Proposals to reduce the reporting threshold for cobalt and to collect additional information related to water releases
Environment and Climate Change Canada proposed to lower the reporting threshold for cobalt and to add requirements to provide contextual information when reporting releases to water for all substances. Consultations on these proposed changes were conducted with the NPRI Multi-Stakeholder Work Group (WG) from April 17 to June 26, 2015. After considering the comments received, Environment and Climate Change Canada has decided to proceed with the changes, as reflected in the 2016-2017 NPRI Canada Gazette notice.
- Summary of Proposal by Environment and Climate Change Canada to lower the National Pollutant Release Inventory (NPRI) reporting threshold for cobalt (April 2015)
- Summary of Proposal by Environment and Climate Change Canada to improve the understandability of releases to water by adding the reporting of non-detect and concentration values to the National Pollutant Release Inventory (NPRI)(April 2015)
- Summary of Stakeholder Comments and Environment and Climate Change Canada's Response (March 2016)
Proposal by Environment and Climate Change Canada to Lower the National Pollutant Release Inventory (NPRI) Reporting Threshold for Cobalt
Environment and Climate Change Canada is proposing to change the threshold for “cobalt (and its compounds)” as described below, as of the 2016 reporting year.
Summary of Proposal
The following is a summary of the proposal. To obtain a copy of the full proposal, please contact the NPRI.
1. Summary of proposed modification
Environment and Climate Change Canada is proposing to change the NPRI reporting threshold for “Cobalt (and its compounds)” to a 50 kg manufacture, process or other use threshold, and 0.1% concentration threshold, commencing with the 2016 reporting year. “Cobalt (and its compounds)” is currently listed on the NPRI, at the standard 10-tonne manufacture, process or other use threshold and 1% concentration threshold.
Cobalt is a naturally occurring element that is generally present in raw materials at a very low concentration and in small quantities. The current NPRI reporting threshold for cobalt is considered too high to capture incidental releases, and many facilities are not required to report on this substance. Since cobalt has been found to cause adverse environmental effects at low concentrations, our analysis indicates that releases which could be of concern to the environment are not currently required to be reported to the NPRI. The proposed reduced threshold would result in an improved data set that includes more information about releases of cobalt that may be environmentally significant. The reduced threshold would increase the coverage of NPRI data on cobalt and establish an early and accurate baseline for the performance measurement of potential risk management activities.
3. Proposed Timing for the Change
Environment and Climate Change Canada proposes that this change be implemented for the 2016 reporting year. The proposal to lower the NPRI threshold for “Cobalt (and its compounds)” stems from the recent publication and initial findings of the draft Screening Assessment Report of Cobalt and Cobalt-containing Substances (dSAR). Following the review of feedback received during the public comment period on the dSAR, as well as any new information gathered thereafter, Environment and Climate Change Canada and Health Canada plan to publish the Final Screening Assessment Report (fSAR) and, if required, a Risk Management Approach. Any changes to the conclusions between the dSAR and the fSAR would be taken into consideration when adjusting the NPRI requirements for cobalt. Deferring consideration of this change until after the fSAR is published would mean deferral of this change until the 2018 reporting year – this timeline would mean that data collection would not occur in time to support risk management decision making.
4. Industrial Sectors Affected
A number of sectors incidentally manufacture, process, or otherwise use cobalt as a by- product, as listed below. As such, this change may result in additional facilities reporting for cobalt from these sectors. No specific industry exemptions to this reduced threshold are proposed.
- Metal mining (including uranium mining)
- Coal mining
- Iron and steel manufacturing
- Base metals smelting and refining
- Cement production
- Pulp and paper production
Proposal by Environment and Climate Change Canada to improve the understandability of releases to water by adding the reporting of non-detect and concentration values to the National Pollutant Release Inventory
Environment and Climate Change Canada is proposing to collect more contextual information on releases to water by adding the reporting of non-detect and concentration values to the National Pollutant Release Inventory (NPRI) for the 2016 reporting year. The proposed change is intended to improve the understandability of NPRI data on water releases by providing more contextual information, to address comments raised by data users during the NPRI Data Users’ Workshop in 2013 and by other data users within Environment and Climate Change Canada.
The NPRI already collects data on non-detect and concentration values for disposals of tailings and waste rock, as explained later on in this proposal. For some industrial sectors, information on concentration of certain NPRI substances in effluent is already being submitted to Environment and Climate Change Canada (for example, under regulations for the metal mining and pulp and paper sectors). As described below, consideration will be given to the best approach to minimize duplication in reporting where concentration data is already being collected and published for NPRI facilities and substances.
The National Pollutant Release Inventory (NPRI) collects and publishes data on pollutant releases to surface water from industry. These releases include:
- Direct discharges: direct discharges to surface waters. Discharges to sewers that do not feed into a wastewater treatment facility are considered to be releases to surface waters. Discharges to municipal or other off-site wastewater treatment facilities are not considered to be releases to surface waters. These discharges are reported as off- site transfers for treatment prior to final disposal.
- Spills: spills include any accidental releases to surface waters, normally occurring over a short period of time (hours or days).
- Leaks: leaks differ from spills in that they are chronic events, occurring over a comparatively long time (days, months, etc.).
2.1 Non-detect values
There are a variety of ways to calculate releases to water, but sometimes the amount of a pollutant in effluent being released is very small and cannot be detected through analytical means. The general rule for reporting these releases is that if some laboratory analytical results are a non-detect (ND), then generally half of the detection limit is used as the value. For example, ND at 0.001 mg/L (or < 0.001 mg/L) would be calculated as 0.001/2 = 0.0005 mg/L even though the actual quantity being released is not known.
The 2014-2015 Guide for Reporting to the NPRI suggests handling non-detect values in the following manner:
“An indication that a reportable substance is below the method detection limit (MDL) is not equivalent to stating that the substance is not present. If it is known that the substance is present, a concentration equivalent to half of the MDL should be used. In a year where multiple measurements of the concentration of a substance in a given process stream are all below the MDL, and there is no other reason to believe that the substance is present, it can be assumed that the concentration of the substance in that process stream is zero. In a year where multiple measurements are taken, and some measurements indicate that the concentration is above the MDL and some indicate that it is below the MDL, there is reason to assume that the substance is present. Therefore, a value of half the MDL should be used for those measurements where the concentration is below the MDL.”
This type of estimation can be problematic from a data understandability perspective, especially for facilities with high volumes of throughput. Using the ½ detection limit method can result in an inaccurate quantification of a pollutant in released effluent. When non-detect values are not taken into consideration, inaccurate conclusions can be drawn from the data. Adding the requirement to specify if non-detect values were used in the calculation of reported water releases would ensure that NPRI data users are aware of this consideration when performing analyses.
Another factor that could affect how water release data is interpreted is the concentration of a given pollutant in the effluent. It is important to take this into consideration because the effect of a release to water on the environment is strongly dependent on the concentration. A more dilute release will typically have a smaller effect on the environment than one that is highly concentrated. The effects of pollutant releases to water are often felt much more locally (for example, within a specific lake) rather than being widely dispersed, which is of concern to people and organisms that live near or access the receiving water body. Reporting the concentration of substances released to water will help data users better assess the relative impacts of reported values on the environment.
3.0 Rationale for the change
Recent NPRI efforts have been focused on improving data quality. The NPRI Data Quality Management Framework was created to ensure that NPRI data achieves and maintains a high level of quality and meets the needs of data users. This framework identifies six dimensions of data quality: relevance, accuracy/reliability, completeness, understandability, accessibility, and timeliness. Adding the requirement to report non- detect and concentration values to the NPRI supports the NPRI’s efforts to improve data quality by addressing issues of understandability of reported values for releases to water.
The proposed change would address comments raised by data users during the NPRI Data Users’ Workshop in 2013, as well as comments from other Environment and Climate Change Canada data users, by providing more contextual information to enhance the information already provided by reporters.
4.0 Potential impact on reporting community and NPRI program
For 2013, 450 individual facilities reported releases to water of 93 substances for a total of 2397 substance reports. These facilities belong to 41 different industry sectors (based on four-digit NAICS codes), summarized in Annex 1.
An analysis of the comments provided by the facilities that reported releases to water revealed the following information. Two facilities reported a comment specifying the use of the ½ detection limit method for non-detect values as a method to estimate releases. Approximately 9 other facilities (4 from the Water, Sewage, and Other Systems sector; 2 from Pulp and Paper; 2 from Metal Ore Mining; and 1 from Other Professional, Scientific and Technical Services) appear to report comments related to values below the detection limit, and it is assumed that they used the ½ detection limit method.
When it comes to reporting of concentration, many facilities simply state that there was an increase/decrease in effluent concentrations from the previous year. A small number of facilities (approximately 10) reported the specific concentration of pollutants released and how it changed from previous years. Some examples of the types of comments received from reporters can be found in Annex 2.
It is proposed that the requirement to report non-detect and concentration values for releases to water would apply to all sectors, to meet the intent of providing this important contextual data for all reported water releases. However, for some sectors such as metal mining, this data is already provided to Environment and Climate Change Canada under regulatory requirements and made publicly available. In implementing this proposal, NPRI understands the need to minimize reporting burden and avoid duplication. As described below, Environment and Climate Change Canada will examine approaches other than collecting this data through NPRI that may meet the stated intent while limiting duplication.
It is expected that most facilities calculate their water releases using concentration values multiplied by effluent flow rates, and will therefore have average concentration values to be reported. In a case where a facility calculates their water releases though another method, without using the average concentration value, reporting of an average concentration value would only be required if the value is available or can reasonably be obtained.
5.0 Implementation options
A number of possible implementation options have been identified to incorporate the reporting of non-detect and concentration values for releases to water into the NPRI. Environment and Climate Change Canada is seeking input from data users and the reporting community on which options for this reporting will provide the contextual information needed while minimizing additional effort for reporting.
5.1 Options for reporting non-detect values
The current reporting system contains functionality for collecting data for non-detect values for disposals of tailings and waste rock. Two options have been identified for reporting non-detect values for releases to water:
- A check box could be used to specify whether a release is based on the ½ the detection limit method for non-detect values.
- Similar to reporting for tailings and waste rock, a drop-down menu could be used to indicate how a reported release was estimated and to provide other contextual information.
When publishing the NPRI data in the online search tool, the information regarding non- detect values could be communicated by putting a less than sign in front of the reported quantity (i.e., < 5 tonnes), with a footnote indicating that the value is based on estimation using data below the detection limit and is therefore expected to be below the reported value.
5.2 Options for reporting concentration values
Similar to above, the NPRI reporting system also contains functionality for collecting concentration values for the disposal of tailings and waste rock, with the average concentration value being collected as a numeric value (in ppm) whenever tailings or waste rock disposals are reported. Environment and Climate Change Canada is proposing a similar approach for water releases, with collection of the average concentration value, in ppm, whenever a water release is reported.
For sectors mentioned above where effluent concentration data is already collected by Environment and Climate Change Canada and published online under other regulations, NPRI has identified some options to reduce reporting burden and limit duplication:
- The NPRI data search tool could link to the external data in cases where data exists under another program for a specific facility and NPRI substance.
- The data from the other program could be imported directly into NPRI data sets (both the online data search and downloadable files).
- Given possible challenges in linking the data, it may be determined that it is simplest for both industry and Environment and Climate Change Canada to report the data to both the applicable regulation and under the NPRI.
During the consultation period, Environment and Climate Change Canada will engage industry sectors for which effluent concentration data is already reported and published to explore implementation options. As always, Environment and Climate Change Canada welcomes any feedback on the issue of potential duplication, other potential impacts of the change, and other concerns with or support for the proposal.
Annex 1: Summary of 2013 reporting of releases to water to the NPRI
|Industry Name||NAICS Code||Total - All Releases to Water (tonnes)||Facility Count||Number of substances reported||Total number of Substance Reports|
|Water, Sewage and Other Systems||2213||111101.264||170||33||591|
|Metal Ore Mining||2122||2861.079||70||21||505|
|Pulp, Paper and Paperboard Mills||3221||5955.161||65||40||566|
|Basic Chemical Manufacturing||3251||246.477||19||22||42|
|Electric Power Generation, Transmission and Distribution||2211||41.228||17||16||85|
|Petroleum and Coal Product Manufacturing||3241||388.724||14||40||113|
|Iron and Steel Mills and Ferro-Alloy Manufacturing||3311||587.027||10||42||100|
|Oil and Gas Extraction||2111||3287.420||7||33||55|
|Alumina and Aluminum Production and Processing||3313||0.054||7||24||70|
|Non-Ferrous Metal (except Aluminum) Production and Processing||3314||161.856||6||16||46|
|Pesticide, Fertilizer and Other Agricultural Chemical Manufacturing||3253||175.493||5||16||23|
|Meat Product Manufacturing||3116||432.998||4||4||8|
|Resin, Synthetic Rubber, and Artificial and Synthetic Fibres and Filaments Manufacturing||3252||51.243||4||6||7|
|Other Chemical Product Manufacturing||3259||15.466||4||5||6|
|Non-Metallic Mineral Mining and Quarrying||2123||47.979||3||15||25|
|Steel Product Manufacturing from Purchased Steel||3312||1.192||3||3||6|
|Coating, Engraving, Heat Treating and Allied Activities||3328||19.499||3||5||6|
|Fruit and Vegetable Preserving and Specialty Food Manufacturing||3114||708.792||2||3||4|
|Other Food Manufacturing||3119||551.100||2||3||5|
|Sawmills and Wood Preservation||3211||0.019||2||2||3|
|Rubber Product Manufacturing||3262||0.140||2||2||3|
|Other Miscellaneous Manufacturing||3399||115.100||2||1||2|
|Petroleum Product Wholesaler-Distributors||4121||0.406||2||3||4|
|Other Specialty Trade Contractors||2389||0.000||1||1||1|
|Grain and Oilseed Milling||3112||0.622||1||2||2|
|Sugar and Confectionery Product Manufacturing||3113||25.426||1||3||3|
|Dairy Product Manufacturing||3115||14.500||1||1||1|
|Soap, Cleaning Compound and Toilet Preparation Manufacturing||3256||0.003||1||1||1|
|Cement and Concrete Product Manufacturing||3273||0.006||1||5||5|
|Other Non-Metallic Mineral Product Manufacturing||3279||2.430||1||1||1|
|Engine, Turbine and Power Transmission Equipment Manufacturing||3336||0.003||1||1||1|
|Other Electrical Equipment and Component Manufacturing||3359||0.000||1||1||1|
|Motor Vehicle Manufacturing||3361||0.355||1||1||1|
|Motor Vehicle Parts Manufacturing||3363||0.000||1||1||1|
|Support Activities for Water Transportation||4883||0.217||1||3||3|
|Other Professional, Scientific and Technical Services||5419||0.000||1||2||2|
|Waste Treatment and Disposal||5622||265.070||1||2||2|
|Remediation and Other Waste Management Services||5629||2.728||1||1||1|
|Other Local, Municipal and Regional Public Admin||9139||9.382||1||1||1|
Annex 2: Examples of comments received for releases to water in 2013
Comments received from reporters vary in the level of detail provided. Requiring the reporting of non-detect and concentration values for releases to water would help standardize the information collected and provide more contextual information to compliment the reported comments.
- Increased lead in releases to water is primarily attributable to increased detection limits on water sample analyses.
- Analytical results for this substance are typically below the laboratory MDL. The laboratory MDL was higher this year resulting in higher estimated discharges.
- The effluent concentration in 2013 were less than 2 ug/L and so used 1 ug/L. The detection limits in 2012 was lower and so emission results were lower. The drinking water criterion for lead is 10 ug/L.
- -variability of concentration of NPRI substance in wastewater -lab results less than detection limit
- Emissions based on NCASI handbook emission factors (2007 update) and mill power boiler test data. 1/2 the detection limit is used for non-detect values in the NCASI handbook and the mill test data.
- All effluent results were less than the detection limit in 2013.
- The concentration of cadmium for 2013 decreased by 75% when compared to 2012 due to a higher detection limit during analysis in 2012.
- Cadmium below MDL in 2013.
- Change in laboratory method detection limit.
- For Both 2012 and 2013 the 1/2 the detection limit was used, the only differences between the years were in the number of days per year and the daily effluent flow which affected the calculation.
- Changes in concentration released. 2011= 185 ppb, 2012 = 185, 2013 = 963
Summary of Stakeholder Comments and Environment and Climate Change Canada’s Response
The National Pollutant Release Inventory (NPRI) Multi-Stakeholder Work Group (WG) and the public provided input on Environment and Climate Change Canada’s proposals to:
- Change the NPRI reporting threshold for cobalt (and its compounds) to a 50 kg manufacture, process or other use threshold, and 0.1% concentration threshold, commencing with the 2016 reporting year. Cobalt (and its compounds) is currently listed on the NPRI, at the standard 10-tonne manufacture, process or other use threshold and 1% concentration threshold.
- Collect more contextual information on releases to water by adding the reporting of non-detect and concentration values for the 2016 reporting year. The change is intended to improve the understandability of NPRI data on water releases by providing more contextual information, to address comments raised by data users.
Table 1 summarizes comments received from the WG and the public on the cobalt proposal, and presents Environment and Climate Change Canada’s response to the comments. Table 2 summarizes comments received from the WG and the public on the reporting of water releases proposal, and presents Environment and Climate Change Canada’s response to the comments.
Comments were received from the following stakeholders:
- Canadian Water and Wastewater Association
- Canadian Fuels Association
- Cement Association of Canada
- The City of Calgary
- Canadian Vehicle Manufacturers’ Association
Table 1. Summary of Stakeholder Comments Regarding the Proposal to Lower the Reporting Threshold for Cobalt
|No./Topic||Stakeholder Comments||Environment and Climate Change Canada (ECCC) Response|
|1.No concern with the proposed change||No comments or concerns identified.||ECCC thanks stakeholders for taking the time to consider and provide input on the proposed changes.|
|2.Reporting threshold level proposed|
The proposed threshold for cobalt will include wastewater treatment plants with cobalt releases less than detection limits of 1 µg/L. It is recommended that the threshold be increased, with one comment suggesting a level of 150 kg per year.
The lower threshold will likely trigger reporting for several facilities that are not required to report under the current threshold.
ECCC acknowledges that certain stakeholders have some concern with the 50 kg threshold. However, the purpose of the alternate threshold for cobalt is to capture small, incidental releases of this substance to the environment. Based on the analysis, a threshold of 50 kg is needed to adequately capture incidental releases.
In response to the comment that certain wastewater treatment plants will need to report despite having cobalt releases below the detection limit, changes are being implemented for the 2016 reporting year that will allow for more contextual information to be submitted about these types of releases (see below).
Table 2. Summary of Stakeholder Comments Regarding the Proposal to Modify the reporting of Water Releases
|No./Topic||Stakeholder Comments||Environment and Climate Change Canada Response|
|1.No concern with the proposed change||No comments or concerns identified.||ECCC thanks stakeholders for taking the time to consider and provide input on the proposed changes.|
|2.Parameters of the change|
Reporting of non-detect values occurs for wastewater treatment facilities where the criteria for other sectors is at the 1% level, which is a reporting bias. Knowing a non-detect level that is below surface water criteria would have little value in determining impacts on the environment. Surface water criteria are based on long term impacts and averages would be a better indicator for impacts. If this was applied to parameters that could have impacts, such as mercury or dioxins and furans, there may be some value in the reporting of non-detect values. The non-detect reporting criteria should be specific to a limited range of parameters and not widespread.
The value of additional reporting on non-detect values is questionable and it is recommended that it be for a select set of parameters.
Additional contextual data on releases to water will be collected only for facilities that report direct discharges to water, and only where the report is based on source testing or direct monitoring. The purpose of collecting this information is to allow facilities to provide context around their reported quantities, so that users may understand, for example, where concentrations of a substance are extremely low and the quantity reported is based on ½ of the detection limit.
Information to be collected includes:
The proposal indicates that some of the information being sought, such as concentration of certain NPRI substances in effluent, is already being submitted to Environment and Climate Change Canada through different activities. Therefore, ECCC needs to carefully consider the possibility of introducing additional complexity to the NPRI program, and as a result, potential for errors by adding reporting on this particular data, given that it may already be available through other programs.
Given that this reporting would be in addition to values already reported for releases to water, creating additional reporting burden for reporters, there should be clear added value for collecting this information.
ECCC agrees that additional reporting burden and complexity should be avoided. Reporting to the NPRI is based on information in the possession of the facility or that can be reasonably accessed. The additional data being collected by this change are expected to already be in possession of facilities.
For data that are already reported to ECCC under other risk management activities, efforts will be made to consolidate reporting under the NPRI. However, for this information to meet the objectives of the NPRI, it would need to be available publicly at a facility level. As such, reporting through the NPRI may be needed in addition to existing reporting obligations.
|4.Average Annual Concentration|
A reported average concentration may not be reflective of actual or typical emissions to water from operations and may not provide the information being sought. There may be alternative and more appropriate methods of collecting the desired information.
Average concentrations would be adequate. The proposal is not clear whether monthly or annual average concentrations will need to be reported. It would definitely minimize the reporting burden if we need to report annual average concentrations.
|ECCC acknowledges that average annual concentration may not always be reflective of actual releases to water at a particular point in time. However, in order to minimize the reporting burden on facilities, the average annual concentration will be collected at this time (and not more detailed information on concentrations throughout the year). This value is expected to already be in possession by facilities, and facilities can use the comments fields to provide additional information on other factors such as seasonal variability of the concentration, if such information is relevant.|
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