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: Peter Wong

Company Name: Pilot Working Group of Environment Canada and the Ontario Ministry of Environment (MOE) On the Harmonization of the National Pollutant Release Iventory (NPRI) and the Ontario Airborne Contaminants Dsicharge Reporting and Monitoring Regulation (O.Reg. 127/01)

Address: 125 Resources Road, East Wing
City: Etobicoke
Prov/Terr: On
Postal code: M9P 3V6
Telephone: (416)235-6130
Fax:
E-mail: peter.wong@ene.gov.on.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:

Estimate on the number of facilities from following industrial sectors in Canada which meet the reporting thresholds and will be affected by the change.

Proposals for specific industry exemptions or targets (ex. In the case of SOPs a reporting requirement may be intended for a specific industry sector):

- 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?

Calcium oxide meets the original NPRI criteria, that is:

1. The substance is manufactured, processed or otherwise used (MPO) in Canada with 3 tonnes threshold MPO criteria.
2. Ontario Point of Impingement standard is 20 μg/m³, and
   Ontario Ambient Air Quality Criteria is 10 μg/m³ for 24 hr basis

Calcium Oxide is of special concern because of its corrosive properties and health effects.

Dust irritates to nose and throat.
Solid will burn skin and eyes.
Causes burns on mucous membrane and skin.
Threshold limit value - 2 mg/m².
Short term inhalation limit - 10 mg/m³ for 30 min.

The potential health hazards associated with the inhalation of calcium oxide dust is it being highly irritable and possibly corrosive to the upper respiratory tract. Inhaling would result in coughing, sneezing, labored breathing and possibly burns with perforation of the nasal septum. Chronic inhalation dust may cause inflammation of the respiratory passages, ulcers of the mucous membranes, and possible perforation of nasal septum. The TLV for the substance is 2mg/cubic metre of air; MAK is 5 mg/m³. (source: http://www.jtbaker.com/msds/englishhtml/c0462.htm)

The substance can be absorbed into the body by inhalation of its aerosol and by ingestion. Evaporation at 20°C is negligible; a harmful concentration of airborne particles can, however, be reached quickly when dispersed. Effects of short-term exposure to the substance includes corrosiveness to the eyes, the skin and the respiratory tract. The effects may be delayed. Effects of long-term or repeated exposure include dermatitis possible ulceration and perforation of the nasal septum. (source: http://www.inchem.org/documents/icsc/icsc/eics0409.htm)

Data from the International Program on Chemical Safety (IPCS), published in 1996, can be obtained from the following link: http://www.cdc.gov/niosh/ipcsneng/neng0409.html

This substance is also in the following lists:

• IPCS International Chemical Safety Card
• U.S. National Institute for Occupational Safety and Health Pocket Guide to Chemical Hazards

It is not listed as a carcinogen by NTP, IARC, OSHA or ACGHI (source: http://www.catalogue.fisher.co.uk/scripts/search.dll?ViewMSDS&SheetNumber=04030)

This material is expected to be toxic to aquatic life. (source: http://www.jtbaker.com/msds/englishhtml/c0462.htm)

(iii) Calcium oxide has been released in to the Canadian environment as reported in substantial quantities by various facilities and sectors under MOE's O.Reg.127/01.

Calcium oxide is a widely used chemical compound. It is released in to the environment either naturally (which is beyond the scope of this discussion paper and the purpose of NRPI) and through human activities. Calcium oxide is usually made by the thermal decomposition of materials, such as limestone, that contain calcium carbonate (CaCO₃). As hydrated or slaked lime, Ca(OH)₂, it is used in mortar and plaster to increase the rate of hardening. This substance is also used in glass and metal (steel, magnesium, aluminum and other non-ferrous metals) production. It is also used in water and sewage treatment to reduce acidity, to soften, as a flocculant and to remove phosphates and other impurities; in paper making to dissolve lignin, as a coagulant and in bleaching; in agriculture to improve acid soils; and in pollution control - in gas scrubbers to desulfurize waste gases and to treat many liquid effluents. It is a refractory and a dehydrating agent and is used to purify citric acid, glucose, dyes and as a CO₂ absorber. It is also used in pottery, concrete, paints and the food industry. (source: Hawley's Condensed Chemical Dictionary, http://www.nationmaster.com/encyclopedia/calcium-oxide)

Calcium Oxide has been reported in substantial quantities by various facilities and sectors under MOE's O.Reg. 127/01 for the reporting year 2001, 2002, and 2003. See below.

Source of Data: OnAIR dataset January 7, 2005
[1] 2001 emissions were for the period May 1, 2001 to December 31, 2001.
[2] 2003 emission data are still being subjected to QA/QC.

According to Statistics Canada, Business Patterns Database, December 2003:

There is a total of 89 number of Cement Manufacturing (NAICS 32731) establishments in Canada. There are facilities distributed throughout Canada in all provinces (but not territories). Based on the Annual Survey of Manufactures data, the number of principal establishments changed from 22 in 1993 to 31 in 2002. This represents a growth rate of 3.9% per year. Over the most recent year, the number of establishments in the Cement Manufacturing industry increased by 3.3%. (source: http://strategis.ic.gc.ca/canadian_industry_statistics/cis.nsf/IDE/cis32731este.html)

There is a total of 21 number of Lime Manufacturing (NAICS 32741) establishments in Canada. There are facilities distributed throughout Canada in all provinces (but not territories). Based on the Annual Survey of Manufactures data, the number of principal establishments changed from 12 in 1993 to 14 in 2002. This represents a growth rate of 1.7% per year. (source: http://strategis.ic.gc.ca/canadian_industry_statistics/cis.nsf/IDE/cis32731este.html)

There is a total of 676 number of All Other Non-Metallic Mineral Product Manufacturing (NAICS 32799) establishments in Canada. There are facilities distributed throughout Canada in all provinces (but not territories). Based on the Annual Survey of Manufactures data, the number of principal establishments changed from 185 in 1993 to 379 in 2002. This represents a growth rate of 8.3% per year. Over the most recent year, the number of establishments in the All Other Non-Metallic Mineral Product Manufacturing industry increased by 6.8%. (source: http://strategis.ic.gc.ca/canadian_industry_statistics/cis.nsf/IDE/cis32799este.html)

The three mentioned sectors above are the top three sectors with emissions of calcium oxide in Ontario.

Based on the NAICS of facilities that have reported to O.Reg.127, a data search of NPRI 2003 has revealed the following number of facilities reporting from each province with the same NAICS code. This is shown below:

Many of these industrial sectors can also be found in other provinces. As such, Canada-wide reporting of this pollutant will satisfy the NPRI criteria. Further, with the inclusion of this substance in NPRI, facilities will no longer be required to report to MOE separately.

(iv) Calcium oxide is reasonably expected to be present in the Canadian environment because of its environmental releases.

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. Emission of Calcium Oxide has been reported under MOE regulation O.Reg.127/01 in Ontario in significant quantities from various facilities and sectors for the reporting year 2001, 2002, and 2003.

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

Yes. Inclusion of Calcium Oxide 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 along with other NPRI substances.

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

Emission of Calcium Oxide has been reported to MOE under O.Reg.127/01 in Ontario for the reporting year 2001, 2002, and 2003 by facilities industrial sectors as listed in Section 1. Calcium oxide emissions data is not collected elsewhere in Canada.

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.

No. Calcium Oxide is not included in NPRI presently.

Additional Considerations

 1. Sources of Releases of Calcium Oxide:

Calcium Oxide (CAS # 1305-48-8) is an odourless white or grayish-white solid. There is sometimes a yellowish or brownish tint due to iron. This substance crumbles on exposure to moist air, soluble in acid and reacts with water to form calcium hydroxide with evolution of air. It is released into the environment from industrial uses and natural sources. It is used in refractory, flux in steel manufacture, pulp and paper, manufacture of calcium carbide, sulfur dioxide removal from stack gases, sewage treatment, poultry feeds, sugar refining, food additive, glass manufacture. A detailed list of NAICS codes for sectors reporting the releases of calcium oxide in Ontario can be in Sources of Releases - Decision Factor 1.

Recommendations:

- Section 3 -

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

- Section 4 -

* This section must be completed for proposals for a change to the reporting condition of a NPRI substance. The following items should be addressed in this section:

• the proposed reporting condition;
• reasons/justifications why the reporting condition should be changed;
• implications on NPRI reporting facilities;
• sectors/industries that would be affected by this change (NPRI facilities and potential NPRI facilities that may be required to report due to the change);
• consideration of the value of making this change versus the costs of carrying it out (efforts will be made to implement reasonable measures to reduce burdens, hence costs, without compromising the NPRI);
• etc.

- Section 5 -

* This section must be completed for proposals for a change to the reporting requirement of a NPRI substance. The following items should be addressed in this section:

• the proposed reporting requirement;
• reasons/justifications why the reporting requirement should be changed;
• implications on NPRI reporting facilities;
• sectors/industries that would be affected by this change (NPRI facilities and potential NPRI facilities that may be required to report due to the change);
• consideration of the value of making this change versus the costs of carrying it out (efforts will be made to implement reasonable measures to reduce burdens, hence costs, without compromising the NPRI);
• etc.

- Section 6 -

* This section must be completed for proposals for other possible modifications.

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.