National Pollutant Release Inventory Submittal Form
- Proposal for a Modification to the NPRI -

Please complete this form to propose a modification to the National Pollutant Release Inventory (NPRI) and forward to :

Attention: Co-ordinator for Proposals for Modifications (NPRI)
Consulatations and Outreach
The National Pollutant Release Inventory
Environment Canada
9th floor, Place Vincent Massey
351 St. Joseph Blvd.
Hull, Quebec,
K1A 0H3
telephone: (819) 953-1656
fax: (819) 994-3266
e-mail: npri@ec.gc.ca

- Section 1 -

Name of contact: National Pollutant Release Inventory

Company Name: Environment Canada

Address: PVM, 9th Floor
City: Gatineau
Prov/Terr: PQ
Postal code: K1A 0H3
Telephone: (819) 953-1656
Fax: 994-3266
e-mail: npri @ec.gc.ca

Please indicate the details of the proposal:

Proposed timing for the Change (proposed year for implementation): 2006 reporting year

Background

Mineral Spirits

The 25 mineral spirits that are listed in Table 2B under Ontario's Regulation 127/01 (O. Reg. 127/01) can be broken-down as follows:

• One of the mineral spirits was not reported for 2001 and 2002.
• Minimal quantities of 12 mineral spirits were reported for 2001 and 2002 .
• Five of the mineral spirits were added to the NPRI for the reporting year 2003 (see Table 1).
• The remaining 7 mineral spirits should be considered for addition to the NPRI under Part 5 Voc species.

Glycol Ethers:

The 18 glycol ethers that are listed in Table 2B under O. Reg. 127/01 are broken down as follows:

• There was no reporting for one of the glycol ether's in 2001 and 2002
• Minimal quantities of nine glycol ethers were reported in 2001 and 2002 .
• Ethylene glycol butyl ether (2-butoxyethanol) was added to the NPRI in 1999 and Ethylene glycol was listed in 1994.

The remaining 6 glycol ethers should be considered for addition to the NPRI under Part 5 VOC species

Industry Sectors to be affected by the change:

All these industry sectors reported the VOC speciation to the NPRI

1. Glycol Ethers

• DGBE : Diethylene Glycol Butyl Ether
• DGEEA : Diethylene Glycol Ethyl Ether Acetate
• EGBEA : Ethylene Glycol Butyl Ether Acetate
• EGHE : Ethylene Glycol Hexyl Ether
• PGBE: Propylene Glycol Butyl Ether
• PGMEA : Propylene Glycol Methyl Ether Acetate

2. Mineral Spirits

• HAN: Heavy Alkylate Naphta
• HHN: Hydrotreated Heavy Naphtha
• HLD: Hydrotreated Light Distallate
• SNLA: Solvent Naphtha Light Aliphatic
• SNMA: Solvent Naphta Medium Aliphatic
• WMO: White Mineral Oil

- Section 2 -

* This section must be completed for proposals for the addition or deletion of NPRI substances.

Decision Factors¹

1. Does the substance meet the NPRI criteria, that is:

1. Is the substance manufactured, processed or otherwise used (M,P,O)² in Canada ?
2. Is the substance of health and/or environmental concern?
3. Is the substance released to the Canadian environment?
4. Is the substance present in the Canadian environment?

i, iii, and iv) In Canada the major sources of VOCs from human activity are produced from combustion. For 2001, 2002 and 2003, various facilities reported 3295.894 tonnes, 5484.187 tonnes and 3769.111 tonnes of these 13 Glycol Ethers and Mineral Spirits to MOE Reg. 127/01 respectively.

ii) The health effects depend on the specific composition of the VOCs present, the concentration and the length of exposure. High concentrations of some compounds which may occur when working with materials or processes that emit VOCs could have serious health effects. These should be considered under the effects of the specific component. General effects of lower concentrations include eye, nose, and throat irritation; headaches, loss of coordination, nausea; damage to liver, kidney, and central nervous system. Some VOCs can cause cancer in animals; some are suspected or known to cause cancer in humans. Build ups of VOCs in indoor environments have been associated with 'sick building syndrome'.

The major environmental significance of VOCs is in relation to their role in the formation of photochemical smog. Other environmental effects depend on the composition of the VOCs, the concentration and the length of exposure. As with humans some VOCs can have serious effects on animals and also plants. Effects may also occur due to secondary impacts as, for example, due to the impacts of smog. In liquid form and solutions VOCs can impact water and soil.

2.Do facilities contribute significant releases of the substance?

There are various ways in which 'significant' can be characterised. The concept relates not only to the proportionate quantity of a substance released by NPRI reporting facilities, but also to the potential for health or environmental impacts. In other words, even if facilities do not account for a major proportion of total releases, facility releases may nonetheless be significant depending on such factors as location, timing, concentration, and the hazard associated with the substance.

Yes. Emissions of these substances have been reported to MOE under O.Reg.127/01 in significant quantities from various facilities for the 2001, 2002, and 2003 Reporting year.

Every sector that reported these substances to MOE Reg. 127/01 also reported VOC speciation to the NPRI. If these substances are added to the NPRI, it is expected that the change would only affect existing reporters. For 2003, 2252 facilities from the sectors in Table 3 reported VOCs to the NPRI.

3. Does inclusion of the substance support one or more of the objectives of NPRI?

Yes. Inclusion of these substances does support some of the objectives of the NPRI. This will encourage voluntary action to reduce releases, allow tracking of progress in reducing releases, and improve public understanding.

Inclusion of these VOCs, is also required for regional air quality modelling. Other drivers for speciation include domestic and international programs that require information on emissions, trends and forecasts. Key amongst these are:

• Canada-Wide Standard for Particulate Matter and Ozone
• Canada Wide Acid Rain Strategy
• Ozone Annex of the 1991 Canada-US Air Quality Agreement
• Convention on the Long Range Transport of Air Pollutants
• Development of Ambient Air Quality Objectives.

Regional air quality modeling require speciated VOC information because of the following:

• Different VOC species have different reactivities;
• Different VOC species have different ozone-forming potentials;
• Different VOC species have different volatilities, and
• Different VOC species have different aerosol-forming potentials.

4. Is the substance reported elsewhere? Or if it is reported elsewhere, is there nonetheless additional value in reporting to the NPRI?

Emission of these substances have been reported to MOE under O.Reg.127/01 for the reporting year 2001, 2002 and 2003 and except for White mineral oil, all mineral spirits are also listed on the National Emissions and Reductions Masterplan (NERM) inventory for members of the Canadian Chemical Producers' Association (CCPA).

5. Is the substance already on the NPRI in some form? If it is already on the NPRI in some form, is there nonetheless additional value in including it in another form?

When considering adding a substance in another form (e.g., tetraethyl lead as a separate listing from lead and its compounds), the potential for double-counting will be avoided. For example, a compound will not be both listed as an individual substance, and included as part of an aggregate category. To the extent possible, substances will be listed with their Chemical Abstracts Registry (CAS) numbers.

These substances would be included as part of the VOC Part 4 listing. Speciation would only be required if the Part 4 VOC substance is reported and more than 1 tonnes of a part 5 substance is released

Additional Considerations

VOC Speciation and Regional Air Quality Modeling:

Regional air quality models (RAQM) are used in Canada and the United States to support the scientific assessment of air pollution problems and in the development of air pollution control strategies. To date, emissions processing systems have been used in conjunction with process-level reporting of total VOC emissions to estimate speciated VOC emissions for input into RAQM. Reporting total VOC emissions at the facility level does not provide sufficient information for use by RAQM, but where more detailed information is not available, assumptions are made.

It is important to note that air quality models and monitoring are complementary processes. In fact, regional air quality models provide the following:

• Linkage between emissions to the atmosphere and ambient air concentrations/ atmospheric deposition;
• Permit a synthesis of our best understanding of all processes relevant to acid deposition;
• Used to determine the importance of various processes;
• Used to test scientific hypotheses (e.g., linearity assumption);
• Used to "fill in" the gaps in monitoring networks;
• Used to design/ optimize monitoring networks;
• Used for source attribution,
• Used to simulate " what if" scenarios

The role of VOC in atmospheric chemistry and air quality include the following:

• RAQM require information on VOC to determine gas-phase and aqueous-phase atmospheric reactivities and influence formation of secondary pollutants (e.g., ozone, sulphate, nitrate, & secondary organic aerosol)
• Contribute directly and indirectly to organic aerosol mass
• Some individual VOC affect human health

1 These decision factors are applicable to candidate substances at both 10-tonne and alternate thresholds.

2 For the purposes of the NPRI, the definition of M,P,O includes by-products. A by-product is an NPRI substance that is incidentally manufactured, processed or otherwise used at a facility and is released to the environment and transferred off site for disposal.

3 In sum, the NPRI is recognised as a key national emissions database; and where a substance falls within the NPRI's mandate, efforts will be devoted to ensuring a single window approach through the NPRI.