Ontario Provincial News – Air Emissions Permitting Updates
Air Quality Limits
In February, the Ministry of the Environment (MOE) published a Jurisdictional Screening Level (JSL) List to assist applicants for Certificates of Approval (CofAs) to assess contaminants released to the air that have no MOE standards or guidelines. The MOE has standards or guidelines for almost 350 commonly-used substances in industry; however, there are many lesser-used substances for which no limit guidance exists. Where such substances are necessarily included in a CofA application, their acceptability is evaluated on a case-by-case basis in a different branch of the Ministry and can cause delays in issuing permits. For substances with impacts below the JSL values, no further evaluation is required, and therefore permits are processed in a shorter time. The JSL list supplements the current “de minimis” list, used in much the same way.
The MOE indicates that they will be re-assessing air quality standards for: nickel, chromium and chromium compounds, benzene, PAHs, 1,3-butadiene, dioxins and dioxin-like compounds, and manganese compounds.
If your facility emits these substances contact Franco DiGiovanni (ext. 102) to monitor the standards development process for you and to indicate possible impacts of revised standards on your regulatory compliance.
New MOE Emphasis on “Process Fugitives” and Combined Modelling-Monitoring Studies
Process fugitives are air emissions that are not released through well-defined points such as pollution control devices or exhaust stacks. Examples include loading or unloading vehicles, outdoor material handling or emissions from plant processes into the general plant air that are indirectly emitted to the environment via general plant ventilation.
These emissions tend to be overlooked. “Yard” fugitives (i.e., dust from roadways or storage piles), however, have been more clearly recognized by most CofA applicants.
Where yard fugitives may contain significant quantities of metals, specific emission estimates and dispersion modelling is required to assess off-site impacts as part of a CofA application. In other cases a dust Best Management Plan may be required.
Because process and yard fugitives are difficult to recognize or quantify, the MOE provides guidance on combined modelling-monitoring methods. These methods involve off-site ambient air measurements of emitted substances to “back calculate” (using dispersion modelling) emission rates from any sources with uncertain emission rates. This method may require use of air monitors for extended periods to collect sufficient data for the emission analysis. This method can be considered to be another form of source estimation.
Recent tests of this method by the MOE indicate that plant air imbalance can caused problems with the efficiency of fume hood capture devices as can the improper use of operator cooling fans.
First Announcement of ASAP Process
In June, the MOE announced the Accelerated Select Applications Pilot (ASAP) process to provide a “fast-track” for CofA applications and substantially reduce the review time for CofAs.
In its initial form, eligible facilities must be in the general manufacturing sector, must not be Reg. 419 Schedule 4 companies, must screen-out for noise assessment, require a mandatory pre-consultation with their local district office and must apply for a Comprehensive CofA. Applications must be prepared by qualified preparers and undergo enhanced QA/QC.
Emission Limits for Power Generation
In response to recent interest in using emergency back-up generators to provide electricity in non-emergency situations (e.g., peak-shaving or peak-clipping), the MOE released a proposed policy to limit emissions from these generators to values similar to those from natural gas turbines. The emission limits are NOx 1kg/MWh until 2010 but 0.4 kg/MWh thereafter, PM 0.2 kg/MWh to 2010 but 0.02 kg/MWh thereafter, NMHC 1.3 kg/MWh, CO 0.19kg/MWh and SO2 3.5 kg/MWh with a requirement that diesel generators must use Ultra-Low Sulphur Diesel. These limits, however, do not apply to participants in the Independent Electricity System Operator Emergency Load Reduction Program.
Federal News
Air Quality Alert System Expanded in the GTA
On June 6th the Federal government announced an expansion of the forecasting area of the Air Quality Health Index (AQHI) to the GTA.
The AQHI, issued by Environment Canada, assists people to understand the possible impacts of air quality on health the same day and on the next day. In the scale of numbers from 1 to 10+, 1 represents very low health risk and 10+ represents very high risk. The information and forecast are particularly aimed at individuals sensitive to poor air quality, and offers additional advice on how to minimize health effects on days with poor air quality.