Ontario Provincial News
Permitting Standards and Background Concentrations
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.
The laboratory is accredited by CALA to ISO/IEC 17025 for specific tests on the scope of accreditation.