .............................................................................................. 1

SECTION 2:FACILITY OVERVIEW & RATIONALE ..........................................................2

2.1 FACILITY OVERVIEW.......................................................................................................... 2 2.2 FACILITY MARKET ANALYSIS.............................................................................................. 2

SECTION 3: SITING & FACILITY DESIGN...........................................................................6

3.1 FACILITY DESCRIPTION ..................................................................................................... 6 3.2 SITING INFORMATION ........................................................................................................ 6 3.3 FACILITY DESIGN .............................................................................................................. 8 3.4 FACILITY OPERATION ...................................................................................................... 10 3.5 PROPOSED DATES OF CONSTRUCTION AND OPERATION ................................................... 10 3.6 OTHER APPROVALS ......................................................................................................... 10

SECTION 4: ENVIRONMENTAL CONSIDERATIONS ......................................................12

4.1 ENVIRONMENTAL PROTECTION MEASURES....................................................................... 12 4.2 WASTE MINIMIZATION ..................................................................................................... 13 4.3 MONITORING & REPORTING............................................................................................ 13 4.4 EMERGENCY RESPONSE PLANS & CONTINGENCY PLANS................................................... 14 4.5 CLOSURE AND RECLAMATION PLAN ................................................................................. 14

SECTION 5: PUBLIC CONSULTATION PROGRAM..........................................................15

5.1 GENERAL INFORMATION.................................................................................................. 15 5.2 PUBLIC CONSULTATION DETAILS ...................................................................................... 15

SECTION 6: LEGAL AND MUNICIPAL INFORMATION .................................................17

6.1 CONFIRMATION OF LEGAL CONTROL OF THE SITE............................................................ 17 6.2 MUNICIPAL PLANNING & ZONING.................................................................................... 17

Page i

6.3 DEVELOPMENT PERMIT................................................................................................... 17

SECTION 7: CLOSING REMARKS: .......................................................................................18

APPENDICES

Appendix A: Project Schedule

Appendix A-1: Engineering, Procurement and Construction Schedule Appendix B: Site Mapping

Appendix B-1: Site Plan Appendix B-2: Topographic Map of Sec. 35-055-20 W4M

Appendix C: Facility Design

Appendix C-1: Facility Process Flow Diagram Appendix C-2: Sulphur Storage Pad Plan & Details (Drawing No. 085433-5901-0003) Appendix C-3: Dust Suppression Product Data Sheets Appendix C-4: Storm Water Run-Off and Fire Water Supply Pond Plan & Details

(Drawing No. 085433-5901-0002) Appendix D: Public Consultation Program Details

Appendix D-1: Open House Notifications (Redwater Review) Appendix D-2: Public Consultation Contact List Appendix D-3: Open House Sign-In Sheet Appendix D-4: Open House Presentation Boards Appendix D-5 Resident Correspondence Appendix D-6: Project Information Package

Appendix E: Offer to Purchase and Land Title Information Appendix E-1: Offer to Purchase and Land Titles

ENCLOSURES

Enclosure 1: Siting Investigation Report – Proposed Sulphur Forming and Storage Facilty, Komex International Ltd., July 2005. Enclosure 2: An Assessment of Air Quality Impacts Associated with Operations at the Proposed Bruderheim Sulphur Forming Facility, DM Leahey & Associates Ltd. and Jacques Whitford, August 31, 2005.

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EPEA APPROVAL APPLICATION ALBERTA SULPHUR TERMINALS LTD.

SECTION 1: GENERAL INFORMATION

1.1 DATE OF APPLICATION: October 19, 2005 1.2 NAME OF APPLICANT: Alberta Sulphur Terminals Ltd. (a division of Hazco

Environmental Services Ltd.) 1.3 CONTACT PERSON: Corey Higham, M.Eng., P.Geo.

Sr. Environmental & Regulatory Planner 1.4 ADDRESS OF APPLICANT: 24th Floor Watermark Tower

530 – 8th Avenue SW Calgary, Alberta T2P 3S8

1.5 TELEPHONE NUMBER: (403) 231-8425 1.6 FAX NUMBER: (403) 261-5612 1.7 NAME OF FACILITY: Alberta Sulphur Terminal 1.8 LOCATION OF FACILITY: 35-055-20 W4M 1.9 PURPOSE OF APPLICATION: Sulphur Forming and Pastille Storage Facility 1.10 CORPORATE INFORMATION: The proposed project will be entirely funded and completed by the HAZCO division of CCS Income Trust. HAZCO is an industry leader providing a wide-range of specialized services including: Sulphur Services, Site Remediation, Decommissioning, Waste Services, Environmental Construction, Environmental Technologies, Emergency Response and Other Specialty Services. HAZCO operates a network of industrial landfills, bioremediation facilities and hazardous waste transfer stations that span Western Canada. HAZCO also provides services throughout Canada, Peru and select services in the United States and other international markets. HAZCO was incorporated in 1989 and has operated as a private company until being purchased in the fall of 2004 by CCS Income Trust. More information is available at our web site www.hazco.com or the CCS Income Trust web site at www.ccsincometrust.com.

CCS Income Trust services the global energy and environment sectors through three other major divisions; CCS Energy Services, CCS Energy Marketing, and Concord Well Servicing.

OCTOBER 2005 PAGE 1 OF 18

http://www.hazco.com/

http://www.ccsincometrust.com/


SECTION 2: FACILITY OVERVIEW & RATIONALE 2.1 FACILITY OVERVIEW Sulphur, a byproduct of the oil and gas industry, is primarily used in the production of fertilizer world wide. With increased activity in the heavy oil sector producing resulting in more produced sulphur, combined with an increase in demand for sulphur exports worldwide, there is a shortage of sulphur forming capacity in Alberta. The sulphur is produced during oil and gas production and refining in Alberta in a molten form, manufactured in to a dry product (i.e. sulphur pellets) for handling, loaded to rail car for transport to Vancouver, stockpiled and eventually loaded on ships for further delivery to export markets. The proposed project includes facilities for sulphur forming, sulphur pastille storage and shipping. At this time, HAZCO has no plans to provide for emergency inventory storage (i.e. sulphur block) at this location. Therefore, molten sulphur and dry formed product will be the only sulphur storage methods employed at this site. In terms of operations, molten sulphur will be received by one of three methods, pipeline, rail tank car or truck. The sulphur will be stored in tanks before being pumped to the forming process. Alberta Sulphur Terminals Ltd. plans to use an environmental friendly technology provided by Sandvik Process Systems to process the liquid sulphur into a formed product (i.e. pastilles) suitable for export. The product will be stored on engineered storage pads and when volumes dictate loaded to rail car unit trains. The volumes of liquid and dry storage will be dependant on market demand for our services and will also grow with demand. All sulphur received at the facility remains the sole responsibility of major oil and gas companies. The purpose of the proposed facility is to provide a service in the form of sulphur receiving, forming, and shipping by rail. 2.2 FACILITY MARKET ANALYSIS Alberta Sulphur Terminal (“AST”) will service oil and gas production and refining operations within three main areas: Fort Saskatchewan, Fort McMurray and Lloydminster. With increased applications, approvals and operation of bitumen upgraders and ongoing sulphur recovery initiatives, there is a shortage of sulphur forming facilities in Alberta. The AST will provide area oil and gas producers with a state of the art sulphur forming, storage and export facility that will include design elements and monitoring programs that focus on environmental protection. Responding to the level of oil and gas production and refining operations in Alberta and the future reliance on heavy oil to replace conventional reserves, the HAZCO Business Development Team has identified the need for a facility in the area based on industry requests and necessity. The existing and future oil and gas activity, specifically heavy oil and oilsands development will provide a strong demand for the services that the proposed facility would offer.



The following sulphur production, supply and demand information has been obtained from the Alberta Energy and Utilities Board1. “In 2003, Alberta produced 6.8x106 t of sulphur, of which 5.7 106 t was derived from sour gas, 1.1x106 t from upgrading of bitumen to synthetic crude oil, and just 20 thousand (103) t from oil refining. Sulphur production from these sources is depicted in Figure 2.1.

Source: EUB, 20041

Figure 2.1 Sources of Alberta Sulphur Production

While sulphur production from sour gas is expected to decrease from 5.7x106 t in 2003 to 5.1x106 t, or some 11 per cent, sulphur recovery in bitumen upgrading industry is expected to increase to 3.2x106 t from 1.1x106 by the end of the forecast period. The Alberta refineries are also expected to replace conventional crude and synthetic crude with bitumen as integration of bitumen upgrading and refining takes place in this forecast period. With this integration, the sulphur recovery will increase from 20x103 t in 2003 to 49x103 t by 2013. Total sulphur production is expected to reach 8.4x106 t by the end of forecast period (EUB, 2004). According to the EUB, demand for sulphur within the province in 2003 was only about 250x103 t. It was used in production of phosphate fertilizer and kraft pulp and in other chemical operations. Some 97 per cent of the sulphur marketed by Alberta producers was shipped outside the province, primarily to United States, Asia Pacific, and North Africa. In the early 1990s, a number of traditionally sulphur-importing countries installed sulphur-recovery equipment in oil refineries and other sulphur-emitting facilities, largely for environmental reasons. Consequently, many of these countries became self-sufficient in sulphur 1 Alberta Energy & Utilities Board. 2004. Alberta’s Reserves 2003 and Supply/Demand Outlook 2004-2013. Statistical Series 2004-98. Calgary, Alberta. 136pp.



and the price declined significantly. Under such low price conditions, many of Alberta’s competitors ceased production of sulphur, enabling Alberta’s market share to rise throughout the late 1990s. In 2002 and 2003, China increased its sulphur imports from Canada substantially. Increased global demand for sulphur resulted in a major price change, from Cdn$16/t in 2001 to $40/t in 2003. As of July 4, 2005, sulphur is being marketed at an approximate price of Cdn$60/t. The export demand for sulphur is expected to increase over the next few years. Demand for Alberta sulphur, both domestic and export, is expected to rise slowly, reaching 7.5x106 t per year by the end of the forecast period. Figure 2.2 depicts the Alberta demand and sulphur removal.”

Source: EUB, 20042

Figure 2.2 Sulphur Demand and Supply in Alberta

Based on current market information from oil and gas producers in the region, AST expects to process, form and export approximately 9.0x105 t of sulphur annually. Actual quantities of sulphur received will vary with market fluctuations, based primarily on oil and gas production levels. The technical, environmental, and economic benefit of building a new Sulphur Forming and Dry Product Storage facility are as follows: Technical: AST and its team of engineers, contractors and consultants have extensive experience in constructing and operating sulphur forming and dry storage facilities. As a result, AST brings expert knowledge and equipment to Lamont County and Alberta’s Industrial

2 Alberta Energy & Utilities Board. 2004. Alberta’s Reserves 2003 and Supply/Demand Outlook 2004-2013. Statistical Series 2004-98. Calgary, Alberta. 136pp.



Heartland to safely and effectively manage sulphur produced from oil and gas production and refining/upgrading operations. The HAZCO Division currently owns/operates 14 industrial landfills within Western Canada and the CCS Energy Services Division owns and operates 16 Treatment, Recovery and Disposal Facilities servicing the oil and gas industry demonstrating our capabilities to own/operate a facility of this nature safely and responsibly. A preliminary schedule for the project is provided in Appendix A-1. Environmental: The general soil stratigraphy encountered at the site consists of surficial topsoil and/or fill overlying silty sand and/or glacial clay till deposits underlain by weak sedimentary bedrock. Silt clay overburden at the site had low hydraulic conductivity values ranging between 2.2E-09 and 4.4E-09 cm/s and the vertical hydraulic gradient is also low which is significant as this decreases the potential for downward migration of potential contamination(i.e. soil pH impacts). The existing groundwater quality at the site indicates that natural buffering capacity exists. The favourable site conditions will be further complimented by the proposed facility design that makes use of double liner systems, and run-off control systems as well as environmental monitoring programs and sound facility operation. Economic: During facility construction, the local regional economy will benefit as a result of the work force. Construction activities over the proposed nine month period are expected to employ approximately 36,000 man-hours. Facility operations are expected to add approximately 40,500 man-hours annually to the regional economy (~20 full-time positions). Preliminary cost estimates suggest the development would involve capital spending of approximately $30 million dollars (CDN).



SECTION 3: SITING & FACILITY DESIGN 3.1 FACILITY DESCRIPTION The sulphur forming component of the proposed facility includes:

• Rail and road access for receiving and shipping sulphur; • Sulphur unloading and transfer facilities; • Sulphur forming facilities to produce sulphur pastilles; and, • Loading and shipping facilities for formed sulphur.

An overall site plan indicating the facility layout and surrounding area is included in Appendix B-1. In addition, a topographic map of Sec. 35-55-20 W4M is also provided in Appendix B-2. 3.2 SITING INFORMATION Prior to selecting a site for the proposed AST, a set of technical criteria and criteria specific to AST were developed that would assist in finding a potential facility location. Those criteria are listed below:

• Proximity to market area. • Suitable access (i.e. proximity to high grade road capable of supporting heavy haul truck

traffic). • Local rail access (i.e. Dual access to both CPR and CNR). • Low residential density. • Topographical restraints (i.e. no excessive slopes, no drainage problems, etc). • Site Geology and Hydrogeology • Surface / Sub-surface Features (i.e. wellsites, pipelines, utilities, etc.). • Not included in the “Listing of Significant Historical Sites and Areas” produced by

Alberta Community Development. • Opportunity to purchase land (i.e. for sale). • Industrial Zoning

AST retained Komex International Ltd. (Komex) to complete a siting investigation for a proposed sulphur forming and pastille storage facility located in section 35-55-20 W4M (the Site). A copy of the siting investigation for the Site completed by Komex is provided as an enclosure to the submission. The purpose of the siting investigation was to assess the hydrogeological and geotechnical suitability of the Site for the proposed development; to provide initial hydrogeological and geotechnical design recommendations; and provide a proposed soil, groundwater and surface water monitoring program. Based on this program, the site is suitable for siting the proposed sulphur facilities. The results of the investigation are summarized as follows:

• The soil stratigraphy generally consisted of surficial topsoil and/or fill overlying silty sand, clay and/or glacial clay till deposits underlain by weak sedimentary bedrock that extended beyond the completion depth of the boreholes.



• The surficial geology on the Site was variable both in composition and thickness. Although, till or till-like clay was encountered in most boreholes, the till was silty and/or contained High-plastic clay, silty sand and/or sand seams.

• Samples submitted for calcium carbonate equivalent analysis indicate that the soil has a natural buffering capacity capable of buffering minor depressed pH levels.

• Fill was encountered across the Site at depths ranging between 0.5 and 2.5 meters below ground surface. The fill varied in composition and consistency and is not considered suitable to support shallow foundations or concrete slabs-on-grade. Structures are recommended to be supported by pile foundation systems.

• All existing fill material within building envelopes or paved sections should be over excavated and replaced with a suitable “engineered fill”.

• The native silty clay deposits encountered at the Site are highly plastic and susceptible to swelling or shrinkage due to moisture changes. Exposure of the high plastic clay should be minimized, and therefore, deep cast-in-place concrete piles are considered the most suitable foundation system to support structures.

• Laboratory permeability tests showed that there likely is clay on-site suitable for a compacted clay liner.

• The measured depth to groundwater in the “A” series monitoring wells, which were completed in the Quaternary materials, ranged from 0.14 to 2.64 meters below ground surface (mbgs).

• The measured depth to groundwater in the “B” series monitoring wells, which were completed in the bedrock, ranged from flowing (greater than 0.66 meters above ground surface) to 2.65 mbgs.

• Very low upward and downward vertical hydraulic gradients were observed. This indicates a decreased potential for downward migration of contaminants, and a potential for added natural hydraulic containment of the engineered containment area.

• Hydraulic conductivity testing of the overburden monitoring wells showed two orders of magnitude difference between monitoring wells screened within predominantly clay soils and predominantly silty sand or sand (2.3 x 10-8 to 3.0 x 10-6 m/s). Similar results were found with the bedrock wells completed within the deeper clay shale and the sandstone (4.6 x 10-9 to 6.6 x 10-6 m/s).

• Estimates of the shallow and bedrock groundwater flow velocity were in the order of 0.5 m/yr.

• The groundwater flow direction calculated from both the shallow and the bedrock monitoring wells was inferred to be to the northeast.

• Based on the two-hour pumping test an estimated yield of 7.9 L/min (1.7 igpm) was calculated within what appeared to be the highest yielding groundwater zone. Based on the variable geology, diminished yield could occur over time.

• Hydrochemistry of groundwater measured on the Site showed that the groundwater is predominantly sodium-bicarbonate. Therefore, the addition of acidity would be naturally buffered.

• Baseline groundwater at the Site indicates that the total dissolved solids, dissolved sulphate, dissolved sodium and/or dissolved manganese concentrations in all or some of the monitoring wells exceeded the Health Canada (2004) Drinking Water Aesthetic Objective Guidelines The dissolved aluminum concentration in monitoring well 05-01B



also exceeded the Health Canada (2004) Drinking Water Maximum Allowable Concentration Guideline.

• Both the potability and dissolved metals results are not considered to be a design issue in the context of the proposed development.

• The surficial geology and bedrock, coupled with the hydrochemical type and hydraulic conductivity measurements of the first clay shale layer, indicate that the overburden groundwater is somewhat hydraulically connected to the more shallow bedrock groundwater. However, groundwater from approximately 45 m and deeper, appears to be protected by a thick, competent shale unit.

• The proposed facilities are within a lower lying area of the Site, adjacent to two field verified drainage courses. Surface grading and contouring will be required to ensure that drainage is directed away from the facilities.

• Groundwater is near surface in most locations drilled on the Site, and may be encountered during construction of the facility. Groundwater control measures may have to be implemented during construction and potentially during operation of the facility.

• The engineered containment design may have to include an under-drain system to keep the leachate collection system free of groundwater. If both of these layers are relatively free of groundwater, the compacted clay liner could remain saturated, and therefore provide natural hydraulic containment.

• Although the overburden groundwater appears to be somewhat hydraulically connected to the more shallow bedrock groundwater, the proposed engineered containment system if designed and operated properly should be able to minimize any potential groundwater impacts resulting from the operation of the facility.

Based on the siting criteria listed above and the siting investigation, the section of land located at 35-055-20 W4M was considered suitable as it satisfied the requirements of the proposed facility. As a result, the proposed site was determined to meet relevant AENV and CCS siting criteria and was also found to be available for purchase. The proposed site at Sec. 35-055-20 W4M met all applicable siting criteria and was selected for development. 3.3 FACILITY DESIGN For the purpose of this Project, AST has chosen to utilize a third generation drop forming Sulphur solidification technology from Sandvik Process Systems named Rotoform ‘HS’®. Each unit has a guaranteed capacity of 12.0 Metric Tonnes per hour. The equipment is modular, in design, flexible, in that any number of machines can be used at any given time, and is an exceptionally clean process without any sulphur contact with water, steam, air surges during the forming process. The elimination of direct contact with water, steam or air currents as the forming medium effectively addresses major environmental concerns, namely fugitive gas, and dust emissions as well as water contamination. It also does not require specialized personal protective equipment including artificial breathing air or confined space entry. A detailed Process Flow Diagram is provided in Appendix C-1.



The molten sulphur to be received at the proposed facility will arrive by either pipeline, rail car or truck and only sulphur that has been degassed to a maximum of 10 ppm H2S will be received. Upon arrival at the facility, the pipeline or tankers will unload via a pumping station into insulated and heated tanks (T-101 – T106), each having a holding capacity of 750 metric tonnes of molten sulphur. All storage areas will meet the requirements of the Alberta Energy and Utilities Board Guide 55 and the storage tanks will be vented to atmosphere. Molten sulphur is pumped from receiving tanks to a feed tank (T108). The Sulphur is then pumped from the feed tank to a duplex filter (V102), then, from the filter sulphur passes through a conditioning unit (E101) which cools the sulphur to 125°C. The product then enters a recirculation loop which feeds the Rotoform HS® Drop forming equipment (RF101 – RF109). The product then travels through the in feed adaptor through a stator bar and into a metering bar. From the metering bar it travels through specially designed nozzles and passages in the metering bar which ensure even product distribution across a rotating stainless steel belt. The belt is cooled by cold water sprayed against the under side of the rotating belt causing the pastilles on the top of the belt to cool and solidify. The water utilized by the Rotoform HS® is sent through a cooling tower (CT101) in a closed loop for filtration and temperature reduction. Make up water for the cooling tower is supplied from the run off pond (S101) which is designed to collect and treat surface water from the site and also serves as the source of fire protection water. Details of the fire protection system in place at the facility can be provided upon request. A more detailed description of the pastillation technology (including equipment specifications) can be found as an enclosure to the submission. In addition, a copy of the manufacturer’s information video is also provided with the submission. The solid pastilles fall onto a collection conveyor (CV101) and moved outside the production building where they are transferred to a radial stacking conveyor (CV102) and onto an asphalt bulk sulphur pastille storage pad. Sulphur pad design details are provided in Appendix C-2 in Drawing No. 085433-5901-003. Dust suppression on the sulphur pastille storage pad, transfer points and rail load-out area will be completed with a proprietary dust suppression agent, Dustbind S3 and the proprietary sulphur release aid, IPAC SRB+. The Dustbind S3 will be applied to 2565 metric tonnes per day at a usage of 76.95 Kg (75.45L) per day. Water usages will range from 6,000 L to 7,545 L at 80 to 100 - 1. These dosages will be applied at the transfer points behind the hopper and at the train load-out. The amounts used will depend on the size of the trains being loaded and the conveyor size. Dust suppression will also be applied before the stockpile to suppress dust in the loading of the sulphur. Dust suppression will also be applied as needed. IPAC SRB+ will be applied from a makedown tank via a pump supplying each individual rotoformer. Usage should be approximately 29.4 mL per metric tonne. Copies of the product data sheets fro Dustbind S3 and IPAC SRB+ are provided in Appendix C-3. Dust suppression equipment will include an assembly of a metering pump, capable of delivering a maximum of 102 mL/minute at 150 psi; 2” camlock, draw down tube and stainless steel pump hanger.



Hazco will initially utilize a front end loader to retrieve product from the stockpile. The product will be discharged from the front end loader to a surge bin that is equipped with a dust suppression package described above. The dust treated product is then deposited on a load out conveyor (CV103) equipped with a Weighveyor / Totalizer and on to rail or trucks for shipment from the proposed facility. Based on the facility design, an air quality assessment and air modeling study was completed by DM Leahey & Associates and Jaqcues Whitford. The study concluded that air emissions associated with the proposed facility should have no effect on the environment or surrounding area. A copy of the Air Quality assessment report is included as an enclosure. All surface water that comes in contact with the sulphur handling and pastille storage areas will be collected and stored within a surface water run-off pond. Design details for the surface water run-off pond and ditching details are provided on the design drawings provided in Appendix C-4. 3.4 FACILITY OPERATION Prior to facility start-up, a copy of the proposed operating procedure manual for the AST can be provided to Alberta Environment upon request. 3.5 PROPOSED DATES OF CONSTRUCTION AND OPERATION Proposed date of construction commencement: April 1, 2006 Proposed date of operational commencement: December 1, 2006 3.6 OTHER APPROVALS Since the proposed Sulphur Management Facility does not fall under either “mandatory” or “exempted” activities as listed in Alberta Regulation 111/93 “Environmental Assessment (Mandatory and Exempted Activities) Regulation” no formal review of the proposed project has been completed under the environmental assessment process. AST believes that an environmental impact assessment is not required for this project due to the nature of the operation (i.e. sulphur forming and pastille storage). AST is not aware of any prior requirements within Alberta for environmental impact assessments for “greenfield” sulphur management facilities. No other approvals have been issued or applied for under the Environmental Protection and Enhancement Act or Water Act or its predecessor or any temporary field approvals issued under section 19(1)(c) of the Public Lands Act. Potable and makeup water required for the facility will be supplied by Lamont County’s Water Cooperative.



No other approvals from a regulatory agency (i.e. Alberta Energy and Utilities Board, etc.) exist for the proposed facility/location. Municipal approvals required for the facility are outlined in Section 7.0. Alberta Transportation has been contacted with respect to the Highway 15 and Highway 45 access points associated with the proposed facility. AST will forward the Alberta Transportation approvals once they are received.



SECTION 4: ENVIRONMENTAL CONSIDERATIONS 4.1 ENVIRONMENTAL PROTECTION MEASURES 4.1.1 Sulphur Pastille Storage Area The sulphur pastille storage area has the following environmental protection measures incorporated into its design (Appendix C-2, Drawing No. 0854333-5901-0003):

• Sloped containment pad for surface water run-off collection; • 150mm thick asphalt primary containment liner and working surface; • 300mm clay secondary containment liner (specifications can be forwarded to Alberta

Environment upon request); and, • Prepared sub-grade.

4.1.2 Surface Water Run-on and Surface Run-off Controls The surface water run-off and run-off control systems have the following environmental protection measures incorporated into its design (Appendix C-5, Drawing No. 0854333-5901-0001):

• Areas surrounding the sulphur handling areas will be sloped away from the facility to prevent surface water run-on;

• Lined ditching systems on the pastille storage area; • 60mil HDPE liner within surface water run-off pond; • Geotextile or 100mm sandy clay and prepared sub-grade; and, • Capacity of 10,960m3.

4.1.3 Dust Suppression Measures Dust suppression will be completed on the sulphur pastille storage pad, transfer points and rail load-out area using proprietary dust suppression agents, Dustbind S3 and the proprietary sulphur release aid, IPAC SRB+. The storage pad and rail-load out area may be surrounded by wind screens to mitigate any airborne sulphur particulate. Based on the results of a dust modeling study, the need for dust screens will then be evaluated. A copy of the Air modeling results will be forwarded to Alberta Environment upon completion. 4.1.4 Sound Operation and Environmental Monitoring The facility will be operated by qualified professionals and a copy of the facility’s Operations Plan can be provided to Alberta Environment upon request. The environmental monitoring programs proposed for the site are described within Section 4.3 of the application document. 4.1.5 Soil Liming Due to fugitive emissions from the sulphur handling areas (i.e. elemental sulphur dust), a soil monitoring program will also be put in place to characterize the sulphur impact on soil



surrounding the facility. Based on a similar facility operating near Sundre, Alberta, dust impacts will likely be present within a 150-200m radius surrounding the facility. To mitigate the dust impacts, a soil liming program will be completed to neutralize the impacts associated with the sulphur dust. The Alberta Environment Air Monitoring Directive requires that all operators that handle solid sulphur establish an approved soil monitoring program. 4.2 WASTE MINIMIZATION Based on the facility design and operation, AST is striving to be a “zero discharge” facility with respect facility operations and wastes. The facility has been designed to produce almost no wastes (other than air emissions). All dust that is collected at the site will be recycled and placed back in the sulphur feed tanks to be formed in the process. During operations, there may potentially be some waste or contaminated sulphur (i.e will not meet saleable product specifications) collected as part of equipment maintenance and on-going operations. It is anticipated if any waste sulphur is collected, no more than 1m3 of waste sulphur will be collected during a month’s operation and will be disposed at an appropriate facility (i.e. Class II Landfill). The waste sulphur will be stored separately on the sulphur storage pad to take advantage of the containment measures incorporated into the design. In addition to the “zero-discharge” facility, AST has no plans to discharge any of the surface water run-off collected in the surface water pond as the pond will be used as a source of water for process make-up water requirements and the fire suppression system. In the event where water from the surface water pond needs to be released due to capacity restraints (likely due to excessive precipitation events), the water will be sampled and analyzed to confirm the surface water pond water quality meets applicable surface water quality guidelines. All domestic garbage will be disposed at an authorized municipal solid waste landfill. To minimize domestic wastes generated at the site, a recycling program will be employed at the facility to collect plastics, cardboard and beverage containers. Domestic wastewaters generated at the site will be collected in a septic tank and subsequently hauled off-site for disposal. 4.3 MONITORING & REPORTING Monitoring programs during the operation of the proposed sulphur handling and pastille storage facility are planned for soil, groundwater, surface water, and air quality. The siting investigation report completed by Komex (Enclosure 1) outlines the proposed soil, groundwater and surface water monitoring programs. The proposed air quality monitoring program has been provided as an enclosure to this application. The following proposed monitoring programs have been designed to comply with the conditions outlined for soil, groundwater and surface monitoring as typically required under the Alberta Environmental Protection and Enhancement Act (AEPEA) approvals. The sampling areas are based on the current design plans (Appendix B-1) for the facility. Should the facility change in any way (i.e. design, capacity, location, components, etc.) the monitoring programs would be re-evaluated.



4.4 EMERGENCY RESPONSE PLANS & CONTINGENCY PLANS Contents of the AST Emergency Response Plan have not yet been finalized as the ERP is still under development. Upon completion of a “draft” plan, copies will be forwarded to Town of Bruderheim, Town of Lamont, Lamont County, Northeast Region Community Awareness and Emergency Response Group, local industry representatives and Local Emergency Response officials for comment. Upon receipt of the comments, a final ERP will be developed and filed with all stakeholders mentioned above prior to commencement of operations. 4.5 CLOSURE AND RECLAMATION PLAN Prior to closure of the proposed facility, a decommissioning plan will be prepared and submitted to Alberta Environment for approval. Contents of the decommissioning plan will include the following:

1. A plan for dismantling the plant; 2. A plan to manage all wastes produced during decommissioning of the plant; 3. A Phase II Environmental Site Assessment completed to determine the nature, degree and

extent of soil and groundwater impacts (if present) at the plant and surrounding area; 4. A Remediation Plan (if required) to evaluate and outline remediation technologies to be

used at the plant and surrounding area; 5. A Reclamation Plan that outline the intended land use, soil replacement information,

drainage restoration, erosion control measures, revegetation plan and schedule. In terms of soil conservation at the site, topsoil and subsoil will be stockpile at the site to be used for final reclamation and soil replacement. The subsoil will spread over the reclaimed site followed by the topsoil layer. The topsoil will be replaced in sufficient thickness to allow the establishment of vegetation.



SECTION 5: PUBLIC CONSULTATION PROGRAM 5.1 GENERAL INFORMATION The public consultation program conducted by AST included the following: 1. Identifying residents - The proposed site is located within an area of the County that has a low density of residences. There are only 6 residences within 1.0km of the site with the closest located approximately 600m to the east. 2. Personal meetings - Personal meetings were held with nearby landowners, residents, industry, Lamont County, Alberta Industrial Heartland officials and Alberta Environment representatives. 3. Open House - The purpose of Open House was to discuss the project with all interested parties on Tuesday, June 28, 2005 between 6:00pm and 8:00pm at the Bruderheim Memorial Hall. Invitations to the Open House were mailed to landowners, residents, government representatives and companies within the area. The Project Open House was advertised in the Redwater Review on June 14 and 21, 2005, respectively. Copies of the tear sheets are provided in Appendix D-1. 4. Ongoing Communication – Due to concerns from area residents and the subsequent formation of the Friends of Lamont County for Responsible Industrial and Community Development, Hazco has continued discussions with all project stakeholders to inform and supply stakeholders with accurate information regarding the proposed project. 5.2 PUBLIC CONSULTATION DETAILS CCS initiated the public consultation process by contacting and meeting with landowners/residents/occupants located within a 1.6 km radius of the site (a listing of landowners/residents is included in Appendix D-2). The details of the proposed AST were discussed, an information package was provided, and CCS committed to sending an invitation to the open house (date not set at the time of the initial visit) to each person contacted. An open house was held on June 28, 2005 in Bruderheim, Alberta as a component of the public consultation program. Sixty-three (63) people attended the open house. A copy of the open house sign-in sheets are included in Appendix D-3. A copy of the open house presentation boards are included in Appendix D-4. Public feedback to the proposed development has been mixed. There have been some concerns raised and requests for additional information related to the proposed facility have been noted. CCS is committed to working with interested parties to satisfy any concerns that they may have. Complete consultation details are included in the 1.6 km Stakeholder Listing included in Appendix D-2. Issues raised have been primarily related to groundwater protection, air quality and sulphur dust, impacts to property values in the area and nearby industrial facility safety.



Copies of correspondence sent to residents and project stakeholders requesting additional information are provided as Appendix D-5. In addition to the individual correspondence sent out, Hazco completed a general mail-out to Lamont County to provide project stakeholders with additional information. This information can be viewed on the Hazco website at www.hazcoenv.com in the Hazco News page under Alberta Sulphur Terminals. CCS will continue to update Alberta Environment as to the status of the public consultation program. A copy of the information package delivered to all landowners, residents and occupants within a 2 km of the proposed site is included in Appendix D-6. The information package was also available to all attendees of the open house held June 28, 2005.



SECTION 6: LEGAL AND MUNICIPAL INFORMATION 6.1 CONFIRMATION OF LEGAL CONTROL OF THE SITE The proposed site is currently owned by Encana Corporation of Calgary, AB. AST has entered into an “Offer to Purchase and Interim Agreement”, dated November 27, 2004, conditional upon receiving all approvals to construct and operate the AST. A copy of the land title search and the Offer to Purchase are included in Appendix E. 6.2 MUNICIPAL PLANNING & ZONING The land use designation of the site located at 35-055-20 W4M is Industrial/Commercial under the County of Lamont zoning bylaws. Section 35 is one of four contiguous sections of land that are zoned industrial in the area. Sections of land to the south (25, 26-055-20 W4M) and west (24-055-20 W4M) of 35-055-20 W4M are also zoned Industrial/Commercial and are included as part of Alberta’s Industrial Heartland. Land use in the area is predominantly still agricultural with the exception to the immediate west and south of the site where Erco Worldwide and Nexen Chemicals operate sodium chlorate production facilities and Triton Energy operates a fabrication shop, respectively. The proposed site is located within an area of the County that has a low density of residences. There are only 6 residences located within 1.0 km of the site located in 35-055-20W4M. CCS does not expect these residences to be effected by the proposed development due to the design, operation and monitoring of the facility. 6.3 DEVELOPMENT PERMIT AST has submitted an application for a development permit with the County of Lamont in August 2005. AST expects a development permit to be issued upon satisfying Lamont County’s information request. A copy of the development permit will be forwarded to Alberta Environment upon receipt from the County.



SECTION 7: CLOSING REMARKS: CCS Income Trust and it group of divisions have been providing environmentally responsible management solutions to the upstream oil and gas industry for over 20 years. We feel that the addition of the AST Bruderheim Sulphur Forming and Pastille Storage Facility will fulfill the requirements of the upstream oil and gas industry for sulphur management in Alberta. I trust that the information provided in this application is complete. If you have any questions or comments related to the application, please feel free to reach Mr. Corey Higham at the contact numbers provided on page 1 of the application.


APPENDIX A

PROJECT SCHEDULE

ActID Description Dura

-tionEarlyStart

EarlyFinish 2005

M2006

J20

J A S O N D JAN F M A M J JUL A S O N D J

0895 Survey & Geotechnical 44 02MAY05 * 30JUN05

0900 Commence Regulatory Permitting 22 15JUN05 15JUL05

0910 Public Consultation 97 01JUN05 14OCT05

1000 Letter of Intent 0 30JUN05

1005 Negotiate Contracts 65 01JUL05 30SEP05

1010 Process P & ID's 53 01JUN05 15AUG05

1020 Mechanical / Equipment 172 01JUL05 28FEB06

1030 Piping 132 01AUG05 31JAN06

1040 Civil / Structural 163 15JUL05 28FEB06

1050 Instrumentation 152 01JUL05 31JAN06

1060 Electrical 195 01JUL05 31MAR06

1070 Bid & Purchase Major Equipment 66 01AUG05 31OCT05

1080 Bid & Purchase Balance of Equipment 65 01SEP05 30NOV05

1090 Field Move-In 20 03APR06 28APR06

1100 Permit to Construct 0 31OCT05

1110 Construction Site Work 20 03APR06 28APR06

1120 Construction 142 01MAY06 15NOV06

1130 Start-Up 22 15NOV06 30NOV06

ATHABASCA OIL SANDSMERCHANT SULPHUR FORMING FACILITY

PROJECT SUMMARY SCHEDULE

chigham

Rectangle


APPENDIX B

SITE MAPPING


APPENDIX B-1

SITE PLAN

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ALBERTA SULPHUR TERMINALS LTD.


U U

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APPENDIX B-2

TOPOGRAPHIC MAP OF SEC. 35-055-20 W4M


APPENDIX C

FACILITY DESIGN


APPENDIX C-1

FACILITY PROCESS FLOW DIAGRAM

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APPENDIX C-2

SULPHUR STORAGE PAD PLAN & DETAILS (DRAWING NO. 085433-5901-0003)

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APPENDIX C-3

DUST SUPPRESSION PRODUCT DATA SHEETS

Product Data Sheet

IPAC Chemicals Ltd., 1620 West 75th Avenue, Vancouver, B.C. V6P 6G2 Phone: (604) 261-3019

The information given and the recommendations made herein are based on our research and are believed to be accurate but no guarantee of their accuracy is made. In every case we urge and recommend that purchasers test the product for their particular purpose under their own operating conditions. The products discussed herein are sold without any warranty as to merchantability or fitness for a particular purpose or any other warranty, express or implied. No representative of ours has any authority to waive or change the foregoing provisions but, subject to such provisions, our engineers are available to assist purchasers in adapting our products to their needs and to the circumstances prevailing in their business. Nothing contained herein shall be construed to imply the non-existence of any relevant patents or to constitute a permission, inducement or recommendation to practice any invention covered by any patent, without authority from the owner of the patent.

IPAC DUSTBIND S3

WATER-BASED SULPHUR DUST SUPPRESSANT

Description and Uses IPAC Dustbind S3 is a specially formulated dust suppression agent, free of nonylphenols, developed to provide immediate and long-term dust control on a variety of sulphur forms and high fines content material. Field trials in commercial applications of IPAC Dustbind S3 have confirmed that simple atomized spray applications provide sufficient chemical coverage to effectively control dust, thus eliminating large capital investment and service requirements inherent to aerated foam application systems. IPAC Dustbind S3 contains a component which is selective to sulphur surfaces and upon drying remains a viscous, agglomerative liquid, thus remaining effective for extended periods of time. Impurity specifications set by Alberta Sulphur Research Ltd. have been met or exceeded.

Typical Properties Appearance ............................................................................................................................Clear liquid pH ................................................................................................................................................8 ± 1.5 Specific Gravity .................................................................................................................................1.02 Viscosity .......................................................................................................................................50 cPs Freezing Point ...................................................................................................................................0°C Freeze-Thaw Stability ......................................................................................... Complete with agitation Solubility in Water ............................................................................................................................Good Shelf Life.......................................................................................................................................2 years

Application IPAC Dustbind S3 should be diluted with water in the ratio of 80 to 100 to 1, depending on the need. The dilution can be achieved either via in-line static mixing or in a bulk tank with agitation. Complete dissolution will be evident when the solution is clear. For further application information, please contact your IPAC representative.

Shipping and Handling IPAC Dustbind S3 is supplied in 200 L drums or 1000 L tote bins. Bulk delivery to an on-site storage tank is also available. Do not store near excessive heat. Do not freeze.

Quality Products are manufactured under ISO standards.

Regulatory Status TDGA: Not Regulated WHMIS: D2B

2001/12/01

Product Data Sheet

IPAC Chemicals Ltd., 1620 West 75th Avenue, Vancouver, B.C. V6P 6G2 Phone: (604) 261-3019

The information given and the recommendations made herein are based on our research and are believed to be accurate but no guarantee of their accuracy is made. In every case we urge and recommend that purchasers test the product for their particular purpose under their own operating conditions. The products discussed herein are sold without any warranty as to merchantability or fitness for a particular purpose or any other warranty, express or implied. No representative of ours has any authority to waive or change the foregoing provisions but, subject to such provisions, our engineers are available to assist purchasers in adapting our products to their needs and to the circumstances prevailing in their business. Nothing contained herein shall be construed to imply the non-existence of any relevant patents or to constitute a permission, inducement or recommendation to practice any invention covered by any patent, without authority from the owner of the patent.

IPAC SRB PLUS

SULPHUR RELEASE AID

Description and Uses IPAC SRB PLUS is a specially formulated product which combines surfactant blends for improved formation and release of the sulphur with a preservative to inhibit the growth of thiobacilli, which is responsible for acid generation and corrosion problems during the storage and transportation of sulphur. IPAC SRB PLUS is water-based, readily soluble in water, easy to handle and safe. IPAC SRB PLUS is very stable and can be reused in operations such as Sandvik or similar forming equipment where recycling of release aid is necessary. IPAC SRB PLUS can reduce the amount of water used in an operation by up to 80%, and since it is effective at low concentrations, the high purity level of the sulphur is always maintained.

Typical Properties Appearance ........................................................................................................................Opaque liquid pH ....................................................................................................................................................6 - 8 Specific Gravity ...................................................................................................................................1.0 Viscosity .......................................................................................................................................20 cPs Freezing Point ..................................................................................................................................-2°C Solubility in Water ..................................................................................................................... Complete Flash Point (COC) ..........................................................................................................................>93°C

Application IPAC SRB PLUS can be either diluted in-line with 20 to 100 parts water, passed through a static mixer and fed as such directly to the forming surface, or dilute product can be prepared in bulk volumes. Ideally for batches, IPAC SRB PLUS should be added to warm water at a point of turbulence and the dilute solution continually mixed with slow sweeping mixing blades to maintain quality. For further application information, please contact your IPAC representative.

Shipping and Handling IPAC SRB PLUS is available in 205 L drums and 1150 L tote bins. Bulk delivery to an on-site storage tank is also available. Product shelf life is one year.

Quality Products are manufactured under ISO standards.

Regulatory Status TDGA: Not regulated WHMIS: Not controlled

2001/12/01


APPENDIX C-4

STORM WATER RUN-OFF AND FIRE WATER SUPPLY POND PLAN & DETAILS (DRAWING NO. 085433-5901-0002)

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APPENDIX D

PUBLIC CONSULTATION PROGRAM DETAILS


APPENDIX D-1

OPEN HOUSE NOTIFICATIONS (REDWATER REVIEW)


APPENDIX D-2

PUBLIC CONSULTATION CONTACT LIST

HAZCO - Bruderheim Sulphur Forming and Temporary Storage Facility1.6km Stakeholder & Concerned Citizen Listing Around Section 35-55-20-W4M

Legal Description Owner Address Phone Comments ConcernsSE 25-55-20-W4M Jerry B. Strand and 46 McCullough Cresent (403) 342-4190 May 11th - In Montreal, left message None identified.

Rosemary Strand Red Deer, Alberta Mail out packageT4R 1S7 May 18th - Package sent via courier

June 3/05 - Invitation to open house sent Marian Investments Ltd. 8538-100th Ave

Ft. Saskatchewan,ABT8L 3B5

NE 25-55-20-W4M Kevin D. Schultz and Box 787 (780) 895-7554 May 11th-Meeting set up for 3:00 on May 17th Dust, air quality, EIA, Use of land, property values.Brenda M. Schultz Lamont, AB (780) 940-9832 (cell) June 3/05 - Invitation to open house sent Requested further information.

T0B 2R0 July 22/05 - Request for additional information sent.

NW 25-55-20-W4M Albert J. Schultz (Farmer) and 4439 50A Ave (780) 895-7734 May 11th-Meeting set up for 6:00 on May 17th None identified.Audrey Elizabeth Schultz Lamont, AB June 3/05 - Invitation to open house sent

T0B 2R0Leslie Howard Sawers and Box 40 (780) 796-3426 May 11th - Spoke with Howard & he will get None identified.Diane Given Sawers Bruderheim, AB (780) 203-6382 (cell) Leslie to call me back.

T0B 0S0 send out information packageMay 18th - Package sent via courierJune 2/05 - Invite to open house sent courierJune 29 - Invite for open house was not picked up a the Greyhound Depot

SW 25-55-20-W4M Stanley Wilten Arndt and Box 155 (780) 796-3802 May 11th - Talked to Stanley Supports local industrial development and the project.Marlene Ruth Arndt Bruderheim, AB He is selling his land to another company

T0B 0S0 and is a little confussedMay 12th - Meeting set up 6:00 on May 16th June 2/05 - Invite to open house sent courier

SW 26-55-20-W4M Wesley L. Hauer and Box 88th (780) 796-2372 May 11th - Send out Information package No concerns identified.Elfrieda Hauer Bruderheim, AB May 18th - Package sent via courier

T0B 0S0 June2/05 Invite to open house sent courierJune 28 - Information package & Invite to open house was not picked up at the Greyhound Depot

NW 26-55-20-W4M Churchill Industrial Group Ltd. 8525 Davies Road Bought out from Triton Energy No concerns identified.Edmonton, AB June 3 - Package dropped off @ Fabrication ShopT6E 4N3

NE 26-55-20-W4M Stanley Wilten Arndt and Box 155 (780) 796-3802 May 11th - Attended the county meeting Supports the project.Marlene Ruth Arndt Bruderheim, AB He feels very informed.

T0B 0S0 June 2/05 - Info to open house sent courier

Warren Stanley Arndt Box 155 (780) 405-5578Bruderheim, AB

SE 26-55-20-W4M Francis Kenneth Cholak Box 86 (780) 796-2108 May 11th - Mail package Cattle heatlh.Lamont, AB Runs Organic Cattle Operation, is opposed No further information requested.T0B 2R0 Father recently passed on

Met on May 17 at 1:00May 18th - Package sent via courierJune 2/05 - Info to open house sent via courier

Page 1 of 5


Legal Description Owner Address Phone Comments ConcernsSE 27-55-20-W4M Theodore William James 304, 10634-80 Ave May 11th - Lives in city No concerns identified.

Frauenfeld Edmonton, AB Brother to BruceT6E 1V5 June 2/05 - Info to open house sent via mail

Bruce Gregory Frauenfeld Box 261 (780) 796-3525 May 11th - Mail package (x2)Bruderheim, AB Bruce is the one who looks after the landT0B 0S0 May 18th - Packages sent via courier

June 2/05 - Info to open house sent courierNE 27-55-20-W4M Emil T. Hauer **ADDRESS** May 11th - Passed away No concerns identified.

Bruderheim, AB son lives on farm**POSTAL CODE** Kevin Hauer

Box 368thBruderheim, AB T0B 0S0(780) 796-2473May 12th - Left messageMay 24-Package sent via courierJune 2/05 - Info to open house sent courierJune 29 - Invite for open house was not picked up at the Greyhound Depot

NW 27-55-20-W4M Herbert E. Rinas and 10607-101 Ave (780) 998-1472 May 11th-Meeting set up for 2:00 on May 17th Groundwater and air qualityAudrey G. Rinas Ft. Saskatchewan,AB June 2/05 - Info to open house sent via courier No request for additional information.

T8L 1A1SW 27-55-20-W4M Barry Ward Schram Box 494 (780) 796-2223 May 11th - Left message No concerns identified.

Bruderheim, AB May 12th - No answerT0B 0S0 June 2/05 - Info to open house sent via courier

Edward William Schram Box 232 nd (780) 796-3784 May 11th - Left message No concerns identified.Bruderheim, AB May 12th - Meeting set up at 9:00 on May 17thT0B 0S0 June 2/05 - Info to open house sent via courier

SW 34-55-20-W4M Glen Fibke and PO Box 96 (780) 998-2700 May 11th - Mail out package No concerns identified.Sarah Fibke Bruderheim, AB May 18th - Packages sent via courier

T0B 0S0 June 2/05 - Info to open house sent via courierNW 34-55-20-W4M Canadian Pacific Limited 205-9th Ave SE (403) 319-7539 May 12th - Left message with land department No concerns identified.

Calgary, AB looking for contact nameT2P 4Z4

Superior Plus Inc. c/o Erco 302 The East Mall both companies via courierWorldwide Toronto, ONAttn: Mary Lou McDonald M9B 6C7Legal Department

NE 34-55-20-W4M Timothy Gustav Bartz PO Box 421 (780) 796-3990 May 11th-Meeting set up for 8:00 on May 17th Traffic, speed, dust, air quality, groundwater quality.Bruderheim, AB June 2/05 - Info to open house sent via courier No request for additional information, however, HAZCO to T0B 0S0 continue to consult with Bartz's.

SE 34-55-20-W4M Nexen Inc. 801, 7th Ave SW (403) 699-4000 May 12th - Left message with land department Dust and Emergency Response PlanCalgary, AB looking for contact person HAZCO continuing to provide further information.T2P 3P7 Send out package Attn: Ray MacEachern

May 18th - Package sent via courierJune 2/05 - Info to open house sent via courierJune 24 - Spoke with Facility Manager

Page 2 of 5


Legal Description Owner Address Phone Comments ConcernsNW 35-55-20-W4M Altalink Management Ltd. Box 20, Station 'M' June2/05 - Info to open house sent via courier No concerns identified.

Calgary, AB T2P 2G9

Alberta Energy Company Ltd. #1200, 10707-100Ave Facility location N/AEdmonton, AB**POSTAL CODE**

NE 35-55-20-W4M Alberta Energy Company Ltd. #1200, 10707-100Ave Facility location N/AEdmonton, AB**POSTAL CODE**

SE 35-55-20-W4M Alberta Energy Company Ltd. #1200, 10707-100Ave Facility location N/AEdmonton, AB**POSTAL CODE**

SW 35-55-20-W4M Alberta Energy Company Ltd. #1200, 10707-100Ave Facility location N/AEdmonton, AB**POSTAL CODE**

SE 36-55-20-W4M Shriners Hospital for Children 2900 Rocky Point Dr May 11th - send out package No concerns identified.Tampa, FL USA May 18th - Package sent via courier33607-1435 June 2/05 - Info to open house sent via courier

SW 36-55-20-W4M Robert Kottke Box 553 (780) 796-3698 May 11th - Meeting Scheduled for 1:00 Air and groundwater quality, aesthetics, land values.Bruderheim, AB Met on May 17 at 1:00 No request for additional information.T0B 0S0 June 2/05 - Info to open house sent via courier

NW 36-55-20-W4M Jason Boon Box 411 (780) 796-3918 May 11th - Left message No concerns identified.Bruderheim, AB May 12th - No answerT0B 0S0 Met on May 17 at 1:00

June 2/05 - Info to open house sent via courier

Albert Komant and Box 691 May 18th - Packages sent via courierBarbara Komant Smokey Lake, AB June 2/05 - Info to open house sent via mail No concerns identified.

T0A 3C0NE 36-55-20-W4M Marvin Merle Bartz and 7307-137 Ave (780) 475-7972 May 11th - Send out package See Tim Bartz

Elsie Elizabeth Bartz Edmonton, AB May 18th - Package sent via courierT5C 2L4 June 2/05 - Info to open house sent via courier

NE 1-56-20-W4M Dennis James McCartney and Box 593 (780) 895-2651 May 11th - Meeting set up at 7:00 May 17th Facility design, acid rain, water management, fire hazards.Mary Grace McCartney Lamont, AB June 2/05 - Info to open house sent via courier Requested additional information.

T0B 2R0 July 22/05 - Request for additional information sent.NW 1-56-20-W4M Rodger Bartz Box 76 (780) 796-2327 May 11th - send out package No concerns identified.

Bruderheim, AB Dean Bartz is Rodgers sonT0B 0S0

May 18th - Package sent out via courierJune 2/05 - Info to open house sent via courierJune 29 - Invite for open house was not picked up at the Greyhound Depot

SW 1-56-20-W4M Denis Vanbrabant and General Delivery May 11th - Robert Koltke has invited them to Air quality, groundwater quality, noise, traffic, property value.Fiona Farrell Bruderheim, AB attend there 1:00 meeting on May 17th Requested additional information.

June 2/05 - Info to open house sent via mailT0B 0S0 July 22/05 - Request for additional information sent.

Page 3 of 5


Legal Description Owner Address Phone Comments ConcernsSW 1-56-20-W4M Canadian Pacific Ltd. 205-9th Ave SE Track through property No concerns identified.

Calgary, AB see page 3T2P 2Z4

Dean Bartz Box 76 (780) 893-0273Bruderheim, AB May 11th - Asked to call when in town No concerns identified.T0B 0S0 Met on May 17 at 3:00

June 2/05 - Info to open house sent via courierJune 29 - Invite for open house was not picked up at the Greyhound Depot

SE 1-56-20-W4M Douglas Lorne McCartney Box 761 (780) 895-2403 May 12th - Left message Air and groundwater quality.Bruderheim, AB June 2/05 - Info to open house sent via courier No request for additional information.T0B 2R0 June 29 - Invite for open house was not picked up at the Greyhound Depot

SE 2-56-20-W4M Jeffrey William McNeill and Box 637 (780) 796-3958 May 12 th - Left message Air, surface water, groundwater, dust, and property value.Laura Lynn McNeill Lamont, AB (780) 796-3963 Met on May 18 at 9:00. Requested Additional information July 5 - Sent via email.

T0B 2R0 June 2/05 - Info to open house sent via courier continue to consult.June 13 - Met to further discuss issues

SW 2-56-20-W4M Maschmeyer Farms Ltd. Box 188 (780) 992-0595 May 11th - Left message for Stewart from No concerns identified.Bruderheim, AB Ft. SaskatchewanT0B 0S0 Believe it is his farm

NW 2-56-20-W4M Roy Benjamin Hauer #603,10130-114 St (780) 488-7398 May 11th - asked for package to be sent to No concerns identified.Edmonton, AB himself and his sister EllaT5K 2S6 June 2/05 - Info to open house sent via courier

Ella Reao Quebec 1165-20 Ave Ella lives out of the province No concerns identified.Prince George, BC Roy looks after land**POSTAL CODE** May 18th - Packages sent out via courierold address

NE 2-56-20-W4M Neil J. Woitas and Box 149 (780) 796-3734 May 11th - Talked to Rosanna and she will get No concerns identified.Rosanna M. Woitas Bruderheim, AB Met on May 17 At 1:00.

T0B 0S0 June 2/05 - Info to open house sent via courierJune 29 - Invite for open house was not picked up at the Greyhound Depot

NE 3-56-20-W4M Cyril D. Paul and Box 195 (780) 796-3764 May 11th - Left message No concerns identified.Wanda G. Paul Bruderheim, AB Met on May 17 At 1:00.

T0B 0S0 June 2/05 - Info to open house sent via courierNW 3-56-20-W4M Audrey J. Maschmeyer Box 147 Arlan (780) 796-3974 No concerns identified.

Bruderheim, AB call Arlan for Audrey's #**POSTAL CODE** June 2/05 - Info to open house sent via mail

SW 3-56-20-W4M Stewart Cameron Maschmeyer Box 188 (780) 992-0595 May 11th - Left message No concerns identified.Bruderheim, AB Met on May 17 At 1:00.T0B 0S0 June 2/05 - sent to Maschmeyer farms

Andre R. Fournier and Box 298Diane H. Fournier Bruderheim, AB June 2/05 - Info to open house sent via mail No concerns identified.

T0B 0S0SE 3-56-20-W4M Cyril Donald David Paul and Box 195 (780) 796-3764 May 11th - Left message No concerns identified.

Wanda Gayle Paul Bruderheim, AB Met on May 17 At 1:00.**POSTAL CODE** June 2/05 - Info to open house sent via courier

Page 4 of 5


Legal Description Owner Address Phone Comments ConcernsCounty of Lamont No. 30 May 10 - Project Disclosure PresentationLamont, AB T0B 2R0 June 3/05 - Invitation to open house sent via courier No concerns identified.Attn: Debbie HamiltonAlberta's Industrial Heartland May 12 - Project Disclosure Presentation No concerns identified.Suite 1240 June 3/05 - Invitation to open house sent via courierSun Life Place10123 99th StEdmonton, AB T5J 3H1Attn: Larry WallTown of Bruderheim May 12 - Project Disclosure Presentation No concerns identified.Box 280 June 3/05 - Invitation to open house sent via courierBruderheim, AB T0B 0S0Attn: Jack LambertAlberta Environment May 12 - Project Disclosure Presentation N/A111 Twin Atria Building June 3/05 - Invitation to open house sent via courier4999-98 Avenue Did not attend open houseEdmonton, AB T6B 2X3Attn: Kem SinghAttn: Park PowelAttn: Clement NgLuanne Penner Met at Open House Life of facility, sulphur demand?, market area, customer list, closure, Box 402 July 22/05 - Request for additional information sent. liner selection, fires.Bruderheim, AB T0B 0S0 Requested additional information.Henry Vissher Met at Open House Facility design, water quality, dust, noise, property value.Box 1074Lamont, AB T0B 2R0Bill Dembicki Met at Open House Irrational - Opposed project, specific reason not given.Address not given No request for additional information.Jerry & Evelyn Dach Met at Open House Irrational - Opposed project, specific reason not given.Address not given No request for additional information.Dianne Grosenick Met at Open House Air and groundwater quality, infrastructure.Box 176 July 22/05 - Request for additional information sent. Requested additional information.Lamont, AB T0B 2R0

SW11-56-20 W4M Paul Purschke Met at Open House Directional lighting at the site.Box 151 July 22/05 - Request for additional information sent. Requested that HAZCO commit to using directional lighting at the Bruderheim, AB T0B 0S0 site.

Page 5 of 5


APPENDIX D-3

OPEN HOUSE SIGN-IN SHEET


APPENDIX D-4

OPEN HOUSE PRESENTATION BOARDS


APPENDIX D-5

RESIDENT CORRESPONDENCE


APPENDIX D-6

PROJECT INFORMATION PACKAGE

Integrated Industrial Railway Park & Alberta Sulphur Terminals Ltd.

Lamont County 35-055-20 W4M

April 2005

PROPOSED DEVELOPMENT HAZCO Environmental Services Ltd. (HAZCO), a division of CCS Income Trust, is developing plans to build an Integrated Industrial Railway Park in Section 35-055-20 W4M, 2.2km east of Bruderheim, Alberta. Proposed uses of the railway park would include a sulphur forming and handling for export facility (developed by Alberta Sulphur Terminals Ltd., a division of HAZCO), a rail car storage facility, as well as a rail car repair and maintenance company. The proposed project will be located on lands owned by HAZCO at 35-055-20 W4M. This intent of this package is to provide information surrounding the Alberta Sulphur Terminals Ltd. (AST), its proposed services and related development. The proposed project outlined in this document is based on preliminary information obtained by HAZCO. Project plans will be finalized upon the completion of an environmental site assessment at the proposed development site. Please review the following document for more detailed information related to the proposed project. If you have any questions, comments or concerns related to the information provided, please contact us. Contact information is provided on the last page of this document. COMPANY BACKGROUND The proposed project will be entirely funded and completed by the HAZCO division of CCS Income Trust.

CCS Income Trust is a dynamic growth trust based out of Western Canada with three focused divisions: CCS Energy Services, Concord Well Servicing and HAZCO. These divisions and their subsidiaries provide integrated and environmentally responsible solutions to environmental and waste management challenges. HAZCO Environmental Services Ltd. is a full service environmental contractor based in Western Canada providing services to the government, industry and the oil and gas sector. HAZCO was incorporated in 1989 and has operated as a private company until being purchased in the fall of 2004 by CCS Income Trust. More information is available in the enclosed brochures and can found on our web site www.hazco.com or the CCS Income Trust web site at www.ccsincometrust.com.

CCS Income Trust Service Locations

CCS and its divisions are committed to providing environmentally responsible solutions for their customers and



Proposed Site

Location

surrounding communities. Protecting the environment and pollution prevention is at the core of our business and we are committed to continually improving our environmental performance. PROJECT OVERVIEW Sulphur, a byproduct of the oil and gas industry, is primarily used in the production of fertilizer world wide. For example, Agrium, a global producer and marketer of agricultural nutrients and industrial products, has a manufacturing facility located at Redwater, Alberta and consumes approximately 350,000 tons of sulphur per year. With increased activity in the heavy oil sector resulting in more produced sulphur, combined with an increase in demand for sulphur worldwide, there is a shortage of sulphur forming capacity in Alberta. The sulphur is produced by various oil and gas operations in Alberta in a molten form,

manufactured in to a dry product (i.e. sulphur pellets) for handling, loaded to rail car for transport to Vancouver, and loaded on ships for delivery to export markets. The proposed project will require an operating approval issued by Alberta Environment. Ongoing monitoring and the associated reporting activities will also be reported to Alberta Environment on an annual basis. The proposed project includes facilities for sulphur forming and shipping, as well as facilities for short-term storage of excess sulphur in cases of an emergency or market down turn. In terms of operations, molten sulphur will be received by one of three methods, pipeline, rail tank car or truck. The sulphur will be stored in tanks before being pumped to the forming process. AST plans to use an environmental friendly technology provided by Sandvik

Process Systems (information enclosed) to pastillate the sulphur into a formed product suitable for export. The product will be stored on engineered storage pads and loaded to rail car unit trains. The volumes of liquid and dry storage will be dependant on market demand for our services and will also grow with demand.

• A primary synthetic liner; • Neutralization and discharge

systems to manage water that accumulates in the storage cells;

• A compacted clay liner to act as secondary containment in the event that the primary liner in compromised;

• Perimeter berms to provide a sight and sound barrier and prevent run-on and run-off; and,

This sulphur can be poured into a block and recovered when conditions change. The supply chain for sulphur can be subject to interruptions such as rail stoppage, labour shortages, port space, vessel availability and many others. Interruptions require as much flexibility in the sulphur forming facility as possible. The facility will require a small storage area for a sulphur block. The sulphur block storage will be surrounded by an earthen berm which will provide a sight barrier. The sulphur stored in the block can be recovered when conditions improve. We are not permitting for long term subsurface storage, only allowing for a block to pour without a visual impact.

• Appropriate security systems, operating and monitoring procedures.

Estimated Cost – Preliminary cost estimates suggest the development would involve capital spending of approximately $30 million dollars (CDN). Economic Impact – HAZCO anticipates that the facility will create approximately 8 to 12 full time positions. In addition, HAZCO will make every effort to utilize local contractors during facility construction.

The sulphur forming component of the proposed facility includes:

Estimated Schedule – A preliminary schedule for the project is outlined below.

• Rail and road access for receiving and shipping sulphur;

• Sulphur unloading and transfer

facilities; REGULATORY APPROVAL AND CONSULTATION PROCESS • Sulphur forming facilities to

produce sulphur pellets (pastilles); and,

The regulatory approval process provides many opportunities for public consultation and input. Actual dates for community meetings and open houses will be advertised in the local media.

• Loading and shipping facilities for formed sulphur.

The short term storage facilities will consist of an engineered containment area having the following design features:

Specific timing for HAZCO’s planned regulatory review and consultation is outlined as follows: • Community consultation– May

though to proposed facility operations

• Regulatory Application Filing – Fall 2005

• Regulatory Review and Approval – Winter 2005/2006

As part of the regulatory review and approval, Alberta Environment will evaluate, among other things, geotechnical considerations, site suitability and environmental controls and monitoring programs. HAZCO will seek input from all stakeholders during each phase of the project. Stakeholder consultation will be completed before filing regulatory applications, during construction and after facility start-up. Consultation will include individual meetings, public meetings, updates, open houses and presentations. If you think you are directly affected by the proposed facility, please do not hesitate to call us. Our contacts and their areas of responsibility are on the last page of this document. Discussions will be held to identify, address and resolve issues wherever possible. Interested parties will also have the opportunity to review the detailed regulatory application documents once they have been filed. SULPHUR MANAGEMENT Largely due to environmental concerns, the processing of Western Canada’s oil and gas resources requires the extraction of as much sulphur as possible. When the sulphur is extracted from gas and/or oil, the sulphur is handled in a liquid form at temperatures ranging from 124 -145°C. These high temperatures mean that handling, transportation and storage of the sulphur creates issues not only from a

health and safety perspective but also in terms of economical handling. For easier handling, storage and transportation, sulphur is formed into flakes or pastilles (pellets). The proposed AST facility plans to utilize the Sandvik Rotoform® system to process the liquid sulphur received at the facility. The process starts with the delivery of liquids sulphur by pipeline or in special trucks. There will be no associated odour with the sulphur as the facility will only accept degassed sulphur (i.e. majority of the H2S has been removed to <10ppm H2S). The sulphur is then transferred into heated tanks awaiting the pastillation process. The basic pastillation principle consists of a feeding system which deposits droplets of liquid sulphur onto a continuously running steel belt. Water is sprayed against the underside of the belt and the resulting transfer of heat converts the droplets into solid pastilles. This process forms molten sulphur product into pastilles so there is no requirement for grinding or crushing upon subsequent processing by HAZCO clients. This eliminates the costs for environmental problems such as noise and dust, which are usually associated with these secondary processes. A process flow diagram outlining the pastillation process is provided on the following page. All workers will be properly trained to operate the facility and a facility emergency response plan will be developed in cooperation with local emergency response officials.

M

Granules silo

Storage

Baggingweighing

M

Release agent applicator

Tensioning drum(Heating optional)

water collecting tank

Reactorresp. Mixer

Prefilter

Raw material I

Raw material II

Release agent

cooling water

cooling waterreturn

Product pump Fine filter Rotoformer Steel belt cooler

Exh

aust

air

Exh

aust

air

Typical Rotoform®-Plant

ENVIRONMENTAL MANAGEMENT HAZCO is committed to environmental management as it is a vital part of our business. The environmental protection measures put in place at all CCS Income Trust facilities are second to none. We meet or exceed regulatory requirements and coupled with monitoring programs and sound facility operation, this ensures that there is no adverse impact to the environment. That being said, HAZCO anticipates a variety of concerns from community stakeholders and government officials due to the nature of the proposed project. In addition, community consultation is a top priority for the company and we are committed to work with project stakeholders to ensure the project creates minimal impact to the community and the environment. As a result, HAZCO will assemble a team of environmental experts to undertake an Environmental Site Assessment for the facility. In conjunction with Alberta Environment and project stakeholders, HAZCO will ensure that all information requirements are met prior to the filing of the regulatory application. Since the project is very preliminary at this point, many of the site specific information is not yet available. Once this information is obtained, HAZCO will provide updates to project stakeholders as part of the consultation and information sharing process.

COMPANY CONTACTS All proposed development activities will be coordinated from the CCS Income Trust office in Calgary, Alberta. The company address is: HAZCO Environmental Services 2400, 530 8th Avenue S.W. Calgary, Alberta T2P 3S8 Inquiries related to the proposed project are welcome and should be directed to: Paul Kaethler Project Sponsor Tel. 403.231.8438 [email protected] Corey Higham Regulatory and Environment Tel. 403.231.8425 [email protected] Toll Free: 1-888-842-7833

mailto:[email protected]



HAZCO Environmental Services Ltd., a division of CCS Income Trust, has submitted an application to Alberta Environment for approval to construct and operate a Sulphur Management Facility to be located at Section 35-055-20 W4M approximately 2.2 km east of Bruderheim, Alberta, just north of Highway 15. The following information is intended as a brief overview of the project in an effort to maintain effective communications with stakeholders.

The proposed project will be entirely funded and completed by the HAZCO division of CCS Income Trust. HAZCO is an industry leader providing a wide-range of specialized services including: Sulphur Services, Site Remediation, Decommissioning, Waste Services, Environmental Construction, Environmental Technologies, Emergency Response and Other Specialty Services. More information is available at our web site www.hazco.com or the CCS Income Trust web site at www.ccsincometrust.com.

Sulphur, a by-product of the oil and gas industry, is primarily used in the production of fertilizer world wide. Increased activity in the heavy oil sector resulting in more produced sulphur and combined with an increase in demand for sulphur exports worldwide, there is a shortage of sulphur forming capacity in Alberta. The proposed project includes facilities for sulphur forming and shipping, as well as facilities for the temporary storage of excess sulphur in cases of an emergency or market interruption. Molten sulphur will be received by pipeline, rail tank car or truck. The sulphur will be stored in tanks before being pumped to the forming process. Alberta Sulphur Terminals plans to use an environmental friendly technology, provided by Sandvik Process Systems, to process the liquid sulphur into a formed product (i.e. pastilles) suitable for export. The product will be stored on engineered storage pads and loaded onto rail car unit trains when certain volumes are required. The volumes of liquid and dry storage will be dependant on market demand for our services and will also grow with demand. This sulphur also can be poured into a block and recovered when conditions change. The supply chain can be subject to interruptions, such as rail stoppage, labour shortages, port space, vessel availability and many others. Interruptions require as much flexibility in the sulphur forming facility as is possible. As a result, the facility will require a small temporary storage area for a sulphur block. The sub-grade sulphur block storage area will be visually restricted on two or more sides by an earthen berm which will provide a sight barrier. The sulphur stored in the block can be recovered when conditions improve.

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ALBERTA SULPHUR TERMINALS BRUDERHEIM, ALBERTA

PROJECT OVERVIEW

CORPORATE OVERVIEW



Subject to regulatory approvals, construction will commence in the spring of 2006 and will take approximately 6 to 7 months to complete. Facility operations will commence immediately after the facility has been constructed with a target date of November 2006.

HAZCO is committed to supporting the local economy both in construction and operations of the facility. Long-term facility operations are expected to create up to 20 full time positions.

HAZCO plans to utilize the latest technology to control emissions and minimize its impact on the surrounding environment.

AIR QUALITY Odours at the site will be minimal as all of the sulphur received on site is degassed to less than 10 parts per million H2S. With the facility located at the center of property and with a minimum 600 meter setback from the surrounding properties, there will be essentially no odours from the proposed site. Air quality and dust impacts will be addressed through air monitoring programs and a soil monitoring program. The monitoring programs will be required as part of an Alberta Environment Environmental Protection and Enhancement Act Approval. The approval will stipulate acceptable air monitoring parameters and associated criteria that will ensure no adverse effect on human health or the surrounding environment.

SOIL QUALITY Facility operations are not expected to adversely affect local soil quality. Alberta Environment and Alberta Energy and Utility requirements have been incorporated into the design and will be strictly adhered to. An Alberta Environment approved soil monitoring program will also be completed and reviewed on a yearly basis.

TRAFFIC At the busiest times, HAZCO anticipates approximately one to two additional trains per week as well as approximately 40 trucks per day. HAZCO is currently completing a Traffic Impact Assessment which will indicate if any upgrades to the Highway 15 and Highway 45 intersections are required to maintain a safe access. HAZCO will incorporate all appropriate measures to ensure proper access and egress of truck traffic from Highways 15 and 45. All proposed accesses are required to be reviewed and approved by Alberta Transportation.

GROUNDWATER QUALITY Groundwater monitoring wells will be installed in accordance with Alberta Environment guidelines and will be used to sample groundwater each spring and fall. The groundwater monitoring program will be designed and performed by an independent professional hydrogeologist. Collected samples will be sent to an offsite, third party laboratory to determine the groundwater quality beneath the site for the life of the project. This will provide early indication of any impacts on local geology and/or hydrogeology in the unlikely event they may occur. The favourable site conditions (silt clay overburden with low hydraulic conductivity) and the monitoring program will be further complimented by the proposed facility design that makes use of double liner systems, and run-off control systems as well as sound facility operation.

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PROJECT SCHEDULE

ECONOMIC IMPACT

ENVIRONMENTAL CONTROLS

SURFACE WATER QUALITY All precipitation that falls on the active working area of the facility will be collected in a lined ditching system and directed to a lined surface water collection pond. At this time, HAZCO has no plans to discharge any of the surface water run-off collected in the surface water pond as the pond will be used as a source of water for process make-up water requirements and for the fire suppression system. In the event where water from the surface water pond needs to be released due to capacity restraints (likely due to excessive precipitation events), the water will be sampled and analyzed to confirm the surface water pond water quality meets applicable surface water quality guidelines. If the water does not meet the applicable criteria the water will then be treated and re-tested.

NOISE LEVELS Hazco is in the initial stages of completing a Noise Impact Assessment (NIA). The NIA will be completed prior to facility start-up and, if approved, after start-up of operations. Any noise impact beyond established acceptable levels will require attention to mitigate noise impacts.

FACILITY SAFETY The proposed facility’s operation plans, Occupational Health and Safety policy and Emergency Response plans for facility operations, sulphur fires and potential evacuations will be reviewed and filed with all local emergency response officials and organizations, Alberta Environment and the local municipal governments.

The HAZCO Alberta Sulphur Terminals project team is committed to working with the community throughout the development of this project. Should you wish to obtain additional information regarding this project, please contact: Paul Kaethler HAZCO Environmental Services Ltd. 2400, 530 – 8 Avenue S.W. Calgary, AB T2P 3S8 Direct: (403) 231-8438 Toll Free: (888) 842-7833 Email: [email protected] Corey Higham HAZCO Environmental Services Ltd. 2400, 530 – 8 Avenue S.W. Calgary, AB T2P 3S8 Direct: (403) 231-8425 Toll Free: (888) 842-7833 Email: [email protected]

Page 3 of 3

HAZCO CONTACTS

August 2005

Hazco Environmental Services Ltd. Alberta Sulphur Terminals Project

Project Questions and Answers

1. Who is actually proposing this facility? Is it Hazco or CCS? The facility is proposed by Hazco Environmental Services Ltd. Hazco is a wholly

owned subsidiary of CCS Income Trust.

2. What exactly are you proposing to build? Hazco is proposing to build a Sulphur Management Facility. The facility would

receive liquid sulphur and form the sulphur (using a process called Rotoforming)

into a pastille product that would then be shipped off site to market. There would

be a portion of the site dedicated to temporary storage, either as formed product

or poured to block, in the event that downstream logistics fail (rail, port, and

shipping).

3. Where will it be located and how much land will be required? The proposed site will be located near the centre of section 35, Township 55,

Range 20, W4M (2.2 km east of Bruderheim, Alberta, just north of Highway 15).

The facility footprint will be approximately 79 acres (32 ha.), not including the rail

track.

4. What will it look like when completed? How big will the sulphur pile

be? Will it be stacked in blocks or a giant pile? The facility will consist of a storage tank area, office/manufacturing structure,

product receiving and storage area, surface water storage pond, and a rail

loading area. It is intended that the storage pile will be less than 50 feet tall and

cover an area of less than 3 acres (1.2 ha.). Sulphur may be stored as both

block and finished product depending on market conditions.

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August 2005

5. What is your proposed schedule for approvals, construction and completion?

An application for the facility was submitted to Alberta Environment on July 25,

2005. Typical turnaround for these applications is 4-6 months. Construction

activities are estimated to take 6-7 months depending on the time of year.

Completion is targeted for November 2006.

6. How much will it cost? The anticipated capital cost of the project is approximately $30 Million (Cdn.)

7. How many people will be required to build the facility and how many of those will be local?

It is anticipated that 36,000 person hours will be required to build the facility

(approximately 40 full time employees). Once the facility is operational, the site

will provide up to 20 full time positions. It is Hazco’s intent to hire as many local

people as possible.

8. Why is this a good area to build your facility? What makes this better than somewhere more remote?

The area is an ideal choice for the facility due to access to rail, road and

infrastructure as well as availability of a skilled labour pool. Placing the facility in

a remote area would negate these benefits and significantly increase the capital

cost while reducing the usefulness of the facility.

9. Why do you think so many local people are opposed to your project? Actually there is a lot of support for this project and through continued honest and

transparent communication; we believe that the community will accept Hazco

based on the sound design, construction and operation of the proposed facility.

We believe those opposed lack of understanding about the project as well as

apprehension about what this project means to local property values and existing

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August 2005

lifestyle. So it’s our job to ensure we provide them with as more information as

possible to make an informed decision.

10. How willing would you be to live near this facility? I’d be very will to live near this facility because I understand that the facility

design, environmental monitoring programs and safe operation of the facility will

work together to ensure that there is no impact to human health or the

surrounding environment.

11. How would you like it if you looked out your window and all you saw was a sulphur storage facility?

Hazco is taking steps to limit or eliminate the visual impact that the facility will

have. A combination of tree lines, fences, wind screens and earthen berms will

be employed to reduce the visual impact of the facility.

12. What’s your reaction to the petition opposing the facility that going around?

It’s not appropriate for us to comment on what others are saying or doing.

Everyone is entitled to their opinions. Hazco encourages open and constructive

feedback. That’s why we’re conducting sessions, holding meetings and in

general, making it easy for folks to provide us with their feedback to the project.

13. What’s your reaction to the opponent website that’s now up and running?

Again, it’s not appropriate for us to comment on what others are saying or doing.

Everyone is entitled to their opinions and Hazco encourages open and

constructive feedback.

14. What guarantees can you give that your project won’t have negative impact on air quality, especially dust and particulates?

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August 2005

Bulk handling of any aggregate or solid will result in the formation of dust (gravel,

sand, coal, sulphur). Hazco recognizes that there will be some localized impact

immediately adjacent to the proposed facility but believes that this impact will be

limited to a 200 metre radius around the facility itself. Given that there is greater

than 600 meters from the facility to the property boundary in all directions Hazco

does not believe that there will be any offsite impact. In addition, Hazco will be

required to complete a yearly approved soil monitoring program that will be

reviewed by Alberta Environment.

15. What guarantees can you give that this project won’t have a negative impact on water quality, especially runoff?

Environmental protection is a top priority for Hazco. The measures incorporated

into the facility design (such as the surface water run-off pond) and sound

operation will ensure that there will be no impact to human health or the

surrounding environment. With respect to surface water run-off, all precipitation

that falls on the active working area of the facility will be collected in a lined

surface water collection pond. The water collected in the pond is then tested,

treated and then recycled, released or disposed.

16. How will you collect, store and treat runoff water? With respect to surface water run-off, all precipitation that falls on the active

working area of the facility will be collected in a lined surface water collection

pond. The water collected in the pond is then tested, treated and then recycled,

released or disposed.

17. What assurances can you give that this project won’t have negative

impacts on drinking water? Environmental protection is a top priority for Hazco. The measures incorporated

into the facility design will ensure that there will be no impact to drinking water in

the area. For example, silt clay overburden at the site had low hydraulic

conductivity and the vertical hydraulic gradient is also low. Hazco will also

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August 2005

implement a semi-annual groundwater monitoring program performed by an

independent hydrogeologist. The favourable site conditions and monitoring

program will be further complimented by the proposed facility design that makes

use of double liner systems, and run-off control systems as well as sound facility

operation.

18. How much more rail and truck traffic can residents expect when your project is up and running?

We anticipate approximately one to two additional unit trains per week as well as

approximately 40 trucks per day.

19. What kind of support do you have for your project from local

councils and municipalities? We made a presentation to the Lamont County Council in May 2005 and at that

time the response was favourable. To date, we have not submitted any

applications to the county, and have not followed up with the councilors regarding

this project. The intent is to submit the development permit application in late

August 2005.

20. How will you deal with the safety issues with so much more road and rail traffic?

Hazco’s health and safety program is second to none. As a result, Alberta

Transportation has been contacted with respect to the Highway 15 and Highway

45 access points associated with the proposed facility. A traffic impact

assessment is currently being completed on the proposed intersections. The

results of the traffic impact assessment are pending.

With respect to the rail traffic, Hazco anticipates one to two unit trains per week

so the effect on traffic patterns will be minimal. Discussions with Lamont County

may be initiated to upgrade rail crossings if they become a safety issue.

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August 2005

21. What assurances can you give people living nearby that noise, lights and smells won’t impact their quality of life?

With respect to the noise, Hazco will be completing a Noise Impact Assessment

prior to and, if approved, after start-up of operations. Any noise impact beyond

established acceptable levels will require attention.

Lighting concerns have been identified and as a result Hazco is committed to

using directional lighting as opposed to flood lights, minimizing the amount of

light pollution.

Odours at the site will be non-existent as all of the sulphur received on site is

degassed to less than 10ppm H2S. With the facility located at the center of

property and a minimum of 600 meter setback from the surrounding properties,

we believe there will be no odours at the site boundaries.

22. What have you done to keep area residents informed about your proposal?

Communication with all of our stakeholders is a top priority at Hazco. We believe

that to be accepted into a community and become a good neighbour, our

communication lines need to be transparent and continue much further than just

the application process. To date, we have met with officials with Lamont County

and Alberta Environment and have individually met with all residents located

within a 1.6km (1 mile) radius of the site. In addition, we have hosted an open

house where 63 people attended. Hazco has also committed to providing

community members with updates related to project status.

23. Opponents to your project claim that the technology you’re using to

store the sulphur is new and untested? What are you doing differently compared to more traditional sulphur storage facilities?

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August 2005

A similar facility located near Sundre, Alberta, using the same technology, has

been operating for the last 14 years in a similar environment. To date, the

Sundre facility has processed more than 22 million tonnes of sulphur. The only

change to the facility would be designing and construction the temporary sulphur

storage block sub-grade and constructing perimeter berms to provide a visual

barrier from the sulphur block.

24. What assurances can you give residents that this technology will actually work, especially on the long term?

A similar facility located near Sundre, Alberta, using the same technology, has

been operating for the last 14 years in a similar environment. To date, the

Sundre facility has processed more than 22 million tonnes of sulphur. To our

knowledge, there have been no issues or emergencies with respect to the

Sundre, Alberta facility.

25. What would happen if your sulphur pile caught fire? What would the threat be to nearby residents?

In the unlikely event of a sulphur fire on site, the first responders would be the

personnel currently on shift. Given the proper training and equipment, it is

intended that all such incidents will be dealt with immediately by personnel on

site. Sulphur fires are easily extinguished using water or by the use of any

chemical fire extinguisher. The onsite surface water runoff pond will also double

as a fire water pond for source water.

There would be no threat to any nearby residents in the vast majority of

incidences. The Emergency Response Plan (ERP) for the facility will detail any

actions required should the first responders fail to control the incident. As a

result, the ERP will be filed with the Town of Bruderheim, Town of Lamont,

Lamont County, Northeast Region Community Awareness and Emergency

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August 2005

Response Group, local industry representatives and Local Emergency Response

officials.

26. What would you do about the stink of burning sulphur?

Extinguish the sulphur fire. The primary emission from a sulphur fire is Sulphur

Dioxide (SO2). Sulphur Dioxide is colorless, denser than air, and has a pungent

odour. Control of any sulphur fire is the key to eliminating the gas. Normal

atmospheric dispersion will eliminate the gas in time. The Emergency Response

Plan for the facility will detail any actions required should sulphur dioxide be

released in hazardous quantities.

27. How dangerous are the health risks if there is a sulphur fire?

No more or less dangerous than a fire at any other industrial site. It depends on

the situation and how well any potential incident is managed. The Emergency

Response plans, coupled with proper training of the onsite personnel and first

responders will minimize or eliminate any potential health risks.

28. There’s strong concern that if water seeps into your sulphur pile it

will create significant amounts of sulphuric acid. What assurances can you give that this won’t happen and what will you do if it does happen?

Environmental protection is a top priority to Hazco. The measures incorporated

into the facility design (such as the surface water run-off pond) and sound

operation will ensure that there will be no impact to human health or the

surrounding environment. All precipitation that falls on the active working area of

the facility will be collected in a lined surface water collection pond. The water

collected in the pond is then tested, treated and then recycled, released or

disposed.

29. Why, according to the petition, haven’t you developed an emergency response plan for the project?

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August 2005

The safety of the public and workers and environmental protection is a top

priority at Hazco. The Emergency Response Plan for the plant is currently under

development. Upon completion of a “draft” plan, copies will be forwarded to

Town of Bruderheim, Town of Lamont, Lamont County, Northeast Region

Community Awareness and Emergency Response Group, local industry

representatives and Local Emergency Response officials for comment. Upon

receipt of the comments, a final Emergency Response Plan will be developed

and filed with all stakeholders mentioned above prior to commencement of

operations.

30. How many full time jobs will this project create? It is anticipated that 36,000 person hours will be required to build the facility

(approximately 40 full time employees). Once the facility is operational, the site

will provide up to 20 full time positions. It is Hazco’s intent to hire as many local

people as possible.

31. How significant will this project be to the local tax base? The estimated taxes for the proposed project will be approximately $100,000.

This value is based on a preliminary estimate and would need to be finalized

based on a formal property tax assessment of the site.

32. Where will the sulphur come from and how will it get here? The sulphur is produced during oil and gas production and refining in Alberta.

The major sources of sulphur to be process at the proposed facility will be Fort

Saskatchewan, Fort McMurray and Lloydminster. Molten sulphur will be received

by one of three methods, pipeline, rail tank car or truck.

33. What do you do with the sulphur once it arrives? How is it processed?

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August 2005

In terms of operations, molten sulphur will be received by one of three methods,

pipeline, rail tank car or truck. The sulphur will be stored as a liquid in tanks

before being pumped to the forming process. Hazco plans to use an

environmental friendly technology provided by Sandvik Process Systems to

process the liquid sulphur into a formed product (i.e. pastilles) suitable for export.

The product will be stored on engineered storage pads and when volumes

dictate loaded to rail car unit trains. The volumes of liquid and dry storage will be

dependant on market demand for our services and will also grow with demand.

This sulphur also can be poured into a block and recovered when conditions

change.

34. The website opposed to your proposal speaks to tens of thousands of hits about sulphur fires and evacuations. Why do they happen so often and what steps will you take to make sure it won’t happen here?

Hazco can not comment about the web site searches with respect to sulphur

fires, however, we can confirm that sulphur fires can and do happen. The

proposed facility’s operation plans, Occupational Health and Safety (OH&S)

policy and Emergency Response plans for sulphur fires and potential

evacuations will be reviewed and filed with all local emergency response officials

and organizations, Alberta Environment and the local municipal governments.

35. Why not build this facility at a more remote location, not so close to farms and communities?

Hazco was attracted to the area due to the availability of industrial land. Since

the land was zoned industrial, Hazco believed the site was a great fit due to the

site characteristics, proximity to rail, highways and sulphur production sources.

36. Why not build in a community that supports your project instead of one with so much opposition?

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August 2005

It is common for any industrial facility to encounter public opposition in an area

that has historically been agricultural. Through honest and transparent

communication, we believe that the community will accept Hazco based on the

sound design, construction and operation of the proposed facility.

37. A flyer is being distributed by the Friends of Lamont County who are opposed to your project. What’s your reaction to the things being said in the flyer?

It’s not appropriate for us to comment on what others are saying or doing. Hazco

realizes that a flyer and petition are being distributed within the community. I

would suggest you contact the people distributing the flyer for further information.

38. The flyer asks “Will our quality of life survive Hazco’s Sulphur Storage facility. Its’ obvious some people are very concerned about your proposal. What do you say to these folks?

Environmental protection and safety is a top priority to Hazco. Hazco maintains

that the quality of life will not be affected due to facility design and sound

operation of the facility which will ensure no impact to human health or the

surrounding environment.

39. The flyer maintains that the storage facility is a waste of prime industrial land with very little tax return. What’s your response to that?

Hazco maintains that the proposed facility is a good fit for the property due to the

surrounding area.

40. What impact do you think your facility will have on attracting other industrial developments in the community?

Hazco can not comment on the intent of other industries moving to Lamont

County.

11

August 2005

41. The residents say this is just the tip of the iceberg and that if this project is approved than Lamont County will become the dumping ground for Alberta sulphur. What’s your response to those concerns?

The production of sulphur within the oil and gas industry is reality. Facilities such

as the one proposed here are sound methods of processing the sulphur into a

saleable product such as fertilizer.

42. Why was a similar proposal from Hazco rejected in Sturgeon County and Thornhild 2002?

The proposed projects in Sturgeon and Thornhild Counties were not rejected, the

proposals were withdrawn by Hazco. The facilities were different than the facility

proposed here as the Sturgeon and Thornhild projects proposed sub-surface

long term storage (i.e. burial) as opposed to short term storage. The proposed

projects also encountered difficulty securing customers.

12

Alberta Sulphur Terminals Ltd. Bruderheim, Alberta Area

Alberta Sulphur Terminals Ltd., a division of Hazco Environmental Services (“HAZCO”), is proposing to build a Sulphur Management Facility 2.2 kilometers east of Bruderheim, Alberta, just north of Highway 15. The facility would receive liquid sulphur and form the sulphur (using a process called Rotoforming) into a pastille product that would then be shipped off site to market. There would be a portion of the site dedi-cated to temporary emergency storage, either as formed product or poured to block, in the event that down-stream logistics fail (rail, port, and shipping). • Lamont County is an ideal choice for the facility due to access to rail, road and infrastructure, site hydrogeology as well as availability of a skilled labour pool. • The facility design, environmental monitoring programs and safe operation of the facility will work to-gether to ensure that there is no impact to human health, public safety or the surrounding environment. We believe that to be accepted into a community and become a good neighbour, our communication lines need to be transparent and continue much further than just the application process.

Local Benefits • HAZCO is committed to supporting the local economy both in construction and operations of the facil-ity. • Construction of the facility will create between 40-50 positions. • Long-term facility operations are expected to create up to 20 full time positions. Create a larger base to grow industry in the area. Schedule • Application was made to Alberta Environment for approval to construct and operate the proposed facil-ity in July 2005. Application currently under review. • Application was made to Lamont County for a Development Permit in August 2005. Application cur-rently under review. Construction activities would commence once all approvals and permits are in place.

Information Package Project Questionnaire—Revised

Current Project Information Downloads Project Information Package Project Question & Answer Package Site Plot Plan Facility Plot Plan

Project Contacts Paul Kaethler (403) 231-8438 [email protected] Corey Higham (403) 231-8425 [email protected]

http://www.hazcoenv.com/InformationPackage-August2005_000.htm

http://www.hazcoenv.com/InformationPackage-August20052.htm

HAZCO Environmental Services Ltd., a division of CCS Income Trust, has submitted an application to Alberta Environment for approval to construct and operate a Sulphur Management Facility to be located at Section 35-055-20 W4M approximately 2.2 km east of Bruderheim, Alberta, just north of Highway 15. The following information is intended as a brief overview of the project in an effort to maintain effective communications with stakeholders.

The proposed project will be funded and completed by the HAZCO division of CCS Income Trust. HAZCO is an industry leader providing a wide-range of specialized services including: Sulphur Services, Facility Operation, Site Remediation, Decommissioning, Waste Services, Environmental Construction, Environmental Technologies, Emergency Response and Other Specialty Services. More information is available at our web site www.hazco.com or the CCS Income Trust web site at www.ccsincometrust.com.

Sulphur, a by-product of the oil and gas industry, is primarily used in the production of fertilizer world wide. Increased activity in the heavy oil sector resulting in more produced sulphur and combined with an increase in demand for sulphur exports worldwide, there is a shortage of sulphur forming capacity in Alberta. The proposed project includes facilities for sulphur forming and sulphur pastille storage. Molten sulphur will be received by pipeline, rail tank car or truck. The sulphur will be stored in insulated, heated tanks before being pumped to the forming process. Alberta Sulphur Terminals plans to use an environmental friendly technology, provided by Sandvik Process Systems, to process the liquid sulphur into a formed product (i.e. pastilles) suitable for export. The product will be stored on engineered storage pads and loaded onto rail car unit trains on a regular basis. As Hazco proceeded with its public consultation program, it has become evident that there is a great deal opposition and confusion with respect to the emergency sulphur staging area (i.e. sulphur block) as originally published in Hazco’s project information documents. After consultation with Hazco’s prospective clients, the decision was made to remove the emergency sulphur staging area from the proposed facility application. This action was taken to clarify the main objective of the project which is to provide a long term service/manufacturing facility for the oil and gas industry facilitating the export of sulphur from Canada to the world.

Subject to regulatory approvals, construction will commence in the spring of 2006 and will take approximately 6 to 7 months to complete. Facility operations will commence immediately after the facility has been constructed with a target date of November 2006.

Revised: October 21, 2005 Page 1 of 3

ALBERTA SULPHUR TERMINALS BRUDERHEIM, ALBERTA

PROJECT OVERVIEW

CORPORATE OVERVIEW

PROJECT SCHEDULE



HAZCO is committed to supporting the local economy both in construction and operations of the facility. Long-term facility operations are expected to create 21 full time positions initially.

HAZCO plans to utilize the latest technology to control emissions and minimize its impact on the surrounding environment.

AIR QUALITY Odours at the site will be minimal as all of the sulphur received on site is degassed to less than 10 parts per million H2S. With the facility located at the center of property and with a minimum 600 meter setback from the surrounding properties, there will be essentially no odours from the proposed site. Air quality and dust impacts will be addressed through air monitoring programs and a soil monitoring program. The monitoring programs will be required as part of an Alberta Environment Environmental Protection and Enhancement Act Approval. The approval will stipulate acceptable air monitoring parameters and associated criteria that will ensure no adverse effect on human health or the surrounding environment.

SOIL QUALITY Facility operations are not expected to adversely affect local soil quality. Alberta Environment and Alberta Energy and Utility requirements have been incorporated into the design and will be strictly adhered to. An Alberta Environment approved soil monitoring program will also be completed and reviewed on a yearly basis.

TRAFFIC At the busiest times, HAZCO anticipates approximately one to two additional trains per week as well as approximately 40 trucks per day. HAZCO has completed a Traffic Impact Assessment which has indicated that upgrades to the Highway 15 intersection are required to maintain a safe access. No improvements will be necessary for the Highway 45 intersection. The Traffic Impact Assessment is currently under review by Alberta Transportation.

GROUNDWATER QUALITY Groundwater monitoring wells will be installed in accordance with Alberta Environment guidelines and will be used to sample groundwater each spring and fall. The groundwater monitoring program will be designed and performed by an independent professional hydrogeologist. Collected samples will be sent to an offsite, third party laboratory to determine the groundwater quality beneath the site for the life of the project. This will provide early indication of any impacts on local geology and/or hydrogeology in the unlikely event they may occur. The favourable site conditions (silt clay overburden with low hydraulic conductivity) and the monitoring program will be further complimented by the proposed facility design that makes use of double liner systems, and run-off control systems as well as sound facility operation.

SURFACE WATER QUALITY All precipitation that falls on the active working area of the facility will be collected in a lined ditching system and directed to a lined surface water collection pond. At this time, HAZCO has no plans to discharge any of the surface water run-off collected in the surface water pond as the pond will be used as a source of water for process make-up water requirements and for the fire suppression system. In the event where water from the surface water pond needs to be released due to capacity restraints (likely due to excessive precipitation events), the water will be sampled and analyzed to confirm the surface water


ECONOMIC IMPACT

ENVIRONMENTAL CONTROLS

pond water quality meets applicable surface water quality guidelines. If the water does not meet the applicable criteria the water will then be treated and re-tested.

NOISE LEVELS Hazco is in the initial stages of completing a Noise Impact Assessment (NIA). The NIA will be completed prior to facility start-up and, if approved, after start-up of operations. Any noise impact beyond established acceptable levels will require attention to mitigate noise impacts.

FACILITY SAFETY The proposed facility’s operation plans, Occupational Health and Safety policy and Emergency Response plans will be reviewed and filed with all local emergency response officials and organizations, Alberta Environment and the local municipal governments.

The HAZCO Alberta Sulphur Terminals project team is committed to working with the community throughout the development of this project. Should you wish to obtain additional information regarding this project, please contact: Paul Kaethler HAZCO Environmental Services Ltd. 2400, 530 – 8 Avenue S.W. Calgary, AB T2P 3S8 Direct: (403) 231-8438 Toll Free: (888) 842-7833 Email: [email protected] Corey Higham HAZCO Environmental Services Ltd. 2400, 530 – 8 Avenue S.W. Calgary, AB T2P 3S8 Direct: (403) 231-8425 Toll Free: (888) 842-7833 Email: [email protected]


HAZCO CONTACTS

Alberta Sulphur Terminals Ltd. Bruderheim, Alberta Area

Alberta Sulphur Terminals Ltd., a division of Hazco Environmental Services (“HAZCO”), is proposing to build a Sulphur Forming and Pastille Storage Facilty 2.2 kilometers east of Bruderheim, Alberta, just north of Highway 15. The facility would receive liquid sulphur and form the sulphur (using a process called Rotoforming) into a pastille product that would then be shipped off site to export markets. There would be a portion of the site dedicated to formed product.

• Lamont County is an ideal choice for the facility due to access to rail, road and infrastructure, site hydrogeology as well as availability of a skilled labour pool.

• The facility design, environmental monitoring programs and safe operation of the facility will work together to ensure that there is no impact to human health, public safety or the surrounding environment.

• We believe that to be accepted into a community and become a good neighbour, our communication lines need to be transparent and continue much further than just the application process.

Local Benefits

• HAZCO is committed to supporting the local economy both in construction and operations of the facility.

• Construction of the facility will create between 40-50 positions. • Initial facility operations are expected to create 21 full time positions. • Create a larger base to grow industry in the area.

Schedule

• A revised application was made to Alberta Environment for approval to construct and operate the proposed facility in October 2005. The application was revised to incorporate removal of the emergency inventory staging area (i.e. sulphur block). The EIS area was removed in response to stakeholder concerns. The revised application is currently under review.

• Application was made to Lamont County for a Development Permit in August 2005. Lamont County has requested further information. Hazco has retained independent third party consultants to satisfy the County’s request..

• Construction activities would commence once all approvals and permits are in place.

For more information about the project, please visit the HAZCO website at www.hazco.com and follow the link to the Alberta Sulphur Terminals information page.

Revised: October 21, 2005



APPENDIX E

OFFER TO PURCHASE AND LAND TITLE INFORMATION


APPENDIX E-1

OFFER TO PURCHASE AND LAND TITLES

sulphur handling terminal alberta environment 28102005

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