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May 24, 2017
LAFARGE CANADA INC. BATH CEMENT PLANT
EVALUATION OF LOW CARBON FUELS - PROJECT 3, CONSIDERATIONS FOR PERMANENT USE
Draft Project Description Version 1.0
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Report Number: 1649607
Distribution:
Lafarge Canada Inc. 1 PDF Copy - Golder Associates Ltd.
Submitted to:
Lafarge Canada Inc. 6501 Bath Road, Hwy. 33 Bath, ON K0H 1G0 DRAFT
EVALUATION OF LCF - PROJECT 3 DRAFT PROJECT DESCRIPTION
May 24, 2017 Report No. 1649607 i
DOCUMENT VERSION CONTROL
The Project Description Report is a living document; it will be updated periodically throughout the environmental
assessment (EA) process in response to stakeholder comments. Updates will be documented in the following
table to allow stakeholders to track and monitor changes to the Project Description over time.
Version Date Revision
Description Prepared By
Reviewed By
(Facility Contact)
1.0 May 24, 2017 Draft Rachel Lee Gould Blair Walker
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Table of Contents
1.0 INTRODUCTION .................................................................................................................................................... 1
2.0 RATIONALE FOR THE PROJECT (ESP STEP 2) ................................................................................................ 2
2.1 Problem and Opportunity Statement ......................................................................................................... 2
2.2 Canada and World-Wide Fuel Substitution ............................................................................................... 3
2.3 Purpose of the Project .............................................................................................................................. 4
2.4 Project Background .................................................................................................................................. 4
2.5 Project Location ........................................................................................................................................ 7
2.6 Project Proponent ..................................................................................................................................... 8
3.0 PROJECT DESCRIPTION (ESP STEP 2) ............................................................................................................. 8
3.1 Service Areas and Fuel Types .................................................................................................................. 8
3.2 Project Phases .......................................................................................................................................... 9
3.2.1 Construction ........................................................................................................................................ 9
3.2.2 Operations .......................................................................................................................................... 9
3.2.3 Retirement .......................................................................................................................................... 9
3.3 Low Carbon Fuel Transport ...................................................................................................................... 9
3.4 Fuel Staging/Processing System ............................................................................................................ 10
3.4.1 Sorting Operations ............................................................................................................................ 10
3.4.2 Shredding Operations ....................................................................................................................... 11
3.5 Fuel Delivery System .............................................................................................................................. 12
3.5.1 Fuel Off-Loading System .................................................................................................................. 12
3.5.2 Fuel Storage System ......................................................................................................................... 12
3.5.3 Fuel Injection System ........................................................................................................................ 13
3.6 Low Carbon Fuel Efficiency .................................................................................................................... 13
3.7 Low Carbon Fuel Storage ....................................................................................................................... 13
3.8 Relevant Bath Operations Activities ........................................................................................................ 14
3.8.1 Water Usage Relevant to the LCF Operations .................................................................................. 14
3.8.2 Water Discharge to the Environment ................................................................................................ 15
3.8.3 Ash Production/Disposal ................................................................................................................... 15
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4.0 REFERENCES ..................................................................................................................................................... 15
TABLES
Table 2-1: Project Proponent ........................................................................................................................................... 8
Table 3-1: Low Carbon Fuel Storage Areas .................................................................................................................. 14
FIGURES
Figure 1 Site Location
Figure 2: Site Layout and Fuel Management
Figure 3: Low Carbon Fuel Management Process
Figure 4: Low Carbon Fuel Delivery System
APPENDICES
APPENDIX A Maps
No table of figures entries found.
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1.0 INTRODUCTION
Lafarge Canada Inc. (Lafarge), Canada’s largest diversified supplier of construction materials, has undertaken a
broad initiative to improve the sustainability of their Bath Plant by the year 2020, termed the Cement 2020 Initiative.
Under this initiative, and working in Partnership with Queen’s University, environmental non-government
organizations and various levels of government, Lafarge is reducing its imported fossil fuel use (with a current goal
of a 30% reduction of fossil fuel use by the year 2020), and so lowering its Green House Gas (GHG) emissions,
through the use of local and/or regional, sustainable, Low Carbon Fuels (LCF). Lafarge is currently approved to
use virgin biomass (crops such as switch grass and oat hulls) as fuel in the cement manufacturing process and
has a pilot study underway to assess the use of mixed biomass or otherwise lower carbon materials as fuels.
The first group of mixed biomass LCFs proposed for permanent use were:
construction and demolition materials;
asphalt shingles; and
weathered treated wood (such as railway ties and utility poles).
In April 2016 Lafarge completed an Environmental Screening Process (ESP) for these fuels (termed the
“Evaluation of Low Carbon Fuels – Project 1”). The study concluded that the use of these LCFs is expected to
have an overall positive affect on the environment and to benefit the community-at-large. With the use of these
LCFs, Lafarge demonstrated it can reduce its imported fossil fuel use and thereby reduce their emissions of GHGs
(specifically carbon dioxide [CO2]). Notably, the emission testing demonstrated that the GHG reductions were
achieved with no increases in other emissions.
The second group of mixed biomass LCFs proposed for permanent use were:
paper fibre/wood/plastic composite materials, such as manufacturing rejects and trimmings of unused
off-spec personal hygiene products, household goods, packaging labels and tape;
non-recyclable paper fibre packaging (and related similar products), such as rejects and trimmings from paper
recycling facilities (i.e., ragger tails);
textiles, carpet cuttings, manufacturing end rolls and cores; and
disposable beverage cups and lids (e.g., K-cups).
Lafarge began an ESP for these fuels (termed the “Evaluation of Low Carbon Fuels – Project 2”) in June 2016.
Preliminary results from this study indicate that the use of these LCFs can also reduce emissions of GHG
(specifically CO2) from the Bath Plant. Once the analyses of the results are completed, Lafarge will present the
study findings to the public at an open house event, and submit the study report to the Ministry of Environment
and Climate Change (MOECC) for evaluation. This study report will also be made available for the public to review.
Lafarge is now using the same ESP to evaluate a third group of mixed biomass LCFs. These materials are
classified as by-products of existing recycling programs (i.e., have passed through an existing recycling program
and been rejected), or are not eligible for recycling, and are therefore destined for landfill. Three additional types
of LCFs have been identified:
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Non-recyclable rubber (not including used tires) and rubber recycling by-products (e.g., polyester/nylon fiber
from tire recycling facilities);
Non-recyclable plastics from Material Recovery Facilities and the ICI sector; and
Non-odorous oversized and/or unused compost materials (e.g., twigs, plastic bags).
This study (termed “Evaluation of Low Carbon Fuels - Project 3”) is being undertaken in accordance with the
requirements of Ontario Regulation 101/07 under the Environmental Assessment Act for Waste Management
Projects. The ESP will carefully assess potential effects (including benefits) of these proposed fuel sources to the
community and the environment.
2.0 RATIONALE FOR THE PROJECT (ESP STEP 2)
2.1 Problem and Opportunity Statement
There is more concrete sold per year than all other building materials combined. Concrete is made from aggregates
(gravel and sand), cement, and water and is much in demand for its building material qualities, and superior life
cycle and environmental performance. However, cement, the active ingredient, requires thermal energy to
produce. Traditionally, this thermal energy is obtained from fossil fuels such as coal, natural gas, and petroleum
and its by-products. However, worldwide, fossil fuel alternatives (derived from fossil sources, biomass, and
mixtures of the two) have been a growing source of energy for cement manufacturing due to their better ranking
from a sustainability perspective. Further, with the emerging global need to reduce GHG emissions to mitigate the
impacts from climate change, the need for lower carbon fuels – a subset of fossil fuel alternatives – is growing
urgent.
Lafarge is amongst many members in the cement sector assessing fossil fuel alternatives, related technologies,
and their optimum use. In Ontario, the Lafarge Bath Plant Cement 2020 initiative aims to identify broad measures
for improved sustainability (e.g., energy, water, economics, emissions, biodiversity) and extend the findings to the
rest of the sector. One of the key focus areas of the Cement 2020 initiative is to reduce imported fossil fuel use by
30% by the year 2020, and so lower GHG emissions and other emissions, through the use of local and/or regional,
and sustainable, LCF sources. Under the sustainability model adopted by the Project team, to be considered a
sustainable fuel, they must be environmentally sound, socially responsible, and economically viable.
The Ontario MOECC defines alternative LCFs in the new Alternative Low Carbon Fuels Regulation 79/15
(O. Reg. 79/15) as “a fuel that has a carbon dioxide emission intensity that is less than the carbon dioxide emission
intensity of the coal or petroleum coke in the place of which the fuel is combusted and that meets one of the
following descriptions:
The fuel:
is not derived from or composed of any material set out in Schedule 1 (of O. Reg. 79/15);
is wholly derived from or composed of materials that are biomass or municipal waste or a combination of
both; and
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unless the fuel is wholly derived from or composed of materials that are solid biomass, has a high heat
value of at least 10,000 mega joules per tonne.
The fuel is wholly derived from or composed of organic matter, not including peat or peat derivatives, derived
from a plant or micro-organism and grown or harvested for the purpose of being used as a fuel."
Lafarge has adopted the MOECC definition of alternative LCFs for this project.
There is great potential for adoption of LCFs within North America, where there are approximately 115 operating
cement kilns. Much of the 2 million tonnes of fossil fuels used every year by the Canadian cement industry is
imported and enabling the industry to receive local LCFs will create immense local spin-off benefits; bringing new,
direct and indirect, economic values well in excess of $100 million per year while preserving the existing cement
industry’s competitiveness. In addition, the business models being developed can be readily replicated and the
science readily adapted to other facilities. Other large energy users such as electricity and steel can build on the
in-depth science produced to adopt LCFs as may be appropriate for their sector.
The vision of the Cement 2020 initiative is to achieve 30% substitution of the traditional fuel sources currently in
use at the Bath Plant with practical, sustainable LCF alternatives by the year 2020, and to continue developing
LCFs and related technologies to reach ever higher replacement rates in the future.
In addition, there are a number of social benefits that are expected from the sustainability model adopted.
By working in a Partnership comprised in part of local entities, each partner brings expertise and values that
synergistically ensure the community values are integrated, including transparency, the precautionary principle
and local enrichment. Through a series of communication efforts and events, the Project team ensures that the
local public is offered the opportunity to engage with the team and to participate in the program.
It is also anticipated that this Project will decrease the amount of material destined for landfill and extend landfill
life spans as imported fuels are replaced with local and/or regionally1 produced fuels.
2.2 Canada and World-Wide Fuel Substitution
Alternative fuels have been used by the cement industry worldwide since the 1970s. Globally, the average
substitution rate of alternative fuels for coal and/or petroleum coke in cement plants is approximately 14%,
with Europe at a remarkable level of 36% (Zhang and Mabee 2015). The alternative fuels used as a substitute
include fossil-based fuels (such as tires and tire-derived fuels, waste solvents, plastics, and used oils),
and renewable biomass-based fuels (such as sewage sludge, meat and bone meal, agricultural plants, and wood
wastes). The most common alternative fuel used globally in cement plants is used oil, representing 50% of all
alternative fuels (Zhang and Mabee 2015).
In Canada, five provinces (British Columbia, Alberta, Ontario, Quebec, and Nova Scotia) have operating Portland
cement plants, with an average alternative fuel substitution rate of approximately 11% (Zhang et al 2015). The
substitution rates (calculated by weight) vary between provinces, from 0% in Alberta to over 34% in Quebec. In
Ontario, the fuel substitution rate is approximately 5% (Zhang et al 2015).
1 Alternative fuels may be sourced from Ontario, Quebec or New York State, depending on availability.
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The Government of Ontario promotes the reduction, reuse, and recycling (3Rs) of waste to keep these materials
out of landfills for environmental reasons (i.e., save scarce resources and reduce GHGs), and also because these
materials have tremendous value and potential to generate new investment, new factories, new jobs, and new
Ontario-made products. To achieve its vision of a ‘zero-waste’ society, a new act, called the Resource Recovery
and Circular Economy Act, came into force in Ontario in November 2016. This act holds individual producers
responsible for recovering resources and reducing waste associated with their products and packaging, and
establish a strategy and identify actions to increase resource recovery and waste reduction in Ontario. In a parallel
initiative, a new Alternative Low Carbon Fuel Regulation (O. Reg. 79/15) was passed in Ontario in May 2015 that
recognizes the beneficial uses of alternative fuels, specifically to energy intensive manufacturing facilities such as
cement plants and steel producers, and places the use of alternative fuels in a greenhouse gas reduction policy
framework. Under this new regulation, fuel use will target materials that are currently not-recycled. The use of
alternative fuels supports the government’s GHG and waste reduction policies.
2.3 Purpose of the Project
The purpose of this Project is to assess the potential environmental effects (both beneficial effects and potential
adverse effects) of using the following LCFs in the cement manufacturing process:
Non-recyclable rubber (not including used tires) and rubber recycling by-products (e.g., polyester/nylon fiber
from tire recycling facilities);
Non-recyclable plastics from Material Recovery Facilities and the ICI sector; and
Non-odorous oversized and/or unused compost materials (e.g., twigs, plastic bags).
Doing so would reduce imported fossil fuel use, lowering GHG emissions, and make use of local and/or regional,
and sustainable, LCF sources that would otherwise be directed to landfills.
Lafarge is using an environmental assessment, specifically an ESP, to assess the potential effects of using LCFs
in the cement manufacturing process. Once the ESP is complete, Lafarge will apply for a permanent ECA to add
these specific types of LCFs to the currently approved list of fuels in their cement plant.
2.4 Project Background
In 2010, the Lafarge Bath Plant undertook its first LCF testing program. The Energy Farm Demonstration Project
evaluated several forms of locally-grown virgin biomass for suitability as a LCF: the tested mix included maize,
millet, hemp, oat hulls, and switch grass. The study concluded that these types of materials were not currently
economically viable; results are summarized in a public report submitted to the MOECC and currently available
on the www.cement2020.org website (Hyndman & Associates 2011). This phase of the project was funded in part
by a Biomass Research grant from Natural Resources Canada.
Building upon this success and lessons learned, the Project team expanded the scope of its research to find other
LCFs that meet all three requirements under the Project team’s sustainability approach (environmentally sound,
socially responsible, and economically viable). This search was funded in part by an Asia Pacific Partnership grant
and built on the knowledge gained in previous years. The Cement 2020 initiative commenced, in its current form,
in 2011.
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There were two main elements of relevance to this next phase of the LCF program. The first was a call to the local
business community to identify LCF sources that appear to have merit under the sustainability approach. A second
process, undertaken in parallel, was to engage a multi-stakeholder expert panel to develop a protocol tool for use
in assessing the relative environmental and social benefits of candidate fuels. That is, to develop a transparent
tool to quantify two of the three sustainability requirements recognizing that economics can be readily assessed.
This protocol was called the Greener Fuel Protocol (the “Protocol”). The Task Force panel included members from
Loyalist Township, World Wildlife Fund Canada, Queen’s University, New Energy Project, Cement Association of
Canada, Kingston Environmental Advisory Forum, Kingston Greens, Lafarge, and the local community. While the
Protocol included specific social measures, the team based development of the Protocol itself was a major element
of meeting the social component. This Protocol was then used in its draft form to assess the local LCF proposals
– in addition to an economic analysis – and as a result a number of fuel types were put forward for additional
development. These fuels included: forest and agricultural production by-products and waste, construction and
demolition materials, asphalt shingles, railway ties, pulp and paper by-products, fibre based industrial discards,
and post-consumer fibre based materials that are not readily recoverable through existing recycling systems.
The next phase of the LCF program, currently underway, is to validate the Protocol’s performance prediction for
these fuels at full scale. The Low Carbon Fuel Demonstration Project evaluates potential fuel management
systems for the dedicated injection of LCFs into the main cement kiln combustion system. A detailed air emission
testing program forms a key component of this project (Golder 2016). Its aim is to assess the expected positive
results (or negative changes, if any), to the air quality from the stack emissions. Further information on the project
can be found in the Design and Operations Report (Lafarge 2016).
Under the Cement 2020 initiative, a series of environmental approval and assessments activities have or will be
undertaken, for the use of LCFs in the cement manufacturing process. These activities are briefly discussed below.
Round 1 of environmental approval activities was completed in 2009 for the Energy Farm Demonstration Project.
A Pilot Project Environmental Compliance Approval (ECA #1202-7UTPZJ) was issued by the MOECC in
November 2009 to use/assess virgin biomass (including switch grass, Miscanthus, sorghum, hemp, and willows)
in the cement manufacturing process.
Round 2 was completed for the Permanent Low Carbon Fuel Project (formerly called the Energy Farm
Demonstration Project) in December 2012.
Lafarge received approval (ECA #3610-8Y9NVD) to permanently use virgin biomass as a supplemental fuel
in their cement manufacturing process based on its successful demonstration in 2010.
Lafarge also received approval in this same ECA to permanently operate the LCF fuel management system.
This includes the LCF fuel staging/processing system (shredding, blending, mixing and grinding the fuel) and
fuel delivery system (off-loading, storage and injection into the kiln). This approval grants ‘limited operational
flexibility’ to allow the plant to optimize the staging and delivery systems, as determined through the Low
Carbon Fuel Demonstration Project. This system is approved on an ongoing basis for virgin biomass fuels
(see above) and on a temporary basis for use in the Pilot Project (see below).
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Round 2 also included activities completed in December 2012 for the Low Carbon Fuel Demonstration Project.
ECAs for the Pilot Project (#7984-8YYR75 and #9606-8Z7S9Z) were issued by the MOECC to use/assess
mixed biomass LCFs in the cement manufacturing process. These ECAs specifically address the handling
and storage requirements for the LCF material, and source and emission monitoring requirements.
Round 3 is underway for the Evaluation of Low Carbon Fuels - Project 1.
Lafarge completed an environmental assessment (specifically an ESP) in April 2016 of the potential
environmental effects of using construction and demolition materials, asphalt shingles, and weathered treated
wood (such as railway ties and utility poles) in their cement manufacturing process. The study concluded that
the use of these LCFs is expected to have an overall positive affect on the environment (reduce GHG
emissions) and to benefit the community-at-large.
Lafarge submitted ECA amendment applications to the MOECC in September 2016 for the permanent use
of these fuels.
Round 3 also included activities completed in March 2017 for the Low Carbon Fuel Demonstration Project.
ECAs for the Pilot Project (#2950-AK2RFX and #9606-8Z7S9Z) were amended and issued by the MOECC
to use/assess the following additional fuels: non-recyclable rubber (not including used tires) and rubber
recycling by-products (e.g., polyester/nylon fiber from tire recycling facilities), non-recyclable plastics from
Material Recovery Facilities and the Industrial, Commercial and Institutional (ICI) sector, and non-odorous
oversized and/or unused compost materials (e.g., twigs, plastic bags). The Pilot Project was also extended
to December 2018.
Round 4 is underway for the Evaluation of Low Carbon Fuels – Project 2. Lafarge is conducting an environmental
assessment (specifically an ESP) of the potential environmental effects of using the following types of LCFs in
their cement manufacturing process:
paper fibre/wood/plastic composite materials, such as manufacturing rejects and trimmings of unused
off-spec personal hygiene products, household goods, packaging labels, and tape;
non-recyclable paper fibre packaging (and related similar products), such as rejects and trimmings from paper
recycling facilities (i.e., ragger tails);
textiles, carpet cuttings, manufacturing end rolls, and cores; and
disposable beverage cups and lids (e.g., K-cups).
These specific types of LCFs were selected through the “Greener Fuel Protocol” process described above. Once
the ESP is complete, pending successful results, Lafarge will apply for a permanent ECA to use these specific
types of LCFs indefinitely in their cement plant.
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Round 5 is underway for the Evaluation of Low Carbon Fuels – Project 3. Lafarge is conducting an environmental
assessment (specifically an ESP) of the potential environmental effects of using the following types of LCFs in
their cement manufacturing process:
Non-recyclable rubber (not including used tires) and rubber recycling by-products (e.g., polyester/nylon fiber
from tire recycling facilities);
Non-recyclable plastics from Material Recovery Facilities and the ICI sector; and
Non-odorous oversized and/or unused compost materials (e.g., twigs, plastic bags).
These specific types of LCFs are described further in Section 3.1 of this report. Once the ESP is complete, pending
successful results, Lafarge will apply for a permanent ECA to use these specific types of LCFs indefinitely in their
cement plant.
2.5 Project Location
The Lafarge Bath Plant is situated on a 1,089 hectare property located on the north side of Highway No. 33,
approximately 3 kilometres west of the Village of Bath, Ontario in Loyalist Township (the “Site”). Bath is located
approximately 25 kilometres west of the City of Kingston. The legal address for the Site is Concession 1, Broken
Front Lot 4 to 6 and Lot 7 to 8 Part Lot plus open allowance, Loyalist Township, County of Lennox & Addington.
The mailing address is 6501 Highway 33 / PO Box 160, Bath, Ontario, K0H 1G0. The location of the Site is shown
on Figure 1.
The Site is bordered to the north, east, and west, by residential and agricultural properties. The majority of the
south limit of the Site is bounded by Highway 33 and further to the south by lands owned by Lafarge and water
lots (Lake Ontario).
The Loyalist Township Official Plan (Cumming Cockburn Limited 2014) designates the Site as Aggregate,
providing for a range of aggregate related operations. This includes, but is not limited to, blasting, crushing,
screening, blending, storage, and aggregate recycling. The Site is also situated in an Aggregate Specific Policy
Area and is therefore subject to additional requirements, such as the requirements of the Aggregate Resources
Act, and requirements outlined in an agreement signed by Lafarge Canada Inc. on May 27, 1992. Land use
mapping for the Site and adjacent properties is included in Appendix A.
According to the Loyalist Township Zoning By-Law 2001-38 (Cumming Cockburn Limited 2001), as amended, the
Site is located within an Extractive Industrial (M4) Zone. Permitted uses for the M4 zoning designation are diverse,
and include aggregate processing plants. Based on an exception provision within By-Law 2001-38 (Extractive
Industrial Exception Two – M4-2 Zone) the Site is also situated in a zone which permits the establishment and use
of a cement plant. This zoning also allows the cement plant to receive and use fuels, including LCFs. Lands
surrounding the Bath Plant are a mixture of M4, rural, prime agricultural, and open space designated zones. A
zoning designation map indicating zone classification for the Site and surrounding areas as per By-Law 2001-38
is also provided in Appendix A.
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2.6 Project Proponent
The name of the designated Project is “Evaluation of Low Carbon Fuels – Project 3, Considerations for Permanent
Use”. Contact information for the proponent is provided in Table 2.1 below.
Table 2-1: Project Proponent
The proponent is:
Lafarge Canada Inc.
P.O. Box 160 / 6501 Bath Road
Bath, Ontario K0H 1G0
The primary contact person is:
Mr. Blair Walker
Environment and Public Affairs Manager, Eastern Ontario
1-613-691-2491
3.0 PROJECT DESCRIPTION (ESP STEP 2)
The proposed LCF types, handling and processing systems, and storage requirements are described in further
detail below. The Bath Plant layout, specifically outlining the areas to be used for the LCF operations, is illustrated
on Figure 2, and a schematic of the LCF Management System layout is shown on Figure 3.
3.1 Service Areas and Fuel Types
As discussed in Section 2.4, Lafarge has regulatory approval (ECAs #2950-AK2RFX and #9606-8Z7S9Z) to run
a Pilot Project to use/assess a broad range of mixed biomass LCFs in the cement manufacturing process. For this
Project, Evaluation of Low Carbon Fuels – Project 3, the following types of mixed biomass LCF materials have
been chosen from the longer list to undergo the current environmental approval and assessment process
(Round 5):
Non-recyclable rubber (not including used tires) and rubber recycling by-products (e.g., polyester/nylon fiber
from tire recycling facilities);
Non-recyclable plastics from Material Recovery Facilities and the ICI sector; and
Non-odorous oversized and/or unused compost materials (e.g., twigs, plastic bags).
These materials are classified as by-products of existing recycling programs (i.e., have passed through an existing
recycling program and been rejected), or are not eligible for recycling, and are therefore destined for landfill. None
of these materials are deemed ‘hazardous waste’ under the Ontario Environmental Protection Act, General –
Waste Management Regulation 347.
The materials will be generated from within a service area comprised of the provinces of Ontario and Quebec and
the state of New York, U.S.A. Local materials meeting the three sustainability criteria will be preferentially sourced;
materials from Quebec and New York will be used as necessary to ensure a constant source of fuel to the plant
based on commercial realities. The fuel types selected for Round 5 were so chosen due to their availability in
sufficient quantities to afford a regular supply.
All of these LCF types are expected to perform well as fuels, to reduce emissions, to reduce greenhouse gases
directly and indirectly, and to provide local opportunities for economic development – all the while meeting the
economic criteria necessary to justify capital expenditures.
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3.2 Project Phases
For this Project, Evaluation of Low Carbon Fuels – Project 3, three distinct phases of project development have
been identified: construction, operations, and retirement. A discussion of each phase is provided below.
3.2.1 Construction
As discussed in Section 2.4, Lafarge has received approval (ECA #3610-8Y9NVD) to construct and permanently
operate the LCF fuel management system. This includes the LCF fuel staging/processing system (shredding,
blending, mixing, and grinding the fuel) and fuel delivery system (off-loading, storage, and injection into the kiln).
Consequently, no potential construction-related effects for the fuel platform were assessed for Evaluation of Low
Carbon Fuels – Project 3.
Lafarge proposes to re-grade and re-surface the area identified as LCF 1 on Figure 2 and construct a covered
structure to store processed LCFs. This structure will be temporary in nature, similar to a large hoop tent, installed
directly on the aggregate surface (no flooring), with electricity and water supplied from the cement plant. In addition,
a small, shallow lined collection pond is proposed in LCF 1 to collect surface runoff from the graded aggregate
pad. This infrastructure was assessed as part of the Evaluation of Low Carbon Fuels – Project 1. Consequently,
this proposed infrastructure is not being assessed in Evaluation of Low Carbon Fuels – Project 3.
No other construction activities have been identified for Evaluation of Low Carbon Fuels – Project 3.
3.2.2 Operations
For Evaluation of Low Carbon Fuels – Project 1, Lafarge is proposing to receive and process up to 135,000 tonnes
of LCF per year. A maximum of 250 tonnes of LCF per day would be used as fuel in the cement plant, with
potentially another 125 tonnes of LCF per day processed on-Site and shipped off-Site to third party users. No
changes to the tonnes of LCF received or processed per year are proposed for Evaluation of Low Carbon Fuels –
Project 3.
Further details on the operations phase of the Project are provided in Sections 3.3 through 3.8.
3.2.3 Retirement
All LCFs stored on Site will be fully used or will be removed from the Site and shipped to other approved fuel users
or to an approved waste management facility for disposal or other uses. Remaining equipment will be dismantled
and removed from the Site. No residual impacts from this Project are expected.
The Bath Plant has quarry reserves representing over 100 years of operation and there is a Quarry Rehabilitation
Plan in place that describes the eventual closure of the quarry operations and cement plant.
3.3 Low Carbon Fuel Transport
Lafarge has received approval (ECA #9606-8Z7S9Z) for a maximum of 1,200 tonnes of LCF to be received at the
Site per day, via fully enclosed trailers, tarped dump trucks, or by railcar. For Evaluation of Low Carbon Fuels –
Project 3, no additional increase in maximum LCF tonnage received at the Site per day is required.
LCF material is typically shipped to the Lafarge Bath Plant on a campaign basis, due to the commercial realities
of material availability. The estimated maximum number of trucks transporting LCFs to and from the Site in a single
day is 21 (15 trucks delivering LCF to the Site, and 6 trucks leaving the Site with processed LCF destined for third
party consumers) or residual wastes (destined for recycling/disposal).
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All haulers delivering LCF will be required to comply with Lafarge’s transportation program. This includes
instructions around using public roadways, remaining within approved traffic routes, refraining from the use of
engine brakes, complying with Site safety & insurance requirements, and to be cognizant of the concerns of the
local community. Although the facility will be open continuously 365 days per year, Lafarge’s experience is that
the vast majority of truck traffic will be Monday to Friday, during daylight hours, due to commercial practicalities.
Where practical, LCF will be shipped to the Lafarge Bath Plant using railway gondola cars. The Site railway spur
can accommodate approximately 10 to 16 gondola cars, dependent on their length. This equates to a maximum
shipment of 600 tonnes of LCF materials that would be unloaded and stockpiled on Site.
3.4 Fuel Staging/Processing System
Lafarge currently holds a permanent ECA (#3610-8Y9NVD) for the operation of the LCF staging/processing
system, for activities including sorting, shredding, blending, screening, magnetic separation, and grinding. A brief
description of the LCF staging/processing system is provided below. Further details of the system can be found in
the Design and Operations Report for the Low Carbon Fuel Initiative (Lafarge 2016), and on the sorting and
shredding operations in Sections 3.4.1 and 3.4.2 below.
Deliveries of LCFs are booked in advance through the Lafarge Site Manager (or designate) or an authorized and
trained third party operator designated by Lafarge. All LCF suppliers are required to submit and have approved a
Fuel Data Sheet, prior to scheduling, for each type of LCF. The Fuel Data Sheet includes a detailed description of
the material types expected in the LCF load and associated testing required.
Characterization of the LCFs includes analyses of combustion properties (e.g., moisture content, ash content,
heating value) and chemical contents (e.g., chlorine, sulphur, nitrogen, hydrogen, oxygen, metals). Further testing
details can be found in the Low Carbon Fuels Demonstration Project Testing Plan (Golder 2016). Lafarge has
internal Quality Assurance and Quality Control standards that must be contractually met in order for the fuels to
be accepted at Site.
3.4.1 Sorting Operations
Lafarge has learned through the Low Carbon Fuel Demonstration Project that it cannot rely solely on third party
suppliers to provide LCF materials for the plant in a suitable form. To facilitate a continuous flow of materials and
manage supply fluctuations, Lafarge must be prepared to accept unprocessed (whole) LCF materials (as approved
under their permits) directly from waste generators as well.
Materials that come directly from waste generators would require further processing, to prepare the fuel for
shredding. The fuels would require sorting to segregate the desired LCFs from unsuitable materials (such as bricks
or metal). This sorting process would provide the Quality Control that Lafarge requires: namely that the materials
destined for the shredding and fuel delivery systems are of high quality for cement production and meet the Lafarge
approval requirements. All rejected materials would be shipped off-Site to the municipal landfill, recycling depot,
or licensed disposal facility (dependent on the type of reject material), or reused for another purpose. Lafarge
proposes to sort the LCFs brought to the Site in the area identified as LCF 1 on Figure 2. Most sorting activities
would take place inside a covered structure to protect the fuels from the elements (e.g., rain/snow).
In addition to the sorting process described above, a screening process for small metals (e.g., nails) takes place
during the fuel off-loading system (see Section 3.5.1 for more information).
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EVALUATION OF LCF - PROJECT 3 DRAFT PROJECT DESCRIPTION
May 24, 2017 Report No. 1649607 11
3.4.2 Shredding Operations
Prior to use as fuel through the primary fuel combustion system, the LCFs must be finely shredded into a consistent
size suitable for injection with the pulverized coal and petroleum coke currently used in the cement kiln. Under the
Site’s permanent ECA (#3610-8Y9NVD), shredding operations may be conducted by Lafarge or a third party –
either on-Site or off-Site – with shredded fuel product either used at Site in the cement manufacturing process or
shipped off-Site to other regional fuel users.
LCFs, either processed or partially processed (shredded), or unprocessed (whole), will be supplied from a variety
of suppliers, or directly from waste generators, as determined by market availability. Lafarge has learned through
the Low Carbon Fuel Demonstration Project that access to LCFs is improved if they can provide the shredding
services. This allows the plant to have a more consistent supply of LCFs, and to exercise better quality control
over the materials. Consequently, Lafarge proposes to shred LCFs at the Site, in the area identified as LCF 1 on
Figure 2. This area is ideal for the shredding activities as it allows for unprocessed LCF materials to be brought to
the Site by railcar (a rail spur that can accommodate from 10 to 16 gondola type rail cars, dependent on their
length, is adjacent to LCF 1) or truck. LCF 1 is approximately 2.1 hectares in size.
The equipment at LCF 1 to be used for the shredding operations has not yet been purchased. It is expected that
mobile equipment (such as a hydraulic excavator or ‘grappler’) would be used to transfer the raw materials arriving
on the railway cars to either a temporary storage pile or directly to the shredding equipment. A typical shredding
machine, for an operation of this magnitude, would be a portable machine with a cutting adjustment to allow the
raw materials to be processed into two sizes. Generally, the raw materials would be shredded in a two-step
process, from coarse (larger particle size) to fine (smaller size), to ensure a consistent quality fuel. Other mobile
equipment, such as a front end loader or trailer, would be used to transfer the processed fuels into temporary
storage piles or directly to the fuel delivery system. LCFs would be shredded in batches, dependent on material
availability and cement plant requirements, with shredding activities taking place on and off over the cement plant
operating hours (24 hours a day, 7 days a week) as required.
Shredding machines generally come equipped with water sprays and light gauge metal enclosures and hoods
over the conveyors to minimize the production of dust and keep any dust in close proximity to the shredders.
In addition, to control the dispersion of dust and fine particles, Lafarge would limit the operations of the shredding
equipment during high winds. These measures are anticipated to control dust generated from the shredding
operations. The Site housekeeping program would also be amended to include the shredding operations, so that
the area is kept in an orderly and clean manner.
A covered structure, approximately 20 m wide by 40 m long, will be installed in LCF 1 to store processed fuels prior
to use in the plant and protect them from the elements (e.g.; rain and wind). On occasion, shredded materials
could be stored outdoors, under temporary cover such as tarps, for short periods of time to facilitate material
handling and storage activities. A lined collection sump will also be installed to capture surface water runoff from
the area for sedimentation control and use as dust control. It is anticipated that for most of the year the lined sump
would be dry. However, in the rare event that excess water exists, overflow from the pond would be directed to
the main quarry sump and managed with the quarry’s surface water management system.
To control surface runoff laden with dust and fine particles at LCF 1 area, activities would be limited during intense
rain events and snow would be removed from working areas prior to commencement of shredding operations.
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May 24, 2017 Report No. 1649607 12
3.5 Fuel Delivery System
Lafarge currently holds a permanent ECA (#3610-8Y9NVD) for the operation of the LCF delivery system. For the
Pilot Project (ECAs #2950-AK2RFX and #9606-8Z7S9Z), a maximum of 75 tonnes of LCF may be subjected to
thermal treatment per day. For Evaluation of Low Carbon Fuels – Project 1 and Evaluation of Low Carbon Fuels
– Project 2, a maximum of 250 tonnes per day is proposed for the listed LCFs on a permanent basis; this
represents approximately 30% of the annual fuel usage and matches the stated goal of the Cement 2020 initiative.
No changes to the maximum tonnes of LCFs subjected to thermal treatment per day are proposed for Evaluation
of Low Carbon Fuels – Project 3. Currently, fuel types used for the cement manufacturing process (i.e., coal,
petroleum coke, virgin biomass) are listed in the existing ECAs without limit, other than practical fuel demand
requirements.
A brief description of the LCF delivery system is provided below. A schematic of the delivery system is illustrated
on Figure 4. Further details of the system can be found in the Design and Operations Report (Lafarge 2016).
The System has three distinct phases or sub-systems, as follows:
Fuel Off-Loading System;
Fuel Storage System; and
Fuel Injection System.
3.5.1 Fuel Off-Loading System
The Fuel Off-Loading System transfers prepared LCF into the Fuel Storage System for subsequent controlled
injection into the kiln burner by the Fuel Injection System. The Fuel Off-Loading System is located east of the
cement storage dome.
Fuel is typically transported to the Fuel Off-Loading System in self-unloading tractor trailer trucks (e.g., walking
floor). The trucks back up to a stationary bunker where the prepared LCF is unloaded into a receiving hopper. The
fuel is subsequently transferred via a conveyor to the screening station. The presence of nails and other metal
components can result in damage to conveyance systems and, if in high enough amounts, can create a risk of
product contamination. Magnetic separation is a common material processing step and the number of magnetic
separation stages and the type of system will vary depending on the likelihood of metal contamination in the fuel
source material and the nature of the contamination. The screening station, in a series of steps, removes oversized
LCF materials and detects and removes small metal materials. These residual wastes (e.g., tramp metal, off-spec
material, and materials arising from maintenance activities on equipment) will be removed from the LCF off-loading
system and collected in bins for transport to a recycling/disposal facility.
After screening, the prepared LCF is transported via conveyor to a 3-way diverter valve in the Fuel Holding System.
LCF material is separated into one of two bulk storage bins, depending on the type of fuel, or it can bypass the
Fuel Storage System and go directly to the Fuel Injection System.
3.5.2 Fuel Storage System
The Fuel Storage System acts as the buffer between the Fuel Off-Loading System and the Fuel Injection System
and, where both bulk storage bins and/or the bypass are in use, affords the opportunity to blend different types of
LCFs. Typically, the Fuel Storage System controls the unloading of material from the truck trailers.
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May 24, 2017 Report No. 1649607 13
The Fuel Storage System is comprised of two bulk storage bins to hold the off-loaded prepared LCFs. These bins
can store up to an estimated 150 tonnes each. Two discharge conveyors transport the fuel from each bin to the
Fuel Injection System. These conveyors operate independently, allowing different ratios or blends of fuel to be
transported. The blends of fuels will differ, dependent on the fuel availability at the time.
3.5.3 Fuel Injection System
From the Fuel Holding System, LCFs are transported via conveyor to the second screening station. Oversized
materials, or LCFs that have clumped together, are separated and directed to the grinder (or shredder) for further
processing. All materials are then transported via a long conveyor up to the burner floor in the mill building into the
kiln metering bin.
Using a series of conveyors, the fuel is transported to the air lock. The air lock is a rotary valve that keeps air from
entering the LCF conveying system. The kiln feed blower moves the fuel from the air lock to the injection point and
ultimately into the kiln. The flow rate of traditional and low carbon fuels is controlled to achieve a uniform delivery
and to ensure that minimum temperatures in the kiln are maintained. The average temperature in the combustion
zone is 1,450 degrees Celsius (the flame is significantly hotter); the residence time at temperatures in excess of
1,000 degrees Celsius is over 10 seconds. These temperatures are well in excess of the temperatures necessary
to ensure efficient combustion of the fuels used in the process.
3.6 Low Carbon Fuel Efficiency
The Site will generate on average 17-19 gigajoules of thermal energy output from every tonne of LCF used. In a
full production year of 7,400 hours of operation, this equates to approximately 400 Terajoules of energy from LCF
for every 10% co-fire (substitution of traditional fuel with LCF) increase.
3.7 Low Carbon Fuel Storage
ECA #9606-8Z7S9Z allows for a maximum of 19,970 tonnes of LCF to be stored at the Site at any one time. This
includes unprocessed (whole) LCFs, partially and fully processed LCFs, and residual waste. Storage of LCF is
critical to the operation of the plant to facilitate a continuous flow of materials and manage seasonal supply
fluctuations (for example, asphalt shingles would only be available in the summer during the roofing season). No
changes to the maximum storage volume of LCFs at the Site at any one time are proposed for Evaluation of Low
Carbon Fuels – Project 3. Storage areas associated with the LCF are illustrated on Figure 2 and are described in
Table 3-1. Further information regarding LCF storage capacity at the site is provided in the Design and Operations
Report (Lafarge 2016). DRAFT
EVALUATION OF LCF - PROJECT 3 DRAFT PROJECT DESCRIPTION
May 24, 2017 Report No. 1649607 14
Table 3-1: Low Carbon Fuel Storage Areas
LCF Area Number
Description Type of Storage
LCF 1
2.1 hectare area situated west of the existing Bath Plant Solid Fuel Storage Area and abutting a section of the on-Site railway spur
LCF staging and processing operations will take place here. Short term storage of self-unloading trailers and dump trucks of unprocessed, partially and fully processed LCFs will be present. Temporary working stockpiles of unprocessed LCFs will be stored uncovered on the ground; stockpiles of partially and fully processed LCFs will be stored under a covered structure. On occasion, processed LCFs could be stored outdoors, under temporary cover such as tarps, for short periods of time to facilitate material handling and storage activities.
LCF 2 Repurposed former “Bunker C” building located near rail spur to west of cement storage silos
Short term storage of self-unloading trailers and dump trucks of unprocessed, partially and fully processed LCFs will be present.
LCF 3
Fuel Delivery system, located east of cement storage dome and south of kiln burner system, at grade and at the kiln burner elevation
Trailers, or storage with walking floor bins, of processed LCFs.
LCF 4 “LSI” building and storage hall Temporary working stockpiles of partially and fully processed LCFs. This storage is inside a building.
LCF 5 10 hectare area located east of the storage hall
Short term storage of self-unloading trailers and dump trucks of unprocessed, partially, and fully processed LCFs will be present.
FF 1 Existing stockpile area for marine shipments of fossil fuels, gypsum, and slag
Unprocessed, partially, and fully processed high density LCFs may be stockpiled here temporarily, in addition to fossil fuels. Non-hydrophobic fuels, or otherwise unsuitable for outdoor storage, will be covered.
3.8 Relevant Bath Operations Activities
The Bath cement plant has been in operation for over 40 years, and has continually sought to improve the
efficiency of its operations and promote an environmentally sustainable business. The use of LCFs at the Bath
plant has been under consideration for many years, with the benefits/impacts to the plant’s sustainability approach
(environmentally sound, socially responsible and economically viable) carefully evaluated. Operational activities
that have been considered are water usage, water discharge to the environment, and ash disposal.
3.8.1 Water Usage Relevant to the LCF Operations
Freshwater is supplied from Lake Ontario for dust control and, if necessary, fire protection at the cement plant in
accordance with the Permit to Take Water (PTTW) No. 4454-9ABRLX, dated August 7, 2013. Water is also
obtained from the on-Site quarry sumps in accordance with PTTW No. 6713-9QJJU9, dated January 19, 2015.
No changes to water usage are anticipated from the use of LCFs.
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EVALUATION OF LCF - PROJECT 3 DRAFT PROJECT DESCRIPTION
May 24, 2017 Report No. 1649607 15
Surface water runoff from the staging/processing area (LCF 1) will be contained as much as practical in a lined
collection pond and used for dust control during the fuel shredding process. Water from the plant and/or the quarry
may be used to supplement the runoff water, if necessary, for dust control; however, the volume of water is
expected to be minimal.
3.8.2 Water Discharge to the Environment
The Bath plant currently has a stormwater management pond on the south end of the Site. This pond is regulated
by the Ontario government under ECA No. 3466-6G6PMQ, dated September 27, 2005. Under that regulatory
approval, Lafarge must monitor the pond on a weekly basis; all measured parameters must meet the stipulated
regulatory criteria prior to releasing the water to Lake Ontario.
The environmental assessment conducted for Evaluation of Low Carbon Fuels – Project 1 demonstrated that no
changes to the water quality in the stormwater management pond are anticipated from the processing and use of
LCFs. Should monitoring in the lined sump at LCF 1 indicate otherwise, Lafarge is committed to implementing
mitigation measures to correct the issue, and if necessary, treating the water prior to release to the environment.
3.8.3 Ash Production/Disposal
In a conventional combustion system, ash is produced from the non-combustible portion of fuel which consists of
ceramics, salts, metals, and minerals. The Bath Plant does not produce ash. As fuels are injected directly into the
kiln during the cement manufacturing process, and thus come into contact with the raw materials, the ash
components get incorporated into the final product.
Ash from other combustion sites is a valuable raw material; the Bath plant has historically recycled ash from power
plants as a raw material. This process of incorporating ash into the final product will not change with the use of
LCFs.
4.0 REFERENCES Cumming Cockburn Limited. 2014. Loyalist Township Official Plan. Available from:
http://www.loyalisttownship.ca/index.cfm/business/planning-and-development/official-plan/.
Cumming Cockburn Limited. 2001. By-Law 2001-38. The Zoning By-law of the Corporation of Loyalist Township.
Available from:
http://www.loyalisttownship.ca/default/assets/File/4%20zoning%20bylaw%20table%20of%20contents.pdf.
Golder (Golder Associates Ltd.). 2016. Lafarge Canada Inc., Low Carbon Fuels Demonstration Project, Testing
Plan. September 2016. Available at http://www.cement2020.org.
Hyndman & Associates. 2011. Lafarge Biomass Demonstration Project Summary Report. May 24, 2011.
Available at http://www.cement2020.org.
Lafarge (Lafarge Canada Inc.). 2016. Design & Operations Report, Low Carbon Fuel Initiative, Lafarge Bath
Plant. September 2016. Available at http://www.cement2020.org.
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May 24, 2017 Report No. 1649607 16
Zhang, L., M.J. Blair, and W.E. Mabee. 2015. Co-firing of alternative fuels with fossil fuels in the Canadian
cement industry. Poster presented by Queen’s University at the Lafarge Canada Inc. open house in
Bath, ON, June 2015. Available at http://www.cement2020.org.
Zhang, L. and W.E. Mabee. 2015. Alternative fuel usage in the world cement industry. Poster presented by
Queen’s University at the Lafarge Canada Inc. open house in Bath, ON, June 2015. Available at
http://www.cement2020.org.
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May 24, 2017 Report No. 1649607
Report Signature Page
GOLDER ASSOCIATES LTD.
Rachel Lee Gould, M.Sc. Sean Capstick, P.Eng.
Senior Project Manager Principal
RLG/SC/wlm
Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.
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FIGURES
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LINKROAD
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COUNTY ROAD 4
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EMERALD 40 FOOT ROAD
STOREY STREET
HUYCK STREET
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TOWNLINE ROADBA
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TAYLOR-KIDD BOULEVARD
BIG CREEK ROAD HAM ROAD
GALT STREET
COUNTY ROAD 21
COUNTY ROAD 8
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Base Data - MNR LIO, obtained 2015, CANMAP v2006.4
Produced by Golder Associates Ltd under licence from
Ontario Ministry of Natural Resources, © Queens Printer 2015
Projection: Transverse Mercator Datum: NAD 83 Coordinate System: UTM Zone 18N
REV. 0.0
Mississauga, Ontario
DESIGN
SITE LOCATION
FIGURE: 1PROJECT NO. 13-1151-0041 SCALE AS SHOW N
PROJECT
TITLE
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REVIEW
PRM 21 Dec. 2011
CHECK
LAFARGE BATH PLANT – LOW CARBON FUELPROJECT STORMW ATER MANAGEMENT REPORT
JR 14 Apr. 2016TDAF
14 Apr. 201614 Apr. 2016
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Orillia
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DRAFT
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DESIGN
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PRM 21 Dec. 2011
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LAFARGE CANADA INC. EVALUATION OF LOW CARBON FUELS - PROJECT 1
KD 12 May. 2015RG 12 May 2015
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PRM 24 Jun. 2013
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LAFARGE CANADA INC. EVALUATION OF LOW CARBON FUELS - PROJECT 1
PRM 24 Jun. 2013RLGFSC
24 Jun. 201324 Jun. 2013
LEGEND
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FIGURE: 4PROJECT NO. 13-1151-0041 SCALE AS SHOWN
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PRM 24 Jun. 2013
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LAFARGE CANADA INC. EVALUATION OF LOW CARBON FUELS - PROJECT 1
PRM 24 Jun. 2013RLGFSC
24 Jun. 201324 Jun. 2013
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APPENDIX A Maps
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RO
AD
AR
T M
CG
INN
'S R
OA
D
HEGADORN ROAD
OLD
WILT
ON
RO
AD
FA
IRB
AN
KS
STR
EE
T
LOW
ER
FO
UR
TY F
OO
T
FIS
K R
OA
DPETERS ROAD
KIDD DRIVEKILDARE AVENUE
SH
ER
WO
OD
AV
EN
UE
FA
IRF
IEL
D B
LVD
BA
CK
BE
AC
H R
D
KER
R P
OIN
T R
OA
D
PURDY ROAD
PA
RK
CR
ES
CE
NT
BAYVIEW
RO
ADTO
WN
LIN
E R
OA
D
SWITZERVILLE R
OAD
HEPC
HEP
C
TRANS-NORTHERN OIL PIPELINE
TRANS-CANADA NATURAL GAS PIPELINE
NO
RTH
ER
N A
ND
CE
NTR
AL G
AS
PIP
ELIN
E
1
F
E
D
C
B
A
G
9
8
7
6
5
4
3
2
1
9
8
7
6
5
4
3
2
1
9
8
7
6
5
4
3
2
1
9
87
6
5
4
3
2
9
8
7
6
5
4
3
2
9
8
7
6
54
3
2
1
98
7
6
5
4
3
2
43
40
39
38
37
36
35
34
33
32
31
30
29
28
27
26
25
24
23
22
20
1918
17
16
15
14
1312
1110
4342
41
40
39
38
3736
35
34
33
32
31
30
29
28
27
26
25
24
23
22
21
20
19
18
17
16
15
14
13
12
11
10
42
41
40
39
38
37
36
35
34
3332
3029
28
27
26
25
24
23
22
21
20
19
18
17
16
14
13
12
11
10
40
39
38
37
36
35
34
33
32
31
29
28
27
26
25
24
23
22
21
20
19
18
17
16
15
13
12
11
10
42
41
40
39
38
37
36
35
34
33
32
31
30
29
28
27
26
25
24
23
22
21
20
1918
17
16
15
14
13
12
11
10
42
41
40
39
38
37
36
35
34
33
32
31
30
29
28
27
26
25
2322
21
20
19
1817
16
15
14
13
12
10
4241
40
39
38
34
33
32
31
3029
28
27
22
21
2019
18
14
13
12
11
10
CON. 3
CON. 2
CON. 1
CON. 8
CON. 7
CON. 6
CON. 4
CON. 3
CON. 2
CON. 1
SOUTH SHORE CON.
NORTH SHORE CON.
BROKEN FRONT CON.
LEGEND
Environmental Protection
Agricultural
Rural
Hamlet
Shoreline Residential
Shoreline Residential - 2 designations
Industrial
Aggregate
Resort Commercial
Open Space
Urban Area
Loyalist Township Official Plan - Schedule ALand Use Plan
0 5 101 2 3 4
Kilometres °
November 8th, 2010 Consolidation OPA #20
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Golder Associates Ltd.
6925 Century Avenue, Suite #100
Mississauga, Ontario, L5N 7K2
Canada
T: +1 (905) 567 4444
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