Provincial News ? Implementation of Amendments to O. Reg. 419 CofA Regulation
Changes reported in previous Air Quality News Bulletins have been implemented including:
- Updated air standards for: N-Butanol; Cadmium and its Compounds; Chlorine Dioxide; Chloroethane; 1,1-Dichloroethane; Ethylene Oxide; Isobutanol; Lead; Methyl Chloride; Phosphoric Acid; Propylene; Sulphuric Acid; Total Reduced Sulphur (TRS) and Compounds; and Trimethylbenzenes. ? New or more stringent air standards will be phased in by February 1, 2013, with the exception of Lead which is being phased in February 1, 2010.
- Dispensation was given to Foundry sector to allow more time to achieve compliance with Schedule 3 standards
- Opacity Assessments must follow new guidelines published by April 1, 2008. ? More details are provided below.
- Modelling Updates, including clarification of which models can be used under certain circumstances, and update of regional meteorological data.
- Standby Generators are exempted from sections 18-20 of Reg 419 but still require a NOx emissions assessment under the Emergency Generator Data Sheet guidance document.
- Odour-based standards have been implemented for total reduced sulphur, mercaptans and hydrogen sulphide, and other reduced sulphur compounds.
- Clarifications of various terms and meanings within the regulation have been made.
For further information see back-issues of our Air Quality Bulletin on our web-site or call us.
Provision of Additional Guidance on Assessing Emission Data Quality for CofA Applications
As part of the air emission calculations for CofA applications, an assessment of data quality? is required. ? This is an assessment of the degree of confidence that a particular emission estimate is equal to, or greater than, the maximum possible for a particular process.
For example, when mass balance calculations are applied to solvent release from paint applications, and those mass balance calculations can be backed-up by company purchasing/inventory records, then we can be fairly sure that actual emissions will not exceed these estimates. ? The emissions estimate is then assigned highest data quality? and resultant impact estimates are considered conservative with a high degree of certainty.
Additional guidance indicates what is allowable when two or more estimation methods are available within the same data quality class. ? Previously, the proponent was forced to choose the highest estimation method, but now the MOE will hear arguments for use of other methods if standards for the compounds are not health-based.
Opacity Provisions
New draft guidance documentation has been issued that clarifies how compliance with Reg 419 requirements for opacity must be met.
Opacity is the measure light obstruction by an airborne contaminant emission. ? Reg 419 requires that opacity is not to exceed 20% in the smoke exiting an exhaust stack, but an allowance of 40% is allowed where there is combustion of fuels with high ash content.
The draft guidance document specifies the measurement technique to be used when human observers are used (namely the US EPA Method 9) but opacity can also be measured in-stack and beyond the stack by specialized instruments.
The draft guideline also explains exemptions from opacity requirements during start-up, shut-down and maintenance activities as long as the facility has a plan to minimize visible emissions.
Federal News
Requirement to Report Emissions for the 2006 Calendar Year
In Dec., 2007, The Government of Canada published a notice requiring major industries to provide 2006 air emissions information for pollutants and greenhouse gases by May 31, 2008.
The following industrial sectors must report: Alumina and Aluminium; Base Metal Smelting; Cement; Chemicals Manufacturing; Electricity; Iron, Steel, and Ilmenite Smelting; Iron Ore Pellets; Lime; Natural Gas Transmission, Distribution and Storage; Oil Sands; Petroleum Products Terminals; Petroleum Refining; Potash; Pulp and Paper; Upstream Oil and Gas.
Focus on Federal Emission Regulations
Many Provinces regulate air quality by imposing air quality standards on industry. ? These are often imposed as an air quality limit for substances emitted that travel beyond the property boundary of an industrial facility, or impact on sensitive receptors such as residences, or schools. ? Such impact assessments require computer modelling of the dilution of air emission as they travel from the emission point to, and beyond, the property boundary. ? Provinces that have such regulations include Ontario, Alberta and Saskatchewan.
However, the Canadian Federal Government also imposes emission regulations on certain industries and for the emission of certain substances. ? These emission regulations govern the amount of pollutant that can be released from an exhaust stack at the facility.
The Federal Government lists industrial emission regulations for: (1) mercury releases into the air from mercury cell chlor-alkali plants; (2) chlorobiphenyls (one gram per day limit for PCBs in the course of commercial, manufacturing and processing activities involving specified equipment); (3) lead-in-dust emissions from secondary lead smelters; and (4) vinyl chloride from vinyl chloride and polyvinyl chloride plants. ? Proposed Federal government emission regulations exist for: (1) hexavalent chromium emissions from Chromium Electroplating, Chromium Anodizing and Reverse Etching operations; and, (2) amendments to the vinyl chloride release regulations currently in existence.