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

Industry Sectors to be affected by the change:

- 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?

1. Like other PAHs, these three PAHs are incidentally manufactured by industries in Canada .
2. PAHs have been declared toxic substances under the Canadian Environmental Protection Act, 1999 (CEPA 1999) and are listed together in Appendix 1 of CEPA 1999. Many individual PAHs meet the criteria of persistence, bioaccumulation and toxicity as defined by various international bodies. Specifically, ecotoxicological studies of these three substances on aquatic organisms have shown adverse effects on lethality, growth and reproduction.
3. and (iv) Like other PAHs, these three PAHs are released into the Canadian environment from natural and anthropogenic sources. The primary anthropogenic sources of atmospheric PAHs are aluminum smelters that use the horizontal stud Söderberg process. Residential wood heating, agricultural burning, and wood waste incineration are other significant sources of atmospheric PAHs. Creosote-treated products, oil spills, metallurgical plants, coking plants, and atmospheric fallout are the primary sources of PAHs in aquatic environments and in soil. Most anthropogenic sources are point sources that regularly release PAHs, either on a continuous or intermittent basis (e.g., foundries, coking plants, metallurgical plants), or nonpoint sources that release PAHs at a very specific time and place (e.g., urban sources, such as vehicle emissions or wood combustion), resulting in the chronic exposure of living organisms to PAHs.

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.

In 2003, Ontario facilities released a total of 4,000.41 kg of these three PAHs into the province's environment. From the standpoint of human health, these releases are relatively significant.

The following table provides an overview of PAH emissions across Canada for 2002, as well as PAH data for 2003 from the Ontario Ministry of the Environment.

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

Like other PAHs, acenaphtene, acenaphtylene and fluorene are "toxic" as defined in Section 64 of the Canadian Environmental Protection Act, 1999 (CEPA 1999). They are "Track 2 substances." Adding these substances to the NPRI addresses several of the above objectives, particularly with respect to regulatory initiatives and the identification of priority measures and priorities for action.

More specifically, the addition of fluorene will make it possible to negotiate environmental performance agreements between the Quebec Environment Department and Alcan and Alcoa.

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

The three substances appear on the MOE PAH list. Reporting them through the NPRI will result in harmonization with MOE .

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.

The three substances are not listed in the NPRI in any other form.

- Section 3 -

* This section must be completed for proposals for a change to the reporting threshold of a NPRI substance.

Thresholds must be an important consideration to make sure that they are the same and do not create a burden for industry via differences between government agencies. If the five kg threshold used by MOE is carried over to the NPRI for the three substances added to the NPRI from O. Reg. 127/01, this will just add another level of complexity and burden. From a review of the data submitted, the NPRI 50 kg alternate threshold applied to the aggregate total of all 17 PAHS that the NPRI requires provides sufficient level of accuracy and would capture the PAHs reported under O. Reg. 127/01

- Section 4 -

Additional information

1. NPRI - These substances are the PAHs listed on NPRI substances list 9 reporting thresholds 50 kg)
2. TRI - A group of 21 PAHs substances form the polycyclic aromatic compounds category on the U.S. EPA Toxics Release Inventory (TRI). These substances are considered a group because they are human carcinogens. Benzo(g,h,i)perylene is not included in this group; rather than a human carcinogen, it is reported separately.
3. IARC - Substances assessed for carcinogenicity by IARC (International Agency for Research on Cancer).
   • Group 1: The agent is carcinogenic to humans
   • Group 2A: The agent is probably carcinogenic to humans
   • Group 2B: The agent is possibly carcinogenic to humans
4. UN ECE POPS - While PAHs as a group are considered to be persistent organic pollutants under the UN ECE POPs Protocol, four indicator compounds were selected for the purposes of emission inventories.
5. PSL - in the PSL 1 Assessment, EC 13 key PAH substances of concerns, but concluded that all PAHs are considered to be CEPA-toxic substances.

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.