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COMMITTEE OF THE WHOLE REPORT Heather Avison, CAO for the Committee of the Whole FROM: DATE: Tara IlWin, City Planner May 14',2018 SUBJECT: ROC Holdings Ltd. Development Permit No. 01-2018 for Lot A, District Lot 1745, Range 5, Coast District, Plan PRP14269 Except Plan BCP43221 (5402 Highway 16 West) RECOMMENDA non: It is recommended that Development Permit No. 01-2018 be issued to ROC Holdings Ltd. for the property legally described as Lot A, District Lot 1745, Range 5, Coast District, Plan PRP14269 Except Plan BCP43221 (5402 Highway 16 West) to permit the conversion of an existing building to a pellet plant and complete the site enhancements to enable this development. BACKGROUND: On January 31, 2018 "Skeena Bioenergy" submitted an application for a Development Permit (DP) for 5402 Highway 16 West. The property owner is proposing the development of a new biofuel pellet plant, site enhancements, and supporting accessory buildings and structures. This pellet plant development will enable Skeena Sawmills to process their waste material into a marketable product. This will help support the overall sustainability of their sawmill operation, as currently it is both costly and difficult to find a market for the wood waste from the sawmilling process. The development will include a production facility, which will utilize the existing onestory metal building on site (formerly the "FolWest" building). The existing building will have additions for fibre infeed, process equipment and electrical senice. The development proposal includes the placement of two new detached accessory structures. The first is. a 5.5 meter x 31 meter (18 x 102 foot) loadout container. The loadout container will be placed on the east side of the production facility building and to sene as the location where trucks will be loaded with the end product. The second accessory structure is for storing raw fibre prior to having the fiber enter the production facility. This proposed structure is a prefabricated "artic shelter" type building to be

ROC Ltd. DP 2 Development Services Component of the Committee of the Whole placed on lock blocks with concrete pad. This structure will be placed on the north east side of the property and will measure approximately 297 square meters. This proposal has involved certain challenges from a redevelopment perspective. Firstly, a unique feature of this site is the location of the City of Terrace Frank Street well house infrastructure on the southeast corner of the property. The City will need to retain access to this infrastructure in order to maintain the well. The City is requiring new right-of-ways or access easements be registered on the subject property to ensure continued access. Secondly, the City of Terrace has an existing 200mm water main and related right-ofway that runs along Frank Street north to south. Following in-depth review with the applicant and internal discussions, it was recommended that the City of Terrace abandon this water main and that it be capped at the extent of Frank Street near Highway 16. The City will undertake the process to discharge the right-of-way on the property and the old pipe will remain buried on the Skeena Sawmills property. A new fire hydrant is required by the Fire Department for the pellet plant operations. This will be installed in the Frank Street dedication near Highway 16. These works are further detailed in a separate off-site Works and Services Report. Two access points to the site are proposed. Access to the site on Frank Street will be for loading transport trucks with the finished product and for access to the transport truck turnaround area. Green Street will be used as the primary access to the employee and visitor parking area. Minor off-site works will be required to improve the surface of Green Street and for the installation of a new driveway. Applicant has shown a landscaping buffer along Highway 16 frontage, which will provide screening from the site and parking area. Plantings shown on site plan near City of Terrace well house are not required. The applicant has submitted details of the emissions technology for this plant as part of their Development Permit package. The attached Appendix outlines the concerns related to air quality and particulate matter associated with wood pellet manufacturing facilities and compares their proposed technology with status quo. When considering new pellet plant developments the Province (MOE) has established emissions limits Total Particulate Matter (TPMs) can have negative impacts on local air quality and human health. Typical wood pellet manufacturing facilities create PM10 and PM2.5 as a result of sawdust dryer exhaust. The applicant has proposed to employ the best available technology for their development, including a low temperature belt dryer and a natural gas energy system, both which will help to drastically reduce the amount of particulate matter being released by the facility. The applicant has indicated this is very new technology with only five similar systems operating in BC at this point. To date, the emissions results that have been shown from these other systems have been positive

ROC Ltd. DP 3 Development Services Component of the Committee of the Whole and fall well below the provincial limits should help maintain the great air quality particulate matter. The technology proposed our community. Overall, this is a promising new proposed development which will reactivate an underutilized industrial site and help to continue to support the growth and viability of the adjacent Skeena Sawmills operation. The proposal meets the intent of the Official Community Plan (OCP) and Zoning Bylaw and the applicant has submitted all items required by staff for the processing of the permit. The property is currently zoned M2 - Heavy Industrial as per Zoning Bylaw 2069-2014 and designated as Industrial in the OCP and as such is appropriate for this use. Reviewed by = David Block, Dir. of Development Services Approved for Submission to Council Tlltw

Existing Conditions Site Photos 1. Driveways into site and subject property to be improved

2. Proposed landscaping buffer along site property line along Highway 16 3. City of Terrace Well house infrastructure on site property

Information on emissions technology for Terrace City Council and 2018-02-14 Skeena Biofuel LTD Sawdust dryer This chart is the limits set by the Provincial Ministry of Environment in 2010 and is to be used as a guideline only. Since 2010 the main focus has been in reducing the Particulate Matter ( PM ) from the sawdust dryer exhaust as this is primarily where the PM 10 and PM 2.5 come from. What is Total Particulate Matter (TPM)? Particulate matter refers to tiny solid or liquid particles that float in the air. TPM consists of filterable and condensable particulate matter. Filterable particulate matter includes all PM10 and PM2.5 emissions, where PM10 and PM2.5 are comprised of particulate matter with aerodynamic diameters less than 10 and 2.5 micrometers respectively. Condensable particulate matter is any material that is not particulate matter at stack conditions, but condenses and/or reacts to form particulate matter immediately after discharge from the stack.

Why are TPM emissions limited? TPM emissions are limited because they can have negative impacts on local air quality and human health. PM2.5 is known to cause aggravation of respiratory and cardiovascular disease, reduced lung function, increased respiratory symptoms and premature death. TPM also impairs visibility, affects climate and can damage and/or discolour structures and property.2 Why does PM10 and PM2.5 come from in the dryer? Traditionally a Rotary dryer has been used for drying sawdust. Rotary dryers usually have a direct fire biomass burner for an energy source with the ash going directly into the dryer with the energy. Rotary dryer technology is also based on high temperatures ( 400c+ ) in the dryer which will partially burn the very small particles of wood and terpenes which create smoke ( blue haze ). It has also been proven that just by reducing the temperature in the dryer from 400c down to 300c that the PM is reduced but not to the required levels today. Smoke or Blue haze from high temperature drying is PM2.5. Example of a permit for a rotary dryer with a cyclone before the 2010 guidelines. This section applies to the discharge of air contaminants from ONE WOOD FIBRE DRYER. The site reference number for this discharge is E243049. 1.1.1 The maximum authorized rate of discharge from the dryer stack is 24 m3/s. The authorized discharge period is 24 hours/day, 7 days/week. 1.1.2 The characteristics of the discharge are exhaust gases from a wood fibre heated drum dryer including particulate matter, nitrogen oxides, sulphur oxides, volatile organic compounds, and carbon monoxide. 1.1.3 The maximum authorized discharge of contaminants shall not exceed a concentration of 180 mg/m3 total particulate matter and condensable organics. 1.1.4 The authorized emission control works are one M-E-C Model reciprocating grate dryer equipped with dual high efficiency cyclones discharging to a 24.4 meter high stack, and related appurtenances approximately located as shown on the site plan in Appendix A. This dryer discharge would have a high percentage of PM2.5 as it uses only a primary high efficiency cyclone for pollution control. The operator would also be limited to a temperature closer to 300c to stay in compliance. Cyclone technology does not remove smoke from the high temperature rotary Dryer technology.

Example of a permit to meet the 2010 guidelines for permitting a rotary dryer AUTHORIZED SOURCES 1.1 This section applies to the discharge of air from a WET VENTURI SCRUBBER treating emissions from a natural gas and wood dust burner and rotary wood dryer. 1.1.1 The maximum authorized rate of discharge is 5 cubic meters per second. 1.1.2 The authorized discharge period is continuous. 1.1.3 The characteristics of the discharge must be equivalent to or less than: Total Particulate Matter (including condensable particulate matter) of 60 milligrams per cubic meter 1.1.4 The authorized works are a System wet venturi scrubber, a natural gas and wood dust burner, rotary wood dryer, emergency bypass stack and related appurtenances A machine called a Wet Venturi Scrubber was installed for this permit. How this works is all the gasses after the separation cyclone are passed through a water bath before discharging to the stack. The water acts as a filter and captures a portion of the particulate. The water then has to be cleaned or replaced. Usually the city sewer system will get this discharge as it is contaminated with high levels of tar from cooling the smoke from the drying process. Please note also that the energy system is a combined natural gas/wood dust burner to minimize the amount of PM2.5 generated from burning wood. This system was best available technology at the time but struggles to meet the required 50mg/m3 Typical Rotary dryer with a biomass burner for energy system

Best available dryer technology 2018 The best technology available today is a low temperature Belt dryer. The temperature of the dryer is kept below 115c. The sawdust is not transported through the dryer with air but on a 20 wide perforated belt which removes the need for any cyclones on the dryer system. The belt is made with a special high temperature woven plastic which also acts as the filter before discharge. Skeena biofuel has chosen to use this dryer technology combined with a natural gas energy system for the pellet plant. This is very new technology with only 5 operating in the Province now and the test results that have come in is very promising. We have applied for a dryer permit based on 30mg/m3 and discussions with the MOE is that they are not concerned with us meeting or exceeding the targeted limit of 30mg/m3. Attached is a test result from belt dryer in BC that is operating right now Summary of Test Results Stack: December 20, 2017 Gas Temperature: 96 o F 35 o C Moisture Content (by volume): 3.32 % Average Stack Gas Velocity: 36.9 ft/sec 11.2 m/sec Total Actual Gas Flow Rate: 173932 ACFM Dry Gas flow Rate at Reference Conditions: 151062 SCFM 71.3 m3/sec Total Particulate Concentration: Dry Basis Actual at Reference Conditions 0.006 gr/ft3 12.8 mg/m3 Front Half Particulate 0.004 gr/ft3 9.7 mg/m3 Back Half Condensable 0.001 gr/ft3 3.2 mg/m3 Mass Emission Rate 7.26 lbs/hr 3.29 kg/hr Belt dryer installation

Conceptual drawing of belt dryer process Image of belt filter

Multi cyclone Other Plant Process https://youtu.be/mp0po7g_bsy Please watch the above video in regards to a controlled baghouse explosion. Baghouses are old proven technology which work very well in some applications and can reach the 20mg/m3 target in the guidelines. They can also be very dangerous when used with explosive dust which led Skeena Biofuels to look for an alternative to solve the dust collection for the plant equipment. What we are doing is combining the primary cyclone discharges for the cooler, Wet hammermill and Dry hammermill into one stack which will go through a secondary multi cyclone before being discharged. Airtek has given us a guarantee of 30mg/m3 or less for the discharge stack of the multicyclone. Airtek has installed enough of these now in Western Canada that they feel very comfortable with this guarantee as the testing they are doing on existing units are coming in under 13mg/m3. It is understood that because both the dryer and multi cyclones are very new technology that the permits have some excess room for the guarantee s. The permit can always be adjusted down once the technology is proven. Cyclones are not known to explode as the concentration of dust is minimal compared to a baghouse. The multi cyclone has been chosen by Skeena Biofuel as it is a safer option that has the potential of being cleaner than a Baghouse.

Fugitive dust The current business plan for Skeena Biofuel is to utilise the residuals from Skeena Sawmill Just in time. There is not other sources of fibre in the area so the pellet plant will only get fibre from the existing sawmill which makes fibre management much easier than other plants who purchase all their fibre on the open market from multiple sources and thus have to manage large stockpiles. Initially there is no requirement for covered storage but it has been considered for the future based on keeping the fibre as dry as possible before drying. It is not expected that there will be any problems with fugitive dust from the plant raw material. Gary Johnston