OSEMD-00-PP2 Page 1 of 5

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1 OSEMD-00-PP2 Page 1 of 5 Oil Sans Environmental Management Division Approvals Program Interim Policy Emission Guielines for Oxies of Nitrogen (NOx) for New Boilers, Heaters an Turines Using Gaseous Fuels Base on a Review of Best Availale Technology Economically Achievale (BATEA) DATE: Decemer 14, 2007 ISSUE: Interim Emission Guielines for Oxies of Nitrogen (NO x ) for New Boilers, Heaters an Turines using Gaseous Fuels for the Oil Sans Region in the Regional Municipality of Woo Buffalo North of Fort McMurray ase on a Review of Best Availale Technology Economically Achievale (BATEA) DISCUSSION: As each new oil sans project enters the airshe in the Fort McMurray area, the amount of NO x eing emitte is increasing. While the moile mine fleets are a significant source of NO x emissions, the stationary sources (e.g. turines, oilers, heaters) also contriute to the NO x emissions. A review of information on the NO x emission control BATEA (Best Availale Technology Economically Achievale) for stationary sources etermine that the previous NO x emission requirements appear to e ate in comparison to what may now e achievale. The Regional Ozone Management Framework, as evelope through the Cumulative Environmental Management Association (CEMA) process, recommene that Alerta Environment lea a process to estalish regional BATEA-ase stanars for ozone precursors (which inclues NO x ). The NO x BATEA Review was also reference uring the Alerta Energy an Utility Boar Hearings in 2006 for the Suncor Voyageur Project, the Alian Sans Muskeg Mine Expansion Project, an the Imperial Oil Kearl Oil Sans Project. NO x contriutes to aci eposition, nitrogen eutrophication, ozone an increases in amient levels of nitrogen ioxie (NO 2 ) in the natural environment. POLICY: See Appenix 1 for the Interim Guieline. SUPPLEMENTARY INFORMATION REQUIRED: In support of the interim guieline review an finalization in 2009, a technology review will e unertaken y AENV in conjunction with regional an inustrial stakeholers to valiate the performance of existing technologies an the applicaility of aitional technologies that coul e use in the future (oth comustion an post-comustion NO x controls will e reviewe), as well as consieration of the potential extension of the use of the guieline outsie of the North of Fort McMurray area.

2 OSEMD-00-PP2 Page 2 of 5 BACKGROUND: Fort McKay First Nation expresse concern regaring the increasing levels of NO x an requeste that Alerta Environment etermine or confirm a NO x emission control BATEA for stationary sources in the Fort McMurray area. In aition, the Fort McKay Inustry Relations Corporation issue a iscussion paper in January 2006 regaring NO x emission limits from turines, oilers an furnaces, an technology that they felt coul e use as BATEA. The scope of the NO x BATEA Review was kept to gas-fire new stationary sources north of Fort McMurray to aress the specific concerns rought forwar y the Fort McKay First Nation in Statements of Concern for applications. AENV iscusse the scope an project with the CEMA NO x SO 2 Management Working Group in March AENV issue a request for stakeholer input on NO x emission control BATEA an feeack on raft ocuments in Septemer 2006, March 2007, an Septemer AENV contracte the Alerta Research Council (ARC) to conuct an inepenent review of NO x emission control technologies. AENV evelope a raft emission guiance ocument ase on the input receive from stakeholers an the ARC report. AENV hel a stakeholer meeting on July 5, 2007 to iscuss the status of the NO x BATEA review an viale options for completing the guieline. The Fort McKay IRC representatives an inustry representatives from Regional Issues Working Group (RIWG) requeste the opportunity to prepare an alternative consensus raft guieline for AENV to consier. They sumitte this alternative option to AENV for consieration. The final raft of the Interim Guieline was ase on the alternative option. APPROVED: Original Signe y Shannon Flint DATE: Decemer 14, 2007 DIRECTOR

3 OSEMD-00-PP2 Page 3 of 5 Appenix 1 Emission Guielines for Oxies of Nitrogen (NO x ) for New Boilers, Heaters an Turines Using Gaseous Fuels Base on a Review of Best Availale Technology Economically Achievale (BATEA) Interim Guieline Decemer 2007 The purpose of this guieline is to upate NO x emissions criteria for stationary sources. Currently, these limits are ase on CCME (1992, 1998) an CASA (2003). Concerns have een raise as to the applicaility of these guielines ase on technology improvements (ARC, 2007). This guieline is interim an is intene for review an finalization in The guieline has two primary components: Compliance Limit is the minimum operational performance limit a given piece of equipment must achieve in orer to meet approval conitions. Performance Target 1 represents the approximate level of NO x emissions achievale y using the est availale NO x control comustion technology economically achievale an operate uner normal conitions an average over a year. It generally represents a etter level of NO x control than is require to meet the compliance limit. The esign, selection an operation of equipment are to e ase on meeting the performance target. It is recognize that in some cases performance target levels may not e realize espite the use of the est availale NO x control comustion systems or that the est availale NO x control comustion systems may not e appropriate for all applications. Information gathere uring the operation of units will e use to estalish future performance targets an to guie future equipment selection, esign an operation to minimize NO x emissions from susequent facilities. During guieline finalization as contemplate y this interim guieline, oth comustion an postcomustion NO x controls will e reviewe. Monitoring of these targets will e ase on the CCME guielines that are liste in references section. The compliance limits an performance targets are shown in Tale 1. 1 This target is not to e use in the same context as the Target in the Specifie Gas Emitters Regulation (SGER) where it is set for Greenhouse Gas (GHG) reuction compliance of a facility.

4 OSEMD-00-PP2 Page 4 of 5 Tale 1: Emission Guielines for NO x Type of Unit Su type Fuel Type Compliance Limit (g/gj) Performance Target (g/gj) a Gas Turines 20.4* c HRSG Heater >10.5 GJ/hr Boiler > 10.5 GJ/hr Inustrial OTSG natural gas alternate gaseous fuel incluing refinery fuel gas, prouce gas, etc. HRSG heat recovery steam generator OTSG once through steam generator a An annual average value Base on CASA (2003) or CCME (1992) whichever is more stringent an will e calculate for the entire cogeneration unit, i.e. turine plus HRSG, in accorance with the methoology specifie in the CASA or CCME guielines. c To e etermine as part of the guieline finalization To e etermine as part of the guieline finalization, ut for interim to e ase on CASA (2003) or CCME (1992) whichever is more stringent *The Performance Target for gas turines () is ase on heat input Note: Energy input for heaters, oilers an steam generators is ase on higher heating value. Energy input for gas turines is ase on lower heating value. The asis for the performance targets is natural gas. This interim guieline is intene for: New approvals Amenments to existing approvals that involve new stationary sources Existing approvals with greater than 2 years elay etween approval an start of construction Replacement of existing equipment at the en of esign life Potentially, projects constructe in phases/stages, for phases commencing construction after August 2, 2007, ase on a case-y-case etermination y AENV. In support of the interim guieline review an finalization in 2009, a technology review will e unertaken y AENV in conjunction with regional an inustrial stakeholers to valiate the performance of existing technologies an the applicaility of aitional technologies that coul e use in the future. This interim guieline was evelope for immeiate use in the AENV approvals process for new gas turines, oilers an heaters operating in the oil sans region in the Regional Municipality of Woo Buffalo north of Fort McMurray. Potential extension of the use of the guieline will e consiere uring the process for guieline finalization.

5 OSEMD-00-PP2 Page 5 of 5 References Alerta Research Council Inc. (ARC) Technologies for Reucing NO X Emissions from Gas-Fire Stationary Comustion Sources. Prepare for Alerta Environment y the Alerta Research Council, Caron an Energy Management. Feruary 27, Canaian Council of Ministers of the Environment (CCME) National Emission Guielines for Stationary Comustion Turines. PN CCME NO X /VOC Management Plan, Mutistakeholers Working Group an Steering Committee. Winnipeg, MB. CCME National Emission Guielines for Commercial/Inustrial Boilers an Heaters. CCME NO X /VOC Management Plan, Mutistakeholers Working Group an Steering Committee. Winnipeg, MB. Clean Air Strategic Alliance (CASA) An Emissions Management Framework for the Alerta Electricity Sector, Report to Stakeholers. Prepare y the Electricity Project Team. Novemer 2003.