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A CITIZENS’ GUIDE TO
AIRBORNE CONTAMINANT REPORTING IN ONTARIO

IN SUPPORT OF

ONTARIO REGULATION 127/01
(AIRBORNE CONTAMINANT DISCHARGE - MONITORING AND REPORTING)

November 2002

Table of Contents

• Part 1: The Citizens’ Guide
• Part 2: The Development of Airborne Contaminant Reporting
  · Why Airborne Contaminant Reporting?
  · The Development of the Current Reporting System
• Part 3: Understanding Airborne Contaminant Reporting 5
  · Who must report?
  · What substances must be reported?
  · What information must the reporter provide?
  · When must the reports be provided?
  · How can the public gain access to the reports?
• Part 4: Canada’s National Pollutant Release Inventory (NPRI) and Ontario Regulation 127/01 (O. Reg. 127/01)
• Part 5: Conclusion
• Glossary and Appendices

Glossary
Appendix 1: Source Sectors for Airborne Contaminant Discharge Reporting
Appendix 2: Airborne Contaminants with MOE Release Based Thresholds
Appendix 3: Airborne Contaminants with MOE Graded Manufactured, Produced or Otherwise Used (MPO) Thresholds
Notes to Appendices 2 and 3
Annex 1 to Appendix 2 (Definition of Volatile Organic Compounds)
Annex 1 to Appendix 3 (Contaminants Listed under Glycol Ethers)
Annex 2 to Appendix 3 (The Three Mineral Spirits Groups)
Appendix 4: Contact

PART 1: THE CITIZENS’ GUIDE

The Ontario government requires the owners and operators of approximately 5,000 facilities across the province in the industrial, commercial, institutional and municipal sectors to report on over 350 contaminants that they release to the air. As well as reporting this information to the provincial government, these facilities are required to make their reports available to any member of the public. The reporting organization (facility) is responsible for the validity and quality of its reported data.

The purpose of the Citizens’ Guide is to help members of the public understand the air contaminants reporting system and to indicate how they can gain access to the information. The Guide describes who is required to report, what substances are reported, when the information must be reported, what is done with the reports and how the public can gain access to the reports.

This Citizens’ Guide is for those who wish to gain access to and use the data that are reported. It is not a guide for those who do the reporting. The latter purpose is fulfilled by the provincial government’s Step by Step Guideline for Emission Calculation, Record Keeping and Reporting for Airborne Contaminant Discharge; available at www.ene.gov.on.ca/envision/monitoring/monitoring.htm.

The information in Guide reflects Ontario’s current reporting system, and addenda and revisions will be made as required.

PART 2: THE DEVELOPMENT OF AIRBORNE CONTAMINANT REPORTING IN ONTARIO

Why Airborne Contaminant Reporting?
Ontario’s reporting system is to ensure that Ontario’s residents have access to information on contaminants being released to the air in their communities.

An informed public will be better positioned to encourage companies and governments to take the actions needed to clean up Ontario’s air. The information will also put the public in a better position to be able to make informed decisions in their personal lives that will result in cleaner air. For example, increased awareness of the pollutants released through power generation could stimulate the public to reduce their use of energy by adopting better conservation practices.

The Development of the Current Reporting System
Ontario has been monitoring and reporting on air quality throughout the province since the 1970s. However, information on the sources of the contaminants affecting air quality has been limited. But this information is essential for Ontario to make the proper decisions to improve air quality.

Therefore, in January 2000, the Ontario government announced plans to pass regulations requiring the owners and operators of certain types of facilities to report their air releases to the provincial government and to the public.

The first step in this strategy was the passing of Ontario Regulation 227/00 (O. Reg. 227/00), which required the electricity sector to report its emissions of 28 specified air pollutants provided their emissions met or exceeded the thresholds defined in the regulation. This regulation came into effect on May 1, 2000.

The second step was the passing of O. Reg. 127/01, which extended the monitoring and reporting requirements beyond the electricity sector to a wide range of industrial, commercial, institutional and municipal sectors. It also increased the number of substances for which reporting is mandatory to over 350 pollutants. This regulation came into effect for the larger source sectors on May 1, 2001 and for facilities belonging to smaller source sectors on January 1, 2002. O. Reg. 127/01 includes the provisions of O. Reg. 227/00 within it and as a result, replaces that regulation.

PART 3: UNDERSTANDING AIRBORNE CONTAMINANT REPORTING

In this part of the Citizens’ Guide, the following questions will be answered:

• Who must report?
• What substances must be reported?
• What information must the reporter provide?
• When must the reports be provided?
• How can the public gain access to the reports?

Who must report?
The owners and operators of all specified Ontario facilities are required to assess whether they meet certain reporting criteria. If they meet these criteria, they are required to report their airborne contaminant emissions.

Failure to follow the requirements of the Airborne Contaminant Discharge Monitoring and Reporting Regulation (O. Reg. 127/01) can result in prosecution under Ontario’s Environmental Protection Act.

Types of facilities:
Three classes of facilities are specified under O. Reg. 127/01:

• Class A: Electricity Generation;
• Class B: Sectors that contain large sources; and,
• Class C: Sectors that contain small sources.

The detailed list of these facilities is in Appendix 1. If a facility that you are interested in is not one of the types listed in Appendix 1, the owner or operator of that facility is not required by O. Reg. 127/01 to provide you with their airborne release data.

Class A facilities were required to begin monitoring 28 airborne pollutants after May 1, 2000 (O. Reg. 227/00). Class A and B facilities were required to begin monitoring releases of over 350 pollutants after May 1, 2001 (O. Reg. 127/01). Class C facilities were required to begin monitoring their releases after January 1, 2002 (O. Reg. 127/01).

As of January 2002, there is no difference in the monitoring requirements for Class A, B or C facilities. The only reason you would need to distinguish between these classes is if you want to know whether a facility has to provide you with data for its releases before January 2002.

If a facility listed in Appendix 1 does not meet the reporting criteria, it will be exempted from reporting. Figure 1 summarizes the process that an owner or operator of a facility in Appendix 1 goes through to decide whether it is required to report.

Figure 1: Quick Reference for Reporting

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* For Class A facilities, this regulation does not apply to a generation facility that has a generating capacity of 1MW or less, or that sells 10 percent or less of its total electricity generated to the Independent Market Operator administered markets.

** If the facility belongs to Class C, the gathering of emissions data will begin January 1st, 2002.

*** The NPRI contaminants are listed at website: http://www.ec.gc.ca/pdb/npri

What substances must facilities report?
Ontario has three lists of substances that facilities may have to report on, provided they meet certain criteria: National Pollutant Release Inventory (NPRI) substances, criteria air pollutants and greenhouse gases, and air toxics. These substances were chosen to address a broad range of air issues.

NPRI substances: Provided they meet the reporting criteria, Ontario facilities listed in Appendix 1 must submit a copy of the air releases data from their NPRI report to the Ontario government. As of the 2001-reporting year, the NPRI air pollutant list was made up of 265 substances, which may be obtained through Environment Canada’s NPRI website at http://www.ec.gv.ca/pdb/npri.

Criteria air contaminants and greenhouse gases: Ontario requires facilities to report on the following criteria air contaminants and greenhouse gases: oxides of nitrogen (NO_x), airborne particulate matter (PM), sulphur dioxide (SO₂), volatile organic compounds (VOCs), carbon dioxide (CO₂), carbon monoxide (CO), hydrofluorocarbon-134A (HFC-134A), methane (CH₄) and nitrous oxide (N₂O).

If a facility meets at least one of the following criteria, it will be required to determine its airborne contaminant releases each year for the specified criteria air contaminants and greenhouse gases.

• The facility can reasonably be expected to use coal, refuse, wood or waste oil as a fuel at any time during the year.
• The facility can reasonably be expected to have, at any time during the year, a name plate (rated) capacity of greater than 3 million British thermal units (BTUs) per hour.
• The facility can reasonably be expected to use 3,000 kilograms (kg) or more of solvents during the year.
• The facility can reasonably be expected to use 3,000 kg or more of coating materials during the year.
• The facility can reasonably be expected to use 3,000 kg or more of printing ink during the year.
• The facility can reasonably be expected to use 5,000 kg or more of welding rods or welding wires during the year.

Once the facility has made its air emission calculations, it will have to submit a report detailing these releases, if the individual amount released during the year is equal to or greater than the respective threshold set by the province. Appendix 2a lists the reporting thresholds for each of the criteria air contaminants and greenhouse gases.

For example, a facility does not have to report the quantity of carbon dioxide if it released less than 100 million kg (i.e., 100,000 tonnes) during the year; by contrast, a facility has to report the quantity if it has released at least 10 kg (i.e., 0.01 tonnes) of HFC-134A.

The reporting thresholds have been set with the objective of capturing 90% of the releases of criteria air contaminants and greenhouse gases from all the facilities listed in Appendix 1.

For individual reporting facilities, the Step-By-Step Guideline specifies a due diligence provision that states:

For the purpose of reporting under this regulation, it is intended that for any given contaminant whose emissions are equal to or greater than its respective reporting threshold, at least 95% of the facility’s total emissions are to be accounted for.

Even if the quantities of criteria air contaminants and greenhouse gases released during the year were below the threshold, the facility must submit a report that says these emissions were below the threshold, but it does not have to specify the quantity released.

Air Toxics: Ontario requires reporting on 76 air toxics (Appendix 2b). Some of these air toxics are not on the NPRI list whereas others on the NPRI list have been put on Ontario’s air toxic list for one or both of the following reasons:

• the substance is more precisely defined in the Ontario case.
• the NPRI reporting threshold is less stringent than Ontario’s. For example, for all of the 76 air toxics, Ontario requires reporting below the NPRI’s threshold of 10,000 kilograms manufactured, processed or otherwise used (MPO) during the year. For 35 of these substances, Ontario has a threshold of 3,000 kg MPO during the year; for another 35 substances, the threshold is 500 kg per year. For the remaining six substances, the thresholds are either 5 kg each year or 0.0001 kg each year.

A facility listed in Appendix 1 has to calculate and report its releases of these 76 air toxics if it meets both of the following criteria:

• the facility can reasonably be expected to employ or engage persons who work a cumulative total of 20,000 hours or more during the year.
• the contaminant can reasonably be expected to be MPO at the facility during the year in an amount equal to or greater than the threshold amount for the contaminant listed in Appendix 2b.

Ontario has set these reporting criteria at a level that it expects will result in reporting on at least 80% of the total air toxics released from all the facilities listed in Appendix 1. As stated earlier, for individual reporting facilities, the Step-By-Step Guideline says that 95% of the facility’s total emissions should be accounted for.

Two cautions:
The users of these data should exercise caution in aggregating reported contaminant emissions in order to avoid misinterpretations.

Caution 1 — Avoid Double Counting: The list of over 350 pollutants listed in O. Reg. 127/01 includes both individual pollutants (e.g., toluene) and contaminant groups and compounds (e.g., VOCs). Therefore toluene should not be summed with total VOCs because the total VOCs value should already include toluene.

Caution 2 — Consider Differing Impacts: Since not all substances have the same effects on the environment and on human health, it is not appropriate to sum up all the emissions to generate a single value to indicate the magnitude of the effect on the environment or human health.

Simply adding up all the reports from a facility to get a total release may also result in double counting. In addition, year-to-year comparisons of releases at a facility or comparisons among facilities of total releases usually do not result in a good basis for making decisions about environmental and health impacts or the relative significance of releases.

Therefore when you make comparisons, you should first decide what kinds of environmental or health effects you want to focus on.

What information must the reporter provide?
The reporter must include information about the location of the facility, and the name and address of the organization that owns the facility. The reporter must also include contact information about the person who prepared the report.

Reporters for facilities in the electricity sector must also describe:

• the design capacity of the facility;
• the type of energy source; e.g., fossil fuel, hydro-electric, geothermal, nuclear, solar or wind;
• the fuel type used; e.g., the kind of coal or gas; and
• the amount of electricity generated at the facility each year and during the smog season (from May 1 to September 30).

Reporting is done on a facility-wide basis for each substance. For each substance, the following pieces of information must be included in the report:

• the total amount of emissions over the reporting period;
• the “mode of releases” of emissions; and
• the “estimation method.”

The “mode of releases” refers to the way in which the pollutant was released to the air. The pollutant may have been released directly from a stack at the facility or as a result of substances vapourizing while in storage or during loading and unloading. The release to the air could also be the result of fugitive emissions from leaks at the facility, pollutants rising from roads on the facility site, or spills.

The “estimation method” refers to the way in which the owner or operator of the facility determines how much of each contaminant was released to the air. These methods include:

• continuous emission monitoring;
• predictive emission monitoring;
• source testing;
• mass balance;
• emission factors;
• emission estimation models; and
• engineering calculations.

Usually the data are not the result of continuous emission monitoring since this would be very difficult to do, if technically possible at all, and very expensive. The emissions data are more frequently the product of calculations based on knowledge about the level of activity at the facility, occasional monitoring at the site and experience in similar operations. This allows the operator of the facility to arrive at an estimate of the level of emissions.

When must the reports be provided?
Ontario has three timings for reports.

1. An annual report is required for each of the pollutants covered in O. Reg. 127/01 provided the facility meets the reporting criteria and thresholds. The report covers January 1 to December 31 of each calendar year and must be submitted to the province and made available to the public by June 1 of the following year. Because O. Reg. 127/01 came into effect on May 1, 2001, the annual report for the year 2001 covers only the May 1 to December 31 period. The annual thresholds are reduced by one-third for 2001 to match the reduced reporting year. The emissions to air portion of the NPRI substances are reported to the ministry as reported to the NPRI (i.e., reporting and thresholds are for the 12-month period for 2001). For subsequent reporting years, annual reporting will cover the full 12-month period.
   
2. Facilities also must submit a report on the amount of certain smog contributing pollutants (SO₂, NO_x, VOCs, CO, PM, PM₁₀ and PM_2.5) that they released during Ontario’s smog season, which is defined as from May 1 to September 30. This smog season report must also be submitted by June 1 of the following year.
   
3. In addition to providing an annual report and a smog season report, facilities are required to submit quarterly reports on their releases of NO_x and SO₂. The quarterly reports must be submitted within 60 days after the end of each quarter.

The facility must provide these quarterly reports if it has a discharge unit with the capacity to use 73 megawatts of total energy input (i.e., a name plate capacity of 73 megawatts) and can be expected to release at least 20 tonnes of SO₂ and/or 14 tonnes of NO_x (expressed as NO) during the full year.

The quarterly report must include information on the discharge unit. This information must include the capacity of the unit, the type of activity at the unit, the type of energy source and the fuel used. It also must include information for SO₂ and NO_x on the total quarterly release, the estimation method, the emission control device and the average emission rate.

How can the public gain access to the report?
Facility owners and operators must submit their reports to the Ontario Ministry of the Environment by the required reporting dates.

At the same time, reporters must ensure that their reports are available to any member of the public. Reports must be provided to the public, upon request, without any charge to the person who requests the report. Reports are to be available in either hard or electronic copies.

The owner or operator of the facility is required to ensure that each report is kept publicly available for at least seven years.

The totals for the airborne contaminant releases that are provided in these reports are based upon numerous calculations. The owner or operator of the facility must keep the information used to arrive at the totals for at least seven years. These records must be available to the provincial government for inspection at any time. The owner or operator does not, however, have to make these records available to the public.

If you wish to obtain a copy of an annual, smog season or quarterly report, you should contact the owner or operator of the facility that you are interested in. Some facilities may post these reports on their web site.

The ministry has also established a central Internet Web site where the public can access these reports. This Web site is available through a hotlink on the ministry’s homepage at http://www.ene.gov.on.ca.

Part 4: CANADA’S NATIONAL POLLUTANT RELEASE INVENTORY (NPRI) AND ONTARIO REGULATION 127/01 (O. Reg. 127/01)

In January 1993, Canada’s National Pollutant Release Inventory (NPRI)¹ came into effect requiring facilities to report each year on their releases of certain pollutants to air, water and land. These facilities must also report their transfers of these substances to other facilities for recycling or disposal.

The NPRI and O. Reg. 127/01 are similar but yet differ in several significant respects.

• The pollutants covered are more numerous in Ontario’s reporting system. As of the 2001-reporting year, Ontario’s system requires reporting on over 350 airborne contaminants in comparison with the 265 required by the NPRI.
• The reporting thresholds differ between the two systems for some substances.
• O. Reg. 127/01 requires reporting only on releases to air in contrast with the NPRI’s requirements for reporting on releases to all three media (air, water and land), and on transfers off-site.

The Ontario and federal governments are working together to reduce potential confusion and duplication for reporters to the two systems and for users of the data. The objective is to develop a joint reporting system to allow for a one-window approach to reporting.

¹ The NPRI Internet site is www.ec.gc.ca/pdb/npri .

PART 5: CONCLUSION

Ontario’s airborne contaminants reporting system is aimed at helping citizens better understand the sources of air pollutants and to help them participate in decision-making to address these issues. However by itself, O. Reg. 127/01 can not give a complete picture of the sources of air contamination in Ontario.

The Ontario reporting system does not include the air contaminants released from sources outside of Ontario. These sources can be responsible for a significant proportion of the air contaminants impacting our province. For example, more than 50 percent of the acid rain and smog-causing substances in Ontario’s air come from sources in the United States.

The system also does not report on all air pollution sources within Ontario. For example, air contaminants from the exhaust pipes of motor vehicles are not included. This is usually the largest local source of smog-causing pollutants.

O. Reg. 127/01 is designed to collect air emissions data specifically from stationary sources. The Ministry of the Environment uses other methods to estimate emissions from mobile sources. The Ministry also has programs to control emissions from mobile sources, such as Drive Clean.

Nevertheless, Ontario’s airborne contaminant reporting system provides you with substantial quantities of significant information from approximately 5,000 industrial, commercial, institutional and municipal facilities in Ontario.

We hope that this Citizens’ Guide to Airborne Contaminant Reporting in Ontario will help you access and understand this information so that you can use it in your efforts to clean up and protect Ontario’s air.