-- Final Report 2006 --
Report of the NPRI Multi-stakeholder Work Group on Substances
2. Issues Referred to Sub-groups and Ad Hoc Groups
2.1 Inclusion of Particulate Matter Emissions from Unpaved Road in the NPRI Reporting of PM Emissions
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.
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.
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.
ENGO WG members are supportive of EC's proposal that 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. ENGOS have the expectation that EC would provide guidance for reporting.
Industry members, however, are unanimous in their opposition to the EC proposal. Industry representatives seek improved rationale for adding this substance to the NPRI, and express concern about the credibility and utility of the proposed NPRI reporting criteria, the quality of emissions estimates, and also the derivation and credibility of emission factors.
Aboriginals' representatives are also concerned about emission factors and reporting criteria. In addition, these WG members have expressed concern about the broader use of NPRI data and the wider communication of the context and nature of the NPRI.
There was no consensus reached among the WG members regarding reporting of road dust.
EC's response regarding the Inclusion of Particulate Matter Emissions from Unpaved Roads in the NPRI Reporting of PM Emissions
Considering the recommendations and opinions expressed from the different groups at the WG meetings, EC has decided to go forth with its proposal to require reporting of PM emissions from unpaved roads, for those facilities that exceed the threshold of 10,000 VKT on unpaved roads within the facility in a given year, starting with the 2007 reporting year. The principle rationale for adding this reporting is to provide a more comprehensive understanding of the total PM emissions from facilities (for many facilities, emissions of PM from unpaved roads represent a large proportion of the total PM emitted). This improved data will allow NPRI to provide better data to Canadians and decision-makers, as well as improving our ability to conduct air quality modeling. The threshold of "10,000 VKT on unpaved roads" is designed to capture only those facilities with the most significant PM emissions from unpaved roads. Since EC recognizes that there may be complexities associated with interpretation of this requirement, guidance will be provided on this matter for the 2007 reporting year.
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):
- Removal of the mining exemption for pits and quarries by determining an appropriate threshold for aggregate pits and quarries
- Options for including reporting to the NPRI by advanced exploration
- Including alternative threshold mechanisms to the employee threshold and their implications for the mining sector
- Implementation issues, including:
- The development of tools and approaches to assist mining sub-sectors in creating awareness, ensuring accuracy, and dealing with the reporting burden
- The identification of costs to industry and government, the need for additional resources, and appropriate priorities.
The SG has also reviewed its 2003 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 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.
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.
Questions were raised about 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 WG has been considering the following two options:
- Establish a single reporting threshold specifically for pits and quarries at 500 000 tonnes of production.
- This would affect ~20% of facilities, and capture ~80% of production.
- Keep the present mining threshold: 20,000 hours worked (i.e. 10 employees) threshold combined with the BTU threshold for the release of Criteria Air Contaminants (CAC). If a facility does not meet the 20,000 hr. (10 employees) threshold, it must still report if it emits CAC substances from stationary, external combustion equipment with a nameplate capacity of more 10 million BTU/hour.
- This would affect ~45% facilities. EC needs to do further analysis to determine how much production it would capture.
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.
The ENGO members support Option #2, since it is consistent with the community right to know and would improve the number of facilities reporting.
Industry representatives are concerned that the discussion continues to revolve around the number/ percentage of facilities reporting, rather than the capture of emissions. Citing, in addition, the burden of reporting, industry members continue to support the conventional threshold.
Additional information regarding a threshold for pits and quarries is included in Appendix E.
EC’s response regarding the Mining Exemption
In light of the WG recommendations, EC agrees to remove the current exemption for pits and quarries for the 2007 reporting year. Since no consensus was obtained on the most appropriate threshold, EC decided to establish a reporting threshold specifically for pits and quarries at 500 000 tonnes of production. That threshold is expected to affect ~20% of pits & quarries facilities, and capture ~80% of production.
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:
- Evaluate the comprehensiveness, the accuracy, the consistency of the reported emissions, and the methods used to estimate the emissions by the facilities;
- Compile the comprehensive emission inventory trends and projections for the CACs on an annual basis to meet the reporting obligations of domestic and international programs;
- Compile the necessary information for the air quality modelling and the development of air quality management policies in Canada and in the United States;
- Compile the comprehensive emission inventories using comparable information over time.
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:
- Discuss and clarify the issues identified during the first SG meeting by the stakeholders;
- Discuss possible options and considerations to resolve the data issues and data gaps including the collection of process level emissions and related information;
- Discuss the preparation of the SG discussion paper and the Report to the NPRI WG; and,
- Discuss the future role of the SG.
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 CAC SG is continuing its deliberation and future work will be presented in 2006/2007. The SG's report will be made available to the WG for the November meeting.
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.
EC's Response to the Data Gaps Related to Criteria Air Contaminants
EC has accepted that all current undergoing work related to CACs will be continued throughout the 2006-2007 year. The recommendations to be proposed by the SG should resolve the initial data quality and data gap issues.
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 to the 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:
- 2,3,7,8 - tetrachlorodibenzo-p-dioxin (CAS number 1746-01-6)
- 2,3,7,8 - tetrachlorodibenzofuran (CAS number 51207-31-9).
The Joint Stakeholders Sub-group on Harmonization (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. It is increasingly evident that international "dioxins" inventories tend to include the dioxin-like PCBs for the data estimation.
In February of 2006, EC tabled its proposal to the stakeholders regarding reporting changes for D/F and HCB. Those changes were 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.
- Reporting the 17 D/F congeners currently reporting to the NPRI on an individual basis
- Adding the 12 coplanar or dioxin-like PCBs in the D/F category for individual reporting with g WHO TEQ values
- Changing the reporting of the D/F values from g ITEQ values to g WHOTEQ values with the ability to access the underlying detail
- Adding two activities to the list of D/F reporting activities - (a) regeneration of spent catalyst in petroleum refineries, and (b) land application of municipal biosolids (or land disposal of municipal sewage sludge)
- Adding three activities to the list of HCB reporting activities - (a) regeneration of spent catalyst in petroleum refineries, (b) land application of municipal biosolids (or land disposal of municipal sewage sludge), and (c) production of industrial pigments
EC Rationale on Proposal
EC 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 its Toxic Equivalency Reporting Rule becomes final.
EC 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 Alternate Threshold (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 also be 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.
Status of Ad Hoc Group
Based on an investigation of the appropriateness and implications of the proposed reporting changes by EC, the ad hoc group on D/F and HCB made the following recommendations to the NPRI WG.
A consensus was reached by the ad hoc group to proceed with this proposed change:
- Reporting the 17 D/F congeners on an individual basis instead of on a category basis.
The ad hoc group also considered the following change:
- Changing the reporting of D/F values from g ITEQ to g WHO-TEQ.
The ad hoc group 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. The long-term trend information will be based on ITEQ. EC would be obliged to develop the ITEQ and WHO-TEQ comparison mechanism to ensure that congener quantity details would be fully understood. In turn, EC would outline the information in the NPRI website in such a way as to ensure easy access for all users.
The following items still need discussion within the ad hoc group before being formulated as final recommendations to the WG:
- Adding the 12 dioxin-like PCBs in the D/F category for individual reporting.
It has been said that the National Academy of Sciences (NAS) study to evaluate the 2003 U.S. EPA dioxin reassessment report would contain valuable information regarding emission factors, health effects and risk assessment results. As of the ad hoc group's final consultation in July, the NAS report had not been released. The report is expected soon but further delays are possible.
Acknowledging this, two divergent positions emerged in discussions regarding the addition of dioxin-like PCBs without first reviewing the NAS report. The first suggested that recommendations would be premature until the ad hoc group was given a chance to fully consider the NAS report. Further action should therefore be deferred until the NAS report is given due consideration by the ad hoc group .
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 ad hoc group was not reached on this issue.
Another change considered by the ad hoc group was the following:
- Adding activities to the list of reporting activities.
This issue will remain outstanding until further discussion by the ad hoc group .
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 Sciences, 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 immediately undertaken as much as possible in parallel between Ontario and NPRI consultation processes for harmonization purposes.
The WG accepted the recommendation presented by the ad hoc group, changing the reporting of D/F from a category basis to individual listing of congeners. The WG also accepted the recommendation that the reporting of D/F values would be expressed in grams, with the ability to access the data details in both ITEQ and WHO-TEQ.
The WG agreed for the SG to keep working on the outstanding issues and requested that the SG report its findings to the WG at future meetings.
EC’s Response regarding Reporting Requirements for Dioxins/Furans and Hexachlorobenzene
EC supports the WG's recommendations to accept two of the recommendations presented by the ad hoc group:
Since additional work is required to address remaining issues, EC agrees to extend the mandate for the Dioxins/Furans and Hexachlorobenzene ad hoc group for another year.
2.5 Long-term Direction and Scope7
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:
- To explore:
- how the NPRI may be streamlined
- enhancement of data quality, and
- considerations of emissions of substances of concern.
- Advise on further work and analysis that EC should undertake to support informed discussion and recommendations.
- Advise and assist the WG in ensuring that the consultation process and its outputs (the WG reports) meet the needs and expectations of the stakeholders and that the process is run in a cost-effective manner.
- Provide a communications link between the consultation process and their respective constituencies
- Make recommendations relating to each of the issues, including areas of consensus, explanations of any disagreements, and the description of any additional issues that need to be resolved
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.
- Option 1:
- Workshop (2 day)
- Plenary sessions and breakouts
- Develop recommendations for path forward
- Workshop (2 day)
- Option 2:
- Several meetings
- Wider consultations
- Final report with recommendations for path forward
- Several meetings
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.
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 NPRI8. The objectives of the Ad Hoc group on TRS are therefore to develop recommendations to the NPRI WG on the following issues:
- Proposals on:
- the addition of TRS to the NPRI
- the addition of TRS species to the NPRI
- appropriate thresholds for TRS and TRS species
- The most appropriate form for TRS to be reported (e.g. in terms of H2S)
- The appropriate species to include in the NPRI definition of TRS
- Any implementation 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 ,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 (C2H6S), methyl mercaptan (CH4S) and dimethyl disulphide (C2H6S2), 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; 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.
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.
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.
EC's Response regarding Total Reduced Sulphur
EC agrees with the WG and accepts the proposal put forth by the ad hoc group. This proposal states that the NPRI should add TRS to Part 1 of the NPRI substances list starting with the 2007 reporting year. TRS will be defined as consisting of hydrogen sulphide (H2S), carbon disulphide (CS2), carbonyl sulphide (COS), dimethyl sulphide (C2H6S), methyl mercaptan (CH4S) and dimethyl disulphide (C2H6S2). The three currently reported species (H2S, CS2, and COS) will continue to be reported separately under Part 1 of the NPRI. EC also agrees that it will address the double counting issues for TRS and its species.
In 2005, EC proposed the addition of 12 new Polycyclic Aromatic Hydrocarbons (PAHs): three from the MOE O. Reg. 127 acenaphthene (CAS No 83-32-9) , acenaphthylene ( 208-96-8) , and fluorene ( CAS No: 86-73-7) 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:
- To review the environmental and health effects of the 9 PAHs currently being reported to the US TRI and their relevance to Canadian industry;
- To determine the appropriateness of adding any of the 9 PAHs to the NPRI;
- To examine the implications of adding a reporting de minimis for all PAHs reported under Part 2
- To review the current 50 kg threshold for Total PAH.
Status of Ad Hoc Group
The ad hoc group presented the following recommendations to the WG:
- Add the 9 TRI PAHs to Part 2 of the NPRI for the 2007 reporting year and reassess the information collected by facilities in 3 to 5 years
- Retain the 50 kg reporting threshold for Total PAH
- Add a 5 kg de minimis per individual PAH (17 NPRI PAHs, 3 MOE PAHs and 9 TRI PAHs)
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 to:
- Add the 9 TRI PAHs to Part 2 of the NPRI for the 2007 reporting year and reassess the information collected by facilities in 3 to 5 years
- Retain the 50 kg reporting threshold for Total PAH
- Add a 5 kg de minimis per individual PAH (17 NPRI PAHs, 3 MOE PAHs and 9 TRI PAHs)
EC’s Response regarding Polycyclic Aromatic Hydrocarbons
After examining the information put forth by the ad hoc group and the WG, EC endorses the following decisions made by the WG for the 2007 reporting year:
5 Reporting of PM10 therefore includes reporting of PM2.5.
6 US EPA AP-42, chapter 13.2.2-4
7 This SG will henceforth be referred to as the "Challenge and Opportunities Sub-Group".
- Date Modified: