To find out how Airzone One can help you with reporting for your facility send us an email.

If reportable substances are used or emitted from an eligible facility then by law, toxics reduction plans (for each reportable substance) must be produced.  These plans must be developed or certified by an Ontario-Certified Toxics Reductions Planner.  A summary of your toxics reduction plan becomes public and so it is important to start planning for this as the first toxics emission reports are required by June 1st 2011 and the first plans are required by the end of 2011.   To find out how Airzone One can help you with reporting send us an  email.

National Pollutant Release Inventory/O. Reg. 127 Reporting

These reports must by submitted by June 1st, 2010 to the federal government (Environment Canada) under the National Pollutant Release Inventory (NPRI), and the provincial government (Ministry of the Environment).  Reports are mandatory for eligible companies as required by the Canadian Environmental Protection Act (1999, NPRI) and the Ontario Environmental Protection Act (Reg. 127/01), respectively.

Under the NPRI program, companies are required to report all pollutant emissions (air, water and waste) if they meet criteria.  Companies reporting data must ensure “due diligence” in calculating emissions and estimating reporting thresholds.  All data will be displayed on the publically accessible NPRI website.  It is important that facilities produce defensible data for reporting.

Airzone can help your company assess whether you are required to report, and assist with the reporting and the toxics reduction planning process.

Location:

Airzone One Ltd., 222 Matheson Boulevard East, Mississauga, Ontario, L4Z 1X1, (north side of Matheson, east of Hurontario St., between Whittle and McAdam Road).

Session Dates:

1st Seminar: Certificates of Approval (C of A [Air]) in Ontario: New Developments

-Wed. Oct. 14th, 2009

Details covered include the criteria required to apply for or to be exempt from  C of A, recent regulatory changes, noise-related requirements and a description of the application package.  [Registration required by Oct. 7th, 2009]

2nd Seminar:  Industrial Hygiene in the Workplace and Changes in OH&S Regulations- Wed. Nov. 25th, 2009

Worker air exposure assessment topics will include Occupational Health & Safety Acts & Regulations and recent changes, exposure limits, sampling and analytical methods, results interpretation, and control strategies.  [Registration required by Nov. 18th, 2009]

3rd Seminar:  New Developments in Indoor Air Quality- Wed. Jan. 27th, 2010 (snowdate: Thurs Jan 28th, 2010)

Indoor air quality issues:  Updates on issues and concerns in indoor environments.  A description of IAQ requirements in LEED certification. [Registration required by Jan. 20th, 2010]

4th Seminar:  Changes in Annual Emissions Reporting- Web. Mar. 3rd 2010

(snowdate: Thurs Mar. 4th, 2010)

We will be covering OReg 127 and NPRI reporting inculding who is required to report, reporting thresholds and calculations, reporting methods and reporting deadlines.  Updates on the reporting methods will be provided.  [Registration required by Feb 24th, 2010]

5th Seminar: Updates on Mould and Indoor Air Quality- Wed. Apr. 14th 2010

The effects of mould on human health will be explored, assessment and sampling strategies outlined and requirements for remediation described.  [Registration required by Apr. 7th 2010]

Registration:

Please send your RSVP and contact details via our email form, Attention:

Natalie De Sousa

Vigilance Required for Land Re-zoning Applications

Recent incidents highlight the need for vigilance in re-zoning applications for nearby lands.

Municipalities zone lands according to permitted uses (e.g., residential or industrial) and allow only specific development on those lands.  Municipalities must make public re-zoning applications from developers and inform other land owners within a specific distance of the subject lands.  Existing landowners may object to the re-zoning based on “incompatibility” of land uses most commonly due to potential nuisance emissions from industrial activities (e.g., dust/noise) on nearby residences or “sensitive receptors.”  These may be a problem for existing or proposed residences, for example, from the proposed or existing industries.

Existing landowners have the right to object to re-zoning if there is an incompatibility that may lead to problems.  For example, an existing industry, that emits dust or noise in its normal operation, may object to the re-zoning and subsequent development of adjacent lands for residential use since future homeowners may complain about noise or dust levels and require tighter emission controls than they would otherwise have needed had no homes been built.

City of Toronto Environmental Reporting, Disclosure and Innovation Program

In December 2008, the City of Toronto adopted a new bylaw to require City businesses to publically report the use and release of 25 chemicals: Acetaldehyde, Acrolein, Benzene, 1,3-Butadiene, Cadmium, Carbon tetrachloride, Chromium, Lead, Manganese, Mercury, Nickel, Chloroform, 1,2-Dibromo ethane, Nitrogen Oxides, Particulate Matter 2.5, Polycylic Aromatic Hydrocarbons, Vinyl chloride, Dichloromethane, 1,2-Dichloroethane, 1,4-Dichlorobenzene, Trichloroethylene, Formaldehyde, Tetrachloroethylene, and Volatile Organic Compounds.

The bylaw, to be phased-in over four years, comes into effect Jan 1, 2010.  The program will focus on small-to-medium sized businesses and require reporting by June 30, 2011 for calendar year 2010 on usages and emissions to air, water and land.  Reporting protocols are expected to be similar to those for the Federal National Pollutant Release Inventory (NPRI) but have lower usage reporting thresholds to capture SMEs.

Ontario Provincial News

Permitting Standards and Background Concentrations

The MOE continues to consult with stakeholders on incorporating background air concentrations into the air emissions permitting (Certificate of Approval, CofA) process.  The Air and Waste Management Association Practitioners Committee provided MOE staff with concepts and ideas to consider in April (presentation by F. DiGiovanni) including a review of methods used in other jurisdictions.

Technical Notes for CofA Compliance

We provide a brief discussion of two technical issues that are often misunderstood when compiling CofA applications.

When dealing with fugitive dust emissions from on-site roadways and storage piles the MOE’s exemption from air dispersion assessment only applies when there are no significant quantities of contaminants in the dust that may cause a health effect.  Many road and aggregate dusts may lead to emissions of crystalline silica (for example), a known carcinogen, and would therefore not exempt these sources from an air dispersion assessment as part of CofA applications.  Furthermore, most natural geological dusts contain potentially harmful substances such as crystalline silica and mica.

AP-42 emission factors (EFs) for estimating emissions from certain activities reflect simple averages of data collected by the US EPA.  AP-42 EFs were developed to estimate emissions over large areas and long time periods and not with worst-case emissions predictions in-mind.  In contrast, Reg. 419 requires worst-case emissions to be estimated; this is not consistent with the use of AP-42 average emission factors.  However, in some cases, where the resultant off-site concentrations of pollutants are predicted to be very low, it may still be acceptable to use the average EF.  In other cases, alternative EFs or emission estimation techniques must be sought.

Sector-based Approaches to Managing Air Pollution

Pollutant emitters can apply for temporary “alternate standards” (AS’s) as part of the phase-in of Reg. 419 if they cannot meet the new air quality standards (to be fully phased-in by 2020).  These AS’s are site-specific and require some effort to obtain from the MOE.  Because many facilities within an industrial sector face the same challenges in pollution prevention, the MOE allows a sector-based approach as an alternative to site-specific AS’s.

This approach involves the specification of common technical standards to control air emissions within an industrial sector.  It is likely that industry associations would propose such sector-based standards (such as those submitted by the Foundry and Forestry Products industries) for MOE review and public comment.

Toxics Reduction Act

This new Act (passed in June) establishes a framework for the reduction in use of toxic substances by industry in Ontario.  Regulations will be developed to require: tracking and quantifying the substances used and created; development of plans to identify ways to reduce toxics; making summaries of the plans available to the public; and, reporting on progress.

Additional details will be specified in the regulations, including the substances of concern, facilities to be covered, and timelines for planning and reporting.  These regulations will be developed in consultation with stakeholders.

Occupational Health and Safety

Airzone One’s occupational health and safety group is experienced in the design and management of programs, audits, policies and procedures and training programs. Our staff of occupational hygienists have the expertise to perform inspections, conduct training sessions, identify toxic agents, and make recommendations to achieve regulatory compliance, reducing risks and personal and property losses, improving productivity, employee morale and the overall effectiveness of health and safety at a facility.

Air Dispersion Modelling

In addition to providing routine modelling of airborne pollutants with regulatory models, we also provide consulting services related to air dispersion modelling such as input and output data interpretation.

Air Monitoring Services

Airzone One provides a variety of air quality services with a base of experience spanning more than 30 years. We deal with regulatory requirements for air quality monitoring, but also have unique capabilities to deliver many other air quality services.

Passive Sampling

Passive air sampling is a method of determining airborne concentrations of volatile contaminants using a passive sampling device (PSD). Instead of using bulky pumps and sorbents, such as charcoal in tubes, or summa canisters, air samples are collected with a small badge-like device that relies on the diffusion of compounds to a collection surface or sorbent.

Certificates of Approval

Airzone One’s permitting experience includes involvement in permit applications for many industrial, commercial and institutional facilities over the past ten years. The permitting group’s leader, Franco DiGiovanni PhD, has been involved in the consultative processes leading to the development of the new guidance documents for the new application process and he continues to serve in technical groups guiding the implementation of the new application procedures.

Noise Assessments

Airzone One is experienced in conducting noise impact assessments that are acceptable to the Ministry, and in specifying noise control requirements where compliance cannot be demonstrated.

CofA permits must be approved before operation of the emitting sources commences, that is, befor commissioning of a building, or a renovation.  To apply for a CofA you need to demonstrate that the impacts of your emissions are below provincial standards at your facility’s property-line; provincial standards vary according to substance emitted.

If a CofA already exists, the law requires an up-date to account for production increases, altered ingredients or upgraded boilers, for example.  Many sources that you might not be aware of may also require a CofA:  For example, gas-fired comfort heating for large residential buildings or office towers (greater than 1.5 MMBTU/hr heat input) require CofAs as do gas-fired units of any heat input capacity used for purposes other than space heating.

Applying for a CofA, or up-dating an existing one, is a complex process requiring expertise in air pollutant dispersion modelling and the interpretation of point-of-impingement results.  Lay-persons may have some difficulty in processing applications, resulting in a waste of human and financial resources. 

Airzone One has many years experience in air quality issures and CofA applications for various industries.  Airzone One also assesses indoor air quality and occupational exposures and assists facilities with emissions requiring reporting under Provincial (O. Reg 127) and federal (NPRI) regulations.  Very often the best time to conduct the impact analysis is during the design stage so that potential problems can be addressed in this stage of a development.

If you require assistance with air emissions regulatory compliance please contact Dr. Franco Di-Giovanni, PhD @ 905-890-6957 ext. 102 or by email.

Changes to POI Standards

The June 2006 posting included proposed changes to Schedule 1, 2 and 3 standards.  Schedule 1 standards apply to all facilities immediately (apart from new facilities falling under Schedule 4 and 5 classes).  We concentrate on those, but interested readers may contact us for changes to 2 and 3 standards.

Schedule 2 updated 0.5 hr standards will apply in 2010 to most facilities, while Schedule 3 standards will apply to all facilities by 2020.

Proposed Action: All companies requiring Certificates of Approval (Air) should re-evaluate their compliance status using the proposed new and upcoming standards now.

Update to Schedule 4

Comments were submitted by the foundry sector indicating the sector’s difficulty in meeting the new Schedule 3 standards with the new US EPA models by 2010, since many foundries are small- to medium-sized businesses.

The Ministry accepted the industry’s comments and have begun a sector compliance initiative.  They have also de-listed foundries from Schedule 4, thus obviating the need for foundries to comply with the new models and standards by 2010.

Regional Meteorological Data

The Ministry is considering revising the missing-data interpolation method in the meteorological records used as input into the new, more advanced, US EPA models that will come into force for many companies in 2010.

Many data are missing in records due to wind speeds too low to register on older anemometers.  However, the low wind speed condition is also of concern as they can represent periods of elevated airborne concentrations.

Odour Issues

Odour assessments are subjective due to varied human responsiveness to odour impacts.  The Ministry is considering introducing the concept of frequency of odour exceedances (in testing compliance) and also clarifying “human receptors;” that is, where human activities regularly occur.

Other Provincial News –Environmental Review Tribunal Case
A recent Tribunal, in the case of certain environmental groups versus Lafarge Canada Inc., held that the MOE must account for its own “Statement of Environmental Values” (SEV) in issuing CofAs; in particular, the requirement to protect the overall ecosystem.  Interestingly, this requires accounting for cumulative impacts; a requirement not met by the present impact assessment method of comparing emissions of each substances from each facility against single standards.  For more information, see the ERT website (www.ert.gov.on.ca).

Possible Future Consequences: The Ministry may advocate a more holistic and cumulative impact assessment in future versions of air emissions regulations.

Federal News

Bill C-30: Canada’s Clean Air Act – Committee Report

On Oct. 19, 2006, Bill C-30 received the first reading (see Winter 2007 News Bulletin).  The Act was sent to Committee in Dec. 2007 and the report published in Mar. 2007.  Highlights of the changes proposed by the Committee include: emphasis on Canada’s commitment to the Kyoto Protocol, identification of “significant areas” vulnerable to toxic releases or that contain a significant volume of toxic releases (the Government will have the power to obtain any information deemed necessary for release of toxics into the area), and, the creation of air standards across Canada, divided into different zones.  If air quality standards are not met in a particular zone, then air emission standards will be imposed on industrial emissions in the zone.

“Turning the Corner:  An Action Plan to Reduce Greenhouse Gases and Air Pollution”

Announced in April, this plan seeks to reduce industrial and other air emissions by 20-55% from 2006 emission levels by 2012-2015 for several industrial sectors including Alumina and Aluminium, Base metal Smelters, Cement, Chemicals, Electricity Generation, Forest Products, Iron & Steel, Iron Ore Pelleting, Lime and Oil and Gas.

The Federal Government will consult with stakeholders over several months culminating in draft regulations intended to be published in Spring, 2008, and finalize all regulations by 2010.  As part of the process, the Government will require all (potentially) regulated industries to submit information on 2006 emissions.

In the Fall of 2008 the Ontario courts upheld the right of neighbours to appeal the granting of an air emissions permit (Certificate of Approval, CofA) to Lafarge.  The permit would have allowed operation of proposed municipal waste and tire-burning at the Bath, Ontario cement kiln.  A major point of objection was that the current air assessment protocols, required in the CofA application process, does not account for the cumulative exposures from both emissions of contaminants from the facility and their background concentrations.

Ontario, unique in North America and possibly world-wide, does not require accounting for background concentrations with facility air emissions.  There is little doubt that the Ministry of the Environment must now account for background airborne concentrations in their decisions to grant emission permits.  Potentially this may drastically affect the way permits are granted.  However, uncertainty remains on how this will be done.  Will the Ministry supply “default” background concentrations to applicants or will applicants be required to derive background concentrations themselves?  Will the Ministry deem certain substances to have negligible background?  Will consideration of background concentrations only apply to certain, highly industrialized areas of Ontario?

Airzone One air quality experts will join other practitioners to guide the Ministry towards an appropriate incorporation of background in the permitting process.  More on these new developments posted in the next Bulletin.

ASAP Permitting Process

In the Fall of 2008, Airzone One representatives joined other industry practitioners to become the first of only a hand-full of professionals qualified to submit ASAP Permit applications on behalf of clients.  The ASAP (Accelerated Select Applications Pilot) Program allows some applications to be “fast-tracked” for review.

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.

Science Policy Related to Air Standards

In September (2008) the MOE announced policy proposals in relation to setting air standards under the Reg. 419 regime.

While air standards for carcinogens are currently set at levels that, on a statistical basis, would cause cancer in 1-in-1,000,000 in the general population some practitioners feel that this limit is too low.  However, the MOE contends that this basis is similar to numerous other jurisdictions and so sees no reason to alter the risk level.

At the meeting there was some discussion of the reasons why Upper Risk Thresholds (URTs) were variable multiples of the air quality standard.  Upper Risk Thresholds are air quality thresholds above which immediate action is required by an emitter upon discovery (by modelling or monitoring).  The MOE generally sets URTs for non-carcinogens at 10x’s the air quality standard and 100x’s for carcinogens but other factors are also taken into consideration.

Averaging times for air quality standards are the averaging period over which a monitored or modelled air quality exposure value is determined.  Acute (short-term) effects are usually controlled by setting short-term (e.g., 10 min. or 1 h) averaging times whereas chronic (longer-term) effects require setting longer-term (e.g., 24 hour or annual) average times.  During the meeting there was some disagreement on the value of 24-hour standards for carcinogens.

The MOE also discussed setting standards for particulate contaminants (e.g., metals dusts) and whether the contaminant concentration should be derived as part of total dust (“TSP,” total suspended particulate) or PM10 (the finer, inhalable fraction of total dust).  They reserved judgement to a case-by-case basis dependent upon the mode of exposure (e.g., by inhalation or ingestion) and by the receptor (e.g., humans or degradation of building materials).

Finally, the MOE also proposed accounting for other routes of exposure for systemic substances; those that humans can be exposed to in different ways at the same time (e.g., inhalation and ingestion).  Since the present standard setting method does not account for exposure by multiple routes, such considerations would likely lead to significantly lower air standards for the systemic substances.  The MOE has yet to announce applicable substances.

Federal News

Turning the Corner:  Canada’s plan to reduce greenhouse gas emissions and air pollution
As part of the federal government’s action plan on climate change, proposed legislation has been introduced to limit the volatile organic compound (VOC) content of certain consumer and commercial products.

Reductions in VOC (solvent) content are required for paints (architectural and automotive refinishing), cleaning and degreasing agents, certain consumer products, the Federal House (federal departments, agencies, crown corporations, federal works and undertakings, and activities that take place on federal and aboriginal land) and the Printing industry.

Airzone contributed background information in the form of emission studies for 2-butoxyethanol for the Federal government.