Other requirements

The Air Emissions EASR regulation has requirements related to small wood fired combustors, modifications, procedures, complaints and records that must be followed.

Small wood-fired combustors

A small wood-fired combustor under the Air Emissions EASR regulation means a wood-fired combustor that has a nominal load heat input capacity of less than three megawatts. If the prescribed activities engaged in at a facility involve the use of a small wood-fired combustor, the following requirements must be met:

  • The small wood-fired combustor must use an automated wood fuel feed system that meets the criteria identified in Chapter 5 of the EASR publication.
  • A wood fuel management plan in respect of the small wood-fired combustor must be prepared and implemented in accordance with Chapter 5 of the EASR publication.
  • The small wood-fired combustor must meet the design criteria identified in Chapter 5 of the EASR publication.
  • The small wood-fired combustor must be operated within the operational parameters identified in Chapter 5 of the EASR publication.
  • The operational parameters identified in Chapter 5 of the EASR publication must be measured using the measurement methods identified in that Chapter.
  • A statement setting out the results of an installation test in respect of the small wood-fired combustor conducted in accordance with Chapter 5 of the EASR publication must be available at all times when engaging in the activity.
  • A performance assessment of the small wood-fired combustor must be conducted in accordance with Chapter 5 of the EASR publication at least once per year, and the results of each assessment must be recorded.
  • Each record described in Chapter 5 of the EASR publication in respect of the small wood-fired combustor must be prepared and retained at the facility for the period identified in that Chapter or, if no retention period is identified in that Chapter, for 20 years after its creation.

It is important to note that the design criteria identified in Chapter 5 of the EASR Publication requires, subject to some exceptions set out in the Chapter, that small wood-fired combustors meet the requirements of the EN-303-5 (2012) standard, be designed to meet Class 5 thermal efficiency and carbon monoxide as set out in EN-303-5 (2012) at nominal load and partial load heat output capacity operating conditions, and must meet at least one of Class 3, 4 or 5 for dust (particulate matter) as set out in EN-303-5 (2012), taking into account any air pollution control equipment specified by the manufacturer at nominal load and partial load heat output capacity operating conditions. The design must also be confirmed by a person who does not own, operate, sell or manufacture the small wood-fired combustor and meets the EN ISO/IEC 17025 requirements for testing as described in EN-303-5 (2012).

It is also a requirement for the small wood-fired combustor to only use the following types of fuel:

  1. Wood briquettes that are grade A1, A2 or B as set out in the standard CAN/CSA-ISO 17725-3:15 published by the Canada National Standard/Canadian Standards –International Organization for Standardization standard on March 1, 2015 and entitled “Solid biofuels – Fuel specifications and classes – Part 3: Graded Wood Briquettes”.
  2. Wood pellets that are:
    1. Grade A1, A2 or B as set out in the standard mentioned above, except Part 2: Graded Wood Pellets; or
    2. Premium or standard grade as set out in the document entitled “Pellet Fuels Institute Standard Specifications for Residential/Commercial Densified Fuel”, published by the Pellet Fuels Institute in July 2015.
  3. Wood chips that:
    1. Have a moisture content, reported on a wet basis, that does not exceed 50 percent when used as fuel; and
    2. If the date is after January 31, 2027, are grade A1, A2, B1 or B2 as set out in the standard 17225-4 mentioned above, except Part 4: Graded wood chips.

Procedures

The following procedures must be developed and implemented at the facility at which a person engages in prescribed activities:

  • Operating, maintenance and monitoring procedures to ensure that the facility is operating within the operational parameters set out in the EASR ESDM report supplement in respect of the facility. The procedures must be developed and implemented having regard to the operating and maintenance procedures identified in the EASR ESDM report supplement and must include any recommendations from the manufacturers of sources of contaminant or of equipment related to sources of contaminant.
  • Operating, maintenance and monitoring procedures to ensure that the facility is operating within the operational parameters, if any, set out in the noise report in respect of the facility. The procedures must be developed and implemented having regard to the operating and maintenance procedures identified in the noise report and must include any recommendations from the manufacturers of sources of sound or of equipment related to sources of sound.
  • If a noise report indicates that a NAAP is being implemented at the facility, procedures to ensure that the NAAP is implemented.
  • Procedures setting out the frequency of inspections and scheduled preventative maintenance of sources of contaminant at the facility and equipment related to the sources of contaminant.
  • Procedures for record-keeping activities and logs relating to the operating, maintenance and monitoring procedures and plans.
  • Procedures to prevent and respond to spills from sources of contaminant.
  • Procedures for training persons who operate and maintain sources of contaminant and the equipment related to sources of contaminant.
  • Procedures for recording and responding to complaints that relate to the facility and the natural environment.

Complaints

If a complaint is received by the person engaging in the prescribed activity and the complaint relates to the discharge of a contaminant to the air from the facility at which the activity takes place, the person must:

  • Ensure that the ministry’s Spills Action Centre is immediately notified of the complaint. The Spills Action Centre can be reached at 1-800-268-6060 (toll free), 416-325-3000 , or 1-855-889-5775 (TTY).
  • Create a record of each complaint that is made that includes the following:
    1. The date and time when the complaint was received.
    2. A copy of the complaint, if it is a written complaint.
    3. A summary of the complaint, if it is not a written complaint.
    4. A summary of the measures taken, if any, to address the complaint.

The complaint records shall be retained at the facility for at least 5 years from its creation. It is helpful to prepare a template that is made available to meet the requirements of this section of the Regulation.

In the event of a spill, these requirements are in addition to the requirements in O. Reg. 675/98 (Classification and Exemption of Spills and Reporting of Discharges).

Records

The retention of records shall be followed as:

  • Each report, EASR ESDM report supplement, plan, odour screening report that is required to be prepared under O. Reg. 1/17 must be retained for at least 20 years after the date the document is signed.
  • Each addendum to the documents mentioned above must be retained for at least as long as the report mentioned above is required to be kept.
  • If a document proposes a modification and that modification was not completed, then that document does not have to retained as described above.
  • If a noise report includes a NAAP the noise report shall be retained for at least 20 years after the date on which the implementation of the action plan is completed.
  • A record of each procedure required to be developed and implemented under O. Reg. 1/17 is created and retained at the facility for at least 5 years after the day the procedure is no longer being implemented at the facility.

The following records shall be created and retained at the facility for at least five years after its creation:

  • A record of each comment from a provincial officer or the Director with respect to a plan required to be prepared under this regulation that includes the comment, a description of whether or not the comment was addressed, and,
    1. If the comment was addressed, a description of the actions taken to do so and the date each was implemented, and
    2. If the comment was not addressed, a description of the reasons it was not addressed.

A record of each complaint shall be created as described in the complaints section above and retained for at least 5 years.

A log containing the following information shall be created, updated and retained at the facility:

  • A description of each modification made to the facility and the date on which the modification was made.
  • A description of each change in the manner in which an approved dispersion model is used in the preparation of an EASR ESDM report and the date on which the change occurred.
  • A summary of how the information described about modifications and changes identified above has been reflected in the relevant report, supplement or plan.

If the prescribed activity involves a boiler or heater, a log must be created, updated and retained at the facility that records each date and duration in hours the boiler or heater uses a non-primary fuel.

A template for the log can be set up with the following suggested columns:

  • Entry Number;
  • Date of Modification;
  • Date of Modification to EASR ESDM Report or Addendum;
  • Description of Change to EASR ESDM Report;
  • Date of Change of Noise Report or Addendum;
  • Description of Change to Noise Report;
  • Date of Change to Odour Survey Report, BMPP for Odour or Addendum; and
  • Description of Change to BMPP for Odour.

An entry in any log shall be maintained for at least 20 years after the day the entry is made.

Director approved forms and electronic format

With respect to any report, plan, table or log that a person is required to prepare or any method that a person is required to use under this regulation, the Director may approve a form that is to be used or that a specified electronic format that is to be used. This includes the Primary Noise Screening form, Secondary Noise Screening form, and odour screening report. Further, records are allowed in electronic form. They have to be kept on site, and if a record is retained in electronic form, the provincial officer may require that a copy of it be provided to him or her on paper or in a machine-readable medium or both.