Initial Identification of Sources and Contaminants

6. Initial identification of sources and contaminants

The purpose of this portion of an ESDM report is to provide an initial listing of the contaminants and individual sources of contaminants at the facility according to paragraphs 2 through 5 of subsection 26(1) of the Regulation:

Please note that it is acceptable for a facility to account for every source and contaminant in an ESDM report. However, if the facility is assessing significance (or non-negligible), the steps described in Chapter 7, Assessment of the Significance of Contaminants and Sources, are intended to focus the initial contaminant list into an identification of the significant^{footnote 7[7]} sources and contaminants for a more detailed analysis of emissions and POI concentrations. As a result, the guidance provided in Chapters 6 Initial Identification Of Sources And Contaminants and 7 Assessment Of The Significance Of Contaminants And Sources of this Procedure Document can generally be used together to satisfy the requirements of paragraphs 2 through 5 of subsection 26(1). In particular, it is recommended that the requirements of paragraph 2; subparagraphs 3i, 3ii and 3iii and paragraph 4 of subsection 26 (1) of the Regulation be presented in a Sources and Contaminants Identification Table which includes, for each source and contaminant emitted from the facility:

• A list of all sources on the property, including a brief description of the source or a source title; a general location (i.e., building or description of portion of property where the source can be found); and a source identifier. The Sources and Contaminants Identification Table should include sources that are addressed under the Technical Standard Registry or have been registered in the Environmental Activity and Sector Registry (EASR) (if a facility is required to do an ESDM report).
• A list of all contaminants that may be discharged from the facility. In most cases, it is sufficient to identify the types of contaminants (e.g., “by-products of combustion”; “volatile organic compounds”; “suspended particulate matter”; etc.)^{footnote 8[8]}. However, if a contaminant is not considered in the dispersion modelling then a specific list of these contaminants (and not just the types of contaminants) must be included as part of the explanation, required by sub-subparagraphs 3 iii B and C and paragraph 5 of subsection 26 (1) of the Regulation. The explanation should address how the facility determined that these contaminants do not need to be considered or were emitted in an amount that is negligible.
• A reference to the method that was used to identify the expected contaminants (see Table 6-2, Reference Information to Assist in Identifying Contaminants). Please note that this is an optional component of the Sources and Contaminants Identification Table.
• An indication of whether a contaminant is discharged from the facility in a negligible amount.
• An indication of whether a source discharges a negligible amount of a contaminant and, consequently, whether the source has been considered in the use of the approved dispersion models.

As per Chapter 2.1.2 Special Case: A Property that includes all or a portion of the facility registered on Technical Standard Registry, only some facilities registered under the Technical Standards Registry would be required to have an ESDM report for sources or contaminants that are not addressed in one or a combination of more than one Industry or Equipment Standards or they are not registered for. These facilities should list their sources of contaminants in the Sources and Contaminants Identification Table.

See Appendix D for an example format for a Sources and Contaminants Identification Table. Also source labels to identify the sources should match the modelling input files and site plans.

The rationale for excluding negligible sources and contaminants emitted in negligible amounts must be included in the ESDM report (e.g., in an appendix to the report).

ESDM reports that are required to be prepared as a result of an exceedence of an Upper Risk Threshold listed in Schedule 6 of the Regulation (see in subsection 30 (4) of the Regulation) are required to consider only those contaminants for which an Upper Risk Threshold is predicted to be exceeded (s. 30 (6.1) of the Regulation).

6.1 Identifying sources

A reference to the term “source” in this guidance document includes an individual point of emission or a distinct process or area from which emissions may originate.

Where multiple stacks or vents arise from a common process, the process itself may be considered a source rather than the individual points of emission. Where several separate processes, each causing a distinct mixture of contaminants, are discharged to a common stack, each separate process should be considered a separate source. For the purpose of this guidance document, a ‘process’ is a production step or series of production steps for which an emission rate is calculated based on assessing the process as a whole.

Sources shall be identified regardless of when a source was installed or whether or not approval under Part II.1 of the EPA was obtained for that source. Starting October 31, 2011, the ministry’s Environmental Approvals Branch (EAB) has implemented a new environmental approvals system to require a facility to either obtain an ECA (formerly C of A) or register online in the Environmental Activity and Sector Registry (EASR) for certain activities. Activities eligible for registration are set out in O. Reg. 245/11: Registrations under Part II.2 of the Act - General. Activities registered under the EASR are not required to obtain an ECA. However, the sources that are included in the activities are still required to be identified in the ESDM report prepared for the facility. The ESDM report must state that these sources are registered in EASR and therefore an ECA for the sources is not required to be obtained.

Note that as a result of the 2011 amendments to the EPA, an ECA is required for the ongoing operation of all equipment engaging in s. 9 (1) activities that are not excepted/exempted from the approval requirement, regardless of whether they were in place.

6.1.1 Fugitive sources

For the purposes of this guidance document, a fugitive source is a source associated with an area or activity rather than a distinct point of emission or a source whose emissions are not emitted through a confined process stream. In general, fugitive sources should be included in the list or in the Sources and Contaminants Identification Table. Some examples of fugitive sources are:

• leakage of gaseous contaminants from valves or pipes;
• leaks of contaminants around process operations;
• incomplete capture from ventilation of process operations (such as hooding);
• particulate emissions from roof vents on a process building;
• particulate emissions from storage piles or open material conveying; and
• particulate emissions from travel over on-site unpaved roadways, paved roadways, and on-site traffic (e.g. bull-dozers, grading, and parking lots) for the sectors identified in Table 6-1 Sectors that Should List Fugitive Sources of Air Emissions.

Where emissions from fugitive sources may originate from a relatively large number of individual sources, it may be reasonable to group them together for the purposes of identification, emission rate estimating and dispersion modelling.

It is anticipated that the fugitive particulate from roadways, storage piles and other fugitive sources emitted by facilities within the sectors listed in Table 7-2 Sectors Where Metal Content Within Fugitive Particulate Must Be Considered may contain significant quantities of contaminants with health-based ministry POI limits such as metals. See Chapter 7.4 Fugitive Dust Emissions for more information on some outdoor dust emissions from fugitive sources.

This Table 6-1 Sectors that Should List Fugitive Sources of Air Emissions contains two columns. The first column contains the North American Industrial Classification System (NAICS) Code and the second column contains the corresponding NAICS code description.

6.2 Description of the contaminants that may be discharged

Contaminants that may be discharged from the facility must be identified in it’s ESDM report. Generally available information such as guidance on air emissions that is published by environmental regulatory agencies; peer-reviewed documents; or industry sponsored studies may be used in most cases for this purpose. An indication of whether or not the study was validated by a regulatory agency or an independent third party should be provided when referencing industry sponsored studies. See Table 6-2 Reference Information to Assist in Identifying Contaminants for specific examples of reference information that can be used to identify the expected contaminants.

All contaminants that may be discharged to the air from the facility must be included in an ESDM report, even if there is no ministry POI Limit. However, it should be noted that the facility is not required to assess emissions for the contaminants that have been registered under the Technical Standards Registry (see Chapter 2.1.2 Special Case: A Property that includes all or a portion of the facility registered on Technical Standard Registry of this Procedure Document for further information) unless the source of that contaminant is from a NAICS code not considered in the technical standard(s) the facility is registered to.

For further information on assessing the significance of sources and contaminants please see Chapter 7 Assessment Of The Significance Of Contaminants And Sources of this Procedure Document.

Table 6-2: Reference Information to Assist in Identifying Contaminants

Material Balances:
Material Safety Data Sheets for materials used in process

Emission Factor Documents and Reports:
The United States Environmental Protection Agency (US EPA) publishes a variety of emissions related information to assist facilities in assessing impacts. This information is often used to assess emission rates from various production processes. Although it is reasonable to use site or sector-specific studies as a means of identifying the expected contaminants emitted from various sources, the following references are also commonly used and widely available:

1. Emission Factors published in the US EPA Document Number AP-42, Compilation of Air Pollutant Emission Factors. This document includes process description and emission factors for a broad range of criteria contaminant emission sources. Supplements are published regularly.
2. Factor Information Retrieval (FIRE) Data System. The FIRE Data System (from the US EPA) is a database that can be used in an initial effort to identify contaminants. Note: although the FIRE Data system can be used to identify contaminants from a variety of sources, the quality of the emission factors listed in this system varies.

3. Locating and Estimating (L&E) documents for specific contaminants. The L&E report series, are for specific air toxic emissions from sources (source category or substance) and characterizes the source categories for which emissions of a toxic substance have been identified. These volumes include general descriptions of the emitting processes, identifying potential release points and emission factors. The L&E series presently contains emission reports for the following contaminants:

   Acrylonitrile, Arsenic, Benzene, 1,3 Butadiene, Cadmium, Carbon Tetrachloride, Chlorobenzene, Chloroform, Chromium, Cyanide, Dioxins and Furans, Epichlorohydrin, Ethylene Dichloride, Ethylene Oxide, Formaldehyde, Lead, Mercury, Methyl Chloroform, Methyl Ethyl Ketone, Methylene Chloride, Nickel, Perchloroethylene, Phosgene, Polycyclic Organic Matter, Styrene, Toluene, Vinylidene Chloride and Xylene.

4. U.S. state environmental agencies also publish information such as the State and Territorial Air Pollution Program Administrators (STAPPA) and the Association of Local Air Pollution Officials (ALAPCO).
5. Guidance and emission rate estimating information provided by the Ontario Ministry of the Environment for Regulation 127/01 - Airborne Contaminant Discharge Monitoring and Reporting and provided by Environment Canada for reporting to the National Pollutant Release Inventory.
6. Contaminants identified from site-specific source testing and/or industry sponsored studies.
7. In addition to the above, other information from regulatory agencies in a variety of jurisdictions is also available including Environment Canada; Australia; and the European Union; etc.

This Table 6-2 Reference Information to Assist in Identifying Contaminants contains just one column, and is intended to emphasize its contents.

6.3 General location

The location of each source identified in the ESDM report prepared for the facility must be provided. The intent is to ensure that ministry staff are able to locate the source either on a site plan or in a site visit.

6.4 Overview of identifying and assessing sources and contaminants

The following summarizes, in broad terms, the approach to initially identify sources and contaminants emitted from the facility. The summary is intended to also provide an analysis that is focused on the significant sources and contaminants. The ESDM report should:

1. Identify the sources and contaminants emitted from the facility (for guidance, see reference material in Table 6-2 Reference Information to Assist in Identifying Contaminants of this Procedure Document). [Note: please ensure the source identifiers in all ESDM reports are consistent. If there is a change in the name, please identify the old and new name. The ESDM report should include a tabulated summary that co-relates short-form source identifications that are used in the modelling runs and/or Source Summary Table with brief descriptions of each source].
2. Document the sources and contaminants in a Sources and Contaminants Identification Table or Tables. (Note: these Tables should include the sources and contaminants that have been registered on the EASR. If a facility has registered under the Technical Standards Registry, and is still required to prepare an ESDM report for other contaminants, then these sources should also be listed in the Sources and Contaminants Identification Table. If there is no requirement for an ESDM report, then this is not necessary).
3. An optional assessment of the significance of sources and contaminants can be done. If an assessment of significance is made, it must be documented (see Chapter 7 Assessment Of The Significance Of Contaminants And Sources of this Procedure Document). (Note: It is acceptable to exclude assessment of the contaminants that have been registered under the Technical Standard Registry by referencing the appropriate section of the Regulation.)
4. Include emission rates that have been developed for the significant contaminants and sources based upon a review of operating conditions (see Chapter 8 Operating Conditions of this Procedure Document).
5. Document the emission rates and source parameters for the significant contaminants and sources in a Source Summary Table (see Chapter 10 Source Summary Table And Site Plan). [Note: A Source Summary Table should contain sufficient information to correlate the contaminant and the source].
6. Include complete dispersion modelling for the significant contaminants and sources (see Chapter 11 Dispersion Modelling).
7. Include the results of the dispersion modelling in an Emission Summary Table (see Chapter 12 Emissions Summary Table and Interpretation Of Results). Note: It recommended that contaminants registered under the Technical Standard Registry should be included in the Emission Summary Table with an indication of the title of the technical standard the facility is registered under.