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Second report of theNational Pollutant Release Inventoryad hoc work group on substances
(Revised March 31, 1999)
3. RECOMMENDED ADDITIONS AND DELETIONS FOR THE 1999 REPORTING YEAR
In this section, the recommendations of the Work Group concerning additions and deletions for the 1999 reporting year are presented. These recommendations were developed by the Work Group on a substance-by-substance basis.
As noted previously, the Work Group separately considered questions relating to implementation of the additions, including the option of phase-in of the 1999 additions. Thus, the substance-by-substance recommendations presented below should be read in conjunction with the implementation recommendations presented in Section 4 of this report.
The recommendations concerning 1999 additions were developed on an iterative basis, as summarized in Section 2 (and described in more detail in the first report of the Work Group). Through this process, and prior to the meeting of the Work Group on February 16-17 1999, the candidate additions had been reduced to a list of 59 substances or groups of substances. This full list is presented for reference purposes in Annex B.
Prior to the Work Group meeting of February 16 and 17 1999, no substance-specific questions or objections had been raised with respect to addition of 41 of the substances listed in Annex BFor the remaining 18 substances or groups of substances, questions or objections to addition had been raised by one or more stakeholders or Work Group members.
The 41 substances for which no substance-specific concerns have been raised are recommended by the Work Group for addition for the 1999 reporting year. Further details are provided in sub-section 3.2 below.
The remaining 18 substances or groups of substances -- those for which substance-specific concerns had been raised -- were considered individually by the Work Group at its February 16 - 17 meeting. For each of these substances, the Work Group arrived at one of four conclusions:
- Recommend addition for the 1999 reporting year
- Recommend deferral of decision until 2000 reporting year
- Recommend deferral of decision until 2000 reporting year, and consider at lower reporting threshold
- No recommendation (for these substances, differing stakeholder views were not resolvable, and participants agreed to disagree).
Sub-sections 3.2 through 3.5 present the recommendations of the Work Group with respect to each of these categories.
In addition to the proposed additions, the Work Group also considered three substances proposed for possible deletion. Sub-section 3.6 presents the Work Group recommendations concerning the proposed deletions.
3.2 ADDITIONS FOR THE 1999 REPORTING YEAR
The substances and groups of substances listed in this section are recommended for addition to the NPRI for the 1999 reporting year. As noted previously, these substance-by-substance recommendations should be read in conjunction with the implementation recommendations presented in Section 4 of this report.
The recommended substances or groups of substances are presented in two tables. First, the Work Group recommends the following 41 substances, for which no substance-specific concerns have been raised, for addition for the 1999 reporting year.
|115-28-6||Chlorendic acid||64-18-6||Formic acid|
|1300-71-6||Dimethyl phenol (Xylenol)||7681-49-4||Sodium fluoride|
|28407-37-6||C.I. Direct Blue 218||78-00-2||Tetraethyl lead|
Second, the Work Group recommends the following 8 substances, or groups of substances, for addition for the 1999 reporting year. These 8 substances are taken from the list of 18 substances for which questions or concerns were raised prior to the February 16-17 meeting of the Work Group (listed in Annex B). In each case, prior to arriving at its recommendation, the Work Group considered the questions or concerns, as well as additional information presented by Environment Canada in response to the questions or concerns. In some cases, the Work Group offers supplementary recommendations designed to address remaining substance-specific issues.
|Nonylphenol and its ethoxylates (includes nonylphenol ethanols and nonylphenol glycol ethers)2|
n-Nonylphenol (mixed isomers)
p-Nonylphenol polyethylene glycol ether
Nonylphenol hepta(oxyethylene) ethanol
Nonylphenol polyethylene glycol ether
|Addition is recommended at current thresholds, but application of alternative thresholds should be considered in the future, particularly in the case of releases from sewage treatment plants. The CAS#s included in this group could evolve over time.|
|110-54-3||Hexane||Environment Canada should ensure that the summary report contains adequate contextual information on the relative importance of other (notably mobile) sources. Also, Environment Canada must recognize that this is a difficult substance to report on due to presence of hexane in mixtures (e.g. mineral spirits) with their own CAS#s. Significant Environment Canada guidance will be required.|
|111-76-2||2-Butoxyethanol||No supplementary recommendations|
|2551-62-4||Sulphur hexafluoride||Environment Canada will discuss with CAPP the question of a possible exemption for tracer applications. Although exemption for this application could be considered, Environment Canada prefers to minimize such conditions. Levels of usage for this application may not be sufficient to trigger NPRIreporting.|
|Short chain chlorinated paraffins|
|Alkanes C6-18, chloro|
Alkanes C10-13, chloro (50-70%)
|Addition is recommended at current thresholds, but application of alternative thresholds can be considered in the future.|
|7783-06-4||Hydrogen sulfide||No supplementary recommendations. The Work Group noted that CSPA supports waiting for US EPA decision regarding TRI reporting on this substance, and that Alberta Environment expressed concern that addition will require significant additional reporting because of the large number of sources (in many cases the reporting would be for relatively small releases).|
|7789-75-5||Calcium fluoride||No supplementary recommendations|
|NA-283||Organotin compounds: non-pesticidal uses||Environment Canada should review which CAS#s are of concern regarding toxicity. Two options should be considered: (1) add a small number of individual CAS#s that are of concern4,or (2) add families of related organotin compounds|
3.3 DEFER DECISION UNTIL 2000 REPORTING YEAR
The Work Group recommends that a decision concerning the following 3 substances, or groups of substances, be deferred until the 2000 reporting year. These 3 substances are from the list of 18 substances listed in Annex B. In each case, prior to arriving at its recommendation, the Work Group considered the questions or concerns, as well as additional information presented by Environment Canada in response to the questions or concerns. In some cases, the Work Group offers supplementary recommendations designed to address remaining substance-specific issues.
|Environment Canada will review how NPRI could better address aluminium salts|
|64-17-5||Ethanol||Environment Canada will review reporting implications, particularly with respect to small breweries, wine making, and micro-distilleries|
|9016-87-9||Polymeric diphenyl methane diisocyanate (PMDI)||Environment Canada will obtain additional assessment (second opinion) regarding toxicity. The option of grouping the different diisocyanates into a single category is not recommended at this time.|
3.4 CONSIDER AT LOWER REPORTING THRESHOLD
The Work Group recommends that a decision concerning the following 5 substances, or groups of substances, be deferred until the 2000 reporting year. The Work Group further recommends that these substances be considered for addition at a lower reporting threshold, because in each case current releases are believed to be low relative to the standard reporting threshold.
These 5 substances are from the list of 18 substances listed in Annex B. In each case, prior to arriving at its recommendation, the Work Group considered the questions or concerns, as well as additional information presented by Environment Canada in response to the questions or concerns. In some cases, the Work Group offers supplementary recommendations designed to address remaining substance-specific issues.
|107-02-08||Acrolein||No supplementary recommendations|
|12002-48-1||Trichlorobenzenes||No supplementary recommendations|
|58-90-2||2,3,4,6-Tetrachlorophenol||Review level of releases in interim; could lead to decision to drop from further consideration if no significant sources in Canada|
|7440-41-7||Beryllium and its compounds||No supplementary recommendations|
|88-06-2||2,4,6-Trichlorophenol||Review level of releases in interim; could lead to decision to drop from further consideration if no significant sources in Canada|
3.5 NO RECOMMENDATION
The Work Group was unable to come to a consensus recommendation concerning the following 2 groups of substances. These 2 substances are from the list of 18 substances listed in Annex B. In each case, the Work Group considered the questions or concerns, as well as additional information presented by Environment Canada in response to the questions or concerns. Although the Work Group was unable to come to consensus on these substances, the deliberations provided some general guidance regarding these substances, presented in the table as “Additional Notes”.
|Ozone depleting substances (ODS)|
Dichlorotrifluoroethane (HCFC-123) and all isomers
Chlorotetrafluoroethane (HCFC-124) and all isomers
The Work Group did not reach agreement concerning addition of the listed ODS. The primary issue is concern about duplication expressed by some stakeholders, vs a desire for more comprehensive reporting expressed by other stakeholders. CVMAand CSPA stated their opposition to addition of ODS to NPRI reporting requirements. STOP, CEASOand CNWM stated their support for addition.
A specific concern was raised regarding inclusion of some substances restricted to very limited applications (air conditioning or fire extinguishers). Environment Canada was asked to reconsider the list of ODS suggested for inclusion, particularly those substances with restricted application or phase-out requirements in the near term.
Some Work Group members suggested Environment Canada consider a stepwise approach to reporting of ODS, beginning with compilation and publication of currently available data by NPRI in 1999. This process would inform a future decision concerning possible addition for the 2000 reporting year. Concerns expressed with this option related to the lack of facility specific data currently available.
|142844-00-6||Refractory ceramic fibre|
The Work Group reached agreement on several points: that the addition of the substance to the NPRI list should be limited to the “friable” form (as in the case of asbestos); that technical guidance will be needed from Environment Canada, because of the difficulties that facilities will face in reporting this substance; and that this addition could be reassessed after the MOU-based monitoring period recommended by the SOP.
The Work Group did not reach agreement on whether the addition should occur for the 1999 or 2000 reporting year. Concerns with addition in 1999 related to the uncertainties and difficulty in reporting this substance; lack of information available through the MSDS system; and concerns about availability of adequate time to establish tracking systems.
3.6 DELETIONS FOR THE 1999 REPORTING YEAR
At its February 16-17 meeting, the Work Group discussed three substances proposed as candidates for deletion: acetone, sulfuric acid (releases to water only), and hydrochloric acid (releases to water only). The Work Group reached the following conclusions:
|Acetone||There was broad support for delisting in the Work Group. The Work Group however noted that CEASO does not support delisting, and noted the similar written position taken by CIELAP. CNWM does not support delisting. Pembina Institute is not convinced, and requested more information regarding volume released to water and its ecological significance.|
|The Work Group does not recommend delisting these acids, and does not recommend elimination of reporting requirements concerning of releases to water. The Work Group also does not recommend eliminating the reporting of zero releases to water.|
4. RECOMMENDATIONS CONCERNING IMPLEMENTATION
The Work Group reviewed a series of issues relating to implementation of the 1999 additions. Concerns were raised by some Work Group members concerning:
- The burden associated with addition of a significant number of new substances in 1999
- Data quality in the first reporting year for new substances
- Lack of context for releases of some substances (where non-NPRI releases are significant).
In response, Environment Canada proposed a series of measures that help address the concerns. Additional possible responses were proposed by other members of the Work Group. These options were discussed by the Work Group. The conclusions and recommendations are presented in the following sub-sections:
- Reducing burden
- Publication of first year information
- Information on releases from other sources
Also presented in this section is a proposed schedule concerning the 1999 additions and deletions.
4.1 REDUCING BURDEN
Possible phase-in of additions over several years
The Work Group discussed the option of phase-in of the recommended 1999 additions over two or more years (for instance, addition of PSL1 and CEPA-toxics in year 1, and the remaining substances in year 2).
This option was supported by some Work Group members (AMEC, CSPA , and CVMA) as a mechanism to reduce the burden on companies, particularly smaller firms that may lack sophisticated tracking systems. Conversely, Environment Canada, while recognizing the burden issue, expressed concerns with an extended phase-in period, arguing that addition of substances is already overdue, and a phase-in process complicates NPRI reporting and compliance promotion.
On balance, the Work Group accepted immediate addition of all recommended 1999 additions, provided other identified measures are taken to reduce the burden. Specifically, the Work Group decision calls for significant effort on the part of Environment Canada to provide guidance concerning the new substances, and a modified approach to publication of information in the first year. The Work Group noted that the concerns of those members favouring phase-in are reduced, but not necessarily fully addressed, by these additional measures.
Environment Canada guidance
Guidance from Environment Canada is considered critical by the Work Group. In particular, there is a need to identify possible (generic) uses of the new substances, to help companies determine where in their operations the new substances may be used. Accordingly, the Work Group recommends significant effort by Environment Canada to provide the necessaryguidance by early June (when companies will start working on reporting for 1999).
The Work Group also noted that guidance should be available to industry associations from their U.S. counterparts (relating to TRIreporting), and from other sources such as:
- Supporting documents/reports from the PSL process (including the Minister’s Advisory Panel) and Section 16 data
- Companies reporting use and release data in the states of New Jersey and Massachusetts
- U.S. EPA web site (TRI and Office of Air Quality and Standards FIRE database).
Environment Canada noted that guidance will not be required for all new substances. Environment Canada also requested input and support from industry with respect to the required guidance – for instance, identification of sources of information, and input on how the information can best be used to meet industry’s needs. Environment Canada will undertake to provide available guidance by June, and subsequently update this guidance as required through postings on the Internet.
In addition to measures relating directly to the 1999 additions, the Work Group considered other approaches to reducing reporting burden: CAS numbers, and alternative approaches to unreported substances.
- The Work Group recommends further work to provide CAS numbers for existing substances on the NPRIlist. Although not directly related to the 1999 additions (for which CAS numbers have already been provided), the Work Group believes that this recommendation will reduce reporting burden. The Work Group also believes that provision of CAS numbers will improve and clarify the information reported, and possibly allow reporting within generic categories to focus on the substances of greatest concern. MAC, AMEC, and CVMAhave offered to assist Environment Canada in this effort.
- The Work Group does not, at this time, recommend changes with respect to unreported substances. Delisting of unreported substances was recognized by the Work Group as an option to be considered on a case-by-case basis. The Work Group is continuing its discussion of future process for listing and delisting substances within NPRI; this will be the subject of a future Work Group report.
The Work Group also considered the option of “probationary status”. No recommendations have been made with respect to probationary status at this time. Instead, the Work Group will consider this option in the development of a future process for listing and delisting substances within NPRI.
4.2 PUBLICATION OF FIRST YEAR INFORMATION
Some work Group members identified issues regarding data quality and consistency in the first year of reporting. In recognition of these issues, Environment Canada proposed a modified approach to publication of information for the substances added for the 1999 reporting year:
- In the annual Summary Report, defer for one year the ranking of companies for largest releases of the new substances.
- Also in the annual Summary Report, report on the new substances in a separate section for the first year.
- As with current substances, provide all reported data concerning the new substances on the Internet.
This modified approach to publication of information was supported, and is recommended as a package by the Work Group. The Work Group recommends the modified approach for one year only following addition of the substances (with a possible exception for nonylphenol and its ethoxylates, where evolution in the list of specific substances may require a longer special reporting period).
4.3 INFORMATION ON RELEASES FROM OTHER SOURCES
Some work Group members expressed concern regarding a lack of information on non-NPRI releases for some substances (particularly substances where the non-NPRI sources are significant). This issue relates to some possible 1999 additions, as well as substances already listed. This additional contextual information was seen as important for priority-setting and other reasons.
The Work Group noted that Environment Canada has done good work in this area, by including data on non-NPRI releases for some substances. The Work Group recommends that the practice of providing additional information on releases from non-NPRI sources continue, and be expanded where possible. Environment Canada is in agreement with this recommendation, but notes that it is dependent on availability of suitable data sources and resources. Environment Canada will also endeavour to provide enhanced links to other web sites providing relevant release data.
The following schedule was proposed by Environment Canada for the 1999 additions/deletions:
|Second Work Group Report Finalized.|
|Environment Canada final response, and text submitted to Canada Gazette for confirmed 1999 additions/deletions|
|Publication in Canada Gazette|
Mid April (estimate)
|Guidance regarding new additions|
Early June (followed by additional guidance as available)
 The list of nonylphenols included in the Canada Gazette notice of February 13, 1999 also included an additional nonylphenol (oxirane, methyl-, polymer with oxirane, mono(nonylphenyl) ether, CAS number 37251-69-7). This substance was not submitted for consideration by the Work Group, and so is not included in the list recommended by the Work Group.
 All individual substances, and CAS numbers, are identified in Canadian Environmental Protection Act Priority Substances List Assessment Report: Non-Pesticidal Organotin Compounds, Government of Canada, 1993, # EN-40-215/18E.
 PSL report (op.cit.) identified 90 non-pesticidal organotin compounds by CAS number, of which 26 pass the DSL 1 tonne screen. Preliminary review suggests that within the group of 26, five compounds are of greatest concern.
 The isomers include, but are not necessarily limited to, HCFC‑123 and 123a (CAS #306‑83‑2 and #90454‑18‑5).
 The isomers include, but are not necessarily limited to, HCFC 124 and 124a (CAS #2837-89-0 and #354-25-6).
 In concept, a substance listed on a probationary basis would be reviewed after a set period of time, to determine if continued inclusion in NPRI was warranted. Probationary status would be limited to a small number of substances, and would be based on defined criteria (for instance, new information expected in the near term).
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