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Content Copy Of Original Ministry of the Environment and Climate Change Ministère de l’Environnement et de l’Action en matière de changement climatique ENVIRONMENTAL COMPLIANCE APPROVAL NUMBER 7556-A67PFG Issue Date: March 1, 2018 Eco Site Assessors Inc. 120 County Road 64, Box 3024 Brighton, Ontario K0K 1H0 Site Location: Napanee Waste Water Facility Part of Lot 24, Concession 3 Town of Greater Napanee, County of Lennox and Addington You have applied under section 20.2 of Part II.1 of the Environmental Protection Act , R.S.O. 1990, c. E. 19 (Environmental Protection Act) for approval of: a 31.72 hectare Waste Disposal Site consisting of: one (1) 2,220 m 2 receiving and processing building; three (3) 37.9 m 3 receiving pits; two (2) 37.9 m 3 solidification pits; three (3) rectangular aqueous waste storage tanks, identified as sources T-01 through T-03, each 7.01 m long, 2.21 m tall and 2.44 m wide; one (1) rectangular oil storage tank, identified as source T-04, 7.01 m long, 2.21 m tall and 2.44 m wide; one (1) rectangular emulsion storage tank, identified as source T-05, 7.01 m long, 2.21 m tall and 2.44 m wide; one (1) rectangular aqueous salts storage tank, identified as source T-06, 7.01 m long, 2.21 m tall and 2.44 m wide; two (2) 16,125 m 3 storage lagoons; one (1) 43 m 3 concrete secondary containment pit for spill containment; two (2) natural gas fired boilers, identified as sources CB1 and CB2, each with a heat input rating of 300,700 kilojoules per hour; twelve (12) photo-catalytic oxidation systems serving the waste water treatment process, each containing four (4) ultra-violet bulbs and four (4) catalytic reaction modules and discharging indoors at a maximum volumetric flow rate of 0.24 cubic

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Content Copy Of Original Ministry of the Environment and Climate Change

Ministère de l’Environnement et de l’Action en matière de changement climatique

ENVIRONMENTAL COMPLIANCE APPROVALNUMBER 7556-A67PFG

Issue Date: March 1, 2018

Eco Site Assessors Inc.120 County Road 64, Box 3024Brighton, OntarioK0K 1H0

Site Location:Napanee Waste Water FacilityPart of Lot 24, Concession 3Town of Greater Napanee, County of Lennox and Addington

You have applied under section 20.2 of Part II.1 of the Environmental Protection Act , R.S.O. 1990, c. E. 19 (Environmental Protection Act) for approval of:

a 31.72 hectare Waste Disposal Site consisting of:

one (1) 2,220 m2 receiving and processing building;•

three (3) 37.9 m3 receiving pits;•

two (2) 37.9 m3 solidification pits;•

three (3) rectangular aqueous waste storage tanks, identified as sources T-01 through T-03, each 7.01 m long, 2.21 m tall and 2.44 m wide;

one (1) rectangular oil storage tank, identified as source T-04, 7.01 m long, 2.21 m tall and 2.44 m wide;

one (1) rectangular emulsion storage tank, identified as source T-05, 7.01 m long, 2.21 m tall and 2.44 m wide;

one (1) rectangular aqueous salts storage tank, identified as source T-06, 7.01 m long, 2.21 m tall and 2.44 m wide;

two (2) 16,125 m3 storage lagoons;•

one (1) 43 m3 concrete secondary containment pit for spill containment;•

two (2) natural gas fired boilers, identified as sources CB1 and CB2, each with a heat input rating of 300,700 kilojoules per hour;

twelve (12) photo-catalytic oxidation systems serving the waste water treatment process, each containing four (4) ultra-violet bulbs and four (4) catalytic reaction modules and discharging indoors at a maximum volumetric flow rate of 0.24 cubic

metre per second;

one (1) geo-membrane lined stormwater management wetland pond, located at the north east side of the property, with rip-rap spillway wide inlet into a 17 metre long forebay and a main cell, with a combined peak stormwater storage volume of 2,543 m3 including 1673 m3 of overall permanent volume at 1.2 m depth in the forebay and 0.9 m depth within the pond, and 50 m3 of extended detention volume, to hold and attenuate storm water of 2 to 100 year event flow for a minimum of 24 hours prior to discharge, outletting through a control structure to a municipal roadside ditch;

one (1) outlet control structure comprising of a valve chamber with a 150 mm inlet pipe, complete with a flow control valve and 150mm outlet pipe installed at an invert elevation of 124.26 m, discharging through a concrete headwall by gravity to a municipal roadside ditch extending north from Goodyear Road, designed to discharge in a batch-wise mode with a maximum of 16 times discharge per year to the roadside ditch; and

all other controls and appurtenances essential for the proper operation of the aforementioned Equipment and Works, all in accordance with the supporting documents listed in Schedule 'A'.

to be used for the receipt and processing of the following types of waste:the processing of non-hazardous liquid industrial waste and hazardous liquid waste limited to waste classes 131, 132, 133, 141, 142, 143, 145, 146, 148, 149, 150, 211, 212, 213, 221, 222, 241, 242, 251, 252, 253, 254, 261, 263, 265, 266, 269 and 270 as described in the Ministry's New Ontario Waste Classes, dated January 1986 or as amended.Note: Use of the site for any other type of waste is not approved under this environmental compliance approval, and requires obtaining a separate approval amending this environmental compliance approval.For the purpose of this environmental compliance approval, the following definitions apply:" Approval" means this Environmental Compliance Approval, including the application and supporting documentation listed in Schedule "A";

"Company" means Eco Site Assessors Inc., that is responsible for the construction or operation of the Facility and includes any successors and assigns;

“Director” means any Ministry employee appointed in writing by the Minister pursuant to section 5 of the EPA as a Director for the purposes of Part II.1 of the EPA;

"District Manager" means the District Manager of the appropriate local district office of the Ministry, where the Facility is geographically located;

"EPA" means the Environmental Protection Act, R.S.O. 1990, c.E.19, as amended;

"Equipment" means the equipment described in the Company's application, this Approval and in the supporting documentation submitted with the application, to the extent approved by this Approval;

"Equipment Manual" means a document, or a set of documents, that provide written instructions to staff of the Company;

"Facility" means the entire 31.72 hectare property located on Part of Lot 24, Concession 3, Town of Greater Napanee where the Equipment and Works are located, and waste management activities take place;

"Guidance Manual" refers to the publication entitled "Registration Guidance Manual for Generators of Liquid Industrial and Hazardous Waste", as amended December 2009, or the most recent revision;

"Ministry" means the ministry of the government of Ontario responsible for the EPA and includes all officials, employees or other persons acting on its behalf;

"Ontario Regulation 675/98" means Ontario Regulation 675/98: Classification and Exemption of Spills and Reporting of Discharges, made under the EPA;

"OWRA" means Ontario Water Resources Act, R.S.O. 1990, c. O.40, as amended;

“Operator” means any person, other than the Company's employees, authorized by the Company as having the charge, management or control of any aspect of the Facility;

“PA” means the Pesticides Act, R.S.O. 1990, c. P-11, as amended from time to time;

"Provincial Officer" means any person designated in writing by the Minister as a provincial officer pursuant to section 5 of the OWRA or section 5 of the EPA or section 17 of PA;

"Publication NPC-232" means the Ministry Publication NPC-232, "Sound Level Limits for Stationary Sources in Class 3 Areas (Rural)", October, 1995 as amended.

"Publication NPC-300" means the Ministry Publication NPC-300, “Environmental Noise Guideline, Stationary and Transportation Sources – Approval and Planning, Publication NPC-300”, August 2013, as amended.;

“Regulation 347" means Regulation 347, R.R.O. 1990, General - Waste Management, made under the EPA, as amended from time to time;

"trained personnel” means employees that have been trained, through instruction and/or practice, in accordance with Conditions 7.1 of this Approval;

"wet soil" means soil or sludge, that does not pass the slump test as described in Schedule 9 of Regulation 347, derived from excavations; and

"Works" means the sewage works for the purpose of stormwater management as described in the Company's application, and this Approval.

You are hereby notified that this environmental compliance approval is issued to you subject to the terms and conditions outlined below:TERMS AND CONDITIONSPART 1 - GENERAL

Compliance

1.1 The Company shall ensure compliance with all the conditions of this Approval and shall ensure that any person authorized to carry out work on, or operate any aspect of, the Facility is notified of this Approval and the conditions herein, and shall take all reasonable measures to ensure any such person complies with the same.

1.2 Any person authorized to carry out work on or operate any aspect of the Facility shall comply with the conditions of this Approval.

1.3 The Facility shall be operated and maintained at all times including the management and disposal of all waste in accordance with the EPA, Regulation 347 and the conditions of this Approval. At no time shall the discharge of a contaminant that causes or is likely to cause an adverse effect be permitted.

In Accordance With

1.4 Except as otherwise provided for in this Approval, the Facility shall be designed, developed, built, operated, modified and maintained in accordance with the application for this Approval dated May 29, 2015, the Design and Operations Report as updated from time to time, and the other supporting documentation listed in Schedule “A”.

Interpretation

1.5 Where there is a conflict between a provision of any document, including the application, referred to in this Approval, and the conditions of this Approval, the conditions in this Approval shall take precedence.

1.6 Where there is a conflict between the application and a provision in any documents listed in Schedule "A", the application shall take precedence, unless it is clear that the

purpose of the document was to amend the application and that the Ministry approved the amendment.

1.7 Where there is a conflict between any two documents listed in Schedule "A", other than the application, the document bearing the most recent date shall take precedence.

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

Other Legal Obligations

1.9 The issuance of, and compliance with, this Approval does not:

(1) relieve any person of any obligation to comply with any provision of any applicable statute, regulation or other legal requirement including, but not limited to:

(a) obtaining site plan approval from the local municipal authority;

(b) obtaining all necessary building permits from the local municipal authority Building Services Division;

(c) obtaining approval from the Chief Fire Prevention Officer, local municipal authority;

(d) obtaining all necessary approvals from the Ministry of Natural Resources and Forestry; or

(2) limit in any way the authority of the Ministry to require certain steps be taken or to require the Company to furnish any further information related to compliance with this Approval.

Adverse Effect

1.10 The Company shall take steps to minimize and ameliorate any adverse effect on the natural environment or impairment of water quality resulting from the Facility, including such accelerated or additional monitoring as may be necessary to determine the nature and extent of the effect or impairment.

1.11 Despite a Company, Operator or any other person fulfilling any obligations imposed by this Approval, the Company, Operator or any other person remains responsible for any contravention of any other condition of this Approval or any applicable statute, regulation, or other legal requirement resulting from any act or omission that caused the adverse effect to the natural environment or impairment of

water quality.

Change of Ownership

1.12 The Company shall notify the Director in writing, and forward a copy of the notification to the District Manager, within thirty (30) days of the occurrence of any changes:

(1) in the ownership of the Facility;

(2) in the appointment of, or a change of, an Operator;

(3) in the address of the Company or Operator;

(4) the partners, where the Company is or at any time becomes a partnership and a copy of the most recent declaration filed under the Business Names Act, R.S.O. 1990, c. B-17 shall be included in the notification; and

(5) in the name of the corporation where the Company is or at any time becomes a corporation, other than a municipal corporation, and a copy of the most current information filed under the Corporations Information Act, R.S.O. 1990, c. C-39 shall be included in the notification.

1.13 No portion of this Facility shall be transferred or encumbered prior to or after closing of the Facility unless the Director is notified in advance and sufficient financial assurance is deposited with the Ministry to ensure that these conditions will be carried out.

1.14 In the event of any change in ownership of the Facility, other than change to a successor municipality, the Company shall notify the successor of and provide the successor with a copy of this Approval, and the Company shall provide a copy of the notification to the District Manager and the Director.

Inspections

1.15 No person shall hinder or obstruct a Provincial Officer from carrying out any and all inspections authorized by the OWRA, the EPA, or the PA, of any place to which this Approval relates, and without limiting the foregoing:

(1) to enter upon the premises where the approved works are located, or the location where the records required by the conditions of this Approval are kept;

(2) to have access to, inspect, and copy any records required to be kept by the conditions of this Approval;

(3) to inspect the Facility, related equipment and appurtenances;

(4) to inspect the practices, procedures, or operations required by the conditions of this Approval; and

(5) to sample and monitor for the purposes of assessing compliance with the terms and conditions of this Approval or the EPA, the OWRA or the PA.

Information and Record Retention

1.16 Any information requested, by the Ministry, concerning the Facility and its operation under this Approval, including but not limited to any records required to be kept by this Approval shall be provided to the Ministry, upon request, in a timely manner.

1.17 The receipt of any information by the Ministry or the failure of the Ministry to prosecute any person or to require any person to take any action, under this Approval or under any statute, regulation or other legal requirement, in relation to the information, shall not be construed as:

(1) an approval, waiver, or justification by the Ministry of any act or omission of any person that contravenes any term or condition of this Approval or any statute, regulation or other legal requirement; or

(2) acceptance by the Ministry of the information’s completeness or accuracy.

1.18 Any information relating to this Approval and contained in Ministry files may be made available to the public in accordance with the provisions of the Freedom of Information and Protection of Privacy Act, R.S.O. 1990, C. F-31.

PART 2 - FINANCIAL ASSURANCE

Financial Assurance

2.1 (1) Within twenty (20) days of the issuance of the Approval, the Company shall submit to the Director, financial assurance as defined in Section 131 of the EPA in the amount of $1000.00.

(2) At least thirty (30) days prior to the commissioning of the Facility, the Company shall submit to the Director, additional funds to increase the financial assurance amount to $200,000.00.

(3) At least twenty (20) days prior to reaching a storage capacity of 8,000 tonnes of total waste, the Company shall submit additional funds to the Director to increase the

amount of financial assurance to $375,000.00.

(4) At least twenty (20) days prior to reaching a storage capacity of 16,000 tonnes of total waste, the Company shall submit additional funds to the Director to increase the amount of financial assurance to $750,000.00.

(5) At least twenty (20) days prior to reaching a storage capacity of 24,000 tonnes of total waste, the Company shall submit additional funds to the Director to increase the amount of financial assurance to $1,125,000.00.

(6) At least twenty (20) days prior to reaching the maximum storage capacities as described in Condition 3.7, the Company shall submit additional funds to the Director to increase the financial assurance to $1,498,940.00.

(7) The financial assurance referred to in Condition 2.1 (1) through (6) shall be in a form acceptable to the Director and shall provide sufficient funds for clean-up, monitoring, analysis, transportation, and disposal of all quantities of waste permitted to be on-site at any one time.

(8) On a monthly basis, the Company shall submit to the District Manager, written notification of construction progress and the estimated date for the commissioning of the Facility. Once the Facility has been commissioned, the Company shall, on a quarterly basis, submit to the District Manager, written confirmation of the amount of waste stored at the Facility an the estimated date when the next financial assurance trigger level will be reached. Notification shall cease once the Company has complied with Condition 2.1 (6) (i.e. reached full capacity).

(9) The amount of financial assurance is subject to review at any time by the Director and may be amended at his/her discretion.

(10) If any financial assurance is scheduled to expire, or notice is received indicating financial assurance will not be renewed, and satisfactory methods have not been made to replace the financial assurance at least sixty (60) days before the financial assurance terminates, the Company shall forthwith replace the financial assurance with cash.

PART 3 - FACILITY OPERATIONS

Service Area and Hours of Operations.

3.1 (1) Only waste generated within the Province of Ontario shall be accepted at the Facility for processing.

(2) Waste may be received and/or transferred from the Facility from 6:00 a.m. to 8:00

p.m. Monday through Friday and 6:00 a.m. to 6:00 p.m. Saturday.

(3) Notwithstanding Condition 3.1(2), waste may be received at any time to accommodate emergency situations (e.g. from spill cleanup activities) provided that the Ministry's Spills Action Centre has been notified.

(4) Notwithstanding Condition 3.1(2), the hours of waste receipt may be extended to accommodate seasonal or unusual quantities of waste, for a period not exceeding 30 days, with prior written approval of the District Manager.

(5) The Facility is approved to conduct waste processing activities 24 hours per day, seven (7) days per week.

Signage and Security

3.2 The Company shall install a sign at the main entrance/exit to the Facility on which is legibly displayed the following information:

(1) the name of the Facility and Company;

(2) the number of this Approval;

(3) the hours when the Facility is open for waste receipt / transfer;

(4) a twenty-four (24) hour telephone number that can be used to reach the Company in the event of a complaint or an emergency.

3.3 The Company shall operate and maintain the Facility in a secure manner. During non-operating hours, the Facility entrances and exits shall be locked, the Facility shall be secured against access by unauthorized persons, and the Facility shall be monitored for intrusions, fire incidents and spills.

Approved Waste Types

3.4 The Company shall only accept the following categories of waste at the Facility:

(1) liquid industrial waste as defined in Regulation 347;

(2) liquid hazardous waste limited to Waste Class Nos. 131, 132, 133, 141, 142, 143, 145, 146, 148, 149, 150, 211, 212, 213, 221, 222, 241, 242, 251, 252, 253, 254, 261, 262, 263, 265, 266, 269 and 270 as described in the Ministry's New Ontario Waste Classes dated January 1986; and

(3) wet soil.

3.5 (1) The Company shall ensure all incoming loads are inspected by trained personnel to ensure only waste approved under Condition 3.4 is accepted at this Facility.

(2) If any unapproved waste is discovered on-site, that waste shall be segregated and disposed of promptly in accordance with the EPA and Regulation 347, and the District Manager shall be notified forthwith.

(3) In the event that a manifest correction is required for an incoming waste load, the Company shall follow the procedure described in s.4.6.3 of the Guidance Manual.

Approved Waste Quantities

3.6 The amount of waste received at the Facility shall not exceed the following:

(1) 75,000 L of hazardous liquid waste per day;

(2) 800,000 L of liquid industrial waste per day; and

(3) 75,000 L of wet soil per day.

3.7 (1) The amount of waste present at the Facility at any one time shall not exceed the following:

80,000 L of hazardous liquid waste;a.

32,826,000 L of liquid industrial waste and including treated water awaiting discharge;

b.

100,000 L of wet soil (includes wet soil undergoing processing);c.

135 tonnes of hazardous solid waste;d.

270 tonnes of non-hazardous solid waste.e.

(2) Notwithstanding Condition 3.7 (1), the amount of waste present at the Facility shall not conform to and not exceed the limits corresponding to the financial assurance schedule presented in Condition 2.1.

3.8 In the event that waste cannot be transferred from the Facility, upon reaching maximum capacity as approved in Condition 3.7, the Company shall cease accepting any additional waste and ensure that the maximum storage capacities approved in Condition 3.7 are not exceeded.

Waste Storage

3.9 The Company shall ensure that waste is stored in accordance with the documents listed in Schedule "A" in addition to meeting the following requirements:

(1) all activities related to the receiving, processing, storage and other handling of waste are conducted indoors, with the exception of leachate which may be treated and stored in the outdoor polishing lagoons;

(2) all liquid industrial and hazardous waste on-site shall be stored in accordance with the Ministry's "Guidelines for Environmental Protection Measures at Chemical and Waste Storage Facilities" dated May 2007, as amended from time to time.

(3) all waste on-site is managed, stored and shipped from the Facility in a manner that prevents the release of contaminants to the natural environment and minimizes the risk of fires, explosions and other hazards;

3.10 Further to Condition 3.9, the Company shall ensure that the following minimum storage requirements are adhered to;

(1) roll off bins used for dewatering of excavated soil, sludge from the receiving pits, or other wet waste shall be kept indoors;

(2) fly ash, clay absorbents, crushed firebrick, lime, hydrophilic absorbents and like material used for the solidification of sludge waste shall be stored indoors. Sawdust used for solidification may be stored outdoors in a manner which minimizes generation of dust and contact with precipitation;

(3) reagents used in the treatment of waste shall be stored indoors, in clearly identified storage areas/vessels, segregated from waste;

(4) drums and totes containing waste shall be stacked on racks up to four racks high. Drums and totes containing waste liquids shall be stored on lower racks whenever possible; and

(5) treated water awaiting discharge shall be stored in above ground plastic storage tanks within the building.

Processing

3.11 The Facility is approved to conduct the following waste processing activities only:

(1) the receipt, storage and transfer of waste listed in Condition 3.4 above;

(2) solidification;

(3) dewatering;

(4) aeration;

(5) pH adjustment

(6) solids removal (settling, screening, filtration and/or ultra-filtration);

(7) emulsion agitation;

(8) liquid density separation;

(9) dissolved air flotation;

(10) membrane separation;

(11) carbon filtration;

(12) ozone oxidation;

(13) drum cutting and/or crushing;

(14) container washing;

(15) bulking; and

(16) blending of compatible waste types for use as waste derived fuel.

3.12 Any waste that does not meet the slump test described in Schedule 9 of Regulation 347 shall be dewatered prior to being solidified in order to minimize the amount of solidification agent(s) required, unless dewatering of the waste will not reduce either:

(1) the amount of solidification agent(s) required; or

(2) the amount of waste to be solidified.

Quality Control

3.13 (1) The Company shall ensure that all incoming and outgoing waste is inspected, tested and characterized by trained personnel prior to being received, processed, transferred and shipped to ensure wastes are being managed and disposed of in accordance with the EPA and Regulation 347.

(2) All testing and characterization of waste shall be carried out in accordance with the criteria and testing methods described in Guidance Manual. All testing and characterization shall use a representative sample for analysis by an accredited laboratory.

(3) The Company shall maintain a waste profile for each waste stream received at the Facility as described in Item 17 of Schedule "A".

Land Disposal Restriction (LDR) Requirements

3.14 For any hazardous waste destined for land disposal, including hazardous residual waste generated during processing activities, the Company shall comply with the LDR requirements outlined in Regulation 347 and the Land Disposal Restrictions (LDR) Handbook", dated December 2009, or the most recent revision, including the following requirements:

(1) conducting analysis for all relevant regulated constituents;

(2) ensuring that waste will not be land disposed unless it meets the treatment/standard requirement;

(3) where waste not subject to LDR requirements is mixed with waste that is subject to LDR requirements, the resulting mixed or bulked waste all becomes subject to LDR and the notification form required by Section 84 of Regulation 347 must be amended to identify this processing, and must be forwarded to the next receiver of the waste;

(4) clearly labelling containers to indicate that they contain waste subject to LDR requirements;

(5) providing a notification form, which complies with Section 84 of Regulation 347, to the receiver to whom the Company is transferring the waste;

(6) sending the notification form required by Condition 3.14 (5) in advance of, or with, the first transfer of waste. Notification forms only need to be resent if the physical or chemical properties of the waste has change, at which time a revised notification form must be sent in advance of, or with, the first transfer of the changed waste;

(7) requesting generators of LDR waste to notify the Company of any changes or process modifications which may affect the waste class and/or waste characteristics.

Sanitary Sewer Discharge

3.15 The Company shall not discharge wastewater generated as part of on-site waste

management operations to the local sanitary sewer unless:

(1) the Company obtains a valid Discharge Agreement with the Town of Greater Napanee; and

(2) the Company provides a copy of the signed Discharge Agreement to the District Manager.

3.16 In the absence of a valid Discharge Agreement with the Town of Greater Napanee, the Company shall transfer all wastewater generated as part of on-site waste management operations to a waste disposal site or approved sewage works (other than a sewage works discharging to the Bay of Quinte) permitted to accept and treat that wastewater stream.

Nuisance Control

3.17 (1) The Company shall operate and maintain the Facility such that dust, odours, vectors, litter, vibration and noise do not create a nuisance or an adverse effect.

(2) Prior to accepting waste at the Facility, the Company shall construct and maintain a landscaped berm along the south and west sides of the Facility to reduce noise and provide for a visual barrier.

(3) The Company shall ensure that there is no queuing or parking of trucks waiting to enter the Facility on public roadways.

Noise

3.18 The Company shall, at all times, ensure that the noise emissions from the Facility comply with the limits set out in Ministry Publication NPC-300 or Ministry Publication NPC-232, as applicable.

Complaints

3.19 (1) The Company shall notify the District Manager, in writing, of each environmental complaint within two (2) business days of the complaint. The notification shall include:

a. a description of the nature of the complaint;

b. the time and date of the incident to which the complaint relates;

c. weather conditions at the time of the incident to which the complaint relates;

d. Facility operations being carried out at the time incident to which the complaint relates; and

e. the name, address and the telephone number of the complainant if the complainant will provide this information.

(2) The Company shall initiate appropriate steps to determine all possible causes of the complaint, proceed to take the necessary actions to eliminate the cause of the complaint and forward a formal reply to the complainant.

(3) The Company shall provide the District Manager with a written report within one (1) week of the complaint date, listing the actions taken to resolve the complaint and the remedial measures, and managerial or operational changes to be put in place to reasonably avoid the recurrence of similar incidents.

PART 4 - STORMWATER MANAGEMENT

Works Construction and Operation

4.1 (1) No waste shall be received at the Facility until such time as the Works, as described in Item 16 of Schedule "A", are constructed and operational; and

(2) One (1) week prior to the start up of the operation of the Works, the Company shall notify the District Manager, in writing, of the pending start up date.

4.2 The Company shall make all necessary investigations, take all necessary steps and obtain all necessary approvals so as to ensure that the physical structure, siting and operations of the Works do not constitute a safety or health hazard to the general public.

4.3 The Company shall ensure that the design minimum liquid retention volume is maintained in the Works at all times, except when maintenance is required.

4.4 (1) The Company shall install and maintain temporary sediment and erosion control measures during construction and conduct inspections once every two (2) weeks and after each significant storm event.

(2) The inspections and maintenance of the temporary sediment and erosion control measures shall continue until they are no longer required and at which time they shall be removed and all disturbed areas reinstated properly.

(3) The Company shall maintain records of inspections and maintenance which shall be made available for inspection by the Ministry, upon request. The record shall include

the name of the inspector, date of inspection, and the remedial measures. if any, undertaken to maintain the temporary sediment and erosion control measures.

Effluent Limits

4.5 The Company shall design, construct, operate and maintain the Works such that the concentrations of the Stormwater Effluent parameters listed in the Table 1, included in Schedule B are met.

4.6 For the purposes of determining compliance with and enforcing Condition 4.5:

(1) non-compliance with respect to a Concentration Limit is deemed to have occurred when any single sample analyzed for a parameter named in Column 1 of Table 1 is greater than the corresponding concentration limit set out in Column 2 of Table 1; and

(2) non-compliance with respect to pH is deemed to have occurred when any single measurement is outside of the indicated range.

Stormwater Discharge

4.7 The Company may discharge the contents of the Works to the roadside ditch along the entrance to the site which drains to Municipal roadside ditch on County Road 64 up to sixteen (16) times a year at a maximum flow rate of 45 litres per second and ensuring that the duration of discharge does not exceed four (4) days.

4.8 No discharge shall be permitted from the Works if oil or petrochemicals are present in the water as detected by a visible film, sheen or discolouration on the surface, or by odour.

4.9 (1) Prior to undertaking any discharge from the Works, the Company shall collect a representative composite sample, comprising of 4 grab samples of equal volume, collected from different locations of the Works on the same day as the planned effluent discharge event, and have the sample analyzed for the parameters listed in the Table 2 included in Schedule B; and

(2) The results of the analysis shall be submitted to the District Manager, and upon written receipt of the District Manager's permission to do so, discharge the effluent; and

(3) The effluent monitoring program specified in Condition 4.12 (1) may be modified by the District Manager after one (1) year of monitoring in accordance with the Condition, upon written request.

4.10 (1) In the event that pre-discharge sampling identifies elevated levels of TSS, the

discharge activity will be delayed to provide more retention time in accordance with the contingency measures outlined in Item 16 of Schedule "A".

(2) The pre-discharge sampling shall be repeated until test results indicate that the effluent limits included in Table 1 of Schedule B have been met.

4.11 Notwithstanding Condition 4.10, in case of an emergency or during a situation in which water levels and/or precipitation events do not allow for further delay, a pump equipped with a Sampson filter with a 1 to 5 Micron filter bag will be utilized for the duration of the discharge to remove suspended solids to an acceptable limit of less than 20 mg/L, in accordance with contingency measures outlined in Item 16 of Schedule "A". In such a situation, a daily sample for TSS will be collected in addition to the regular discharge sampling requirements.

Effluent Monitoring

4.12 The Company shall collect a grab sample of the discharge effluent in the beginning and end of each discharge period in accordance with Condition 4.10 and analyze the sample for the parameters listed in Table 1 included in Schedule B of this Approval.

4.13 The Company shall include all analytical results generated from sampling events in the annual report required by Condition 8.10.

4.14 The methods and protocols for sampling, analysis and recording shall conform, in order of precedence, to the methods and protocols specified in the following:

(1) the Ministry's Procedure F-10-1, “Procedures for Sampling and Analysis Requirements for Municipal and Private Sewage Treatment Works (Liquid Waste Streams Only), as amended from time to time by more recently published editions;

(2) the Ministry's publication "Protocol for the Sampling and Analysis of Industrial/Municipal Wastewater" (January 1999), ISBN 0-7778-1880-9, as amended from time to time by more recently published editions;

(3) the publication "Standard Methods for the Examination of Water and Wastewater" (21st edition), as amended from time to time by more recently published editions; and

(4) for any parameters not mentioned in the documents referenced in (a), (b) and (c), the written approval of the District Manager shall be obtained prior to sampling.

PART 5 - INSPECTIONS AND MAINTENANCE

Facility, Equipment and Works Inspections

5.1 The Company shall ensure that the Facility and Equipment are inspected by trained personnel in accordance with the inspection schedule outlined in Item 17 of Schedule "A".

5.2 (1) Any deficiencies discovered as a result of an inspection carried out under Condition 5.1 shall be remedied immediately.

(2) If a deficiency is causing an adverse effect, as defined in the EPA, the Company shall forthwith notify the District Manager, and the Facility shall cease operations, or the portion of the operations causing the adverse effect, until such time as the deficiency is remedied.

5.3 (1) The Company shall undertake an inspection of the condition of the Works, at least twice a year, and undertake any necessary cleaning and maintenance to ensure that sediment, debris and excessive decaying vegetation are removed from the Works to prevent the excessive build-up of sediment, debris and/or decaying vegetation to avoid reduction of capacity.

(2) The Company shall also regularly inspect and clean out the inlet to and outlet from the Works to ensure that these are not obstructed.

Preventative Maintenance

5.4 The Company shall ensure that the Facility, Equipment and Works are properly maintained at all times and serviced in accordance with good engineering practices and manufacturers' recommendations.

PART 6 - SPILL PREVENTION AND EMERGENCY RESPONSE

Engineering Controls

6.1 The Company shall design and construct the Facility in a manner which prevents the likelihood of spills or the risk of environmental contamination from activities permitted under this Approval. This shall include, but not be limited to:

(1) sealing concrete floors, concrete pits and the lower 0.3 m of concrete walls with a chemical resistant coating system;

(2) installing a primary impermeable membrane (Enviroliner 6000 or equivalent) immediately beneath floor slabs and pits;

(3) installing a secondary impermeable membrane (Enviroliner 6000 or equivalent)

below the base of the concrete pits; and

(4) installing a primary impermeable membrane as the base of the treatment lagoon with a secondary impermeable membrane (both Enviroliner 6000 or equivalent) underneath the primary membrane.

Leak Detection Program

6.2 (1) The Company shall install a series of horizontal and groundwater monitoring wells in accordance with Item 21 of Schedule "A".

(2) Prior to the receipt of waste on site, the Company shall conduct five (5) groundwater monitoring events to establish baseline conditions in accordance with Item 21 of Schedule "A".

(3) Upon commencement of operations, the Company shall:

a. monitor the horizontal wells on a monthly basis for the presence or absence of liquid; and

b. conduct quarterly groundwater monitoring and analysis of groundwater samples, in accordance with Item 21 of Schedule "A";

(4) The results of the leak detection monitoring shall be presented in the annual monitoring report required by Condition 8.11;

(5) After three (3) years of monitoring, the leak detection program shall be critically reviewed and the review results submitted to the District Manager; and

(6) The leak detection program may be modified with the approval of the District Manager.

Emergency Response and Remedial Action Plan

6.3 Prior to the receipt of waste at the Facility, the Company shall have in place a Emergency Response and Remedial Action Plan for the operation of the Facility. The Plan shall include, but is not limited to:

(1) as-built drawings which accurately reflect the final Facility layout and clearly indicates all storage areas;

(2) response procedures to be undertaken in the event of a spill or process upset, including specific clean up methods;

(2) a list of equipment and spill clean up materials;

(3) a list of outside resources, including spill response companies, available for emergency response; and

(4) a notification protocol with names and telephone numbers of persons to be contacted, including Company personnel, the Ministry's Spills Action Centre and District Office, the local Municipality and Fire Department and the local Medical Officer of Health.

6.4 A copy of the Emergency Response and Remedial Action Plan shall be kept in a prominent location available to all staff.

6.5 The Company shall ensure that the equipment and spill cleanup materials outlined in the Emergency Response and Remedial Action Plan are located such that they are immediately available at all times, in a good state of repair and fully operational.

6.6 The Company shall review the Emergency Response and Remedial Action Plan on an annual basis at a minimum. The Plan shall be updated as required to ensure its relevancy. In particular, the Company shall verify that the names and telephone numbers listed in the notification protocol are up-to-date.

Spill Reporting

6.7 (1) All spills, as defined in the EPA, shall be immediately reported to the Ministry's Spills Action Centre at (416) 325-3000 or 1-800-268-6060; and

(2) Within ten (10) working days of the occurrence of any reportable spill as defined in Ontario Regulation 675/98, bypass or loss of any product, by-product, intermediate product, oil, solvent, waste material or any other polluting substance into the environment, submit a full written report of the occurrence to the District Manager describing the cause and discovery of the spill or loss, clean-up and recovery measures taken, preventative measures to be taken and schedule of implementation.

Spill and Emergency Response

6.8 (1) In the event of a spill or emergency, the Company shall promptly implement the Emergency Response and Remedial Action Plan and take all necessary steps to contain and clean up any spills.

(2) Where appropriate the Company shall pump the stormwater from the Works to the storage tanks within the Facility for subsequent characterization and treatment.

Contingency Plan

6.9 The Company shall have in place a Contingency Plan which includes, at a minimum:

(1) details on how waste will be stored or disposed of in the event that it cannot be removed from the Facility in the usual manner; and

(2) the procedures to be followed in the event of a labour disruption, transportation disruption, inability of receiving sites to accept waste or other business disruption to the operation.

PART 7 - TRAINING

7.1 The Company shall develop, implement and keep current a training plan specific to the Facility to ensure that all employees that operate the Facility, or carry out any activity required under this Approval, are trained in its operation. The training plan shall set out the minimum training requirements for each job function and a schedule for refresher training. The training plan shall be designed in accordance with the specific job requirements of each individual employee, including but not limited to:

(1) the Emergency Response and Remedial Action Plan;

(2) the Contingency Plan;

(3) the Procedures Manual;

(4) the Preventative Maintenance Manual

(5) occupational health and safety concerns;

(6) the requirements of this Approval;

(7) Equipment Manual.

7.2 The Company shall ensure that employees who oversee operations at the Facility are trained, and receive annual refresher training in:

(1) relevant waste management legislation, including but not limited to Regulation 347;

(2) terms, conditions and operating requirements of this Approval.

PART 8 - DOCUMENTATION

Design and Operations Report

8.1 (1) The Company shall ensure that the Design and Operations Report, referenced as Item 17 in Schedule "A", is kept up to date to accurately describe current Facility operations.

(2) The Design and Operations Report shall be available for inspection by a Provincial Officer upon request; and

(3) A copy of the most up-to-date version of the Design and Operations Report shall be submitted in support of applications to amend this Approval.

Manuals

8.2 (1) The Company shall develop a procedures manual, specific to the Facility, prior to the commissioning of the Facility. The procedures manual shall contain detailed standard operating procedures relating to all aspects of the handling and processing of waste at the Facility.

(2) The procedures manual shall be kept in a central location that is accessible to Facility personnel and available for inspection by a Provincial Officer upon request.

(3) The procedures manual shall be kept current at all times.

8.3 The Company shall develop an Equipment Manual prior to the commissioning of the Equipment. The Equipment Manual shall outline the operating procedures and maintenance requirements for the Equipment, including but not limited to:

(1) routine operating and maintenance procedures

(2) emergency procedures, including spill clean-up procedures;

(3) procedures for any record keeping activities relating to operation and maintenance of the Equipment;

(4) all appropriate measures to minimize noise and odorous emissions from all potential sources; and

(5) the frequency of inspection and replacement of the filter material in the Equipment.

8.4 (1) The Company shall prepare an operational manual, no later than 180 days from the commissioning of the Works, which should include, but not limited to, frequency and method of clean-out of Works.

(2) The Company shall keep the operations manual up to date with such revisions as may be required. Upon request, the Company shall make the manual available for

inspection by Provincial Officer and furnish a copy to the Ministry.

8.5 (1) The Company shall develop a preventative maintenance manual specific to the site, prior to the commissioning of the Facility. The preventative maintenance manual shall contain details of the work required to maintain the Equipment, Works and Facility in accordance with Condition 5.4.

(2) The preventative maintenance manual shall be kept in a location accessible to Facility personnel who conduct the maintenance activities and shall be available for inspection by a Provincial Officer upon request.

(3) The preventative maintenance manual shall be kept current at all times.

Record Keeping

8.6 The Company shall keep records of all preventative maintenance completed to satisfy Condition 5.4. These records shall include, at a minimum:

(1) the date maintenance work is performed;

(2) the name and signature of the person conducting the maintenance work;

(3) a description of the maintenance work performed; and

(4) the date of the next scheduled maintenance activity.

8.7 The Company shall keep records of the inspections required under Conditions 5.1 and 5.3. The record shall include the following, at a minimum:

(1) the name and signature of person conducting the inspection;

(2) the date and time of the inspection;

(3) a description of the portion of the Facility, the Equipment or the Works inspected;

(4) a list of any deficiencies discovered;

(5) any recommendations for action; and

(6) the date, time and description of actions taken to address the deficiencies.

8.8 The Company shall keep a written record of employee training. At a minimum, the record shall include:

(1) the date of training;

(2) the name and signature of the person who has been trained; and

(3) a description of the training provided.

Record Retention

8.9 The Company shall retain, for a minimum of two (2) years from the date of their creation, all records and information related to or resulting from the recording activities required by this Approval, and make these records available for review by staff of the Ministry upon request.

Reports

8.10 By March 31st of each year, the Company shall prepare and submit to the District Manager, an annual report for the previous calendar year. Each report shall include, at a minimum, the following information:

(1) a detailed monthly summary of the type and quantity of all incoming and outgoing wastes;

(2) a summary and interpretation of all monitoring data and a comparison to the effluent limits outlined in Conditions 4.7 and 4.10, including an overview of the success and adequacy of the Works;

(3) a summary of any effluent quality assurance or control measures undertaken in the reporting period;

(4) any environmental and operational problems that could negatively impact the environment encountered during the operation of the Facility, or during the Facility inspections, and any mitigative actions taken;

(5) a summary of all maintenance carried out on any major structure, equipment, apparatus, mechanism or thing forming part of the Equipment or Works;

(6) a financial assurance re-evaluation in accordance with Condition 2.1(3);

(7) a statement as to the Facility's compliance with all Conditions of this Approval and with the inspection and reporting requirements of the Conditions herein; and

(8) any recommendations to minimize environmental impacts from the operation of the Facility and to improve Facility operations in this regard.

8.11 (1) The Company shall prepare and submit to the District Manager the results of the pre-commissioning groundwater sampling in an initial monitoring report within 14 months from the start of the leak detection monitoring program; and

(2) On an annual basis thereafter, the Company shall prepare and submit to the District Manager, the results of the quarterly monitoring sampling events; and

(3) The monitoring reports shall include, but not be limited to:

a. a description of the hydrogeological setting;

b. a description of the groundwater monitoring locations

c. documentation, dates and methods employed for all sample collection;

d. laboratory and monitoring equipment analytical results;

e. a compilation of all data obtained during the monitoring events;

f. interpretation of the results and comparison against applicable regulatory criteria and/or baseline data;

g. identification of potential contaminant mechanisms and migration pathways; and

h. recommendations for changes to the monitoring plan.

PART 9 - CLOSURE PLAN

9.1 The Company must submit, for approval by the District Manager, a written closure plan at least four (4) months prior to closure of the Facility. This plan must include, as a minimum, a description of the work that will be done to facilitate closure of the Facility and a schedule for completion of that work.

9.2 Within ten (10) days after closure of the Facility, the Company must notify the Director and District Manager, in writing, that the Facility is closed and that the Facility closure plan has been implemented.

SCHEDULE "A"This Schedule "A" forms part of Environmental Compliance Approval No. 7556-A67PFG.1. Environmental Compliance Approval application, submitted by Eco Site Assessors Inc., signed by Scott Pitsch, Operations Manager, dated April 29, 2015.

2. Emission Summary and Dispersion Modelling Report, submitted by AirZone One

Ltd., dated May 13, 2015, signed by Lucas Neil.

3. Email dated July 5, 2016, from Lucas Neil, to Edward Chang-Yen, MOECC.

4. Email dated July 5, 2016, from Scott Pitsch, to Edward Chang-Yen, MOECC.

5. Email dated July 12, 2016, from Scott Pitsch, to Edward Chang-Yen, MOECC.

6. Email dated July 14, 2016, from Lucas Neil, to Edward Chang-Yen, MOECC.

7. Email dated July 15, 2016, from Lucas Neil, to Edward Chang-Yen, MOECC.

8. Email dated August 5, 2016, from Scott Pitsch, to Edward Chang-Yen, MOECC.

9. Email dated August 18, 2016, from Lucas Neil, to Edward Chang-Yen, MOECC.

10. Email dated October 5, 2016, from Lucas Neil, to Edward Chang-Yen, MOECC.

11. Email dated November 2, 2016, from Lucas Neil, to Edward Chang-Yen, MOECC.

12. Email dated January 27, 2017, from Lucas Neil, to Edward Chang-Yen, MOECC.

13. Email dated January 31, from Lucas Neil, to Edward Chang-Yen, MOECC.

14. Email dated February 1, 2017, from Lucas Neil, to Edward Chang-Yen, MOECC.

15. Email dated February 23, 2017, from Lucas Neil, to Edward Chang-Yen, MOECC,

16. Stormwater Management Standard Operating Procedure document prepared for Eco-Site Assessors, provided by email dated March 13, 2017.

17. Design & Operations Manual, Napanee Waste Water Treatment Facility, Eco Site Assessors, Revision 3, dated August 2015.

18. Limited Hydrogeology Study, prepared for Eco Site Assessors, prepared by D.L.Services Inc., dated July 4, 2012.

19. Correspondence dated March 30, 2017, from Scott Pitsch, to Veronica Pochmursky re: additional information on the construction and operation of the facility including: Fill Management Plan, correspondence from Quinte Conservation Authority and Municipality of Greater Napanee, technical specification for polishing lagoon liner system, technical specifications for water treatment facility liner systems, waste water & landfill leachate treatment inspection protocol.

20. Correspondence dated May 20, 2015, revised March 24, 2017, from Scott Pitsch, re: Financial Assurance Assessment.

21. Waste Water Treatment Facility Leak Detection Program, Eco Site Assessors Inc., dated November 2017.

SCHEDULE "B"This Schedule "B" forms part of Environmental Compliance Approval No. 7556-A67PFG.

Stormwater Effluent Compliance LimitsTable 1: Concentration Limits

Final Effluent Parameter

Limit(maximum unless otherwise

indicated)Column 1 Column 2

Total Suspended Solids

20 mg/L

F1- Hydrocarbon Fraction

0.15 mg/L

F2- Hydrocarbon Fraction

0.11 mg/L

pH between 6.5 - 8.5 inclusive

Stormwater Effluent MonitoringTable 2 - Effluent Monitoring

Effluent Parameter Effluent Parameter

CBOD 5 Arsenic

Total Suspended Solids Barium

Total Phosphorus Beryllium

Total Ammonia Boron

Hardness Cadmium

Alkalinity Chromium

Chloride Chromium (VI)

Benzene Cobalt

Ethylbenzene Copper

Toluene Lead

o-Xylene Mercury

m&p-Xylene Molybdenum

F1 - Total Petroleum Hydrocarbons

Nickel

F2 - Total Petroleum Hydrocarbons

Vanadium

F3 - Total Petroleum Hydrocarbons

Zinc

F4 - Total Petroleum Hydrocarbons

Temperature

Nitrate & Nitrite pH

Polyaromatic Hydrocarbons

The reasons for the imposition of these terms and conditions are as follows:

The reason for Conditions 1.1, 1.2, 1.3, 1.9, 1.10, 1.11, 1.16, 1.17 and 1.18 is to clarify the legal rights and responsibilities of the Company and Operator under this Approval.

The reason for Condition 1.4 is to ensure that the Site is designed, operated, monitored and maintained in accordance with the application and supporting documentation submitted by the Company, and not in a manner which the Director has not been asked

to consider.

The reason for Conditions 1.5, 1.6, 1.7 and 1.8 is to clarify how to interpret this Approval in relation to the application and supporting documentation submitted by the Company.

The reasons for Condition 1.12 is to ensure that the Site is operated under the corporate name which appears on the application form submitted for this approval and that the Director is informed of any changes.

The reason for Condition 1.13 is to restrict potential transfer or encumbrance of the Facility without the approval of the Director. Any transfer of encumbrance can be made only on the basis that it will not endanger compliance with this Approval.

The reason for Condition 1.14 is to ensure that subsequent owners of the Facility are informed of the terms and conditions of this Approval. This also applies to all supporting documentation listed in Schedule "A".

The reason for Condition 1.15 is to ensure that appropriate Ministry staff have ready access to the Facility for inspection of facilities, equipment, practices and operations required by the conditions in this Approval. This condition is supplementary to the powers of entry afforded a Provincial Officer pursuant to the EPA and OWRA.

The reason for Condition 2.1 is to ensure that sufficient funds are available to the Ministry to clean up the Facility in the event that the Company is unable or unwilling to do so.

The reason for Condition 3.1 is to specify the service area and hours of operation for the Facility in accordance with the Company's application and supporting documentation.

The reason for Condition 3.2 is to ensure that emergency responders and the public have the necessary contact information in the event of an emergency or complaint.

The reason for Condition 3.3 is to ensure that the Site is secure when unattended to prevent vandalism or theft.

The reason for Conditions 3.4, 3.5, 3.6, 3.7 and 3.8 is to ensure that the types and quantities of waste received and stored at the Facility are in accordance with the Company's application and supporting documentation.

Conditions 3.9 and 3.10 are included to ensure that waste storage is done in a manner which does not result in a nuisance or a hazard to the health and safety of the

environment or people.

The reason for Conditions 3.11 and 3.12 is to specify the types of waste management activities approved to take place at the Facility in accordance with the Company's application and supporting documentation.

The reason for Conditions 3.13, 31.4, 3.15 and 3.16 is to ensure that waste is characterized, transported and disposed of in accordance with the requirements of Regulation 347.

The reason for Condition 3.17 is to ensure that the Facility is operated in a manner which does not result in a nuisance or a hazard to the health and safety of the environment or people.

The reason for Condition 3.18 is to provide the minimum performance requirements considered necessary to prevent an adverse effect resulting from the operation of the Facility.

The reason for Condition 3.19 is to ensure that complaints are properly and quickly resolved and that complaints and follow-up actions have been documented.

Condition 4.1 is included to ensure that, when the Works are constructed, the Works will meet the standards that apply at the time of construction to ensure the ongoing protection of the environment.

Conditions 4.2 and 4.3 are imposed to ensure that the Works are built and operated in the manner in which they were described for review and upon which approval was granted. This condition is also included to emphasize the precedence of Conditions in the Approval and the practice that the Approval is based on the most current document, if several conflicting documents are submitted for review.

Condition 4.4 is included as installation, regular inspection and maintenance of the temporary sediment and erosion control measures is required to mitigate the impact on the downstream receiving watercourse during construction until they are no longer required.

Conditions 4.5 and 4.6 are included to ensure that the effluent discharged from the Works to the receiver meets the Ministry's effluent quality requirements thus minimizing environmental impact on the receiver.

Conditions 4.7, 4.8, 4.9, 4.10 and 4.11 are included in accordance with the application and to ensure that the Works are designed, operated and maintained without any adverse impact on the environment.

Conditions 4.12, 4.13 and 4.14 are included to require the Company to demonstrate on a continual basis that the quality of the effluent from the approved Works is consistent with the effluent limits specified in the Approval and that the approved Works do not cause any impairment to the environment.

The reason for Conditions 5.1, 5.2, 5.3 and 5.4 is to ensure that all equipment and facilities are maintained in good working order.

The reason for Condition 6.1 is to ensure that the Facility is designed and constructed in an environmentally acceptable manner, based on the conceptual design and operations for the Facility.

The reasons for Condition 6.2 is to demonstrate that the engineering controls are performing as designed without impact on the natural environment. Regular monitoring allows for the analysis of trends over time and ensures that there is an early warning of potential problems so that any necessary remedial/contingency action can be taken.

The reason for Conditions 6.3, 6.4, 6.5 and 6.6 is to ensure that the Company is prepared and properly equipped to take action in the event of a spill, fire or other operation upset.

The reason for Condition 6.7 is to ensure that the Company notifies the Ministry forthwith of any spills as required in Part X of the EPA so that appropriate spills response can be determined.

The reasons for Condition 6.8 is to ensure that the Company immediately responds to a spill.

The reason for Condition 7.1 is to ensure that the Company's staff are properly trained in the operation of the equipment used at the Facility and in emergency response procedures.

The reason for Condition 7.2 is to ensure that an employee capable of making decisions on behalf of the Company is present at the Facility when waste management activities are taking place.

The reason for Condition 8.1 is to ensure that the Company always has an up-to-date document of actual site conditions. This will aid in future applications to amend this Approval.

The reason for Conditions 8.2, 8.3 and 8.4 is to ensure that the Company has documents which instruct employees on the safe operation of all aspects of the Facility. This will ensure that operations are undertaken in a manner which minimizes risk to

the environment and public health and safety.

The reason for Condition 8.5 is to ensure that all equipment and Facility structures are regularly services to ensure that they are operating as required. Properly maintained equipment and structures will ensure that the Facility operates in a manner which minimizes risk to the environment and public health and safety.

The reason for Conditions 8.6, 8.7, 8.8 and 8.9 is to ensure that accurate records are maintained to ensure compliance with the conditions in this Approval, the EPA and its regulations.

The reasons for Conditions 8.10 and 8.11 is to ensure that regular reviews of site development, operations and monitoring data is documented and any possible improvements to site design, operations or monitoring programs are identified. Annual reports are an important tool used in reviewing site activities and for determining the effectiveness of site design.

The reason for Conditions 9.1 and 9.2 is to ensure that the Site is closed in accordance with Ministry standards and to protect the health and safety of the environment.

In accordance with Section 139 of the Environmental Protection Act, you may by written Notice served upon me, the Environmental Review Tribunal and in accordance with Section 47 of the Environmental Bill of Rights, 1993 , S.O. 1993, c. 28 (Environmental Bill of Rights), the Environmental Commissioner, within 15 days after receipt of this Notice, require a hearing by the Tribunal. The Environmental Commissioner will place notice of your appeal on the Environmental Registry. Section 142 of the Environmental Protection Act provides that the Notice requiring the hearing shall state:1. The portions of the environmental compliance approval or each term or condition in the environmental compliance approval in respect of which the hearing is required, and;2. The grounds on which you intend to rely at the hearing in relation to each portion appealed.The Notice should also include:3. The name of the appellant;4. The address of the appellant;5. The environmental compliance approval number;6. The date of the environmental compliance approval;7. The name of the Director, and;8. The municipality or municipalities within which the project is to be engaged in.And the Notice should be signed and dated by the appellant.This Notice must be served upon:

The Secretary*Environmental Review Tribunal655 Bay Street, Suite 1500Toronto, OntarioM5G 1E5

AND

The Environmental Commissioner1075 Bay Street, Suite 605Toronto, OntarioM5S 2B1

AND

The Director appointed for the purposes of Part II.1 of the Environmental Protection ActMinistry of the Environment and Climate Change135 St. Clair Avenue West, 1st FloorToronto, OntarioM4V 1P5

* Further information on the Environmental Review Tribunal’s requirements for an appeal can be obtained directly from the Tribunal at: Tel: (416) 212-6349, Fax: (416) 326-5370 or www.ert.gov.on.caThis instrument is subject to Section 38 of the Environmental Bill of Rights, 1993, that allows residents of Ontario to seek leave to appeal the decision on this instrument. Residents of Ontario may seek leave to appeal within 15 days from the date this decision is placed on the Environmental Registry. By accessing the Environmental Registry at www.ebr.gov.on.ca , you can determine when the leave to appeal period ends.The above noted activity is approved under s.20.3 of Part II.1 of the Environmental Protection Act.

DATED AT TORONTO this 1st day of March, 2018

Dale Gable, P.Eng.Directorappointed for the purposes of Part II.1 of the Environmental Protection Act

VP/c: District Manager, MOECC Kingston - District