Provincial Activities
Changes to Emission Reporting Requirements
Most companies must assess if they need to report emissions, under the provincial O. Reg. 127? and the federal NPRI.? ? Amendments to O. Reg. 127 last year included:
- Xylene isomers have been removed from one section but still need to be reported under another section, to reduce redundancy.
- Reporting glycol ethers and mineral spirits that are manufactured, processed or otherwise used if a threshold is exceeded.
- Substances overlapping with NPRI are only referenced and not listed within the O. Reg. 127.
Possible actions: ? your company should review emissions reporting in light of these changes.
15 Air Standard Information Drafts
The Ontario MOE is updating air quality standards for priority contaminants. ? The MOE has summarized data in a series of Air Standard Information Drafts (ASIDs) on 15 substances (Acetone, Acetonitrile, Acrolein, Cyclohexane, Methyl isocyanate, Di(2-ethylhexyl) phthalate, Di-n-octylphthalate, Hexamethylene diisocyanate, Hydrogen cyanide, Hydrogen fluoride, Isopropanol, Methane diphenyl diisocyanate, Phenol, Toluene diisocyanate and Vinyl chloride) to allow stakeholders to comment and provide additional information to consider in setting air quality standards for these substances.
Possible actions: ? If your company uses large quantities of these substances you should review the ASIDs. ? You have until March 31, 2003.
STAC Assessments
STAC (Selected Targets for Air Compliance) is an audit program established by the Ontario MOE to check certain facilities for compliance with Reg. 346 (i.e., whether a facility has an up-to-date Certificate of Approval [Air]). ? A CofA is a live? document; that is, if process changes occur, causing alterations in air emissions (including increased production), an amendment to the CofA may be required. ? The STAC program was established to check this for select companies on a rotating basis. ? For example, in one year, plants possibly emitting particulate metals may be assessed for a STAC report.
Recent guidance from the MOE indicates that adherence to the mandatory O. Reg. 127 emissions reporting now falls under a STAC assessment.
Possible actions: ? Ensure that your company s site-wide air emission summary is kept up-to-date to ease STAC reporting requirements.
Update: Status of New Dispersion Models for Regulatory Compliance
MOE is continuing to develop new guidelines and user manuals for the application of U.S. EPA dispersion model (AERMOD, AERMOD-PRIME, ISC3-ST and SCREEN3). ? This re-affirms the intention to replace the Reg 346? model. ? As noted in previous AirZOne news bulletins (Jan. & June 2001), the implications of adopting the new models may mean that current CofAs may need to be revised because POI estimates from these models differ from those predicted by the Reg. 346 model.
Possible actions: ? Once the new models are adopted, facilities should review if they are still in compliance using the new models.
Ontario s Clean Air Plan for Industry
The Province proposes to expand its emission reduction trading system (for the hydro sector) to other industrial emitters and intends to develop regulated emission limits on nitrogen oxides (NOx) and sulphur dioxide (SO2) by 2010. ? As a result of various consultations since 1998 a revised plan, with more detail included, has been available on the MOE website for public comment (comment period closing Feb 18, 2003).
Ontario s Smog Plan
The Province has posted an update to its Anti-Smog Action Plan report which includes many of the targets under the Clean Air Plan for Industry (CAPI, above), but additionally includes VOCs in terms of target reductions and voluntary initiatives towards meeting Province-wide reductions targets. ? The report indicated that while good progress had been made in reducing emissions of smog-causing substances, further emissions reductions are needed, with greatest reductions required in SO2 emissions.
Changes to Ontario s Air Quality Index
The Air Quality Index (AQI) is a quantification of the quality of Ontario s air. ? Very poor AQI numbers can lead to the Minister requiring temporary industry shut-downs until the air quality level has improved to acceptable levels. ? In recognition of current research, the Ministry will be replacing the category suspended particles? (SP) with fine particulate matter? (PM2.5). ? PM2.5 stands for particulate matter less than 2.5 microns in diameter.
On the Federal Front ? News from Environment Canada
NPRI Reporting
Starting with the 2002 reporting year, facilities that meet or exceed the NPRI reporting requirements for Criteria Air Contaminants, or CACs, (carbon monoxide, sulphur dioxide, nitrogen oxides, volatile organic compounds, total particulate matter, fine? particulate matter [PM2.5] and coarse? particulate matter [PM10]) must report air releases for these pollutants to Environment Canada before June 1, 2003. ? NPRI reporting thresholds are described on a mass-released basis; e.g. if you emit more than 20 tonnes CO/year you will need to report the amount released. ? The criteria that dictate if a facility needs to report are complex ? a case-by-case determination is required for each facility.
Possible actions: ? While some previous activities were exempt, the addition of CACs to NPRI may affect that status as it may affect the modification of exempt activities. ? This should be reviewed.
Environmental Emergency (E2) Plans
As reported in the June 2001 News Bulletin, CEPA (Canadian Environmental Protection Act) Section 199 requires certain facilities to have environmental emergency plans. ? Implementation guidelines are now in place specific to substances defined as toxic under CEPA, especially Schedule 1 substances, although Section 200 of CEPA sets out a risk management framework to deal with a broader range of substances. ? Only declarations of intentions? and completion? of plans need to be submitted to Environment Canada, not the plans themselves.
Possible actions: ? As part of your company s E2 plans, explore emergency release modelling to define impact zones of accidental gaseous releases.
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