highlights of the proposed metal finishers industry standard & registration process november 18,...
TRANSCRIPT
Highlights of the Proposed Metal Finishers Industry Standard &
Registration Process
November 18, 2015Canadian Association for Surface Finishing
CASF Environmental Forum 2015Vaughan, Ontario
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Purpose of Presentation
To provide an overview of:
• Ontario’s Local Air Quality Regulation
• Technical Standards Compliance Approach
• Highlights of the Proposed Metal Finishing Industry Standard
• Overview of Technical Standard Registration Process
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Local Air Quality Regulation
•Ontario’s Local Air Quality Regulation (O. Reg. 419/05: Air Pollution – Local Air Quality) works within the province’s air management framework by regulating air contaminants released into communities by various sources including local industrial and commercial facilities.
•Our goal is to limit exposure to substances released into air that can affect human health and the environment, while allowing industry to operate responsibly under a set of rules that are publicly transparent.
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Local Air Quality Regulation Compliance Pathways
Demonstrate compliance with the air standards by the phase-in period.
(Assessed using approved air dispersion models or through modelling and monitoring.)
Request a site-specific standard.
(Available to facilities affected by new or updated requirements. Assessed using approved air dispersion models or through modelling and monitoring.)
Register under a technical standard for specified contaminants.
(Provided the MOE has developed a technical standard that applies to the sector and those contaminants.)
There are three compliance approaches for industry to continuously improve their environmental performance over time:
OR OR
Technical Standard Compliance Approach
• Technology-based solution designed for two or more facilities in a sector that will not be able to meet an air standard due to technical or economic limitations.
• Can include technology, operating, monitoring and reporting requirements.
• Development includes a better understanding of specific sources of contaminants for that sector, benchmarking technology to address the sources of contaminants and consideration of economic issues that related to the sector.
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Technical Standard Compliance Approach
Industry Standards Address all sources of specified
contaminants from a specific sector.
Equipment Standards Address one source of contaminant(s), but
may apply to one or multiple sectors.
• Any facility in the sector (that may or may not meet the air standard) may request to be registered under the technical standard (once established).
• Goal is to have a more efficient tool to better manage air emissions and reduce overall exposure from various industrial and commercial facilities in a sector.
• There are two types of technical standards:
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Technical Standard – Overview of Process
1. Identify need for technical standard
2. Consult on proposed technical standard/ rationale
3. Minister publishes Technical Standard
4. Industry Submits Request to Register
5. Request posted on Environ-mental Registry for public comment
6. Ministry Technical Review. Post on Environ-mental Registry
Ministry may require industry to hosta public meeting
7. Update Technical Standards Registry
History
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Metal Finishing Technical Working Group
technical working group established
representation from industry, consulting, suppliers, Environment Canada, Ontario Ministry of the Environment and Climate Change
terms of reference developed
regular meetings since 2011
Background Information Assembled
site visits conducted
sector overview
facility profiles
process profiles
identify applicable contaminants
jurisdictional review
dominant source analysis
rationale report development
Technology Benchmarking
identify sources that need to be better controlled, monitored or managed.
identify pollution control options
assess technical feasibility
conduct GAP analysis
assess cost effectiveness
Finalize Technical Standard
Draft legal wording for proposed technical standard
Post proposal on Environmental Registry
Finalize technical standard and rationale document
Post decision on Environmental Registry
We are here
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Dominant Sources
Hexavalent Chromium- Plating tanks- Anodizing- Reverse Etching- General Exhaust
Ventilation- Atmospheric
evaporators
Nickel- Plating tanks- General Exhaust
Ventilation
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Contaminants• Chromium Compounds (Hexavalent), CAS#7440-47-3• Nickel and Nickel Compounds, CAS#7440-02-0
NAICS• 332810 Coating, engraving, cold and heat treating and allied
activities• coating, engraving, heat treating and similarly processing metal or plastics.• examples include tempering, brazing, plating (includingelectroplating and re-chroming), polishing, sand-blasting andcolouring metal and metal products.(Hexavalent), CAS#7440-47-3• Nickel and Nickel Compounds, CAS#7440-02-0
Proposed Technical Standard - Scope
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Proposed Structure
Part I: General Requirements• Definitions• Application
Part II: Technology Specifications• Technology requirements for
dominant sources
Part III: Operational Practices• Operating Parameter Summary
Table• Monitoring• Inspections and Maintenance• No Backsliding• Deviations
Part IV: Reporting and Recordkeeping• Complaint Procedure • Notifications• Summary Reports• Records
Highlights of Proposed Technology Specifications
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Chromium Compounds (hexavalent forms) (Section 3 (1))• Existing sources
• Fume suppressants;• Local exhaust ventilation and air pollution control device; or• Tank covers
• New facilities or sources resulting in facility expansion (Section 3(2))• More stringent air pollution control devices
Nickel and nickel compounds (Section 5)• Existing sources of bright and semi-bright nickel plating
• Wetting agents; or• Local exhaust ventilation and air pollution control device
• New facilities or sources resulting in facility expansion (Section 6)
• More stringent air pollution control devices
Highlights of Proposed Operations and Monitoring
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Operating Parameter Summary Table includes items like (Section 8):• Type of air pollution control device (e.g. composite mesh pad scrubber)• Source of contaminant (e.g. decorative chromium electroplating)• Relevant operating parameters (e.g. pressure differential etc.)• Normal operating range (e.g. 2-5 inches water)• Frequency of monitoring (e.g. daily)• If applicable, notification range (e.g. pressure differential too low or too high 3 days out
of 7)
Operating parameters require monitoring as indicators of performance for key pieces of equipment or sources. Some operating ranges are specified in Technical Standard and some allow for facility to determine the appropriate operating range consistent with professional’s recommendations.
Highlights of Proposed Inspections and Maintenance
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Inspection and Maintenance Table includes items like (Section 14):• Piece of equipment (e.g. air pollution control
device)• Key inspection or maintenance activity • Frequency
Inspections and maintenance are required for key pieces of equipment or sources to help ensure their continuing proper operation. Some are specified in Technical Standard and some allow for facility to determine the appropriate frequency consistent with professional’s recommendations.
Highlights of Proposed Deviations
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• Deviations from normal operating ranges are recorded (Section 12)• Time, date and duration• Operating parameter, normal operating range,
monitored value, • Monitoring device• Suspected cause• Operational adjustment taken and dates
completed and names of personnel that did adjustment
• Similarly, deviations from the frequency of inspections and maintenance activities are also recorded.
Highlights of Proposed Ventilation Program
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Requirements for a ventilation program (Sections 18-22):• Ventilation coordinator• Ventilation system descriptions, specifications
and drawings• Table of in and out flows• Assessing changes to ventilation systems and
new ventilation systems for potential impact on the effectiveness of the ventilation systems with some exceptions
• Ventilation assessment reports• Maintaining negative pressure in certain areas
Highlights of Proposed Multi-Tenant
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It was proposed that metal finishing facilities located in multi-tenant buildings have additional requirements (Section 23):• Request access to conduct annual inspections of air make-up
unit filters of non-metal finishing tenants.• Conduct annual inspections of air make-up unit filters and if
dirty or damaged to clean or replace them.• And if damaged to inspect connected air ducts for possible
soiling or damage and if so to clean or repair.
CASF submitted a recommendation allowing options to either:• Use both a fume suppressant and an air pollution control
device with local exhaust ventilation or• Provide air make up filters for all air make up units on the
building.
Highlights of Proposed No Backsliding
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• Similar to the pulp and paper industry standard the concept of no backsliding has been proposed in metal finishers (Section 24)
• Also referred to as the Requirement to Continue, it requires a facility to record a list of the sources, ventilation systems and methods that are related to the registered contaminants.
• The facility can’t operate the source unless the method used to prevent, minimize or reduce the discharge of the registered contaminant is at least as effective as what is listed in the table.
• Similarly, the facility can’t operate the source unless the ventilation system used to capture the discharge of the registered contaminant is at least as effective as what is listed in the table.
• There are some exceptions.
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Highlights of Proposed Reporting
• All registered facilities are required to document onsite summary reports of information including (Section 27):• Implementation Summary Table • Operating Parameter Summary Table• Deviation Summary Table (i.e. operating outside acceptable
range)• Complaint Summary Table• Performance Summary Table
• In general, reports must be updated annually, by March 31st• Highest ranking employee certifies in writing that reports
have been received and are accurate to the best of their knowledge.
• These reports were specifically developed to assist both the facility and the Ministry to better understand their compliance requirements and to drive continual improvement.
• The Implementation Summary Table and the Performance Summary Table must be made available to the public upon request.
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• A specific facility may choose to comply with either the air standard, a site-specific standard or technical standard (if available).
• If a facility chooses the technical standard compliance approach (once it is available), it involves the following:
• Each facility who requests registration under a technical standard must have its request posted on the Environmental Registry for a minimum 45 day comment period.
• In some situations, similar to the site-specific standard process, a facility may be required to do further notification and consultation with affected stakeholders as part of the registration process for a Technical Standard.
• In addition, the Ministry must publish on its website the “Technical Standards Registry – Air Pollution” that lists all registered facilities.
Overview of Technical Standard Registration
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ESDM Reports andTechnical Standard Registration
• If registered to a sufficient number of industry and/or equipment standards to address all sources of that contaminant at that facility:
• registering for and complying with technical standard(s) is an alternative to meeting the air standards for the relevant contaminants
• no ESDM report is required for the relevant contaminants
• If registered for industry and/or equipment standards in respect of a facility and a contaminant, but all sources of the contaminant at the facility are not addressed by these technical standard(s):
• may only exclude the sources of contaminant(s) that are associated with the NAICS code addressed in the technical standard(s)
• an ESDM report would be required for the remaining sources
• Note: The Director may give notice requiring an ESDM report even if the facility is registered.
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Next Steps
• Consideration of comments submitted on the posting of the proposed Metal Finishers – Industry Standard on the Environmental Registry (#012-3610).
• Finalization of the technical standard and rationale report.
• Once a decision has been made, the publication “Technical Standards to Manage Air Pollution” would be updated – anticipated spring 2016.
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Contact Information
Kelly Miki, P.Eng.Air Pollution Control EngineerLocal Air Quality SectionStandards Development BranchOntario Ministry of the Environment40 St. Clair Avenue West, 9th Floor,Toronto, Ontario, Canada M4V 1M2Tel: (416) 327-6292Fax: (416) 327-2936Email: [email protected]
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Questions?
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Appendix - New/Updated Air Standards
Substance Schedule 3 Schedule 2
µg/m3 µg/m3
Benzene 0.45 annual 7 1/2 hr
1,3-Butadiene 2 annual 30 1/2 hr
Chromium and Chromium Compounds:Chromium (0,II,III):
Chromium (VI)
0.5
0.00014
24-hr annual
1.5
0.0021
1/2 hr1/2 hr
Dioxins, Furans and Dioxin-like PCBs 0.0000001 24-hr 0.0000003 1/2 hr
Manganese & Manganese Compounds 0.4 24-hr 1.2 1/2 hr
Nickel and Nickel Compounds 0.04 annual 0.6 1/2 hr
Benzo-a-pyrene (as a surrogate for PAHs) 0.00001 annual 0.00015 1/2 hr
Uranium and Uranium Compounds (PM10 fraction) 0.03 annual 0.45 1/2 hr
Air Standards - effective July 1, 2016
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Appendix - New Upper Risk Thresholds
Along with decisions on the air standards, the ministry posted decisions for the corresponding upper risk thresholds (URTs)
URTs:• represent an upper boundary of risk to be managed • signal the need for emissions reduction to reduce risks to local communities • do not have a phase-in period • if the URT is more stringent than a current standard or guideline, it is used for
assessment during the phase-in period of the air standard • do not replace air standards• are referenced in section 30 of O. Reg. 419/05 (notification and ESDM report).• are used in the site-specific standards process and can now be assessed for
frequency of exceedences• continue to be based on a 24 hour average even if the standard in Schedule 3 is
annual
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Appendix - New Upper Risk Thresholds
Substance Schedule 6 (URT) Schedule 6 (URT)
µg/m3 µg/m3
Benzene 100 24-hr 300 1/2-hr
1,3-Butadiene 300 24-hr 900 1/2-hr
Chromium and Chromium CompoundsChromium (0,II,III):
Chromium (VI)
5
0.07
24-hr24-hr
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0.21
1/2-hr1/2-hr
Dioxins, Furans and Dioxin-like PCBs 0.000001 24-hr 0.000003 1/2-hr
Manganese & Manganese Compounds 4 24-hr 12 1/2-hr
Nickel and Nickel Compounds 2 24-hr 6 1/2-hr
Benzo-a-pyrene 0.005 24-hr 0.015 1/2-hr
Uranium and Uranium Compounds (PM10 fraction) 1.5 24-hr 4.5 1/2-hr
URTs - effective July 29, 2011
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Appendix - Technical Standards
There are currently three technical standards:
• Forest Products Industry Standard (2009)
• Foundries Industry Standard (2009 and Proposed Amendment)
The legal requirements are set out in:Technical Standards to Manage Air Pollutionhttp://www.ontario.ca/document/technical-standards-manage-air-pollution
• Contaminants: suspended particulate matter (including many specified metal contaminants), volatile organic compounds (including many specified contaminants), and sulphur dioxide
• Contaminant: acrolein
• Pulp and Paper Industry Standard (2014)• NAICS code 3221 (Pulp, paper and paperboard mills)• Contaminants: suspended particulate matter (including
many specified metal contaminants), volatile organic compounds (including many specified contaminants), and sulphur dioxide