2. SUBSTANCE-SPECIFIC CHANGES
An information note (September 2, 2004) and accompanying draft NPRI Submittal Form for modification to the NPRI (September 7, 2004) set out the background and context for the initiative, including a proposal, explanation, and rationale for the prospective addition of refractory ceramic fibres (RCFs) to the list of substances for reporting under the NPRI. (See Appendix 3: RCF Information Note; Appendix 4: NPRI RCF Submittal Form; and Appendix 5: RCF Presentation Deck..)
The essence of the proposal was to:
- add RCFs to the NPRI list of substances subject to reporting;
- base reporting on 10 tonnes manufactured and/or processed, but not used (Note: this would be a precedent for reporting to the NPRI); and
- remove reporting from Environmental Performance Agreement (EPA) terms, to avoid double reporting.
2.1.3 Work Group Views
Members noted and generally agreed/accepted that:
- RCFs are a Track II substance and, therefore, a substance of concern that meets basic requirements for candidacy as an NPRI-listed substance.
- RCFs are non-threshold carcinogens, for which it is generally desirable to track emissions. However, the proposed reporting of RCFs under the NPRI was prompted not by specific health concerns, but rather because of the inconsistent coverage of the sector under the voluntary EPAs.
- Consideration of substances for reporting under the NPRI should reflect relative priorities of concerns about human health and the environment, as well as the feasibility of securing reliable estimates of emissions in a fair and cost-effective manner.
Industry representatives noted, and others generally accepted, that:
- Human health concerns about RCFs are primarily related to potential workplace exposures, rather than to releases to the open environment.
- RCF production levels in Canada, and hence emissions, are low.
- There are currently no available emission factors that industry can use to prepare reliable and cost-effective estimates of emissions in lieu of stack testing.
- Most emitters are small-scale operations and would find the costs of stack testing onerous (although the NPRI does not require source testing).
- Since the NPRI is based on data that are reasonably available and does not require source testing, the addition of RCFs to the NPRI would not necessarily result in increased reporting or improved data quality.
- Experience with stack testing at several sites has revealed that emissions are below levels of detectability.
- The existing EPA arrangements cover only one-half of the emitters (on a voluntary basis); the non-participating emitters escape any reporting obligations, resulting in unfair reporting burden across the industry and incomplete national reporting.
- While EPA-related issues should be addressed through EPA-specific processes, the situation did raise questions about whether more consistent mandatory reporting under the NPRI might be preferable, provided such reporting is warranted under criteria in the NPRI framework.
- The previous consultations with industry were for the purpose of considering the EPAs, and not specifically for inclusion of RCFs in NPRI reporting; if RCFs are now to be considered for listing under the NPRI, more specific consultations with industry and stakeholders would be warranted.
2.1.4 Conclusions and Recommendations
Work Group members generally agreed with the following approach:
- Environment Canada should consult further with industry representatives to assess more precisely the technical challenges and the practical and financial burdens that might be associated with reporting of RCF emissions, taking into account the prospects of securing reliable estimates of emissions and the relative significance of such, given the likely quantity of emissions and the prospects for emissions to the external environment.
- In the event that, following industry consultations, Environment Canada wishes to continue to pursue mandatory reporting for RCFs, consideration should be given to a sector-wide approach that would entail the development of suitable emission factors (if feasible) to enable relatively cost-effective and reliable estimates by emitters, rather than reliance on stack testing.
|Environment Canada’s response to the addition of RCFs to the NPRI|
At this time, Environment Canada is withdrawing its proposal to add RCFs to the NPRI list of substances. After the October meeting, Environment Canada conducted informal consultations internally and externally and has decided to continue to work within the existing EPA arrangements.
A draft proposal note from the Chemicals Control Branch of Environment Canada (fall 2004) sets out a series of 11 proposed additions and modifications to the list of substances for reporting under the NPRI in future years. (Note: One of the topics - RCFs - was the subject of a separate presentation and detailed discussion, summarized above.) (See Appendix 6: Chemicals Control Branch Note on Proposed Additions and Modifications to the NPRI; and Appendix 7: Other Proposed Additions and Modifications Presentation Deck.)
In addition, as noted in the course of the discussion, there are several other substances that are in various stages of consideration for inclusion or modification under NPRI reporting.
The essence of the proposal of the Chemicals Control Branch of Environment Canada for additions and/or amendments to the NPRI list is as follows:
- Perfluorooctanesulfonate, its salts, and its precursors: proposed addition at a 50-kg manufactured, processed, or otherwise used (MPO) threshold;
- Hexachlorobutadiene: proposed addition using an activity-based threshold;
- Hexachlorobenzene: proposed modification to the activity-based threshold;
- Tetrachlorobenzenes and pentachlorobenzene: proposed addition using an activity-based threshold;
- Benzidine and benzidine dihydrochloride: proposed addition using an activity-based threshold;
- Chlorinated paraffins: proposed modification to listing, and possibly MPO thresholds;
- Ethylene oxide: proposed proceeding with request for modification as already proposed for 2006;
- Refractory ceramic fibres: proposed proceeding with request for addition (see discussion above);
- Polybrominated diphenyl ethers: no changes to listing proposed at this time;
- 2-Butoxyethanol: no changes to listing proposed at this time;
- 2-Methoxyethanol: eventual removal from the NPRI, given anticipated elimination of most uses by 2007.
As Work Group members noted, there are also a number of other substances that are in various stages of consideration for reporting or modification under the NPRI, including:
- N-nitrosodimethylamine (NDMA);
- polychlorinated biphenyls (PCBs);
- dioxins and furans;
- methyl bromide;
- brominated flame retardants;
- nickel (change of threshold); and
- particulate matter speciation (subgroup has not convened).
2.2.3 Work Group Views
The merits of the individual Environment Canada proposals listed above were not discussed in detail, nor were those of the other candidate substances already in various stages of consideration. Instead, NPRI Work Group members focused on more general questions and suggestions about the process and priorities for consideration of additions or modifications to the NPRI list. Discussion focused heavily on seeking to understand and clarify the general nature of the proposal and/or the rationale, in particular what is known about levels of emissions, sources of emissions, and human health effects.
Members raised a number of issues and questions, which pointed to a need/opportunity at this stage in the evolution of the NPRI program for a rethink of the criteria and processes to be followed for future additions and amendments. Some points raised were as follows:
- Some substances, while of concern, are either prohibited or controlled in such a way that reporting under the NPRI may not be necessary.
- Other substances are used for highly specific and rare applications (e.g., benzidine is used in the manufacture of dyes and pigments, with limited applications for analytical procedures in the health sector) and hence may warrant different treatment, rather than making them subject to blanket reporting across all sectors. The latter is a concern for most facilities, especially smaller ones, that must sometimes go through costly and laborious analytical processes to determine if they even produce or use the substances, let alone in sufficient quantities to make them subject to reporting.
- While substances that present risks to human health and the environment will remain of interest to the NPRI program, there may be more cost-effective and fair criteria and processes to target reporting to those classes of emitters or sectors where emissions are known to be of greatest concern; at the same time, such approaches need further analysis and consultation before they can be formally considered for adoption.
NGOs expressed frustration with the very limited progress over the past two years in reviewing and adding substances to the NPRI and with the lack of timely information on the status of those files.
2.2.4 Conclusions and Recommendations
Work Group members generally agreed with the following:
- While the Work Group is not ready at this time to make recommendations on additions, deletions, or modifications to reporting for the candidate substances, the list should remain as a slate of candidate substances for future consideration.
- The status of review of all substances currently being addressed should be updated and communicated to Work Group members.
- All of the substances should be assessed and prioritized for consideration for inclusion, i.e., as part of a more substantial review of the NPRI processes and criteria (see section 5).
|Environment Canada’s response to the other proposed additions and modifications for future years|
Environment Canada agrees that the substances should remain as a list of candidate substances for future consultations. Environment Canada will notify stakeholders of its planned priorities for modifications for the 2006 reporting year.
- Date Modified: