By: Ka Ming Lin
Introduction
The National Pollutant Release Inventory (NPRI) is updated from time to time. These updates have typically been applied every other year. Notice for a new update for the 2022 reporting year (reports due June 1, 2023) was recently published in the Canada Gazette. This new update covers the reporting years 2022-2024.
In previous recent years, updates have been fairly minor with the listing or de-listing of a handful of new substances. The NPRI keeps a list of changes to reporting requirements that have been made over time. However, the new update for the 2022 through to 2024 reporting years are more substantial. The NPRI publishes a guidance document with every update (the Guide). That guidance is available online here: https://publications.gc.ca/site/eng/9.506026/publication.html
It is highly recommended that facilities engage in a more in-depth review of their activities for the upcoming reporting season as the changes to NPRI may involve new or modified data gathering.
The Changes
While there are a number of smaller changes which are similar to the magnitude of previous changes to the NPRI, there are two changes which ORTECH believes have the potential to impact a significant number of facilities. The two big changes are a lowering of the stack height reporting threshold and the removal of the condition that exceedance of the Part 4 VOC (volatile organic compound) threshold are required to trigger Part 5 (speciated VOC) reporting as described further below. Readers should be mindful that there are other changes to the NPRI which may affect them as well and thus all of the changes should be reviewed.
Stack Height Threshold and other Stack Reporting Changes
Part 4 substances (the criteria air contaminants or CACs) have historically had a requirement for individual stack reporting for stacks greater than 50 metres in height above grade. Facilities which triggered these reporting requirements would have to assign the amount of substance released by each affected stack as opposed to only reporting facility-wide total air releases.
50 metres above grade represents a very tall stack and does thus not apply to many facilities. This threshold has been changed to 25 metres above grade, a change which will now include a much larger number of stacks. As a mitigating factor, the reporting thresholds for individual stack reporting have been increased (except for total VOCs which has not changed).
There is also an exemption for stacks which have an annual average exit temperature of less than 50° Celsius. However, this exemption can only be used if the exit temperature is measured. As noted in the Guide – “Estimations, values supplied by manufacturers, values used for the purposes of obtaining an operating approval or permit and default values cannot be used to compare to the temperature threshold.”
These changes can be found in Appendix D of the Guide. Table 1 provides a summary only. It is strongly recommended that facilities consult the Guide and the Notice in the Gazette when it is published.
Stack heights at facilities should be reviewed carefully to see if they now fall under these conditions. Please note that the stack height threshold is measured as “above grade”.
Another change that will affect stack reporting is that stack exit temperatures are to be reported if a stack triggers these thresholds. The Guide notes that if this average exit temperature is not being measured or is not known, “the facility can report the annual average stack exit temperature that was used for the purposes of obtaining a current approval or a permit, or can indicate that the annual average exit temperature is unknown.” For clarity, this type of temperature information (used for permitting purposes) is expected to be reported to the NPRI, but it can only be used to qualify for the exemption for stacks with annual average exit temperatures less than 50° Celsius if it is measured data.
Speciated VOCs
Part 5 of the NPRI is the reporting of speciated VOCs. Historically, speciated VOCs were not required to be reported unless a facility exceeded the annual Part 4 total VOCs threshold (10 tonnes facility-wide releases to air). This requirement has been removed and now facilities which exceed the individual speciated VOC air release thresholds will have to report under part 5 regardless of whether or not the facility wide total VOC threshold is exceeded. The individual annual speciated VOC threshold remains 1 tonne facility-wide releases to air.
Some facilities which previously did not have to report to the NPRI at all may now be captured under this change such as a facility that predominantly releases a small number of speciated VOCs. As an example, a facility that releases ethanol and very few other speciated VOCs, such as a brewery, distillery, or even a bakery, might have annual individual speciated VOC releases that exceed 1 tonne while the total facility-wide VOCs are under 10 tonnes. Such a facility may never have reported to the NPRI before, but will have to for the 2022 reporting year even if their releases are unchanged.
This change is further complicated by the changes to stack reporting. Speciated VOCs previously had to be assigned to individual stack sources if a number of criteria were met. These criteria have changed. Due to the complicated nature of Part 5 speciated VOC reporting and the various exemptions which some facilities may have access to, it is strongly recommended that each facility engages in a detailed assessment of their Part 5 reporting requirements.
Conclusion
The changes for the 2022 NPRI Reporting Year have the potential to impact a lot of different facilities and it is prudent to assess the potential impacts this would have on your facility(ies) as soon as reasonable. Some of these changes may warrant rethinking how data is currently being collected.
ORTECH has many years of experience with NPRI Reporting and a wide range of services associated with stacks and stack testing. If you are looking for an expert to help you through how these changes may impact your NPRI reporting requirements, please contact us at info@ortech.ca.
