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 no. of facilities from following industrial sectors in Canada which meet the reporting thresholds and will 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?

Tetrahydrofuran meets the original NPRI criteria, that is:

1. Emission of Tetrahydrofuran (THF) has been reported in Ontario with 3 tonne MPO criterion.
2. Ontario Point of Impingement standard is 93,000 μg/m3, and
   Ontario Ambient Air Quality Criteria is 93,000 μg/m3 for 24 hr basis

Tetrahydrofuran is of special concern because of its health effects.
Vapour can cause nausea, dizziness, headache, and anesthesia.
Liquid can de-fat the skin and cause irritation.
Liquid also irritates eyes.
Threshold limit value - 200 ppm.
Short term inhalation limit - 500 ppm for 30 min.
Toxicity by ingestion - grade 3, LD=50 to 500 mg/kg

THF may be harmful if inhaled, ingested or absorbed through the skin. Skin contact may cause dermatitis. Long term exposure may lead to kidney or liver damage. THF may cause narcotic effects and irritate the respiratory system.

THF is a suspected cardiovascular or blood toxicant, developmental toxicant, endocrine toxicant, gastrointestinal or liver toxicant, neurotoxicant, and respiratory toxicant (Source: scorecard website)

Properties: Water-white liquid with ethereal odour. Soluble in water and organic solvents.

Derived from 1) Catalytic hydrogenation of furan with nickel catalyst. 2) Acid-catalyzed dehydration of 1,4-butanediol.

Hazard: Flammable, dangerous fire risk. Flammable limits in air 2-11%. Toxic by ingestion and inhalation.

Use: Solvent for natural and synthetic resins, particularly vinyls, in topcoating, cellophane, protective coatings, adhesives, magnetic tapes, printing inks, etc. Grignard reactions, lithium aluminum hydride reductions, and polymerizations; chemical intermediate and monomer (Source: Hawley's Condensed Chemical Dictionary).

Other properties: Incompatible with halogens, strong oxidizing agents, strong reducing agents, strong bases, oxygen. May generate explosive peroxides in storage if in contact with air. Highly flammable. Hazardous polymerization may occur.

THF is listed as a hazardous substance in the U.S. OSHA and California OSHA (Source: Scorecard website). It is also cited by ACGIH, DOT, NIOSH, NFPA and EPA (Source: New Jersey fact sheet).

THF is a high volume chemical with production exceeding one million pounds annually in the U.S.

THF is more hazardous than most chemicals in 2 out of 3 ranking systems.

It scored in the worst 10% of all chemicals in the Ecological Health Rankings, receiving an IRCH (Indiana Relative Chemical Hazard) Environmental Hazard Score of 150. The IRCH Environmental Hazard score indicates how a chemical compares with others based on its capacity to impact human health, ecosystems, or environmental health in general. The score is based on toxicity and persistence considerations.

THF scored in the worst 10% of all chemicals in the Integrated Environmental Rankings, receiving an IRCH Total Hazard Value Score of 31. The score is based on toxicity and exposure considerations.

Source: scorecard website, Purdue University website - IRCHS.

Acute effects: Severe irritation and burning of the skin and eyes, and possibly eye damage. Breathing in THF can cause irritation of the nose and throat, causing wheezing and coughing. THF also causes headaches, nausea and dizziness. Very high exposure can lead to unconsciousness and death.

Chronic effects: There is limited evidence that THF causes cancer in animals. May cause liver and kidney cancer. Many scientists believe that there is no safe level of exposure to a carcinogen. There is limited evidence that THF is a teratogen in animals and therefore is possibly a teratogen in humans as well. Repeated skin contact causes dryness, cracking, and rashes. Since THF irritates lungs, repeated exposure may lead to bronchitis with cough, phlegm and shortness of breath. THF may also damage the liver and kidneys (Source: New Jersey fact sheet).

Air Exposure Limits:

OSHA: 200 ppm (PEL, 8 hr period).
NIOSH: 200 ppm (10 hr period), and 250 ppm (STEL - 15-min work period)
ACGIH: 50 ppm (8 hr work shift), and 100 ppm STEL

Note: with skin contact, overexposure may occur even if air levels are less than the limits (Source: New Jersey fact sheet).

(iii) Tetrahydrofuran 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] Emissions were for the period May 1, 2001 to December 31, 2001

[2] 2003 emission data are still being subjected to QA/QC.

In 2003, releases of THF reported to MOE under Reg. 127/01 totalled 168.048 tonnes. Of the total releases, 148.5 tonnes of THF was released by fabric coating industries (313320).

From Statistics Canada, Business Patterns Database (December 2003):

The number of fabric coating establishments (the largest emitters of THF based on emissions data from MOE O.Reg. 127/01) totaled 54 across 6 provinces (Ontario, Quebec, Alberta, British Columbia, Saskatchewan and New Brunswick).

In 1993, there were 11 principal establishments. This increased to 23 in 2002, representing a growth rate of 8.5% per year. The number of fabric coating industries increased by 15% in the most recent year (source: http://strategis.ic.gc.ca/ canadian_industry_statistics/cis.nsf/IDE/cis31332este.html).

There were 173 establishments in the unsupported plastic film and sheet manufacturing industry (the 2nd largest emitters of THF based on emissions data from MOE O.Reg. 127/01). These establishments were present in all provinces except for PEI (source: http://strategis.ic.gc.ca/ canadian_industry_statistics/cis.nsf/IDE/cis326114este.html).

There were 120 establishments in the motor vehicle seating and interior trim manufacturing industry (the 3rd largest emitters of THF based on emissions data from MOE Reg. 127/01) across Canada except in PEI, Newfoundland and Labrador, and the 3 territories (source: http://strategis.ic.gc.ca/ canadian_industry_statistics/cis.nsf/IDE/cis33636este.html).

The 147 establishments in the plastic pipe and pipe fitting manufacturing industry (the 4th largest emitters of THF based on emissions data from MOE Reg. 127/01) were found throughout Canada except in the 3 territories and PEI (source: http://strategis.ic.gc.ca/ canadian_industry_statistics/cis.nsf/IDE/cis326122este.html).

Industrial sectors that emit THF into the atmosphere according to O.Reg. 127/01 are listed below:

Based on the NAICS of the facilities that have reported to O.Reg 127/01, a data search of NPRI 2003 has revealed the following number of facilities reporting from each province in the same NAICS.

(iv) Tetrahydrofuran is reasonably expected to be present in the Canadian environment.

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 Tetrahydrofuran 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 Tetrahydrofuran 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 Tetrahydrofuran has been reported to MOE under O.Reg.127/01 in Ontario for the reporting year 2001, 2002, 2003 (see attached list) by facilities in the following industrial sectors:

fabric coating (313320),
footwear manufacturing (316210),
petroleum refineries (324110),
unsupported plastic film and sheet manufacturing (326114),
motor vehicle seating and interior trim manufacturing (336360),
pharmaceutical and medicine manufacturing (325410),
paint and coating manufacturing (325510),
plastic pipe and pipe fitting manufacturing (326122),
chemical (except agriculture) and allied product whl. (418410),
other miscellaneous chemical product manufacturing (325999),
wood window and door manufacturing (321911), and
petroleum product whl. (412110)

Some 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.

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. Tetrahydrofuran is not included in NPRI presently.

- 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.