Airzone Winter 2015 News Bulletin
MOE Proposes Plan to Update AERMOD Regulatory Version Models on Regular Basis
OReg 419 was introduced in 2005 as the new regulation governing air assessments for ECA/CofA applications and other types of air quality assessments required by the MOE. OReg 419 provided for the phased-in replacement of the old Reg346 model with newer US EPA air dispersion models (e.g., AERMOD) to assess air regulatory compliance. The US EPA itself updates those models, as the science develops, and the original intent in OReg 419 was to provide a ?rolling reference? to US EPA updates so that the latest US EPA model was automatically the new Ontario regulatory model.
However, it was discovered the regulation could not provide a legally enforceable rolling reference without the MOE providing formal notification of model updates. The last official MOE notification significantly lagged behind US EPA updates. Further, no model update protocol was developed; the resultant situation, at present, is that a mix of AERMOD model versions have been used (and accepted) by the MOE for ECA applications. This is a significant problem because different model versions can provide quite different results for air quality levels, as a result of the developing science. AERMOD updates have been introduced in recent years that (for some facilities) can predict much higher air quality levels. The implication is that even for facilities that had previously demonstrated compliance, they may become non-compliant even where there have been no changes in emissions.
The current mix of AERMOD models creates uncertainty and an ?unlevel playing field? in regulatory compliance and so the MOE has recently announced a draft model update protocol. Full details are yet to be released but some highlights are as follows:
- The MOE will annually review US EPA updates, with the results of the review published in October of each year.
- The published results may (but not necessarily) indicate a new Ontario regulatory version of AERMOD; the new version would be adopted in April of the following year.
Changes in AERMOD model version will need to be accounted for in ECA applications or amendment applications. That means when a new model version is adopted, all new ECA applications or amendments will have to use the new version. Perhaps more importantly, every time there?s an annual ESDM update (for Schedule 4/5 facilities or those with limited operational flexibility/comprehensive ECAs) they will need to remodel with the new version. This may put them out of compliance even if there are no other changes at the facility.
Further, a more detailed description is expected in the coming weeks and months. Dependent on the information forthcoming Airzone may provide additional newsletters, seminars or webinars to communicate this information to our clients.
For help with determining the implications of these changes on your regulatory compliance contact Franco DiGiovanni at ext. 102, or fdi-giovanni\at\airzoneone.com.
Proposed Regulations to Allow Energy-Intensive Industries to Reduce Coal Use
The Ministry of the Environment (MOE) is inviting comments on proposed regulations for industries such as cement, lime, iron and steel, that are significant users of coal-fuel. To assist these industrial sectors switch to low-carbon or renewable (biomass or residual municipal solid waste) fuels the MOE is proposing to exempt such industries from requiring a waste disposal site Environmental Compliance Approval (ECA). Such an exemption means that such sites would not be subject to requirements under the Environmental Assessment Act (EAA).
However sites would still be required to obtain and comply with ECAs under s.9 (i.e. Air & Noise) of the Environmental Protection Act (EPA), for example.
It should be noted that air assessments carried out as a requirement under the EAA usually involved additional components ignored when conducting air assessments for an ECA application. For example, air assessments in support of an application for an ECA do not require consideration of baseline, or background, air quality levels. However, those considerations are usually required when conducting an air assessment as part of an environmental assessment (EA). This can make air compliance demonstration significantly easier for an ECA than for an EA.
For help with evaluating a facility?s contribution to baseline air quality levels contact Franco DiGiovanni at ext. 102, or fdi-giovanni/at/airzoneone.com.
Amendments to Greenhouse Gas (GHG) Regulation (O.Reg. 452/09) and Guideline
The Ontario GHG regulations require that facilities that emit more than 25,000 tonnes of CO2e in a given year to report their emissions to the Province.
The proposed amendments include:
- update to the Global Warming Potential (GWP) values to adopt internationally-accepted values so that the different types of GHG?s (i.e., methane, nitrous oxide, sulphur hexafluoride, nitrogen trifluoride, hydrofluorocarbons, perfluorocarbons, as well as carbon dioxide) can be converted to a CO2e value more accurately.
- more detailed verification statements
- ?administrative clarification on temporary and partial plant closures
- amendments to the guideline to align with reporting methods in other Provinces (e.g., sampling and analysis of fuels)
- clarifying and removing some of the Director consents, approvals and submission requirements
- updating reference to the 2012 NAICS
For help with GHG reporting requirements contact Roy Sabino at ext. 107, or rsabino/at/airzoneone.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.
The Living List Framework (reported in the last news bulletin) will now be implemented by the MOE in 2015 based upon comments.
If you need help with TRA assessments contact Margaret Matusik at ext. 101, ormmatusik\at\airzoneone.com.
Updated Guideline for Control of Air Emissions from Large Wood-Fired Combustors
The MOE has finalized guidance on wood combustors with heat input capacity 3 megawatts or greater. This guidance must be considered for ECA applications or may be required under an MOE Order.
Varying requirements apply to existing, modified or new combustors depending on which you have. Several of the requirements will be phased-in over time.
Requirements include provision of detailed design information (flue gas temperature, residence times, O2 levels), wood fuel management plans, flue gas concentration limits (CO, SPM, NOx, dioxins/furans and dioxin-like PCBs), bi-annual tune-ups and reports and periodic stack testing or continuous in-stack monitoring.
If you need help with wood combustor assessments contact Nicole Shantz at ext. 109, or nshantz/at/airzoneone.com.
Proposed 2016 NPRI Reporting Changes
Environment Canada (EC) has sought comments on its proposal to delete 21 Part 1A substances from the NPRI list, relevant to the 2016 reporting year:
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 to review an indoor air quality assessment after a fuel spill in the basement of an oil-fuel heated home.
Privately Operated Waste Water Treatment Facility ? This project involved assessment of potential emissions from a proposed waste water treatment facility for the purposes of an ECA application. The US EPA WATER9 (v.3) wastewater treatment emissions model was used to estimate emissions from each process within the facility. Use of this model requires a detailed understanding of all waste water treatment steps within the facility and accounts for multiple operating scenarios and waste streams. Emission impacts were modeled using the AERMOD dispersion model.
Airzone reviewed an air quality assessment for a proposed aggregate pit in southern Ontario.
Airzone has a client that operates a wastewater treatment plant in Southern Ontario and we are reviewing the odour monitoring program since there are concerns due to increased population in the area being sensitive to the odour from the plant.
Expanded Cruise Berthing Facility in the Caribbean, EIA ? Involved the review of port operations before, during and after construction of a proposed expansion to the existing cruise ship berthing facility. Emissions (SO2, NO2, dust and greenhouse gases) from approaching and stationary docked marine vessels were assessed using emission factors. On-road vehicle emissions within the study area of the proposed terminal were considered for three scenarios. Vehicle emissions from roads were assessed using AP-42 emission factors and the US EPA international IVE model. The assessment of vehicle exhaust emissions required the investigation and application of engine and emission control technologies specific to the Caribbean island, as well as the properties of the fuel sold on the island. We have also aided in the preparation of a construction mitigation plan based upon best practises for the construction industry.
If you require assistance with similar projects, or have questions, contact Franco DiGiovanni at ext. 102, orfdi-giovanni/at/airzoneone.com, or Phil Fellin, ext. 102, pfellin\at\airzoneone.com.