Local air quality in Ontario is regulated by O. Reg 419/05 (Air Pollution – Local Air Quality). Simply put, this regulation defines the limits for contaminants that are discharged to air, and gives facilities three options for achieving environmental compliance approval. The first one is straightforward: be under the specified limits. In general, most facilities can achieve this naturally or with implementation of pollution control systems. But what if you can’t? What if there are no technically feasible solutions, or at least one that is economically feasible? The Ministry of Environment and Climate Change (MOECC) provides two additional options:
- Request and meet a site-specific standard or
- Registered for a sector-based technical standard (if it exists) and meet its requirements.
So what does all this have to do with changes to Ontario’s Air Quality Regulation? Facilities in Ontario – whether Industrial, Commercial, or Institutional – are required to have an Environmental Compliance Approval (ECA), which is essentially a permit issued by the MOECC to discharge contaminants into the environment. With changes to the Air Quality Regulation coming into effect in July 2016, we are already seeing environmental compliance challenges for many that already have, or need approvals.
So what’s changing?
ContaminantWhich industries are impacted?
|Benzene||Plastics, Steel, Oil & Gas, Cement, Wood Combustion, Speciality Chemicals|
|Benzo(a)pyrene||Steel, Speciality Chemical, Oil & Gas, Wood Combustion|
|Butadiene, 1,3||Rubber, Plastics|
|Hexavalent Chromium||Chrome Plating, Waste Incineration, Refractories, Pigment Manufacturing|
|Chromium and Chromium Compounds||Metal Product Manufacturing, Electro-Plating, Automotive, Furniture Manufacturing, Aerospace, Steel Making, Pigment Manufacturing, Plastics Compounding, Welding, Mining|
|Dioxins, Furans and Dioxin-like PCBs||Waste Incineration, Wood Combustion, Steel Making, Aluminum Smelting/Alloying, Power Generation, Cement|
|Manganese and Manganese Compounds||Metal Product Manufacturing, Automotive, Furniture Manufacturing, Aerospace, Steel Making, Pigment Manufacturing, Plastics Compounding, Welding, Mining|
|Nickel and Nickel Compounds||Metal Product Manufacturing, Automotive, Furniture Manufacturing, Aerospace, Steel Making, Pigment Manufacturing, Plastics Compounding, Welding, Mining, Electro-Plating|
|Uranium and Uranium Compounds (in PM under 10 microns)||Uranium Upgrading, Nuclear Industry|
As you can see, these changes cast a pretty broad stroke. Some are causing challenges in places you would least expect it. For instance, many Mining and Steel Producing companies are currently faced with a compliance challenge for metal emissions. And it’s mainly not because of production at the facilities but rather road dust. Road dust can be problematic from an emissions modeling perspective because it is emitted at ground level. If you think of emissions being discharged from an exhaust stack, it has ample time, and lots of volume of air to dilute with. However, road dust does not disperse as greatly and from our air quality modeling, we are modeling emissions as they impact the property line.
This is a concerning challenge for industries as there are limits to what can be achieved in terms of road dust management.
With the new limits for hex chrome, the chrome plating industry is going to start having to look at pollution control equipment, or other pollution prevention activities such as surface tension monitoring. One thing we’ve noticed is that many facilities are conservatively over reporting hex chrome using old or incorrect data. It’s best to get the suppliers involved as there might be opportunities to reduce off property impacts by simply using more accurate data.
So what should you be doing?
If your facility is in any one of the potentially impacted sectors, you should look at your facility’s Emissions Summary and Dispersion Model (ESDM). If you emitted one or more of the substances with changing air quality standards, then you should consider doing a risk assessment to see what impact the new air quality standards will have and where your company will stand with environmental compliance.