Airzone Summer 2014 News Bulletin
Assessing Cumulative Air Quality Levels in relation to ECA?s?
The MOE regulates air emissions from stationary facilities is by requiring emissions to meet air quality standards at surrounding locations through its permitting process, i.e., requiring an Environmental Compliance Approval (?ECA?). ?However, most locations already have measurable, pre-existing air quality levels for one substance or another. ?Emissions from a new facility emitting, for example, dust will add to pre-existing airborne dust levels.
The application protocols for an ECA do not require a facility to address these ?background? levels. ?So, ignoring these background air quality levels may under-estimate community-level exposures. ?The MOE have been criticized for not requiring inclusion of background in applications for ECA?s, including the loss of the ?Lafarge Case?, at the Environmental Review Tribunal.
However, the MOE have recently updated their ?Fact Sheets? describing their management of local air quality. One, ?Fact sheet on Framework for Managing Risks?, mentions MOE recognition of ?other sources that contribute to exposures within local communities.? This alludes to those pre-existing background air quality levels that facility emissions will contribute to.
The MOE fact sheet then implies that this is dealt with by the fact that ?The local air quality regulation is used with other tools to manage air quality in Ontario.? Unfortunately, the fact sheet does not provide further description of exactly how local air quality is ?managed? with the stated tools.
For help with evaluating a facility?s contribution to baseline air quality levels contact Franco DiGiovanni at ext. 102, or firstname.lastname@example.org.
MOE Accepts Pulp and Paper Industry request for a Technical Standard
Under Ontario?s air compliance regulations (O. Reg. 419) facilities have three methods to achieve compliance. ?Apart from the most common method, meeting air quality standards at points-of-impingement (demonstrated by dispersion modelling) another method is to register a Technical Standard or a technology-based compliance approach designed for two or more facilities in a sector not able to meet one or more air standards due to technical or economic limitations. ?It involves the use of ?best possible? specified technology or emission reduction techniques.
The MOE have granted a Technical Standard to facilities within the Pulp and Paper sector. ?This exempts (except under special circumstances) facilities from having to demonstrate compliance with air standards via an Emissions Summary and Dispersion Modelling (ESDM) report. ?Instead, emissions performance limits are imposed, operational practices are required for certain key equipment or processes, operational optimization assessments are stipulated, and source and ambient monitoring are required.
For help with the new permitting requirements contact Franco DiGiovanni at ext. 102, or email@example.com.
Guidance for Altering Lists of Substances considered under the Toxics Reduction Act
The Toxics Reduction Act (TRA) and regulation (O. Reg. 455/09) require regulated facilities in Ontario to examine their use of ?toxic? substances, develop plans to reduce their use (if possible) and make annual reports and summaries of their plans available to the public.
At present, ?toxic? substances are defined as those listed under the Federal National Pollutant Release Inventory (NPRI) regulations and acetone. ?If your facility falls under NPRI or (for acetone) O. Reg. 127 reporting requirements then it is possible that you fall under TRA reporting and planning requirements.
The TRA requires that Ontario review this list of substances every 5 years. ?The MOE has proposed a protocol (?Living List Framework?) to review and (if necessary) update the list of substances. ?The protocol will allow additions to the list of substances considered ?toxic,? deletions or modifications.
Once the protocol has been finalized it will be used to consider the next review in 2017.
If you need help with TRA assessments contact Margaret Matusik at ext. 101, or firstname.lastname@example.org.
2014-2015 NPRI Reporting Changes
Starting with the 2014 and 2015 reporting years, Environment Canada have made significant changes to the reporting requirements. ?Of note are the following:
- 2-(2-Methoxyethoxy)ethanol (CAS RN 111-77-3) has been added to the list of Schedule 1, Part 1, Group A substances (10-tonne mass threshold, 1% concentration threshold). Thallium (and its compounds) has been added to the list of Part 1, Group B substances (100 kilogram mass threshold, 1% concentration threshold).
- Eight substances or substance groups have been moved from Part 1, Group A to Part 1, Group B which means that the mass threshold for these substances has been reduced from 10 tonnes, and, in some cases, the concentration threshold has been reduced from 1%. The substances are : Acrylonitrile, Bisphenol A, Hydrazine (and its salts), Isoprene, Nonylphenol and its ethoxylates, Toluene-2,4-diisocyanate, Toluene-2,6-diisocyanate and Toluenediisocyanate (mixed isomers).
- Quinoline (CAS RN 91-22-5) has been moved from Part 1, Group A to Part 2 (polycyclic aromatic hydrocarbons). The 10 tonne mass threshold has been reduced to 50 kilograms for total polycyclic aromatic hydrocarbons, including quinoline, and 5 kilograms for reporting quinoline itself.
- Five substances have been removed from the Part 1, Group A list. NPRI reporting requirements no longer apply to these substances: Allyl chloride, C.I. Solvent Orange 7, 3-Chloro-2-methyl-1-propene, Ethyl chloroformate, and 1-Bromo-2-chloroethane.
In some cases the above changes may required significant changes to your facility?s annual reporting. If you need help with NPRI requirements contact Roy Sabino at ext. 107, or email@example.com.
Federal Government Proposes New Air Pollution Regulations
The Federal government (Environment Canada) intends to propose a number of new regulations concerning air pollution over the next two years. ?The regulations would apply to:
- Limit the amount of nitrogen oxides (NOX) emitted from modern (new) and original (existing), gaseous-fuel-fired non-utility boilers and heaters used by industrial facilities.
- Limit the amount of NOX emitted from modern and original stationary spark-ignition gaseous-fuel-fired engines used by industrial facilities (i.e., those used for gas compression or back-up generators).
- Limit the amount of NOX and sulphur dioxide (SO2) emitted from cement kilns.
The proposed Regulations are part of the federal responsibility for implementing the Air Quality Management System (AQMS). ?The System also includes new Canadian Ambient Air Quality Standards (CAAQS), the establishment of new base-level industrial emission requirements (BLIERs) for other industries and the development of targeted air zone management plans by provinces and territories.
Other regulations are proposed for Greenhouse Gases (GHGs), emissions of ozone-depleting substances, revisions to the Off-Road Compression Ignition Emission Regulations to incorporate large spark-ignition engines, regulations amending the Off-Road Small Spark-Ignition Engine Emission Regulations, regulations amending the On-Road Vehicle and Engine Emission Regulations, regulations amending the Passenger Automobile and Light Truck Greenhouse Gas Emission Regulations and regulations amending the Sulphur in Gasoline Regulations.
If you need help deciding whether these proposed new regulations and amendments apply to your operations contact Dr. Nicole Shantz at ext. 109, or firstname.lastname@example.org.
Recent Airzone News and New Projects
- Airzone reviewed an air quality assessment for a proposed aggregate pit in southern Ontario.
- Airzone assisted a waste management facility update their ESDM report and also provided expertise to assess the air quality impacts of proposed sensitive land use changes adjacent to the facility.
- Airzone were retained to provide general opinion on a temporary municipal bylaw halting the development of recycling facilities.
- Airzone assisted a food manufacturing company investigate odour complaints levelled against them by adjacent businesses.
- Airzone are providing air quality expertise in an Environmental Impact Assessment for a major expansion of a cruise ship facility in the Caribbean. This work includes air sampling and emission assessment.
- Our laboratory has been analyzing PAH air samples from a garbage dump fire in a northern Canadian community.
- Airzone were retained on a Ontario Provincial government project to provide on-site laboratory analysis and air sampling (ambient and personal) for a PCB and hydrocarbon contaminated site in remote (fly-in) northern Ontario site. Ambient sampling was conducted to check on any off-site dispersion of contaminants during remediation, whereas personnel (occupational) sampling was conducted to check on worker exposure during the soil removal process. On-site laboratory analysis was required to provide quick turnaround (24 h) for PCB and TPH soil analysis to guide the remediation work as it progressed. Work also involved asbestos air sampling and analysis on-site to guide building demolition.
If you require assistance with similar projects, or have questions, contact Franco DiGiovanni at ext. 102, or email@example.com, or Phil Fellin, ext. 102, firstname.lastname@example.org.