Environmental Reporting

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.

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:

1. Adipic acid manufacturing.
2. Primary manufacturing of aluminum.
3. Ammonia manufacturing.
4. Carbonate use.
5. Cement manufacturing.
6. Coal storage.
7. Copper production.
8. Electricity generation and cogeneration
9. Ferroalloy production.
10. General stationary combustion.
11. Glass production.
12. HCFC-22 production and HFC-23 destruction.
13. Hydrogen production.
14. Iron manufacturing.
15. Lead production.
16. Lime manufacturing.
17. Nickel production.
18. Nitric acid manufacturing.
19. Petrochemical production.
20. Petroleum refining.
21. Phosphoric acid production.
22. Pulp and paper manufacturing.
23. Refinery fuel gas use within a petroleum refinery.
24. Soda ash manufacturing.
25. Steel manufacturing.
26. 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.

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.