ADDITION OF PORTABLE FACILITIES TO NPRI

1. Background

In order to minimize misunderstanding and confusion to the reporting community, both EC and MOE have realized there is a need to harmonize the administration and reporting requirements of their respective inventory programs, NPRI and O.Reg.127/01. As a result of the review of their differences, one of the recommended options for harmonization between O.Reg.127/01 and the NPRI is to have common facility definition and exemption. There are a number of areas to consider in dealing with this facility harmonization requirement. Among them is that NPRI should consider the addition of portable facilities for reporting and that MOE would then delete them from the O.Reg.127. This paper is to discuss the need and impacts of this harmonization proposal.

2. Rationale for the Addition

The current existing definition of a "facility" for both NPRI and O.Reg.127/01 is very similar, in that "facility" means all buildings, equipment, structures and stationary items that are located on a single site, or on two or more contiguous or adjacent sites that are owned or operated by the same person and function as a single integrated site. This concept of a facility definition is very much of "stationary" in nature. However, unlike NPRI , MOE has included "portable facility" as an additional "facility" consideration for reportable emissions. The definition applies to a facility that can be entirely relocated for operation, including portable polychlorinated biphenyls (PCB) destruction equipment, or an asphalt or concrete plant.

Because of this extended coverage for facility definition by the MOE, there are some fourteen (14) portable facilities meeting the special criteria and consequently reporting under O.Reg.127/01. It is found that several of which have also reported to the NPRI even though they are not required to do it. Based on the reporting dataset for NPRI , an analysis is performed as shown below to realize the "significance" of the reporting from portable facilities.

For 2002, there is one "portable" concrete batching plant found reporting insignificant releases of PM10 and PM2.5, accounted for about 1.7% and 0.8% respectively of the total contributions from some 70 facilities reported for the sector (Statistics Canada has estimated a total of 193 establishments in Ontario). No "portable" concrete batching plant is found reporting for 2003. The limited data availability has precluded a meaningful analysis of "portable facilities" for the ready-mix concrete manufacturing industry.

There is sufficient information available to do the data analysis for "portable facilities" for asphalt production as shown in Tables 1, 2, and 3. The major pollutants responsible for the industry releases are total particulate matter, PM10 and PM2.5. A MERAF (Multi-pollutant Emission Reduction Analysis Foundation) study report for the Hot-Mix Asphalt Sector (September, 2002) indicates that the percentage release contributions from this sector to all industry sectors are relatively small, accounted for about 2.2 %, 1.6% and 0.5% respectively of total PM, PM10 and PM2.5. Within the industry sector itself, Table 3 identifies that the portable facilities (in Ontario) would contribute between 12% to 17% of the pollutant releases for 2002, and would increase to a more startling level ranging from 29% to 39% for 2003. It is evident that the pollutant releases from the "portable" type of operations for asphalt production are no less significant than if they come from the "permanent" type of operations. Consequently, "portable facilities" would be better implicated in the facility definition to ensure a broader data capture for the sector.

3. Impacts of the Addition

To address the issue beyond Ontario for a national overview of the operations of portable facilities in the asphalt production sector, several sources have been consulted, including the Canadian Construction Association, Ontario Hot-Mix Producers Association (OHMPA), Bitume Quebec, and the MERAF Report for the Hot-Mix Asphalt Sector.

The OHMPA has identified and documented a listing of 21 portable plants in Ontario . Assuming the 14 plants reporting to MOE is the maximum number of "reportable" portable facilities obtained under the normal conditions of " NPRI thresholds", an applicable reportable rate is calculated. Based on this derived information, a national distribution of "portable facilities" for asphalt production sector is estimated as shown below.

It is for certain that besides in Ontario there are many other asphalt plants operating on a "portable" basis in Canada , and there is a great possibility that some of them would meet the " NPRI thresholds" for the required reporting.

4. Conclusions and Recommendations

The Joint Stakeholders Sub-Group on Harmonization (JSG), in the study report of December, 2004, has proposed four principles to guide the harmonization of NPRI and O.Reg 127/01. These principles are: Program and Reporting Integrity; Congruent Reporting Requirements; Effectiveness and Efficiency; and Value for Effort. It is conceivable that if NPRI would add the "portable facility" to its facility definition and MOE would delete it for its own reporting requirement, then the ultimate goal of "one-window" reporting system would be achieved to satisfy the first three principles.

The addition of "portable facilities" satisfies the fourth principle of Value for Effort for harmonization because of the following facts:

• The effort is minimal - EC could make this intent a reality by simply modifying the facility definition in the Gazette Notice for 2006, and MOE could amend the O.Reg.127/01 accordingly. Ontario reporters are already reporting to MOE and therefore should not have problems to report under the NPRI . As for other reporters, the emission factors information for the sector is readily available for them to use to provide reasonable data estimates
• The value is significant - As demonstrated for the Ontario asphalt plants, some 30% of the major pollutant releases for the industry sector come from the "portable" facilities, and therefore it is worthwhile to amend the facility definition for the appropriate data capture

5. Discussion Points

The following issues need to be considered in clarifying the reporting requirements of portable facilities:

• How should the threshold (employees and MPO) calculations be done if a portable facility is relocated for operations in more than one location in a year? Is it based on each individual location or a summation of all the locations involved?
• How is the reporting facility going to be identified? Is it based on one facility, one address, or one facility, multiple addresses? Can the software accommodate the approach that is meant for one facility with multiple addresses?
• Some ships have fish processing facilities. Is each ship considered a "portable facility" or is the whole group of ships (assume one company and they are in the vicinity of each other) a "portable facility"?
• What other types of portable facilities could be implicated?