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Airzone Summer 2015 Newsletter

MOECC Plant to Update AERMOD Regulatory Version Models on Regular Basis – Update

As we reported in our previous newsletter, the MOECC was looking into developing an implementation plan for the adoption of new air dispersion models for permit applications. ?The new AERMOD version has been updated by the US EPA based on latest available science, debugging software problems and enhancing usability (according to US regulations).? The plan is being outlined as an annual process and will account for the continued evolution of these models. ?Key elements of the plan include the following:

  • Monitoring and assessing regulatory model update developments on an ongoing basis and discussing with stakeholders, as required.
  • Notifying stakeholders, every year, six months in advance of formally adopting updated versions of the models. ?This will give facilities time to that determine if they will be affected by model updates and if so, to contact their local district office for assistance in developing a path forward, as needed.
  • Posting an Information Notice on the EBR six months following pre-notification to formally adopt the updated model versions. ?Airzone will adopt updated model versions annually as necessary.
  • Updating regulatory data files/instruments, and guidance materials to reflect the adoption of updated model versions, as necessary.

Accordingly, in October 2015 the MOECC will be posting an Information Notice on the Environmental Registry to replace current regulatory air dispersion models under O. Reg. 419/05 with the following updated model versions:

1. AERMOD dispersion model ? Will be updated to AERMOD version 14134 (version date May 14, 2014) [current regulatory version ? 07026]

2. AERMET meteorological preprocessor ? Will be updated to AERMET version 14134 (version date May 14, 2014) [current regulatory version ? 06341], and

3. ASHRAE method of calculation ? Will be updated to Chapter 45 (Building Air Intake and Exhaust Design) of the 2011 ASHRAE Handbook ? HVAC Applications [current regulatory version ? Chapter 44 of the 2007 ASHRAE Handbook]

Once the Information Notice is posted on the Environmental Registry (under EBR), the MOECC will also make available updated Ontario Regional Meteorological data sets that have been reprocessed with AERMET 14134.

One consequence of this continual annual updating of model versions is that companies that are required to annually update their ESDM will need to update their modelling even if no other changes that would impact off property contaminant concentrations were made to the facility.? Updated modelling, even in the absence of changes in emissions, may lead to higher predicted impacts on local air quality and alter a facility?s compliance status.

For help with determining the implications of these changes on your regulatory compliance contact Nicole Shantz at ext. 109, or nshantz[at]airzoneone.com.

Metal Finishers – Industry Technical Standard Under the Local Air Quality Regulation (O. Reg. 419/05)

In May of 2015, the MOECC posted a proposal to the EBR to develop a Technical Standard under the local air quality regulation for the metal finishers industry.

A technical standard is a technology-based compliance approach designed for facilities in a sector that are not be able to meet one or more air standards due to technical or economic limitations; essentially they replace the need to conduct an air assessment (including provision of an ESDM report) when applying for an ECA. ?In this instance, the air standards in question are the new chromium compounds (hexavalent forms) and nickel & nickel compounds, which come into effect July 2016.? The goal of a technology standard is to minimize facility emissions through the use of best available technologies, so-called ?best practices? and/or administrative activities.

The MOECC is now reviewing all comments with continued input from industry stakeholders.

This form of permitting is available to all emitter groups and can be considered as a compliance option.? This option, under O. Reg. 419/05, has been criticised as potentially contravening the adverse effects clauses of the Ontario Environmental Protection Act.

For more information on the plating technical standard and the implications for your company contact Lucas Neil at ext. 111, or lneil[at]airzoneone.com.

Delineation of Ontario Air Zones

As mandated by the Canadian Council of Ministers of the Environment (CCME), the province of Ontario is implementing the Air Quality Management System (AQMS).? Under the AQMS, provinces and territories are responsible for delineating and managing air zones, which are used for ensuring the province meets the Canadian Ambient Air Quality Standards (CAAQS).? Provinces are required to take actions towards CAAQS attainment under the AQMS.? Where CAAQS are not currently met, the Province is responsible for proposing and managing techniques to achieve attainment with the CAAQS.

Ontario is Proposing to Delineate the Province into Three Air Zones:

Air Zone 1 ? Areas with limited pollution from either point or non-point sources or transboundary influence; where air quality management activities are focused on maintaining good air quality.

Air Zone 2 ? Areas under pressure from multiple sources including some or all of the following: non-point sources, smaller point sources, individual large industrial point sources, transboundary influences; where air quality management activities are focused on multiple broad-based initiatives targeting many sources.

Air Zone 3 ? Areas with a concentration of large industrial sources; where air quality management activities are focused on the abatement of local industrial emissions as well as non-industrial sources.

The MOECC is now reviewing all comments with continued input from stakeholders.? At this point there is some uncertainty as to how the delineation of Air Zone?s, and subsequent airshed management within Air Zones, may affect individual emitters.

For more information on the AQMS, Ontario?s proposed Air Zones and how this may affect your regulatory status contact Lucas Neil at ext. 111, or lneil[at]airzoneone.com.

Notifying the MOECC of Discharges

Section 14 of the Ontario Environmental Protection Act (EPA) prohibits the unregulated discharge of contaminants from a facility, while Section 15 of the EPA outlines the requirement to notify the MOECC of any unregulated discharge.? According to these sections, any discharge not approved under Section 9 (e.g. an Environmental Compliance Approval) of the EPA or any discharge that ?is out of the normal course of events? must be reported to the MOECC.? What many companies do not realize is that even small or short term discharges must be reported.

In March, Metcan Industrial Corp., a company that manufactures synthetic slag products, was fined $10,000 for failure to notify the Ministry of a spill to the natural environment.? The discharge of a whitish grey particulate, which lasted only a couple of minutes, occurred from an onsite silo and impacted several employee vehicles of two nearby businesses.

In recent rulings, the Supreme Court of Canada has advised that ?when in doubt, report?, even if the discharge does not immediately appear to be significant.? Spills prevention and mitigation planning are regulatory requirements in Ontario for certain classes of industry (O. Reg. 224/07).

For more information on reporting unregulated spills and discharges to the MOECC contact Franco DiGiovanni at ext. 102, or fdi-giovanni[at]airzoneone.com.

National Pollutant Release Inventory

Preliminary data reported by facilities to the National Pollutant Release Inventory (NPRI) for 2014 is now available through the NPRI Online Facility Data Search. ?The preliminary data is made available for the purpose of engaging reporting facilities to review their submitted data and signal any necessary corrections or updates.

NPRI is now offering a new graphical tool for searching for NPRI reported data via Google Earth.? Google Earth map layers are available through the NPRI website and are available for 2012 and 2013 data.? These layers allow you to search geographically for facilities reporting to NPRI, as well as view their reported data.

If you need help with NPRI requirements contact Roy Sabino at ext. 107, or rsabino[at]airzoneone.com.

Recent Airzone News and New Projects

Airzone was retained by an architectural & engineering firm to assist with a land use air quality assessment for a proposed R&D facility.? Airzone assessed potential air emissions from the proposed facility and submitted an air quality study report highlighting the potential influence of the facility on the surrounding air quality.?? Guidance from the MOECC?s D-Series Guidelines, as well as O. Reg. 419/05 permitting protocols, was followed for the modelling study and report. ?The study also included a partial, screening-level, baseline air quality assessment to determine the facility?s cumulative impacts on local air quality. ?The report has been submitted to the local municipality for review.

Airzone has been retained by the World Bank to review the air emissions impact assessments of a proposed lignite-fuelled power plant; initial reviews have and will be conducted of an associated monitoring network and also of preliminary modelling effort by a USAID contractor using the SCIPUFF model.? The area is in significant non-attainment for PM2.5, and possibly other contaminants, with mixed contributions from subject and non-subject sources.? The Kosovan EIA process concentrates on (and requires) avoiding impacts from subject sources, but does not address non-attainment contributions from non-subject sources.? Non-subject, non-attainment-contributing sources included residential heating sources that used lignite and wood fuel; these energy sources may be displaced by electricity production from the subject source thus helping to achieve attainment.

s.9 permitting client ? Road dust sampling required for a client to meet MOECC procedures in regards to hazardous or potentially hazardous species of road dust (including crystalline silica, etc.).? This required site-specific sampling of road dust silt fraction and chemical analysis to identify constituents present.? Subsequent dispersion modelling with site-specific road dust data was not able to demonstrate compliance without the specification of road dust mitigation; further site-specific measurements are planned to quantify the effectiveness of certain road dust controls (oiling vs watering vs sweeping, etc.).

Airzone has been hired to collect and analyze gas samples from a process exhaust.? The analysis will require determination of sulphur dioxide and reduced sulphur compounds in the process exhaust gas to provide comparison for the on-line monitoring system currently being used to measure exhaust gas levels of these substances.? As such, we have formulated a monitoring program to provide traceable quantitation of concentrations of target compounds for comparison purposes.? The purpose of the project is to ensure that the clients on-line monitoring system is working correctly and so to ensure optimization of the combustion process.

If you require assistance with similar projects, or have questions, contact Franco DiGiovanni at ext. 102, or fdi-giovanni[at]airzoneone.com.