Depending on the nature of operations at your facility, you could be required to submit multiple environmental reports to 3 different levels of government (municipal, provincial, and federal). While we cannot make government over-reporting more in sync, we can certainly make it more efficient.
Too busy? Not a problem, we can handle the submission for you.
IS YOUR COMPANY SUBJECT TO ANY OF THESE?
- National Pollution Releases Inventory (NPRI)
- Toxics Reduction Act (TRA)
- Greenhouse Gas Reporting (Federal and/or Provincial O.Reg 452/09)
- National Emissions Reduction Masterplan (NERM)
- Environmental Protection and Enhancement Act (EPEA)
- O.Reg 127
- Chemicals Management Plan (CMP)
- Wastewater Systems Effluent Regulations (WSER)
- Environmental Emergencies (E2)
National Pollutant Release Inventory (NPRI)
The National Pollutant Release Inventory (NPRI) is Canada’s legislated and publicly accessible inventory of pollutant releases that includes releases to air, water and land, as well as disposals and transfers for recycling. Each year, the owner or operators of facilities are required to assess whether or not they met the reporting limits for one or more of the 330 NPRI substances. This requires looking at all products, chemicals, and materials found or manufactured onsite that maybe released, disposed, or recycled. The NPRI substance list is broken down into 5 Parts:
- List of 233 substances and groups of substances (General list)
- List of 30 Polyaromatic Hydrocarbons (PAHs)
- 17 Congeners of dioxins and furans, and hexachlorobenzene
- 7 Criteria Air Contaminants (CACs)
- 75 Selected Volatile Organic Compounds (VOCs)
As part of the NPRI assessment, facilities are to determine which, if any, of the reportable substances meet the MPO (Manufactured, Produced, or Otherwise Used) criteria. This requires tracking material purchasing information, production rates, equipment operating times, disposal and recycling records, etc. To complete an NPRI report, an emissions model of the facility is created in a similar fashion to an Environmental Compliance Approval. One important note of distinction is that Environmental Compliance Approvals are based on worst-case scenario estimates, while NPRI assessments are based on actual operations. NPRI reports are due June 1st annually, and get submitted through Environment Canada’s Single Window Information Manager (SWIM).
The National Pollutant Release Inventory is a dynamic regulation, and each year Environment Canada publishes a notice in the Canada Gazette if there are changes to the substantial list and to the substance reporting thresholds. For the past couple of years in environmental reporting, we have seen more substances added, and the reporting thresholds decrease.
Toxics Reduction Act
Ontario’s Toxics Reduction Act (TRA) was introduced in 2010, and targets Ontario’s manufacturing and mining industries. It is comprised of two components: Reporting and Planning. The substance list for the TRA is identical to the NPRI plus acetone from O. Reg 127/01, and Ontario facilities which report to the NPRI and/or O.Reg 127/01 will be subject to the Toxics Reduction Act. The reporting aspect expands on the information collected for the NPRI report to quantify not only the releases from the facility, but also the amount of a substance that is used, created, or contained in a product. Essentially, it completes the mass balance around the facility by having the inputs, outputs, and releases now collected annually. The Planning aspect is much more substantial, and one report is required for each substance that is on the list. Plans contain detailed information on how facilities use a particular substance, and require that they undergo a use reduction analysis that looks at the technical and economic feasibility of other alternatives. Along with detailed process level quantifications and flow diagrams, the Toxics Reduction Plans must also be certified by the highest ranking employee at the facility, as well as Ministry of Environment & Climate Change licensed Toxic Substances Reduction Planner (TSRP). Plans are valid for a period of 5 years, or until 2018 when all previously prepared TRA plans must undergo a required review and recertification process. Like the National Pollutant Release Inventory, summaries of the Toxics Reduction Act get submitted to the government via SWIM. In additional to the conventional government disclosure obligations, both the reports and plans are required to be disclosed to the public by hosting summary documents online.
Greenhouse Gas Reporting (Federal and/or Provincial O.Reg 452/09)
There are several Greenhouse Has (GHG) regulations in Canada. Rubidium provides services to assist with the Federal GHG and Ontario GHG O.Reg 452/09 programs.
- Carbon dioxide
- Nitrous dioxide
- Sulfur hexafluoride
- 13 Hydrofluorocarbons (HFCs)
- 7 Perfluorocarbons (PFCs)
Ontario’s Greenhouse Gas (GHG) regulation, O. Reg 452/09, was establish in 2009 as a precursor establishing a Cap & Trade economy in Ontario. Facilities that emitted more than 25,000 tonnes of CO2e annually, and are emitted from one of the 26 sources listed in the regulation are required to report this. The regulation is broken two into 2 parts: Quantification and Verification.
The quantification process is similar to building an emissions inventory for the facility, however, strict adherence to the MOECC’s calculation protocols are required. Reports are due annually in June and each report must be verified by an accredited third party that it meets the ISO 14064-3 standards. The verification must be in agreement with the measurements or calculations within 5% for the report to be successfully verified. Submission of verification statements is required prior to September 1st annually. Both the quantifications and verification statements are submitted through the SWIM portal.
The 26 sources that are applicable to O. Reg 452/09 are:
- Adipic acid manufacturing.
- Primary manufacturing of aluminum.
- Ammonia manufacturing.
- Carbonate use.
- Cement manufacturing.
- Coal storage.
- Copper production.
- Electricity generation and cogeneration
- Ferroalloy production.
- General stationary combustion.
- Glass production.
- HCFC-22 production and HFC-23 destruction.
- Hydrogen production.
- Iron manufacturing.
- Lead production.
- Lime manufacturing.
- Nickel production.
- Nitric acid manufacturing.
- Petrochemical production.
- Petroleum refining.
- Phosphoric acid production.
- Pulp and paper manufacturing.
- Refinery fuel gas use within a petroleum refinery.
- Soda ash manufacturing.
- Steel manufacturing.
- Zinc production
ChemTRAC is a Toronto Public Health program designed to collect information from local businesses and institutions that use one or more of the 25 priority substances. ChemTRAC is in many ways similar to the National Pollutant Release Inventory, except with substantially lower thresholds. This regulation was designed to capture additional information that is not available through the NPRI report, and enhance the ‘Right to Know’ disclosure in the community.
Each year, facilities are required to assess their annual emissions to determine if they are subject to the reporting obligations of the regulation. Reports are due into the City of Toronto by June 30 each year.
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