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REPORT OF THE
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| Year | Action |
|---|---|
| 1993 | NPRI List of Part 1 substances was created and expanded based on a uniform 10 tonnes Manufactured, Processed or Otherwise Used threshold for reporting. |
| 1995 | Introduction of by-product definition and changes to 10 tonnes threshold to capture large releases of substances at low concentration |
| 1997 | General review of the NPRI resulted in mandatory reporting of pollution prevention activities and the voluntary reporting of (recycle, reduce and re-use) activities |
| 1998 | Ad Hoc Work Group on Substances formed |
| 1999 | 73 substances added to NPRI |
| 2000 | A permanent process, that included a Multi-stakeholder Work Group on substances, document on how to propose changes was developed |
| 2002 | Criteria air contaminants were added, with release thresholds and new data requirements - stack height, etc. |
| 2003 | Speciated volatile organic compounds (VOCs) were added in Part V |
| 2005 | On-line electronic reporting mechanism called "One Window to National Environmental Reporting System" (OWNERS) launched |
As listed in Table 1, a permanent process for modifying the NPRI was adopted by Environment Canada (EC) in 2000.1 The process was developed through consultations with Canadian stakeholders and with the assistance of members of the 1998 multi-stakeholder Ad Hoc Work Group on Substances. Shortly after, a stand-alone permanent process document, fully describing the process on how to propose changes, was developed by the 1998-2000 NPRIAd Hoc Work Group on Substances and adopted by EC in 2002. In evaluating proposed changes to the NPRI list of substances, a rationale should be provided against each of five Decision Factors. Please see Appendix C for a list of these Decision Factors.2
The permanent process calls for the creation of a NPRI Multi-stakeholder Work Group on Substances (WG) to address complex or multiple requests for future modifications to the NPRI. To obtain a balanced foundation for the NPRI, the WG members are to be drawn from industry, environmental non-governmental organizations (health, environment, labour)3, aboriginal governments and organizations, and federal and provincial governments. Consultation with stakeholders on proposed changes to the NPRI is fundamental to the process. Under the Canadian Environmental Protection Act, 1999 (CEPA, 1999), proposed changes to the NPRI must undergo public consultation prior to their final publication in Part I of the Canada Gazette each year. On an annual basis, EC notifies the public of proposed changes (drawing from suggestions that can be submitted by any party), and establishes an appropriate consultation process for input on those proposed changes.
The WG operates as a part of the broader NPRI consultation process. The Draft Interim WG Reports are posted on the NPRI web site for a 30-day comment period to collect additional feedback from other stakeholders and the public. Individuals can also request to receive the reports by regular or electronic mail. Thus, all interested Canadian stakeholders have an opportunity to comment on the draft recommendations of the WG. Written comments can be submitted to the WG via the web site, or by email, fax or post. WG members will fully consider input received from other stakeholders and the public before finalizing their recommendations to EC. Stakeholders may also, during the WG process, submit information that they feel should be considered in relation to the issues to be addressed by the WG.
The current Draft Interim WG Report presents background information on issues tabled with stakeholders, EC's proposals, and the WG's views and recommendations on proposed changes for the 2007 reporting year and beyond.
This report presents the progress and views on issues following two WG meetings in 2006 (February and June). The next WG meeting is scheduled for early November 2006 to address 2008 reporting year changes.
The tasks for the 2006 WG are to:
The Final 2006 WG Report will be submitted to EC in October 2006.
The WG met in Ottawa on February 22 and 23, 2006, and again in Toronto, on June 19 and 20, 2006, to consider a number of modifications proposed to the NPRI, and to address WG process issues and the longer-term vision, as well as the issues and timelines document for the NPRI WG. The majority of WG members, or their alternates, were present to participate in the discussions at both meetings. A facilitator (The Delphi Group) was retained for the meetings, to ensure balanced participation, assist in work plan and process development, assist in meeting preparation, facilitate dialogue at the meeting, and prepare the Draft Interim WG Report and meeting proceedings.
A number of technical sub-groups (SG) and Ad Hoc groups - some created in previous WG consultation meetings, and some proposed in 2006 - are working on WG issues requiring additional investigation. These groups will report their findings to the WG, for WG consideration. The current SG and Ad Hoc groups are listed below:4
This report reflects the discussion and recommendations of the WG on the following topics:
Issues Referred to Sub-groups and Ad Hoc Groups
Other Issues
The issues for which the WG is particularly interested in input from other stakeholders and the public are preceded in this document by this introductory statement in italics:
"The NPRI WG is seeking comment from stakeholders and members of the public on the following:"
Background
In 2000, EC and the Ontario Ministry of Environment (MOE) initiated a Pilot Working Group (PWG) to harmonize the administration and reporting requirements of the NPRI and Ontario's Airborne Contaminants Discharge Monitoring and Reporting Regulations (O.Reg 127/01). A Joint Stakeholders Group (JSG) was later formed, composed of some members of the NPRI WG and O.Reg 127/01 Stakeholders Work Group. The mandate of the JSG was to make recommendations on the steps to harmonize the two programs. One of the issues to be addressed was the reporting of particulate matters (PM, PM10, and PM2.5) from road dust resulting from vehicular traffic, within facility roads.
Particulate matter (PM) encompasses many different substances originating from a myriad of different sources. It is usually categorized according to particle size. The term PM10 refers to particles with a nominal aerodynamic diameter ≤ 10 micrometers (μm), while PM2.5 refers to a subset of PM10 representing particles with diameters ≤ 2.5 μm.5 Particles up to 100 μm in diameter are called total suspended particulate or TSP. PM is a component of smog and a form of air pollution for which significant adverse environmental and health effects have been identified. Elevated concentrations of PM are found year-round in all regions. As a result, PM10 has been declared toxic under CEPA, 1999. In order to minimize risks associated with PM, a long-term management plan for PM and ozone was established pursuant to the 1998 Canada-wide Accord on Environmental Harmonization of the Canadian Council of Ministers of the Environment (CCME) and its Canada-wide Environmental Standards Sub-agreement.6
PM has been linked to serious health impacts including asthma and premature deaths. Recent scientific evidence indicates that there is no apparent lower threshold for the effects of PM on human health.
Rationale for Inclusion of PM Emissions from Unpaved Road in the NPRI Reporting of PM Emissions
PM emissions from road dust are directly related to broad issues of environmental and health concern, such as smog and decreased visibility. PM emissions from road dust have the potential to cause soil effects, the smothering of leaves by blocking stomata, and reduction of visibility in wilderness as well as urban environments.
Because PM10 have been declared toxic, and PM is known to impact adversely on the environment and human health, and for the purposes of harmonization between O. Reg. 127/01 and the NPRI, EC is proposing the inclusion of PM emissions from unpaved road in the estimation and reporting of facility PM emissions under the NPRI for the 2007 reporting year. Currently, facilities meeting the reporting threshold for PM, PM10 and PM2.5 are required to report under the NPRI. EC, therefore, is proposing that facilities that equal or exceed thresholds for PM emissions from road dust within the facility must report. Furthermore, just as EC does in the scheme of overall inventory, facilities should report all sources of emissions and there should not be any exemptions. The inclusion of PM emissions from road dust in the total PM emissions of a NPRI reporting facility would be linked with its removal from O. Reg. 127/01, to avoid double reporting.
Based on EC's estimation (assuming 5% silt content and 10% moisture content), EC is recommending that reporting of PM emissions from unpaved road be required for 10,000 vehicle kilometres traveled (VKT) on the unpaved road within the facility in a given year. It is expected that 10,000 VKT will trigger the current reporting threshold for PM10 and PM2.5 of 500 kg and 300 kg respectively. Facilities meeting the 10,000 VKT would be required to estimate emissions of PM from road dust and report if they meet the reporting thresholds. Setting 10,000 VKT criteria is not only practical, it will simplify reporting and compliance for facilities where emissions of PM from road dust is small. EC will provide emission estimation guidance on emissions of PM from unpaved road. While other methods for estimation of PM from road dust may be acceptable, the US EPA empirical model to estimate the quantity of size specific PM emissions from an unpaved road per vehicle mile traveled is widely accepted.
Based on MOE data base, the projected number of facilities in Canada which may report particulate matter emissions from road dust is 400. This number is a preliminary estimation only.
Based on 2002 Ontario data, PM emissions from road dust (within facilities) contributes to approximately 1% of the total provincial PM emissions from road dust; however, estimated emissions of PM, PM10 and PM2.5, from road dust represented 24%, 15% and 7% of total facility emissions from facilities in Ontario. In 2002, 13,345 tonnes of PM, 4,645 tonnes of PM10 emissions, and 1,045 tonnes of PM2.5 emissions from road dust were reported by 281, 733 and 612 facilities respectively.
For all those Ontario facilities that reported PM, PM10 and PM2.5 emissions from both road dust and process emissions, PM emissions from road dust accounted for a substantial portion of process emissions. For example, emissions of PM, PM10 and PM2.5 from road dust were reported to be 30%, 17% and 7% of the process emissions respectively.
The analysis of the 2002 MOE PM emissions from road dust data indicated that emissions of PM, PM10 and PM2.5 from road dust associated with facilities in urban areas are estimated to be 60%, 64% and 63% of the total PM emissions from road dust respectively. As a result, PM emissions from road dust in urban areas should not be ignored, considering impact on the environment and human health in populated urban centers.
EC Proposal
Facilities meeting the 10,000 VKT would be required to estimate emissions and report emissions of PM from road dust to the NPRI if they meet the reporting thresholds.
Status of SG
The SG has recognized that there are number of issues related to defining which roads are to be included in the determination of 10,000 VKT in the estimation of PM emissions from road dust. As well, a list of question was forwarded to EC for its response. The SG will provide recommendations to the WG once the SG receives EC's response to the list of questions.
WG Views
The WG observed that it is challenging to quantify PM emissions from road dust. The two primary areas of concern for some members of the WG were: the significance of road dust emissions from industry relative to public roads; and the quantification methods available for this emission source. Other members from ENGOs did not find this to be an issue, and urged EC to proceed. Some WG members expressed concern over the quality of emissions estimates. ENGOs supported the 10 000 VKT proposal. All WG members are expecting that EC would provide guidance for reporting and some associated issues would be fleshed out.
A series of questions and points arose in discussion from industry, and the SG needs answers before making recommendations to the WG. Responses were put forward by EC to the questions raised by certain stakeholders. See Appendix D for a complete list of these questions and responses.
"The NPRI WG is seeking comment from stakeholders and members of the public on the following:"
Facilities meeting the 10,000 VKT would be required to estimate emissions and report emissions of PM from road dust to the NPRI if they meet the reporting thresholds.
Background
Prior to 2005, mining was exempted from reporting to the NPRI, but neither further processing nor other use of mined materials was exempt. This exemption was re-examined in 2005. In 2005, after discussion among WG members, the WG agreed to remove the reporting exemption for mining. However, the NPRI decided to implement the removal of this exemption in stages as facilities are made aware of the changes. This led to a decision by the NPRI to exempt pits and quarries from reporting in 2006, while intending to require reporting in the 2007 reporting year once EC determines an appropriate threshold for this sector.
A Mining SG was formed in 2003 to examine modifications to the mining exemption in the NPRI.
The Mining SG reconvened in 2006 to address outstanding issues. The objectives of this SG for 2006 are to develop recommendations to the NPRI WG on the following issues (noting that linkages may exist between said issues):
The SG has also reviewed its TOR.
Status of SG
The SG decided not to pursue discussions on capturing releases by advanced exploration. It was agreed that while environmental impacts from advanced exploration may be causes for concern, the NPRI is not the most appropriate mechanism to capture this information.
The SG discussed the issue of reporting thresholds for pits and quarries at length and recommended to the WG that an ATH for pits and quarries be established at 500 000 tonnes of production.
WG Views
WG members were uncertain of the action being taken regarding broader discussions on the reporting of mine tailings and waste rock. The WG members felt that there is a need to obtain further input. The WG questioned EC's decision to refer this particular issue to the Mining Sector Sustainability Table for resolution and the approach. The WG expressed a desire to review any outcomes should the Sector Table decide to address this issue.
The WG thinks that clarification and consistency of terms and definitions are required (e.g. "non-metallic minerals, mining and quarrying" to refer to the "pits and quarries" sector; a clear definition for "advanced exploration").
The WG discussed the potential number of facilities that would report under the 10 employee (20,000 worked hours) threshold and the ones that would report under the 500,000 tonnes production threshold.
A WG member questioned whether the proposed production threshold would lead to further complication for facilities determining if they have to report to the NPRI.
WG members are confused about the meaning of all the different thresholds, i.e. 10 employee (20,000 worked hours), production and British Thermal Unit (BTU) threshold.
There is a need for further analysis and clarity on these issues.
The NPRI WG is seeking comment from stakeholders and members of the public on the following:
The WG recommended that two options be included in the Draft Interim WG Report for broader stakeholders' comments.
Option #1
Option #2
NOTE All exempted activities (i.e. pits and quarries, among other activities) also must report on releases of CACs if they meet this BTU threshold, meaning that pits and quarries have always been subject to it. For the purposes of our analysis it is not possible to determine the impact on the number of facilities due to the requirement to report CACs from combustion sources regardless of the number of employees. It is unlikely that pits and quarries have significant external combustion sources unless there are other activities on site such as a concrete batch plant or an asphalt plant.
Background
In 2005, EC presented some data issues and data gaps with the information currently collected for the CACs (substances listed under Part 4 and 5 of the NPRI reporting requirements). EC also identified the impacts of these data issues and data gaps on its ability to compile the comprehensive emission inventories for CACs, meet the annual reporting obligations of domestic programs and international agreements, and provide the data required for air-quality models and policy developments. A decision was made at that time to form a technical SG to review the data issues and data gaps, identify options, and provide recommendations for future modifications to the NPRI reporting requirements.
The SG, established in September 2005, is responsible for reviewing the data quality issues and data gaps identified for the CACs inventory, identify the possible options, and prepare a report that will provide recommendations to the WG. The recommendations will not be limited to the potential modifications to the NPRI reporting requirements and the One Window to National Environmental Reporting System (OWNERS).
The recommendations to be proposed by the SG should resolve the data quality issues and data gaps and allow EC to:
These recommendations will be developed with the consideration that the emission inventories must be transparent, consistent, comparable, complete, accurate; and that they must minimise the reporting burden on the industries.
Facilities have been required to report CAC emissions to the NPRI since 2002. The CACs include: sulphur oxides (SOx); nitrogen oxides (NOx); volatile organic compounds (VOC); carbon monoxide (CO); and particulate matter (TPM, PM10, PM2.5). Emissions for individual VOC species have been reported by facilities to the NPRI since 2003. The VOC species include 34 individual substances, 20 isomer group, and 6 other groups and mixtures.
Status of SG
The CAC SG has held a number of conference calls, and two meetings. The goal of the first meeting was to identify the recommendations to be included in the SG's report to the WG, and to develop the next steps.
The purpose of the second meeting was to:
At the present time, there is continuing discussion on the role of the NPRI and the compilation of comprehensive inventories. The SG is continuing its work and has no proposal at this time. The SG's report will be made available by October.
WG Views
In response to WG members' concerns about the adequacy of NPRI data for other reporting obligations, EC noted that it is always grappling with what will be useful in going forward (and considering stakeholders' perspectives). Industry WG members expressed the desire for NPRI to be the database that is (widely) accepted and used, especially considering the resources that have been devoted to it thus far. Industry representatives of the WG expressed a need for information from EC on issues related to data quality. Industry members maintain their position that facilities are in the best position to calculate and report their emissions because they have the most accurate and up to date understanding of their processes.
Industry members indicated that significant effort goes into the calculation of emissions for their facilities and that they were uncomfortable with EC making adjustments to their reported data. Industry members suggested that in the event that EC has concerns with respect to reported data, EC should consult with the appropriate facility or association. Industry representatives are concerned that the alteration of a facility's reported data by EC, based on an updated emission factor, is not appropriate because EC may not be aware of company-specific issues that may affect the calculation. Additionally, industry stated that because currently, company officials sign off on the reported data and the data is publicly available, therefore, companies should no longer be held responsible or accountable for the data submitted, if there is the possibility that EC may alter industry's data.
An ENGO WG member noted significant issues relating to CAC data that impinge on data reliability and confidence in interpreting and using the data for various purposes, including public dissemination. These issues include data gaps and discrepancies; lack of measured data; verification methodologies and data elements (such as process data) that are not required but may be necessary for the NPRI to serve as the appropriate facility-based data inventory for modelling and other purposes. These issues are very broad and complex; they deserve fair time for discussion. Other issues to be examined are speciation (Part 5) as well as stack height.
From the ENGO perspective, there is a tension between the mutually credible industry claims to want to reduce reporting burden and their assertion that they are best placed to resolve process level data issues. The ENGO view is that in balancing these concerns EC must be guided by the principle that community right to know trumps inconvenience.
The WG will wait to obtain a copy of the SG report before pursuing discussion.
Background
While the final report of the U.S. 2000 Dioxin Inventory Update is still not available for reference, and there is little progress on the U.S. Toxics Release Inventory proposal for reporting changes of dioxin and dioxin-like compounds category (Toxic Equivalency Reporting Rule of March 2005), EC is deciding to move along on the issue since there is an increasing desire for harmonization of D/F between NPRI and Ontario Regulation 127/01 for the 2007 reporting year.
NPRI currently requires a facility to report, in gram (g) International Toxic Equivalence ( ITEQ), the cumulative releases of the 17 D/F congeners, provided the facility is engaged in one of the 17 identified activities, as stipulated in the Canada Gazette of February 25, 2006.
MOE, under the Ontario Regulation 127/01, requires a facility to report for two specific congeners of D/F, if the MPO threshold of 0.1 g for each congener is met. The two congeners are:
The JSG recommended, in December 2004, that NPRI should split these same two congeners from its D/F category of 17 congeners for their individual reporting, and thus allow MOE to eventually delete them from its listing.
It is scientifically recognized that both polychlorinated dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs) have a similarity in physical and chemical properties, and 17 of the possible 210 congeners of the PCDDs and PCDFs exhibit dioxin-like toxicity. These are the same 17 congeners currently included in the D/F category of the NPRI. It is also scientifically recognized that 12 of the possible 209 polychlorinated biphenyls (PCBs) congeners, the so-called coplanar congeners, are structurally and conformationally similar and have the dioxin-like toxicity.
At the beginning of 2006, EC tabled its proposal to the stakeholders regarding reporting changes for D/F and HCB. Those changes had been suggested mainly due to the need for harmonization between the NPRI and the MOE Regulation 127/01 and for meeting Canada's international reporting obligations. Once the proposal was tabled, the WG felt that the proposed reporting changes warranted further discussion and consequently suggested that an ad hoc group be formed to examine the issues surrounding the proposal.
Based on an investigation of the appropriateness and implications of the proposed changes, the ad hoc group on D/F and HCB shall develop recommendations to the NPRI WG on the following issues:
For D/F:
For HCB:
EC Position
NPRI supports the JSG recommendation and proposes to take it one step further, in that all the existing 17 congeners should be reported on an individual basis. This would not only satisfy the MOE requirement for the reporting of two specific congeners, but would also provide EC the opportunity to fulfill its international reporting obligations (e.g. Stockholm Convention) for consistency - leading to improved data comparability with the U.S. Toxics Release Inventory Program if their Toxic Equivalency Reporting Rule becomes final.
NPRI also proposes to maintain the criteria for the reporting of individual D/F congeners as activity-based instead of quantity-based. NPRI would perhaps be in a better position to propose the "quantity-based" option (e.g. 0.1 gram) for stakeholders' consideration once the ATH Framework is fully complete and operational.
As more and more international "dioxins" inventories tend to include the dioxin-like PCBs for the relevant data estimation, NPRI should do the same for data comparability. In view of this fact, NPRI proposes to add the 12 coplanar PCBs to the current D/F category consisting of 17 PCDDs/PCDFs congeners, and requires them to be reported on a congener-specific basis.
Upon review of the most recent available information, it is felt that at least two other activities and/or sources should be added to the existing list for the prescribed reporting of releases, disposals and/or transfers for recycling of D/F, namely: regeneration of spent catalyst in petroleum refineries, and land application of municipal biosolids (or land disposal of municipal sewage sludge).
Since both the HCB and D/F releases result from the same type of thermal and chemical processes, and HCB is formed by a similar mechanism as that for D/F, the two new activities proposed for the D/F reporting must be also considered as additional new activities for the reporting of HCB. Also, pigment production is proposed as an additional activity listing for the HCB reporting since there are HCB releases found from this industrial source, according to the U.S. Toxics Release Inventory.
If NPRI adds the dioxin-like PCBs to the D/F category for reporting, then the WHO-TEQ are the ITEQ. A weighting factor could be used to display dioxin and furan data.
EC Proposal
Proposal #1 is also true for PCBs. EC will weight the individual congeners according to either the WHO-TEQ or ITEQ scheme. Long-term trend information will use ITEQ.
Status of Ad Hoc Group
The ad hoc group provided an activity report to the WG. It included several recommendations for reporting changes.
The most recent recommendations from the ad hoc group are as follows:
1. Adding the 12 dioxin-like PCBs in the D/F category for individual reporting.
The NPRI D-F and HCB SG confirmed that the National Academy Science (NAS) report would contain valuable information regarding emission factors, health effects and risk assessment results. As of the SG's final consultation, the report had not been released. The report is expected later in July but further delays are possible.
Acknowledging this, two divergent positions emerged in discussions regarding addition of dioxin-like PCBs without first reviewing the NAS report. The first suggested that recommendations would be premature until the SG was given a chance to fully consider the NAS report. Further action should therefore be deferred until the NAS report was given due consideration by the SG.
The second position suggested that in light of existing information available elsewhere, a recommendation to add the 12 dioxin-like PCBs for individual reporting should go forward as proposed.
A consensus among the SG was not reached.
2. Changing the reporting of D-F values from g ITEQ to g WHO-TEQ.
The SG recommends that beginning with the 2007 reporting year, industry be directed to report release data for specific congeners in terms of "grams".
This would allow for some degree of flexibility. Release information could be calculated as ITEQ on a continuing basis or be converted to WHO-TEQ at a later time. EC would be obliged to develop the ITEQ and WHO-TEQ comparison mechanism to ensure congener quantity details would be fully understood. In turn, EC would outline the information in the NPRI website in such a way to ensure easy access for all users.
3. Adding activities to the list of reporting activities.
This issue will remain outstanding until further discussion by the SG.
WG Views
The WG has expressed some need for clarification on sewage sludge and on the wastewater treatment processes; there was a common sentiment that there will be a need to precisely define what is meant by processing of wastewater sludge. (The wordings have been subsequently modified to "land application of municipal biosolids" or "land disposal of municipal sewage sludge".)
An impartial scientific review, on D/F and PCBs, by the U.S. National Academy of Science, has been expected since Fall 2005 and the WG is still waiting. The ENGOs commented that there is really no need to wait for the U.S. to act.
A WG member suggested that EC be responsible for converting the TEF values from the I-TEQ scheme to the WHO-TEQ scheme, if the latter is adopted for future reporting needs.
The WG requested that action be undertaken as much as possible in parallel between Ontario and NPRI consultation processes for harmonization purposes.
The WG recommended that EC change the reporting of D-F from category basis to individual listing of congeners. The WG accepted the recommendation # 2 as presented by the ad hoc group. Therefore the WG recommendation is to c hange the reporting of D-F values from g ITEQ to g WHO-TEQ.
The NPRI WG is seeking comment from stakeholders and members of the public on the following:
Recommendation # 2 as presented by the ad hoc group, which is to c hange the reporting of D-F values from g ITEQ to g WHO-TEQ.
Background
In 2004, the WG agreed to form a sub-group Long-term Direction and Scope (LTDS) SG to take stock of the NPRI and explore how it can be refined; in particular to make it more streamlined, to enhance data quality and to address priority emissions of concern. It is an opportune time for a comprehensive reflection on the program's mandate and future opportunities because of a number of circumstances. The NPRI program itself has expanded and matured substantially over the years and many of the most critical substances of concern have been addressed; consideration of future candidate substances will present different challenges. The government is undertaking its mandatory review of CEPA, 1999, raising the question of which issues related to the NPRI need to be addressed, and how EC is embarking on new strategic directions which may present new issues and opportunities for environmental information and reporting in general and the NPRI in particular.
Keeping in mind the priorities and objectives of the NPRI program, the LTDSSG will formulate a process to develop recommendations for delivering the NPRI program for the next decade .
The SG is responsible for preparing recommendations to the WG. In doing so, it will consider the opinions and concerns expressed by all stakeholders.
More specifically the mandate of the WG is:
EC reported that a consultant has been hired to carry out a survey. The focus of this contract work will be to survey users (beyond the WG) who report to, and/or use the NPRI data.
Status of SG
The SG identified issues as well as an Action Plan, including 2 alternative options for a path forward to address the mandate of the SG.
WG Views
The WG decided that the path forward to address the mandate of the SG will be a workshop format followed by a broader consultation.
The SG may decide to seek input from the WG members into the design and content of the survey questionnaire.
Background
During the June 2005 meeting of the WG, EC proposed the addition of total reduced sulphur (TRS) to the NPRI. The listing of TRS on the NPRI could aid in the harmonization effort with the MOE Regulation 127/01, help identify priorities for action, and support targeted regulatory initiatives.
In September, 2005, the WG agreed to form an ad hoc group to look at the issues surrounding the addition of TRS to the NPRI. The WG agreed to add TRS to the NPRI as it met all of the decision factors for the addition of a substance to the NPRI7. The objectives of the Ad Hoc group on TRS are therefore to develop recommendations to the NPRI WG on the following issues:
TRS refers to a group of compounds containing the sulphur atom in its reduced state. TRS consists of hydrogen sulphide (H2S), carbon disulphide (CS2), carbonyl sulphide (COS), dimethyl sulphide (C2H6S), mercaptans (CH4S), dimethyl disulphide (C2H6S2), diethyl disulphide (C4H10S2), thioesters, and alkyl sulphides. TRS is released to the Canadian environment through natural sources as well as anthropogenic sources. TRS natural sources include mostly decaying organic matter, while anthropogenic sources of TRS include kraft pulp mills, natural gas wells, petroleum refineries, steel mills, coking operations, manufacturing of certain abrasives, and sewage treatment plants. However, the largest sources of TRS in Canada derive from the pulp and paper industry and upstream oil and gas facilities. Currently, H2S, CS2, and COS are reportable substances listed in Part 1 of the NPRI.
Ad Hoc Group Proposal
The Ad Hoc group is proposing to the WG that the NPRI should list some TRS, defined as consisting of hydrogen sulphide (H2S), carbon disulphide (CS2), carbonyl sulphide (COS), dimethyl sulphide (C 2H6S), methyl mercaptan (CH4S) and dimethyl disulphide (C2H6S), as well as the currently reported three species, in Part 1. This listing would be consistent with the position taken in the report Review of the Recommendations in the Report ‘Review of Differences and Development of Harmonization Options between Ontario's Airborne Contaminants Discharge Monitoring and Reporting Regulation and the National Pollutant Release Inventory'. This report states that "the JSG agrees that of the four substances (i.e. dimethyl disulphide, dimethyl sulphides, mercaptans and total reduced sulphur), only the addition of TRS be considered for addition to the NPRI" and that "the four substances be deleted from O. Reg. 127/01 since the other three contaminants are, in fact, part of TRS." It is proposed that double-counting could be prevented by the way in which TRS and its species are reported on the NPRI website: When the user opens the online database and selects TRS, another screen could open, showing the releases of the component species reported, ensuring that the releases of the species are not added to the releases of TRS in creating totals. As the issue of double-counting is not isolated to the reporting of TRS, a separate note, available on the online data-search site and on the downloadable database site, advising users on all double-counting, would be valuable.
The last draft of the Ad Hoc group's proposed TRS qualifier is as follows:
"Individuals attempting to calculate total emissions for a certain pollutant, a pollutant class or releases in a certain year are cautioned about the possibility of double- or triple- counting. In reporting to the NPRI, companies may report a release of a pollutant to two or even three separate pollutant classes. As an example, a company may report a release under 'Carbon Disulphide' and the same release again under 'Total Reduced Sulphur' and then again under 'Total VOC'. Therefore, simply adding numbers from the three categories will give an inflated total when attempting to report on total emissions containing sulphur."
The 10-tonne MPO threshold for TRS is appropriate as it has not been shown to warrant an alternate threshold. The current 10-tonne threshold for H2S, COS and CS2 is appropriate because lowering the threshold would likely create an extra reporting obligation for smaller facilities which do not release large amounts of these substances.
Since facilities measure and report TRS in different forms, it is essential to determine whether TRS should be reported on as TRS (i.e. the sum of the individually weighed species), or as TRS in terms of H2S. Pulp and paper facilities measure TRS as H2S, in compliance with their permits. Calculating TRS in terms of the weights of each species from this number would not provide an accurate sum unless the percentage of each species released was known. It is straightforward, however, to calculate TRS in terms of H2S from the weights of individual TRS species, using their molecular weights. TRS expressed as H2S would be comparable to provincial outcomes obtained from permits, and would appropriately relate to the impact of TRS, focusing on the operative sulphur element. Individual species of TRS shall be displayed.
WG Views
The WG has accepted the proposal put forward by the ad hoc group to add TRS to Part 1 of the NPRI for the 2007 reporting year.
The NPRI WG is seeking comment from stakeholders and members of the public on the following:
The addition of TRS to Part 1 of the NPRI for the 2007 reporting year as recommended by the ad hoc group.
Status of Ad Hoc Group
As TRS was accepted by the WG for addition to the NPRI, according to the proposal recommended by the ad hoc group, it was determined that the TRS Ad Hoc group would be disbanded.
Background
In 2005, EC proposed the addition of 12 new Polycyclic Aromatic Hydrocarbons (PAHs): three from the MOE O. Reg. 127 acenaphtene (CAS No 83-32-9) , acenaphtylene ( 208-96-8) , and fluorine ( CAS No: 7782-41-4) and nine from the U.S. TRI: 3-Methylcholanthrene (CAS No. 56-49-5), 5-Methylchrysene (CAS No. 3697-24-3), 1-Nitropyrene (CAS No. 5522-43-0), 7,12-Dimethylbenz(a)anthracene (CAS No. 57-97-6), Dibenzo(a,h)acridine (CAS No. 226-36-8), Dibenzo(a,e)fluoranthene (CAS No. 5385-75-1), Dibenzo(a,h)pyrene (CAS No. 189-64-0), Dibenzo(a,e)pyrene (CAS No. 192-65-4) and Dibenzo(a,l)pyrene (CAS No. 191-30-0).
During the 2005 WG meetings, the WG recommended to EC the addition of three MOE PAHs under Part 2 of the NPRI for the 2006 reporting year. The addition of these PAHs to the NPRI offers several advantages including: removing them from the O. Reg.127/01 list to avoid duplicative reporting; to identify priority measures and priorities for action and to support targeted regulatory initiatives. Since a consensus was reached for the addition of three MOE PAHs, EC agreed to add the three MOE PAHs for the 2006 reporting year under part 2 of the NPRI.
The WG recognized that there were issues related to the reporting of minimum amounts of these PAH, including what may be an appropriate de minimis threshold. There were also environmental and health questions related to the remaining nine PAHs. Under the WG recommendations, EC created an ad hoc group on PAH to examine the issue of a de minimis threshold for reporting of all NPRI PAH and review environmental and health issues related to the nine remaining TRI PAHs.
The term PAH refers to the compounds made up of carbon and hydrogen atoms grouped into rings containing five or six carbon atoms.
PAH constitute a class of chemical products that include about 100 individual compounds. PAHs are generated from both anthropogenic and natural sources. In Canada, natural emissions of PAHs originate primarily from forest fires, which release approximately 2,000 tonnes per year.
The objectives of the NPRI Ad Hoc group on PAHs for 2006 are:
Status of Ad Hoc Group
The ad hoc group presented the following recommendations to the WG:
WG Views
WG members wondered about the compatibility with the US TRI on this issue, and requested that the PAH Ad Hoc Group address the compatibility issue by taking a look at the four substances unique to NPRI.
The ENGO view was that lack of information on specific environmental and health effects should not prevent action - these substances have been declared toxic under CEPA, 1999 and therefore action is required.
The WG endorsed the ad hoc group's intention to continue to examine the number of issues it has identified in its mandate and endorsed its recommendations.
The WG endorsed the recommendations of the ad hoc group.
The NPRI WG is seeking comment from stakeholders and members of the public on the following:
The recommendations of the ad hoc group to:
Background
EC has been working on modifications to the Canada Gazette Notice to allow the capture of information changes after the annual due date of June 1. The intent is to modify the wording for the 2007 Notice, or possibly as an Amendment to the 2006 Notice. EC has explained that the underlying reason for this proposal is optimizing the manner in which contact information and revised data would be kept up-to-date, since NPRI reporting is being done on-line. EC has emphasized that it needs to have a reliable and up-to-date way of reaching representatives of companies.
EC Proposal
The NPRI WG is seeking comment from stakeholders and members of the public on the following:
EC NPRI presented a proposal to have the following changes made to the NPRI Canada Gazette Notice for requesting the re-submission of the report after the due date of June 1.
(a) If a person has submitted information to the Minister in accordance with the NPRI notice and if, at any time within a year after June 1, the due date of submission of the information, the person becomes aware that there has been a change to the following "basic identification" information:
(b) If a person has submitted information to the Minister in accordance with the NPRI notice and if, at any time within a year after June 1, the due date of submission of the information, the person becomes aware that the submitted information was mistaken or inaccurate, that person must provide the explanation as to why this has occurred and if necessary, must correct and re-submit the information to the Minister within 30 days after becoming aware that the submitted information was mistaken or inaccurate. If a person feels that time extension is required in order to adequately prepare the additional information, that person must indicate the need to the Minister in writing. The Minister may grant a reasonable period of time extension upon such request.
WG Views
Some WG members expressed concerns regarding the administrative burden that this proposal could create, and potential compliance problems with providing contact information.
Other members expressed the opinion that all information should be available to the public, and that keeping it up-to-date must be the responsibility of government and industry.
Based on the latest concerns of the WG, EC will continue to work towards a better deliberation of update requirements (e.g. to determine the most simplified contact update that would satisfy the same needs as originally intended). The WG will be provided with another opportunity to comment on the updated revised version before it is published as an Amendment to the 2006 notice.
Background
Prior to 2000, all substances listed in NPRI had common reporting criteria: 10 tonnes manufactured, processed or otherwise used at a concentration of 1% or more, except for byproducts. This is known as the conventional M, P, O threshold.
There is a need to identify substances that may require an alternate threshold (ATH) for their data capture. This should be done in an efficient manner to facilitate the substances' additions and to limit ATHs to those substances that truly require lower reporting thresholds. Consequently, a proposed framework is being developed to list the criteria that would assess whether an ATH is necessary for a candidate substance.
A proposal document of an Alternative Threshold Framework (ATH) was tabled at the NPRI consultation meeting on September 2004.8 This framework, designed to help to streamline the process and make listing of NPRI substances with an alternate threshold more consistent and transparent, addresses the following:
In its Responses to the Recommendations of the Final Report of the NPRI Multi-stakeholder WG on Substances (2004), EC agreed that the draft ATH framework should be used as an "interim framework," pending the results of a more comprehensive review of the NPRI, and that work should continue on the ATH framework to define Category 3 substances.
EC Proposal for Path Forward
EC proposes to develop 3 -5 scenarios for releases to air and to water for modelling emissions from industrial/commercial facilities. These scenarios will be used to help choose the most appropriate "standard" NPRI thresholds for reporting. Models have been used as part of evaluations of toxicity under CEPA, 1999 when there has been no information on ambient concentrations.
EC is soliciting input on the merits of such an approach to establish thresholds. EC will consider input on the most appropriate means to conduct the development of such scenarios, or whether there might be alternative approaches to set thresholds.
EC has proposed the option of utilizing the air dispersion modelling technique for the intended objective. The outputs from the air dispersion modelling will be one of the many considerations on whether to adopt alternate thresholds. Water models, for which the operating principles are generally similar to air dispersion models, can also be used as a tool to help the decision-making.
In order to test the validity of using the "reversible" dispersion modelling technique to determine the ATH threshold, EC is proposing that, once it is agreed in principles by the stakeholders to proceed, some substances be used as case studies to illustrate how the methodology works. Based on the existing knowledge about thallium, beryllium, and nickel and on the anticipation to have ATH for their reporting, these Category 3 substances can be used for that purpose.
WG Views
The WG felt that they required some illustrative case studies, and the context of real examples (i.e. substances), to engage in a valuable discussion on this issue. Industry WG members took issue with the use of models for threshold development because models can be conservative and flawed. ENGOs in particular requested more explanation on the scenarios and how this proposed process could be more applicable and make it easier to determine thresholds. Some WG members expressed concern that this activity could delay action on deferred substances. As well, while the WG was agreeable to this path forward, ENGO members stressed the importance of moving this process along and preventing further delay.
The WG has cautioned that risk assessment and air modelling would require considerable expertise to be effective.
WG members also cautioned about the limitations of modelling and suggested that other scenarios be proposed while cautioning about the resource requirements implied by this modelling proposal.
A WG member suggested that we must test the model beyond just metals.
An ENGO representative noted that the timeline presented for this work is ambitious, and stated that the efforts must have some longevity and the potential to be applied in future. It was outlined that this proposal represents only one way to address category 3 substances which may not be acceptable for air quality objectives.
The WG suggested reactivating the ATH SG to examine how this fits into the bigger picture.
The NPRI WG is seeking comment from stakeholders and members of the public on the following:
The WG recommendation is to reconvene the SG on alternative threshold. Its mandate will include modelling, but also the broader concept of an ATH framework.
WG Views
ENGOs have requested a report on the progress made so far on the deferred substances. There continues to be frustration among some WG members that a number of substances that were previously proposed for addition or listing changes remain deferred due to lack of time and/or adequate information or analysis. These include, among others: PCBs, nickel, beryllium, radionuclides, and thallium.
ENGOs suggested that EC should be using a matrix format for demonstrating the status of issues/ items with more discipline, and for prioritizing issues for action. Such a tool had been suggested in previous meetings.
One ENGO member requested that when deferred substances are tracked, this should include not only substances on the current "deferred substances" list, but also substances that had appeared on previous lists, dating back to 1999. The list needs to be up-to-date and inclusive.
The WG agreed to adopt the use of a tool to track deferred substances, among other WG issues and action items.
2006 STAKEHOLDER CONSULTATIONS ON MODIFICATIONS
TO THE NATIONAL POLLUTANT RELEASE INVENTORY
The NPRI Multi-stakeholder Work Group on Substances
(2006)
TERMS OF REFERENCE
A permanent process for modifying the National Pollutant Release Inventory (NPRI) was developed through consultations with Canadian stakeholders and with the assistance of members of the 1998 multi-stakeholder Ad Hoc Work Group on Substances.
The permanent process provides for the establishment of a NPRI Multi-stakeholder Work Group to address complex or multiple requests for future modifications to the NPRI.
The Work Group will operate as a part of the broader NPRI consultation process. Draft Work Group reports will be posted on the NPRI web site, and individuals can also request to receive the reports by regular or electronic mail. Thus, all interested Canadian stakeholders will have an opportunity to comment on the draft recommendations of the Work Group. Written comments can be submitted to the Work Group via the web site, or by email, fax or post. Work Group members will fully consider input received from other stakeholders before finalizing their recommendations.
Stakeholders may also, during the Work Group process, submit information that they feel should be considered in relation to the issues to be addressed by the Work Group.
Important Note : The issues identified below may be modified by Environment Canada at any time during the consultation period, either as a result of the consultation process or because of emerging priorities.
The objectives of the 2006 NPRI Multi-stakeholder Work Group (WG) are to develop recommendations to Environment Canada on the following issues:
C. Elements of the Work Group Process
In accordance with the requirements of the permanent process for modifying the NPRI, the Work Group process will include the following elements:
D. Timeline
The Draft 2006 report of the Work Group will be submitted by March 15, 2006 and the Final Report by July 31, 2006. The 2006 Work Group report will be submitted to Environment Canada by August 31, 2006.
E. Membership
Membership of the Work Group will be divided amongst the following groups:
Each of these groups will be allocated seats on the Work Group. Nominations for membership will be sought from:
Nominations from other sources will also be considered, as long as the nominated individual fits the profile described in Section C.
The Chief of the NPRI, as well as staff from the NPRI office, will also attend Work Group meetings; and other Environment Canada staff may attend as "expert advisors". A key role of these advisors will be to ensure that Work Group members are fully apprised of the conditions necessary to support the needs of Environment Canada in formulating their recommendations.
Interested stakeholders who are not members may attend Work Group meetings as observers. The number of observers will be limited by space availability, so requests for attendance must be made in advance, with priority given to stakeholders with broadly relevant views or interests that may not be fully represented by Work Group members.
F. Mandate of the Work Group on Substances
The Work Group is responsible for preparing recommendations to Environment Canada. In doing so, it will consider the opinions and concerns expressed by all stakeholders through briefs and letters.
More specifically the mandate of the Work Group is to:
Members of the Work Group will be expected to make every effort to ensure that the views which they express reflect those of their constituency of interest and not only their personal views or those of their organization. It is also expected that they will communicate the fact of their participation and the positions they will be taking on various issues to interested members of their respective constituencies. In recognition of the time necessary for participants to get feedback from their constituencies, Environment Canada and the consultation facilitator will endeavor to provide discussion materials 3 weeks prior to the meetings.
It is recognized that, due to financial and/or organizational constraints, not all participants have the means to communicate regularly with all members of their constituency. Environment Canada will assist participants facing such constraints to develop appropriate means of communication to their constituency.
G. The Role of the Facilitator
The Work Group will be facilitated by an independent facilitator to be chosen by Environment Canada. He/she will be responsible for matters related to the organization and facilitation of the work of the Work Group including preparing the agendas, running the meetings, and preparing the draft and final reports of the Work Group for approval by the Work Group. The facilitator will have an assistant, who will be responsible for the preparation of minutes of the meetings.
The facilitator will also serve as a point of contact for any persons or organizations, participant or non-participant, who has concerns or questions about the consultation process.
H. Expenses
Funds will be made available by Environment Canada, as per Treasury Board guidelines to cover travel, accommodation and other reasonable out-of-pocket expenses for those participants from the voluntary sector who require financial assistance to participate in the work group.
I. Contact for Additional Information
Environment Canada (819) 953-1656
nprimodif@ec.gc.ca or npri@ec.gc.ca
| Member or Alternate | First Name | Last Name | Organization | ||
|---|---|---|---|---|---|
| Associations Representing Reporting Facilities | |||||
| Member | Wayne | Hillier | Canadian Association of Petroleum Producers (CAPP) | ||
| Alternate | Siân | Pascoe | |||
| Member | Bruce | Caswell | Canadian Chemical Producers Association (CCPA) | ||
| Alternate | Dave | Shortt | |||
| Member | Vicky | Christie | Canadian Electricity Association (CEA) | ||
| Alternate | Clement | Ng | |||
| Member | Mark | Blundell | Canadian Energy Pipeline Association (CEPA)/ TransCanada Pipelines Ltd. | ||
| Alternate | Jim | Cormack | |||
| Member | Nancy | Coulas | Canadian Manufacturers and Exporters (CME) | ||
| Member | Marie-Helene | Martin | Canadian Petroleum Products Institute (CPPI) | ||
| Alternate | Adolfo | Silva | |||
| Member | John | Lundigran | Canadian Steel Producers Association (CSPA) | ||
| Alternate | Bruce | Boyd | |||
| Member | Tammy | Giroux | Canadian Vehicle Manufacturers Association (CVMA) | ||
| Alternate | Sarah | Palmer | |||
| Member | Allan | Mumby | Canadian Water and Wastewater Association (CWWA) | ||
| Alternate | Adrian | Toth | |||
| Member | Tracy | Hodges | Cement Association of Canada | ||
| Alternate | George | Venta | |||
| Member | Walter | Sencza | Mining Association of Canada (MAC) | ||
| Alternate | Justyna | Laurie-Lean | |||
| Member | Jasmine | Urisk | Ontario Energy Association (OEA)/Canadian Energy Partnership for Environmental Innovation (CEPEI) | ||
| First Nations | |||||
| Member | Alan | Penn | Grand Council of the Crees | ||
| Member | Gene | Ouellette | Federation of Saskatchewan Indian Nations (AFN) | ||
| Non-Governmental Organizations | |||||
| Member | Anne | Mitchell | Canadian Institute for Environmental Law and Policy (CIELAP) | ||
| Member | Linda | Whalen | Centre for Long-Term Environmental Action Nfld (CLEAN) | ||
| Member | Dave | Stevens | Community Health Opposition to Known Emission Dangers (CHOKED) | ||
| Member | John | Jackson | Ontario Toxic Waste Research Coalition | ||
| Member | Anna | Tilman | STORM Coalition | ||
| Federal and Provincial Departments | |||||
| Member | François | Lavallée | Environment Canada - NPRI | ||
| Alternate | Anne | Legault | |||
| Member | Richard | Martin | Health Canada | ||
| Member | Gary | McGee | Industry Canada | ||
| Alternate | Tim | Karlsson | |||
| Member | Jackie | Scott | Natural Resources Canada | ||
| Member | Vicky | Leblond | Ministère de l'environnement du Québec | ||
| Member | Peter | Wong | Ontario Ministry of the Environment | ||
| Member | Kelly | Der | British Columbia Ministry of the Environment | ||
| Alternate | Tony | Wakelin | |||
Source: http://www.ec.gc.ca/pdb/npri/documents/html/2000_Modify-Final_e.cfm#considerations
When making proposals for addition or deletion of substances to the NPRI list of substances, a rationale should be provided against each of the Decision Factors presented in this document. If individuals or organizations cannot provide rationales against these factors, a proposal can still be submitted to Environment Canada, recognizing that the lack of background information may affect the ability of Environment Canada to move the proposal forward to stakeholder consultation.
The Decision Factors generally reflect the consensus recommendations of the members of the NPRI Ad Hoc Work Group on Substances (1998-2000). Additional information substantiating the Decision Factors, information on areas where consensus was not reached, and Environment Canada's response to the Work Group recommendations are contained in the document entitled "Environment Canada Response to the Fifth Report and Final Recommendations of the NPRI Multistakeholder Ad Hoc Work Group on Substances". It is available from the NPRI office or from the NPRI Web site www.ec.gc.ca/pdb/npri
1. Does the substance meet NPRI criteria, that is:
The first two criteria are intended to be absolute, in the sense that a substance must be M,P,O in Canada, and of health and/or environmental concern, to be added to the NPRI. Similarly, if these criteria are not satisfied for a substance currently in the NPRI, it should be deleted.
The third and fourth criteria indicate that there should be reasonable expectation that a substance is being or may be released into the Canadian environment for it to be added to or retained in the NPRI. In general, however, unless there is evidence or analysis to the contrary, it can reasonably be assumed that a substance that is M,P,O in Canada is likely to be released and, therefore, present in the Canadian environment.
2. Do facilities contribute significant releases of the substance?
There are various ways in which 'significant' can be characterized. The concept relates not only to the proportionate quantity of a substance released by facilities reporting to the NPRI, 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.
3. Does inclusion of the substance support one or more of the objectives of the NPRI?
The objectives of the NPRI are to:
4. Is the substance reported elsewhere? If it is, is there additional value in reporting to the NPRI?
If a substance is reported elsewhere, the value of adding it to or deleting it from the NPRI list of substances would be considered if:
If a substance that is reported elsewhere is to be included or retained on the NPRI list, efforts will be made to the greatest extent possible to consolidate reporting under the NPRI (assuming potential compatibility of data requirements).
5. Is the substance already in the NPRI in some form? If it is, is there 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.
NOTES:
These Decision Factors are applicable to candidate substances at both the 10-tonne and alternate thresholds.
M,P,O of the substance includes the M,P,O of the substance as a by-product. A by-product is an NPRI substance that is incidentally manufactured, processed or otherwise used at a facility at a concentration of less than 1% by weight, and is released on site to the environment or transferred off site for disposal.
In sum, the NPRI is recognized 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.
Inclusion of PM Emissions from Unpaved Road
in
NPRI Reporting of PM Emissions
QUESTIONS RAISED AND
EC'S RESPONSE
Q-What roads are to be considered when calculating facility road dust?
EC's Response :
EC recommends inclusion of PM emissions from all traffic within the facility, excluding emissions from public roads. The facilities would report on emissions from unpaved roads that are under the control of a facility owner/operator.
With regard to reporting from shared roads, any person who owns or operates a facility would be subject to reporting to the NPRI. In the case of two or more owners and/or operators, each would be required to report emissions of PM from their portion of the traffic volume (an annual average traffic volume may be considered adequate). However, EC will deal with such facilities on a case-by-case basis. Furthermore, emissions from a joint access road are already covered under the national inventory program.
Roads that are included in the national inventory include the following:
Expressway / Highway
Freeway
Collector
Arterial
Local / Street
Local / Strata
Local / Unknown
Ramp
Resource / Recreation
Alleyway / Lane
Winter
Service
With regard to employees arriving to work and deliveries etc., the owner/operator should have a process (such as how many deliveries (on average) per month) to estimate emissions for the entire year.
Q-What is the definition of an unpaved road?
EC's Response:
This is unlikely to be considered as a facility in the context of NPRI.
Q-How will this requirement apply to pipeline facilities?
EC's Response :
Above mentioned activities may not be an issue because this activity may not trigger the proposed reporting threshold. For example, emissions from a compressor station may not trigger the proposed reporting threshold.
Q-How are other Federal departments and provincial governments going to manage these requirements? Should they be brought in as stakeholders?
EC's Response
Generally, public roads associated with national/provincial parks are captured under the national inventory. EC will look into any potential emissions of PM from core activities within a park.
Q- How would facilities calculate their road dust emissions?
How will dust emission reduction methodology (oiling, watering, etc.) and climatic conditions (rain, snow cover, frozen roads and permafrost) be accommodated?
EC's Response
In the absence of site specific silt content, default silt loadings could be used to estimate emissions of PM. EPA emission factor and/or limited sampling done by EC could be used as a default value.
Appropriate dust mitigation efforts should be reflected in the estimation of emissions of PM from unpaved road. EC will provide guidance on the use of the US EPA estimation model, specifically, how to incorporate mitigation measures into the model. Mitigation efforts include: watering, oiling, calcining and sweeping.
Frozen roads without high traffic volume can be assumed to have minimal impact on the emission of PM. This would be spelled out in the methodology manual.
1 Details are at: http://www.ec.gc.ca/pdb/npri/documents/html/2000_Modify-Final_e.cfm
2 S ee http://www.ec.gc.ca/pdb/npri/documents/html/2000_Modify-Final_e.cfm for information on Modifying the NPRI. The details on the evaluation of proposed changes and the five Decision Factors are at: http://www.ec.gc.ca/pdb/npri/documents/html/2000_Modify-Final_e.cfm#considerations and are also listed in Appendix C.
3 The 2006 WG does not include a representative from labour.
4 Please note that the terms "ad hoc group" and "sub-group" are interchangeable and mean the same thing. They are both multi-stakeholder groups set up under the WG. The WG has determined that in the future these groups will all be referred to as "sub-groups".
5 Reporting of PM10 therefore includes reporting of PM2.5.
6 US EPA AP-42, chapter 13.2.2-4
7 For information on the decision factors and how TRS meets them, please see: http://www.ec.gc.ca/pdb/npri/consultations/TRS2005_e.cfm
8 The proposal document is available at: http://www.ec.gc.ca/pdb/npri/documents/WG2005/ WG2005/WG_2005_app8_e.cfm
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Last updated: 2006-11-14
Last reviewed: 2006-07-28 |
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