Ontario Provincial Activities
Draft Manual for MOE s New Dispersion Models
The Ontario Ministry of the Environment (MOE) has released a draft Model Usage Guide for the US EPA AERMOD, ISC3-PRIME and SCREEN3 models it intends to adopt to replace the Reg. 346 model. ? The guide also describes alternative models (for shorelines and roads, for example) accepted by the MOE and a proposed tiered approach to assess compliance by using SCREEN3 before using more refined models.
The Guide goes a long way towards describing standardized approaches to deal with modelling issues and presents standard meteorological datasets. ? Nonetheless the enhanced complexity of the models requires much more expert decision making on the part of the modeller as well as substantive pre-modelling consultation with the MOE on modelling techniques.
Proposed Action: Adoption of these models, and the methods proposed in the Guide, requires qualified modellers to conduct the compliance assessment. ? You should ensure that appropriate personnel are conducting the modelling for you.
Update on MOE s Consideration for Adopting a Risk Management Framework (RMF) for Air Compliance
An update was presented by the MOE in Oct. 2003 on a science-based framework for the adoption of new air quality standards for industry. ? This framework will consider the risk of allowing emissions above the (new) standard for up to 5 years lead-time for compliance, as well as allowances economic and technical factors.
Draft RMFs (based on the Canadian Risk Management Standard) are being applied to 5 Ontario facilities as a pilot project. ? Significant outstanding issues include risk estimation methods and appropriate benchmarking for control technologies.
Proposed Action: Watch for regulatory activities related to substances emitted by your facility. ? Prior warning on standards revision will allow extra time for discussions with your industry association or to assess control methods.
VOC-emission Controls for the Friction Products Manufacturing and Commercial Bakery Sectors
The MOE is studying control options for two sectors in an effort to reduce VOC emissions leading to smog and ground-level ozone. This follows the US example (e.g., California introduced Rule 1153 to control VOC emissions for bakeries). ? The US EPA has established rules for the friction product manufacturing sector (NESHAP, Final Rule 2002) that set emission limits for solvent mixers in US facilities.
Proposed Action: Major companies in these sectors should follow developments and ensure that their Industry Association EHS committees are liaising with the MOE on this issue.
On the Federal Front ? News from Environment Canada
Some Changes to NPRI-Reportable Substances for 2003 Reporting Year
Notice published in the January 4, 2003 Canada Gazette indicates that new substances included in the list for emission reporting include carbonyl sulphide, phosphorous (total), nonylphenol and its ethoxylates as a group (textile, pulp and paper, municipal waste water treatment), octylphenol and its ethoxylates as a group and selected (60 speciated) VOCs with additional reporting requirements.
Proposed Action: Reporting for NPRI is becoming more complex. ? Start planning now for 2003 reporting required by June 1st.
Environmental Emergency (E2) Planning
New Environmental Emergency (E2) regulations published in September, 2003 by the Federal government require that all facilities that store or use one of the 174 toxic substances listed above threshold values must notify Environment Canada within 90 days (by Nov. 18, 2003). ? For a list of chemicals see http://cepae2.ec.gc.ca. ? Should you store, or just have the capacity to store, these chemicals above threshold values then these regulations apply.
E2 plans require plans for prevention, preparedness, response and recovery from accidental releases. ? Plans require recognition of hazards, risk assessment of hazards, identification of potential consequences and development of plans to deal with consequences. ? Such planning may require liaison with outside agencies and communication, and involvement with, stakeholders including local communities.
Proposed Action: If this regulation applies to you then your facility must implement an E2 plan. ? The E2 plan s existence will be posted (CEPA web-site) to allow public access to information on facilities within their area.
Limiting VOC content of Paints
The Federal government is assessing possible regulation of the VOC content of paints for architectural coatings and industrial maintenance as part of the Federal agenda to reduce the VOC content of consumer and commercial products. ? Release of VOCs into the atmosphere are precursors to smog and ground-level ozone.
The Federal government has an MOU with the Canadian Paints and Coating Association (CPCA) to monitor VOC content. ? The Canadian Council for the Ministers of the Environment (CCME) has issued standards and guidelines for reduction of VOCs for industrial coatings including traffic markings.
Proposed Action: Coatings manufacturers and users should communicate with the CPCA to keep abreast of developments and the CCME standards (that will apply after Jan 2005).
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