3.7 Exemptions and Exclusions
3.7.1 Facilities Exempt from All NPRI Reporting Requirements
Two types of facilities are exempt from reporting to the NPRI:
- facilities used exclusively for oil and gas exploration or the drilling of oil and gas wells; these are the only types of oil and gas facilities exempt from reporting to the NPRI; and
- pits and quarries where annual production is < 500 000 tonnes.
3.7.2 Exclusions for All Substances
The quantity of a substance contained in any item listed in Table 4 should not be included when calculating and reporting releases, disposals or transfers for recycling. In addition, vehicle emissions (not including unpaved road dust) should not be considered when calculating the thresholds and when reporting releases, disposals or transfers for recycling. A vehicle is any mobile equipment that is capable of self-propulsion, including fleet vehicles and earth‑moving equipment (e.g., loaders, dump trucks, forklifts, excavators and bulldozers).
Table 4. Items Not Considered when Reporting to the National Pollutant Release Inventory
|Articles that are processed or otherwise used(1)|
|Materials used as structural components of the facility (buildings and other fixed structures), but not process equipment|
|Materials used in janitorial or facility grounds maintenance(2)|
|Materials used for personal use by employees or other persons|
|Intake water or intake air, such as water used for process cooling or air used either as compressed air or for combustion|
(1) See section 3.5.2 for the definition of an article.
(2) This includes NPRI substances contained in fertilizers and pesticides used for grounds maintenance, and cleaning agents used for maintaining facility cleanliness. The maintenance of process equipment (e.g., cleaning manufacturing equipment with a solvent) is not excluded.
3.7.3 Activities Exempt from Reporting for Parts 1-3 Substances
The threshold calculation for a substance must exclude the quantity of a substance that is manufactured, processed or otherwise used in the activities listed in Table 5. In cases where a facility met the reporting criteria for a substance based on sources other than those listed in Table 5, the quantity of that specific substance from any exempt activities should also not be included when reporting releases, disposals or transfers for recycling to the NPRI.
A facility is exempt from reporting Parts 1 through 3 substances if the only source or use of that substance is from one or more of the activities listed in Table 5. Note, however, that these facilities are not exempt from reporting releases of Parts 4 and 5 substances from stationary combustion equipment.
Table 5. Activities Not Considered when Reporting Parts 1, 2 and 3 Substances
|Education or training of students|
|Research or testing|
|Maintenance and repair of vehicles (automobiles, trucks, locomotives, ships or aircraft), except painting and stripping of vehicles or their components, or the rebuilding or remanufacturing of vehicle components(1)|
|Distribution, storage or retail sale of fuels, except as part of terminal operations(2)|
|Wholesale or retail sale of articles or products that contain the substance|
|Retail sale of the substance|
|Growing, harvesting or management of renewable natural resources|
|The practice of dentistry|
(1) Substances used for activities involving routine, scheduled and preventative maintenance of vehicles are exempt (e.g., repair, cleaning, replacement of lubricants/fluids). However, substances used in the painting or stripping of vehicles or vehicle components are subject to reporting. There is no exemption for activities that involve the removal, breakdown and total reconstruction of vehicle components (e.g., engines, landing gear, traction motors) using recovered or new parts, such that the rebuilt component is reinstalled or sold as an as‑new replacement.
(2) See section 3.5.2 for the definition of “terminal operations.” The exemption for distribution, storage or sale of fuels does not include terminal operations.
3.7.4 Exclusions for Tailings and Waste Rock
Tailings and waste rock are defined in section 3.5.2. The following sections describe the exclusions for stable/inert constituents of tailings, unconsolidated overburden and inert waste rock. These exclusions apply only to substances contained in tailings and waste rock. If a substance is released to air or water from tailings or waste rock (e.g., in airborne dust or as effluent), the quantity of the substance released must then be included in threshold calculations.
Stable/inert constituents of tailings
Substances contained in certain materials in tailings should be excluded from threshold calculations and reporting (e.g., sand grains from bitumen mines or in-situ production of bitumen). In order to be excluded, these materials must:
- be inert,
- be inorganic, and
- not have been crushed or otherwise physically or chemically altered.
The exclusion applies only to the components of tailings that meet the above three criteria (i.e., if part of the tailings stream met the criteria, only that portion of the tailings would be excluded, and the remainder of the tailings would be included).
Substances contained in unconsolidated overburden should be excluded from threshold calculations and reporting. Unconsolidated overburden is unconsolidated materials overlying the ore or bitumen deposit, including, but not limited to, soil, glacial deposits, sand and sediment.
Inert waste rock
Substances contained in inert or clean waste rock should be excluded from threshold calculations and reporting. Inert waste rock is defined as waste rock that:
- is inert or clean according to a federal or provincial operating permit; or
- has a sulphur concentration of ≤ 0.2%; or
- has a sulphur concentration of > 0.2%, and the ratio of neutralizing potential to acid‑generating potential is ≥ 3:1.
There is one exception to the exclusion for inert or clean waste rock: even if waste rock is inert or clean as defined above, the quantity of arsenic in waste rock cannot be excluded if the concentration of arsenic is < 12 milligrams per kilogram of waste rock.
3.8 Methods of Estimation
Estimates of the quantity of a substance that is manufactured, processed or otherwise used, and of the quantity that is released, disposed of or transferred for recycling, may be based on one of the following methods:
- Continuous emission monitoring systems
- Predictive emission monitoring
- Source testing
- Mass balance
- Site-specific emission factor
- Published emission factor
- Engineering estimates
A description of these methods is provided in the following sections. Examples using these estimation methods can be found in the NPRI Toolbox(www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=65A75CDF-1).
Information on releases, disposals and transfers for recycling needs to be reported if the owner/operator possesses the information or may reasonably be expected to have access to the information. The Notice specifies that if emissions are already monitored or measured under provincial or federal legislation or a municipal bylaw, those measurements must be used to report to the NPRI. If emissions are not monitored or measured under provincial or federal legislation or a municipal bylaw, reasonable efforts must still be undertaken to gather information on releases, disposals and transfers of a substance. What is “reasonable” depends on individual circumstances, but may include additional monitoring for NPRI substances.
In deciding whether additional efforts should be undertaken to generate new information for the purposes of NPRI reporting, the following factors, among others, should be considered:
- the health and environmental risks posed by a substance, including whether the substance has been declared toxic under CEPA 1999;
- the relative contribution of the industrial sector to releases, disposals and transfers for recycling of a substance in Canada;
- the relative contribution of the facility to releases, disposals and transfers for recycling of a substance in Canada; and
- the cost of additional monitoring.
Environment Canada is developing more detailed guidance that will outline suggested estimation methods, and will be recommending their use as they become available. For more information, consult the NPRI Toolbox.
3.8.1 Continuous Emission Monitoring Systems
Continuous emission monitoring systems (CEMS) record emissions over an extended and uninterrupted period. Once the concentration of a substance and the flow rate have been determined, emission rates can be calculated by multiplying the concentration by the discharge flow rate or volumetric stack gas flow rate. Annual emissions of the substance can then be estimated by multiplying the concentration by the annual flow rate of the discharged effluent or the gases in the stack or duct.
3.8.2 Predictive Emission Monitoring
Predictive emission monitoring (PEM) is based on developing a correlation between substance emission rates and process parameters (e.g., fuel usage, steam production, furnace temperature). PEM may be considered a hybrid of continuous monitoring, emission factors and stack tests. A correlation test must first be performed to determine the relationship between emission rates and process parameters. Emissions can then be calculated or predicted using process parameters to predict emission rates based on the results of the initial source test.
3.8.3 Source Testing
Source testing involves collecting a sample of the emission or effluent, then determining the concentration of one or more substances in the sample. The concentration of the substance(s) of interest is then multiplied by the volumetric flow rate to determine the amount of the substance(s) emitted over time. Source testing of air emissions generally involves inserting a sampling probe into the stack or duct to collect a volume of exhaust effluent isokinetically. The substances collected in or on various media are subsequently analyzed. For liquid effluents, grab samples or 24-hour composite samples are extracted from the effluent stream.
3.8.4 Mass Balance
Mass balance involves applying the law of conservation of mass to a facility, process or piece of equipment. If there is no accumulation, all the materials that go into the system must come out. Releases are determined from the differences in input, output, accumulation and depletion of a substance. The general equation for a mass balance is:
Min = Mout + Maccumulated/depleted
Min = Mass of compound in the raw material feed
Mout = Mass of compound in the finished product and released to air, land and water
(Mout = Mproduct + Memitted)
Maccumulated/depleted = Mass of compound accumulated or depleted in the system
The reliability of release estimates based on mass balances is dependent on the source type considered. Mass balance methods may be preferred for some releases, such as solvent use and loss. However, this method may not be suitable for many other sources, such as cases where chemical transformation of input streams occurs.
3.8.5 Site-Specific and Published Emission Factors
Generally, emission factors relate the quantity of substances emitted from a source to a common activity associated with those emissions. Emission factors may be published or developed by facilities using emission testing data and source-activity information. For a particular piece of equipment, specific emission factors may be available from the manufacturer or sales centre. The basic equations for determining emissions from emission factors are as follows:
Ex = BQ × CEFx or
Ex = BQ × EFx × ((100 - CEx) / 100)
Ex = Emission of substance x (kg or other unit of mass)
BQ = Activity rate or base quantity (base quantity unit)
CEFx = Controlled emission factors of substance x (kg/BQ [dependent on any control devices installed])
EFx = Uncontrolled emission factors of substance x (kg/BQ)
CEx = Overall emission control efficiency of substance x (%)
3.8.6 Engineering Estimates
In many cases, sound engineering assessment is the most appropriate approach to determining process factors and base quantity values. Releases can be estimated from engineering principles and judgement by using knowledge of the chemical and physical processes involved, the design features of the source, and an understanding of the applicable physical and chemical laws. The reliability of these estimates depends on the complexity of the process and the level of understanding of its physical and chemical properties. To apply an engineering assessment method, follow these four basic principles:
- Review all data pertaining to the specific source and to the industrial sector in general.
- Use this data to provide gross approximations--and refine the approximations using sound engineering principles as data become available, in order to provide more accurate estimations.
- Whenever possible, use alternate methods of calculation to cross-check each level of approximation.
- Employ good record keeping.
3.8.7 Method Detection Limit
In NPRI reporting, there are several situations in which the issue of measurements below the method detection limit (MDL) arises. The MDL is the smallest concentration of the substance under analysis (i.e., the analyte) that produces an instrumental response and that meets all analyte detection and identification criteria of a specified test method. An indication that a reportable substance is below the 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.
3.9 Sources of Information
Information required to perform threshold calculations and to estimate releases, disposals and transfers for recycling of NPRI substances is available from a variety of sources, including Environment Canada, the U.S. Environmental Protection Agency (EPA) and industry associations. These resources are described in the following sections. Useful information can also be found in Material Safety Data Sheets, and in permits and certificates of approval.
3.9.1 Environment Canada Guidance Documents and Tools
The NPRI Toolbox (www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=65A75CDF-1) provides a number of tools:
- General Guidance
- General Information on Emission Factors and Emission Estimation Techniques
- Useful Equations and Conversion Factors
- Example Calculations
- Information on Fuel Combustion and Fugitive Emission Sources
- Sector-Specific Information
- Miscellaneous Resources and Other Relevant Links
The sections on fuel combustion and fugitive emission sources and the sector-specific pages of the NPRI Toolbox include links to calculation spreadsheets developed for specific activities and sectors. When information (such as production quantities or fuel used) is entered, these spreadsheets will automatically calculate releases of NPRI substances.
In addition to this guide, Environment Canada has developed several substance-, activity- and sector-specific guidance documents to assist in reporting to the NPRI. Table 6 lists these documents and their Internet addresses.
Table 6. Environment Canada Guidance Documents
|Type of Guidance||Title||Internet Address|
|Substances||Criteria Air Contaminants (CACs) Technical Source Guide for Reporting to the National Pollutant Release Inventory||www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=3B695DF5-1|
|Supplementary Guide for Reporting Criteria Air Contaminants (CACs) to the National Pollutant Release Inventory||www.ec.gc.ca/Publications/default.asp?lang=En&xml=4A2D4BB8-BFA0-4129-A5A3-DBA372BD3B32|
|Determining the Reporting Threshold for Total Reduced Sulphur Using Equivalence Factors||www.ec.gc.ca/inrp-npri/default.asp?lang=en&n=AAECF4F6-1|
|Activities||Guidance for the Reporting of Tailings and Waste Rock to the National Pollutant Release Inventory||www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=C115DEB3-1|
|Guidance for the Reporting of Welding Activities||www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=0FAE8C2F-1|
|Guidance on Estimating Road Dust Emissions from Industrial Unpaved Surfaces||www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=5DF2CF83-1|
|Wet Cooling Tower Guidance||www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=2ED8CFA7-1|
|Sectors||Guidance for Wood Preservation Facilities Reporting to the NPRI||www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=29B3E589-1|
|NPRI Guidance Manual for the Wastewater Sector||www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=86E3D932-1|
|Identification of Wastewater Treatment System Configuration and Process Characteristics||www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=57FBBE31-1|
|Pits and Quarries Guidance||www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=A9C1EE34-1|
|National Pollutant Release Inventory Reporting Guidance on Biosolids||www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=FC674F4F-1|
|Reporting Requirements for the Oil & Gas Sector||www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=5B72775D-1|
3.9.2 U.S. Environmental Protection Agency Guidance Documents and Tools
The U.S. EPA has published numerous documents and software programs that can be used to assist facilities; these are described in Table 7.
3.9.3 Industry Association Guidance
Table 8 lists the industry association guidance available through the NPRI Toolbox.
Table 7. U.S. Environmental Protection Agency Guidance Documents and Tools
|Guidance Document/Tool||Description||Internet Address|
|AP 42, Fifth Edition – Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources||Primary compilation of the U.S. EPA’s emission factor information, containing emission factors and process information for more than 200 air pollution source categories||www.epa.gov/ttn/chief/ap42/|
|Guidance Documents for reporting to the Toxics Release Inventory||Industry/process-specific and substance-specific guidance manuals to help estimate releases for reporting to the Toxics Release Inventory, which provide useful information for NPRI reporters||www.epa.gov/tri/guide_docs/|
|Locating and Estimating Documents||Compilations of available information on substances and sources of emissions||www.epa.gov/ttn/chief/le/|
|Landfill Gas Emissions Model||Tool that can be used to estimate emission rates for non-methane organic compounds and individual air pollutants from municipal solid waste landfills||www.epa.gov/ttn/catc/|
|PM Calculator||Contains information that allows the estimation of particulate matter fractions from total particulate matter (Microsoft Access version found under Emissions Inventory Tools)||www.epa.gov/ttn/chief/tools/|
|SPECIATE||Repository of total organic compound and particulate matter speciation profiles for air pollution sources||http://www.epa.gov/ttn/chief/|
|TANKS||Program that estimates volatile organic compound and hazardous air pollutant emissions from fixed and floating-roof storage tanks||http://www.epa.gov/ttn/chief/|
|WATER9||Program for estimating air emissions of individual waste constituents in wastewater collection, storage, treatment and disposal facilities||www.epa.gov/ttn/chief/software/|
|WebFIRE||The online Factor Information Retrieval (FIRE) database, which contains information on air emission factors||http://cfpub.epa.gov/webfire/|
Table 8. Industry Association Guidance Documents
|Mining; base metal smelting; iron ore pellets; potash mining||Mining Association of Canada|
|Chemicals manufacturing||Canadian Chemical Producers Association|
|Upstream oil and gas; oil sands; natural gas transmission, distribution and storage||Canadian Association of Petroleum Producers|
|Petroleum refining; petroleum product terminals||Canadian Petroleum Products Institute|
|Wastewater||Canadian Water and Wastewater Association|
3.10 General Information to be Reported
3.10.1 Contact Information
For each of the following, the name, position, mailing address, telephone number and email address must be provided:
- Technical contact: the person who prepared the report and who will be able to answer any questions pertaining to its contents. All correspondence from Environment Canada regarding the NPRI will be sent to the technical contact if no coordinator (see below) is identified.
- Public contact (if any): the person responsible for answering any questions from the public concerning the report. This name will appear on the NPRI website as the contact for the facility. If a public contact is not identified, the name of the coordinator, or technical contact if no coordinator is identified, will appear instead.
- Coordinator (if any): the person who is responsible for preparing and submitting NPRI reports for more than one facility for the same company. The coordinator is responsible for answering any questions concerning all of the NPRI reports he/she filed. All NPRI correspondence from Environment Canada will be sent to the coordinator, if one is identified.
- Certifying official: the person who is legally responsible for the contents of the NPRI report. The certifying official is usually the owner or operator, or a company official authorized to act on his/her behalf.
- Independent contractor (if any): if an independent contractor prepared the report, contact information must be provided, including the name of the contracting company.
It is important that contact and ownership information be kept up-to-date using the online reporting system or by contacting Environment Canada, if:
- there is a change in the name, address, telephone number or email address of the contacts identified for the facility; or
- there is a change in the owner or operator of a facility.
3.10.2 Facility Information
Table 9 summarizes the general information that must be provided for all facilities that report to the NPRI. Other facility information may also be required, depending on the type of facility and the substances reported.
Table 9. Facility Information Required to Be Reported to the National Pollutant Release Inventory
|Type of Information||Information to Be Reported|
|Facility name and location|
|Parent companies (if any)|
|NPRI identification number|
|North American Industry Classification System (NAICS) Code(3)|
|Pollution prevention plan|
(1) A Dun & Bradstreet (D-U-N-S) number is a unique nine-digit identification number for a single business entity.
(2) A federal business number is a nine-digit registration number issued by the Canada Revenue Agency (CRA) to Canadian businesses that register for one or more of the following: corporate income tax; importer/exporter account number; payroll deductions; or goods and services tax. This number can be found on all forms issued to a business by the CRA. The first nine digits that appear on these forms is the federal business number.
(3) NAICS is an industry classification system developed by the statistical agencies of Canada, Mexico and the United States. For more information, see the Statistics Canada website: www.statcan.gc.ca/subjects-sujets/standard-norme/naics-scian/2007/introduction-eng.htm. For a list of 6-digit NAICS codes, see the NPRI Toolbox at www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=6DE7F8BC-1#n8.
3.11 Other Requirements
3.11.1 Statement of Certification
A Statement of Certification (SOC) must be electronically signed and submitted with the NPRI report using the on-line reporting system. The certifying official should verify that the information submitted is true, complete and accurate, and acknowledge that the data will be made public. The certifying official is legally responsible for the contents of the NPRI report.
3.11.2 Record Keeping
Pursuant to subsection 46(8) of CEPA 1999, the owner/operator of a facility is required to retain copies of all information on which their report is based, including any calculations, measurements and other related data, for a period of three years. This information must be kept at the facility or at the principal place of business in Canada of the owner/operator of the facility to which the information relates, for a period of three years.
- Date Modified: