Guide for Reporting to the National Pollutant Release Inventory 2000: section 6

Section 6: Questions and Answers

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• Question and Answers

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Questions and Answers

1. Is a facility meeting the criteria described in the Canada Gazette notice required to report if there were no releases of NPRI substances during the calendar year?

Yes. The reporting requirements vary by substance. The criteria for most NPRI substances are based on the quantity processed, manufactured or otherwise used, the total number of hours worked by employees or the activity for which the facility was used, and concentration of NPRI substances. The reporting criteria for mercury (and its compounds), PAHs, dioxins/furans and HCB differ from those previously mentioned, and details are provided in the Supplementary Guide. Once you meet the substance-specific reporting criteria, you must report for any NPRI substances, regardless of the amounts released or transferred.

2. Our facility closed part way through the calendar year. Are we required to submit an NPRI report?

Yes. If your facility met the reporting criteria and was in operation during any portion of the calendar year, you are required to report.

3. In British Columbia, several fish processors have factories on ships. They use ammonia and chlorine in their fish-processing operations. Is each ship considered a "facility" under the Canada Gazette notice or is the whole group of ships (assume one company) a facility?

A facility is defined as all buildings, equipment, structures, and other stationary items which are located at a single site or adjacent or contiguous sites owned or operated by the same person. A ship is not a facility as defined under the notice. It is not stationary and it is not located on a single site. Therefore, there is no requirement to report.

4. A barge-repair facility cleans barges by vacuuming out residual products containing listed substances and recycling them. Is the facility required to report?

The facility is processing the chemicals. If the threshold criteria for reporting are met, the facility must file a report. Releases during vacuuming must be reported as well as releases from related activities such as spills and equipment cleaning.

Routine cleaning of the exterior of the barge is considered maintenance of a transportation vehicle and is therefore exempt.

5. Does the determination of a full-time employee "equivalent" include the hours worked by sales staff whose offices are located in the same building as the production staff, or who work outside the facility?

Yes. All staff employed at a facility, regardless of function or location, count toward the employee threshold determination.

6. Would a facility with nine full-time employees and four part-time employees be required to report to the NPRI?

Total the hours worked by all people, including contractors who were performing work related to the operation of the facility. If the total was 20 000 hours or more during the reporting year, the threshold for the number of full-time employees has been met. However, if your facility was used for certain types of incineration or for wood preservation, as listed in the Canada Gazette notice, you must submit a substance report for any NPRI substance that met its respective reporting criteria, regardless of the number of hours worked by employees.

7. When calculating the total number of hours worked by all employees during the calendar year, should overtime, and vacation and sick leave used be included toward the 20 000-hour threshold?

Yes. The facility must include all overtime, and paid vacation and sick leave toward the 20 000-hour threshold.

8. When should an individual's time spent working at a facility be counted for purposes of determining whether or not a facility meets or exceeds the 20 000- hour threshold?

If an individual is employed by the facility or by the facility's parent company to work at the facility, then all of the hours worked by the individual must be counted toward the 20 000-hour threshold.

Contractors performing work related to the operations of the facility must also be included.

If an individual both owns and works for the facility, that individual's hours must also be applied toward the 20 000-hour threshold.

9. Is the owner or the operator responsible for reporting?

The Canada Gazette notice requires a person who owns or operates a facility to report information to which the person has access or can reasonably be expected to have access. This is usually the operator. However, both the owner and the operator are subject to the notice. If no report is received from a facility that meets the reporting requirements, both persons may be held liable.

10. Who is the parent company for a 50/50 joint venture?

The reporting form allows a number of parent companies to be entered with the percentage of ownership for each.

11. A facility had been operating its manufacturing processes in a leased warehouse. In July, they bought their own warehouse and moved the manufacturing operations. These two locations are neither adjacent nor contiguous. The company did not shut down or close during this time. How should the facility make threshold determinations and report to the NPRI?

The company must consider the locations as two separate facilities because the operations were carried out at two distinctly separate physical sites. Threshold determinations must be made for the period of time during which each facility operated.

A new NPRI ID number will be assigned to the new facility.

12. Acme Plastics is a wholly-owned subsidiary of a major chemical company which is a wholly-owned subsidiary of XYZ Oil Corp. Which is the parent company?

XYZ Oil Corp. is the parent company because it is the highest level company that directly controls Acme Plastics.

13. Two manufacturing facilities, owned by the same company, are divided by a public railway. Is this considered adjacent facilities or two separate facilities?

Two facilities owned or operated by the same company that function as a single integrated site, but are separated by a railway, would be considered adjacent sites since they are physically adjacent to one another except for a public right-of-way. Therefore, reporting thresholds would be determined by the combined quantities of substances processed, manufactured or otherwise used at both facilities. The 20 000-hour threshold would be determined by the sum of hours worked at both facilities.

14. A Vancouver-based company has a plant in Alberta which processes 12 tonnes of methanol, a plant in Ontario which processes 8 tonnes of methanol and a plant in Quebec which processes 11 tonnes of methanol. Do the three plants have to report as a company or can they report as separate facilities?

A report is required for each facility that meets the reporting criteria; their activities cannot be combined. In this case, the plant in Ontario is not required to report but the other two are if they meet the other reporting criteria. The company may choose to report for each of the facilities meeting the reporting criteria on one disk, or to have each facility submit their report separately.

15. When contractors working at a facility supply their own materials and supplies such as solvents containing NPRI substances, should these substances be included in the threshold determination and reported by the facility?

Yes. The owner or operator of the facility must include the quantities of NPRI substances used by contractors in their threshold calculations if those uses are relevant to the purpose of the facility.

16. An NPRI substance is the working fluid in our heat transfer equipment. Must the quantity of the NPRI substance be accounted for in determining the reporting threshold?

Yes. The fluid within the heat transfer equipment is considered to be an "other use" of the NPRI substance, relevant to the purposes of the facility as defined in the Canada Gazette notice. All of the NPRI substance in the heat transfer equipment must be included in the threshold calculation.

17. Our company disposes of some of its waste in a landfill site which belongs to the company but is in a different location. Is this an off-site transfer or a release?

This would be an off-site transfer for disposal if the landfill is not adjacent or contiguous with the facility; otherwise it would be a release.

18. Our company sorts scrap metal and compresses it into bales to be sold to secondary metal producers. Most of the metal we recover contains some NPRI substances (Zn, Cr) in excess of 1% concentration. The process does not release any NPRI substances; it only compresses the pieces into bales. Are we required to file a report?

No. In this case, the items being handled would retain their status as articles as long as there are no on-site releases to the environment or off-site transfers for disposal.

19. At what point in the processing of ore must mining companies report?

The exemption for mining is for activities related to the actual removal of ore, rock or overburden, up to and including primary crushing. Any NPRI substances used in the further processing of the rock or ore, such as milling, concentrating, smelting and refining, would be reportable if the thresholds are met. This would include, but not be limited to, NPRI substances found in the processed ore, solvents, acids, flotation agents, flocculation agents, and fuels used in power generation. Listed substances in tailings are not reported unless they leave the tailings impoundment or other forms of on-site containment.

20. If a substance is spilled one year, and will result in air emissions over time in the following year, how should it be reported?

The portion of the spill not cleaned up must be reported as a release the year the spill occurred. It must be reported as a release to the environmental media affected (air, water, land). Further migration between media does not need to be reported.

21. Can a facility use its own software to report electronically to the NPRI?

Environment Canada supplies the software required for reporting and strongly recommends that this be used to submit a report to the NPRI.

However, if you choose to use other software and the report submitted cannot be read and verified by Environment Canada's own reporting software, the report will be considered incomplete and be returned for correction.

Environment Canada reserves the right to change its software and file structure at any time.

22. We use a 50% methanol solution in one part of the plant. The annual consumption of methanol exceeds 10 tonnes. In another part of the plant, a completely separate process produces a few tonnes of methanol which are released through a stack. Do we have to estimate methanol releases from the stack even if they are from a different process?

Yes. Because your facility uses more than 10 tonnes of methanol, it is required to report all its releases of methanol, regardless of the process stream.

23. We have a provincial waste permit to discharge sulphuric acid at a pH between 5.8 and 6.6. How do we report our releases of sulphuric acid if we meet all the reporting requirements?

Releases of mineral acids at a pH of 6.0 or greater are considered neutralized and must be reported as zero (0). The portion of acid discharged at a pH less than 6.0 will constitute a reportable release and must be calculated and reported.

24. We send an NPRI substance to an outside company for recovery. The recovered substance is then sent back to us for reuse. Does the recovered substance count toward the threshold calculation?

Yes, if the recovered substance is being processed or used it would have to be included in the threshold calculation since it is no different than new material being processed or used.

25. A company engaged in electroplating is using equipment and lead anodes purchased and installed before the current reporting year. Fifteen tonnes of lead anodes were originally installed in the plating tanks. The lead anodes dissolve over time and the lead ends up in the sludge and the wastewater. During the calendar year, the company replaced 7 tonnes of lead anodes. Does the company have to submit an NPRI report for lead?

Yes. The entire electrode assembly is considered to be an "other use" of lead, relevant to the purposes of the facility as defined in the Canada Gazette notice. The entire quantity of lead in the electrode assembly (15 tonnes), must be used in the threshold calculation, not just the 7 tonnes consumed in the process.

26. When do metal parts, sheets or wire containing NPRI substances lose their status as articles?

Metal parts, sheets or wire lose their article status when there are releases to the environment or transfers for disposal.

If all materials removed during processing, such as turnings or blanks, are completely recycled and due care has been exercised to ensure that the materials are 100% recycled within the facility, the materials retain their article status.

Due care is considered to have been exercised if no more than 1 kg (0.001 tonne) of an NPRI Part 1 substance is released in a given year as a result of the processing or other use of an article.

Typical metal processing activities that violate article status include welding, torch cutting, quenching, etching and dry grinding.

Typical metal processing activities that do not violate article status (assuming "due care" is exercised in ensuring 100% recycling of materials) include cutting, stamping, bending, punching, machining, shearing, soldering and cold extrusion.

27. Our company purchases metal parts and then welds them together using welding rods. We then paint them and glue other parts to them. What would be reportable in this case?

The original parts would lose their status as articles during welding because the welding process releases emissions to the air. The quantity of NPRI substances contained in the parts would be used to calculate the reporting threshold. The quantity of NPRI substances in the welding rods would also be included in the calculation of the reporting threshold.

The NPRI substances contained in the paints and glues would be reportable if the threshold criteria are met.

28. Is the use of fuel exempt from reporting?

No. The use of fuel is not implicitly exempt from reporting. Use of fuel in a stationary system, such as for power generation, would be reportable if the threshold criteria are met.

Retail sale and fuel distribution are exempt. Refueling of motor vehicles is also covered by this exemption even if the vehicle is refueled from a tank on company property. Mobile sources such as vehicles and earth-moving equipment are not stationary items considered part of a facility. They are not to be included in the calculation of the reporting threshold.

29. Chromated copper arsenate (CCA), is used in the wood-treatment industry but is not on the NPRI substance list. Do we have to report?

While CCA is not an NPRI substance, copper, chromium, arsenic and their compounds are on the list. A threshold calculation must be performed for each individual substance.

A typical bulk solution of CCA (50% concentrate) contains 12.3% Cr, 7.39% Cu, and 11.09% As, by weight. A company would have to use 81.3 tonnes of 50% concentrate of CCA to render Cr reportable. In this situation, As and Cu would not be reportable since they do not exceed the 10-tonne threshold.

30. Should fugitive dust from tailings dams and tailings impoundments be reported to the NPRI as releases?

Yes. NPRI substances that are released as fugitive emissions must be reported. The deposit of NPRI substances contained in the mineral portion of the ore or rock to a tailings impoundment is not reportable, but releases from the impoundment or dam are.

31. Our mine operates a wastewater treatment system for a tailings impoundment effluent. The treatment process generates a metal hydroxide sludge containing two NPRI substances. The sludge is pumped back into the tailings impoundment. Are the NPRI substances in the sludge considered releases?

Substances that are pumped back into a tailings impoundment are not considered releases. The amount of substances leaving the tailings impoundment would be reported as a release.

32. Should hydraulic backfill pumped underground and used for filling open stopes for ground control be reported?

No. Stope filling for ground control is part of the extraction process and is therefore exempt under the mining exemption.

33. We use zinc in our primary crusher as backing for concaves and shells. Is it reportable?

No. The mining exemption is for extraction up to and including primary crushing.

34. Do NPRI substances contained in a refractory brick furnace have to be reported?

No. Refractory bricks would retain their status as articles as long as they do not release any NPRI substances during normal use. However, the refractory bricks lose their article status if during normal conditions of use they degrade and release NPRI substances. In that event, the total quantity of NPRI substances in the refractory lining must be used in the calculation of the 10-tonne reporting threshold.

35. Our ore-processing facility uses greases and fuels to operate the many machines used in the benefaction of the ore. Are NPRI substances in these greases and fuels reportable?

Yes. Process equipment maintenance using materials such as grease, oils or lubricants, disinfectants or paint, etc., is not exempt and must be considered for the purposes of NPRI reporting.

The use of greases and fuels in this situation would be considered "other use".

36. We use more than 10 tonnes of sodium cyanide in our flotation beds. The substance is entirely consumed and transformed to non-ionic cyanides in the process. We meet all other reporting criteria. Are we required to report?

Yes. Reporting of NPRI Part 1 and 2 substances is based on quantity manufactured, processed or otherwise used, not on quantities released. You must perform your threshold calculations based on the amount of cyanide ion used or processed and file a report if you meet or exceed 10 tonnes. Since non-ionic forms of cyanide are not on the NPRI substance list, you would report a zero release of cyanide ion.

37. We use copper sulphate as a reagent. During the process, it attaches itself to other compounds and remains with the concentrate. There are no releases. Is it reportable?

Yes, if the amount of copper meets or exceeds the threshold reporting requirements, you would file a report for "Copper (and its compounds)" and report a release of zero for this process. All other releases of copper from your facility would also have to be reported.

38. We use zinc sulphate, zinc oxide and zinc stearate. How do we handle reporting of all these different metal compounds?

Report only the zinc portion of the compounds under the substance name "Zinc (and its compounds)".

39. Is fuel used for fire-training purposes reportable to the NPRI?

A facility used for the education or training of students is exempt from reporting. Therefore the use of fuels does not need to be reported.

40. We store products in our warehouse that don't belong to us. We do not use these products in the operation of our warehouse. Some of these products contain NPRI substances. Are we required to report?

No. A warehouse is not required to report if it does not manufacture, process or otherwise use NPRI substances. Transfer of NPRI substances between containers is considered processing.

Wholesale distribution is exempt provided there are no releases of NPRI substances.

41. We buy bulk NPRI substances in tanks and drums. Some of these substances are simply repackaged in smaller containers (e.g., tanks to drums, drums to 4- litre plastic bottles). However, some of the substances are mixed together and then repackaged. Are we required to report?

Transfer of substances between containers is considered processing and those quantities must be included in the threshold calculation.

Mixing substances together prior to packaging is also considered processing.

42. We use an NPRI substance in our process that meets all the reporting criteria. Unfortunately, we have no data on possible releases and we cannot find any estimation factors. Is a release of zero acceptable in this case?

For substances other than dioxins/furans and HCB, you are required to report the information that you possess. You must report your facility information and identify the substances for which a report is required. If you meet the reporting criteria for dioxins/furans and HCB, but have no data and cannot find emission factors, you are required to report "no information available" ("Basis of Estimate" code "NI") for any releases and transfers expected to contain these substances (e.g., releases to air from a combustion process that generates dioxins/furans). You would report "zero" releases only if it is known that these substances were not released or transferred. A release of zero will be accepted, but the comment section should include a statement that releases and transfers could not be estimated.

43. We purchased 12 tonnes of an NPRI substance to prepare a solution for our new metal-cleaning baths. The baths will be used this year. How do we calculate the "otherwise use" threshold for this year and the following years?

The metal-cleaning bath is considered to be an "other use" of NPRI substance, relevant to the purposes of the facility as defined in the Canada Gazette notice. The entire quantity of the NPRI substance in the metal-cleaning bath plus any quantity used to top up the bath must be used in the threshold calculation, not just the quantity consumed in the process.

44. Are vinyl chloride and polyvinyl chloride (PVC) the same compound?

No. Polyvinyl chloride is a polymer made from vinyl chloride. It is not the same substance and is not listed in the NPRI, therefore it is not reportable. Only free vinyl chloride monomer is reportable. Some formulations of pre-polymers may contain a percentage of free monomer. If you purchase pre-polymers which contain free vinyl chloride monomer, add this to the threshold calculation.

45. Asbestos is listed with the CAS number 1332-21-4. We use asbestos with the following names and CAS numbers: Azbolen (17068-78-9), Actinolite (77536-66-4), Amosite (12172-73-5), Anthropylite (77536-67-5), Tremolite (77536-68-6) and Serpentine. Are we required to report?

The CAS number 1332-21-4 is defined as: "Asbestos, a greyish, non-combustible fibrous material. It consists primarily of impure magnesium silicate". Asbestos with the CAS number 1332-21-4 is the general CAS number for a number of specific types of asbestos including those mentioned. Those types of asbestos would be reportable as long as they are in friable form.

46. A facility coats materials using a vacuum deposition process. When it uses aluminum for coating, is it required to report for aluminum fumes?

In vacuum deposition, the metal is converted to a vapour state under low pressure. The vapour condenses on the material to be coated. Vapours are not fumes. A metal fume consists of finely-divided particulate matter dispersed in a gas (like smoke). Because vapours and fumes are different, this process would not be considered a reportable activity unless the condensation creates fumes or dust.

47. What types of routine maintenance are exempt?

Routine janitorial or other facility grounds maintenance activities that may use NPRI substances which would be contained in cleaners, fertilizers or pesticides are exempt. Process equipment maintenance using materials such as grease, oils or lubricants, disinfectants or paint, etc., is not exempt and must be considered for the purposes of NPRI reporting.

48. Our process uses metal grinding wheels which suffer regular abrasion. Would NPRI substances in these wheels be reportable?

Yes. Items such as grinding wheels are, by their nature and use, intended to wear down and release substances. They are designed to be replaced and are subject to reporting.

49. Are degreasers used in a plant's maintenance shop reportable?

Yes. Degreasing of equipment for maintenance is not considered routine maintenance and is not exempt. It would be reported as "otherwise used".

50. Is our quality control laboratory exempt from reporting under the research and testing exemption?

Yes, assuming that the laboratory does not perform pilot-plant scale studies or specialty chemical production.

51. Are photo development laboratories exempt?

No. The laboratory exemption includes research facilities which perform auxiliary functions to the manufacturing or processing activities of a facility. Photo development laboratories do not perform auxiliary functions but perform activities which are essential to the development of their products (photographs, films, etc.).

52. We buy more than 10 tonnes of chlorine gas and use it in a reaction vessel to produce more than 10 tonnes of chlorine dioxide. We then dilute the chlorine dioxide to less than 1% concentration. What do we have to report?

Because you meet the reporting threshold for chlorine gas, you are required to report any releases and transfers of chlorine gas. Because you manufacture chlorine dioxide at a concentration greater than 1%, you are required to report any releases and transfers of chlorine dioxide. The subsequent dilution of the chlorine dioxide does not affect the threshold calculation.

53. How do we treat a solvent sent off site for distillation and then shipped back to us?

A solvent received from a recycling operation located off-site counts as new material and must be included in the threshold calculation. The quantity sent off site for distillation must be reported as material sent for recycling.

54. We use a paint thinner that contains toluene. We also use toluene in another part of our plant. In total, more than 10 tonnes of toluene are used annually. The waste thinner is sent to an off-site facility for blending in fuels. How do we report this activity?

NPRI substances sent off site for fuel blending or that add energy to a heat recovery activity must be reported as a transfer for energy recovery. Other releases or transfers of toluene must also be reported.

55. Are NPRI substances used in maintenance activities, such as paint booth cleaning, reportable?

Paint booth cleaning is not considered a routine janitorial activity and would be reportable under the classification "other use".

56. How does the NPRI definition of a facility apply to a multi-plant site?

"Facility" is defined in the Canada Gazette notice. It includes all buildings or structures located on a single site or on adjacent sites which are owned or operated by the same person and function as a single integrated site.

Plants must report separately if they manufacture or process unrelated products and if they do not share common manufacturing or processing operations. For example, a battery plant and a vehicle-assembly plant, located side-by-side, are two distinct manufacturing operations that have different SIC codes. In the case of the battery plant, it also ships products to other installations. Other examples are smelters and fertilizer plants, a refinery and a chemical plant.

57. Is reporting to the NPRI mandatory under the Canadian Environmental Protection Act (CEPA)? If so, how will it be enforced?

It is the responsibility of each person who owns or operates a facility to determine whether they are required to report after examining the Canada Gazette notice and the CEPA. There is an enforcement and compliance policy under the CEPA which dictates how regulations and notices are enforced.

58. A facility that previously reported to the NPRI has been split up and is now owned and operated by two separate companies. How should they report to the NPRI?

If the companies are owned by the same parent company AND function as a single integrated facility, they must report as one facility. If they do not meet both of these conditions, they must perform separate threshold calculations and report separately.

59. Are substances regulated under other legislation (e.g., Pest Control Products Act) exempt from reporting under the NPRI?

There is no exemption for substances regulated under other legislation.

60. Is a solid waste landfill required to report to the NPRI?

Solid waste landfills process NPRI substances and if the facility meets the other threshold criteria, it is required to report.

Additionally, landfills can generate, as a consequence of their process, by-products such as ammonia in their leachate.