Ontario (MOE) Proposes Changes to Air Dispersal Models for Regulatory Compliance
On Mar. 20th, 2001, the MOE proposed replacing the Reg. 346 dispersal model with models from the US EPA. ? The MOE plans a revised modelling guide describing a tiered approach for CofA applications. The screening-level SCREEN3 model will be used for the first tier as an interim until a screening version of AERMOD is produced. ? If necessary, more sophisticated second tier models will be used, AERMOD and ISC-PRIME (in case of appreciable pollutant downwash, until AERMOD is modified with the PRIME code are proposed. ? The new guide will be finalized in 2002 with a 3-5 year phase-in period. ? In the interim, CofA s can use the old model. ? If under certain conditions, the old and new models differ possibly affecting facilities regulatory status, it is the responsibility of the facility to apply the new models and ensure regulatory compliance.
Comprehensive Certificates of Approval (Air)
To streamline management of CofA s and MOE s approval process, Comprehensive CofA s are now acceptable. ? Unlike standard, source-specific CofA s, Comprehensive CofA s itemize all sources of a facility s air emission on one Certificate, to enhance operational flexibility, since amendments are no longer needed when circumstances change as long as compliance is demonstrated. ? It requires, as a prerequisite, maintenance of an emission inventory database and participation in the Ministry s Air Standard-setting process. ? This permitting alternative is a valuable tool for larger facilities, or those where plant modifications are frequent.
Ontario Proposes Risk Management Framework for Setting Air Standards
The Province is proposing a transparent three-stage framework for setting future air quality standards. ? Stage 1 will identify substances (priorities) most in need of a new or revised standard. ? Stage 2 will assess risks. ? Stage 3, risk management, is potentially of most interest to industry, since it incorporates practical considerations in standards implementation. ? Stakeholder input is encouraged at all stages and may require emission inventory development and dispersion modelling to identify issues on behalf of individual industries or industry associations.
Revised Air Standards
Air quality standards for 18 substances have been developed utilizing the Risk Management framework (as per MOE s Standard s Plan revised Oct. 1999) including: acrylonitrile (I), ammonia (I), chlorine (I), chloroform (I), ethyl benzene (I), ethyl ether (I), n-heptane (F), n-hexane(P), hydrogen chloride (I), isopropyl benzene (F), methanol (F), methylethyl ketone (I), methylisobutyl ketone (F), mineral spirits (I), propylene oxide (I), toluene (F), vinylidene chloride (F) and xylene (F). ? Values are either final (F), interim (I) or proposed (P). ? Revised standards for perchloroethylene and dichloromethane posted in 1998 remain as interim ? standards. ? Xylene remains under review. ? Facilities emitting any of these substances should develop a site-wide emission inventory and evaluate compliance to the revised standards with the SCREEN3 or AERMOD models before they become concerns and to allow facilities or industry groups to voice issues about the proposed standards to the MOE.
Emissions Reporting and Standards
New Emission Reporting Requirements
On May 1, 2001 O. Reg. 127/01 amended regulation 227/00. ? The amended regulation requires reporting of air emissions from a much wider range of facilities annually. ? Reports on 358 air contaminants are required, however 268 of the substances overlap with NPRI reporting requirements. ? Facilities will report in 2002 on 2001 emissions. ? In 2003, the regulation requirement will spread to smaller facilities.
New Emission Limits
In 2001, lower regulated limits (caps) for SO2 and NOx took effect for coal and oil-fired facilities generating greater than 25 megawatts in Ontario s electricity sector. ? Future limits to cover generating facilities not previously capped (e.g., combustion turbine units) are also planned. ? Non-compliance may lead to fines or loss of the license to generate or sell electricity. ? New emission limits for other sectors are planned for 2003. ? The MOE plans a consultative process to define the scope of these limits.
Emission Performance Standards
The MOE is also proposing emission performance standards (rate of emission expressed as a mass emitted per megawatt-hour, as opposed to total emissions) for SO2 and NOx for coal and oil-fired generating facilities greater than 25 megawatts producing electricity for Ontario, including out of province facilities. ? New combustion turbine units in the province will have emission performance standards written into their CofA s. ? Non-compliance with the ? standards could result in fines or loss of the license to generate or sell electricity in Ontario.
Emissions Reduction Trading
The MOE is proposing the use of an emissions reduction trading system for SO2 and NOx across all sectors to allow a cost effective and flexible approach to meet air quality standards. ? Credits could be purchased from emitters within or outside Ontario in the regional airshed and would be discounted with distance from the purchaser s site.
On the Federal Front ? Canadian Environmental Protection Act (CEPA)
Sections 193-205 of CEPA allows the Federal Minister to request preparation of emergency plans for accidental releases of substances declared toxic? under CEPA. ? The List of Toxic substances is currently being assessed, but at present 25 of the 44 PSL1 substances are considered toxic. ? These are: benzene, benzidine, bis (2-ethylhexyl) phthalate, bis (chloromethyl) ether, chlorinated wastewater effluents, chloromethyl methylether, creosote-contaminated sites, 3,3′-dichlorobenzidine, 1,2-dichloroethane, dichloromethane, effluents from pulp mills using bleaching, hexachlorobenzene, hexavalent chromium compounds, inorganic arsenic compounds, inorganic cadmium compounds, inorganic fluorides, oxidic sulphidic and soluble inorganic nickel compounds, polychlorinated dibenzodioxins, polychlorinated dibenzofurans, polycyclic aromatic hydrocarbons, refractory ceramic fibres, short chain chlorinated paraffins, tetrachloroethylene, 1,1,1-trichloroethane and trichloroethylene. ? These have been added to the Toxic Substances List bringing the total number of substances (as of 2001) up to 47.
The plans must cover prevention, preparedness, response and recovery. ? Although the plan need not be filed with Environment Canada, a declaration that they have been prepared must be filed. ? If substances are potentially released into the air, heavy gas dispersal models or US EPA emergency gas release models can be used to conduct an impact analysis.
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