Emissions Summary Table and Interpretation of Results

12. Emissions summary table and interpretation of results

Each ESDM report must include an Emission Summary Table. Paragraph 14 of subsection 26 (1) of the Regulation sets out the requirements for an Emissions Summary Table as follows:

See Appendix D for an example format for an Emissions Summary Table. The following is additional guidance regarding paragraph 14 of subsection 26 (1) (i.e., the Emissions Summary Table) in an ESDM report:

• The averaging period reference should be expressed in hours or an annual average.
• The emission rates should be expressed in grams per second.
• The models used, included their version codes.
• The POI concentration should be expressed in the same units (e.g., typically, micrograms per cubic metre) as the ministry POI Limit for the respective contaminant.
• The location of the maximum POI required by subparagraph vii, may be expressed as a map which depicts the location and concentration of each maximum POI.
• To satisfy subparagraph viii, it is generally sufficient to provide:
  • A comparison to ministry POI Limits for the relevant contaminant and
  • The basis of the ministry POI Limit^{footnote 20[20]}.
• The Emissions Summary Table should also include sources that have been excluded from the modelling because they are part of a technical standard.

If the maximum POI concentration is less than the standard (or guideline), the facility is in compliance (conformance) with the standard (guideline). If the maximum POI concentration exceeds the standard (guideline), the facility may (i) refine their assessment in accordance with s.12 of the Regulation; or (ii) take abatement action to bring the facility into compliance with the standard or conformance with the guideline; or (iii) take other actions to comply with the Regulation which may include requesting a site-specific standard or registering for a technical standard (if available).

For more information on what information to include in the Emission Summary Table for facilities registered to a Technical Standard, please see Chapter 2 Overview or ESDM Reports and Chapter 12.4 Contaminants Registered to Technical Standards of this Procedure Document.

12.1 Contaminants with Ministry POI limits

Ministry POI Limits are available for approximately 375 contaminants used or produced by industry in Ontario as listed in the ministry publication, “Summary of Standards and Guidelines to Support Ontario Regulation 419: Air Pollution – Local Air Quality (including Schedule 6 of O. Reg. 419 on Upper Risk Thresholds)” (as amended). This Procedure Document is the primary reference to be used to assess POI concentrations from ESDM reports.

Note: For more information on Upper Risk Thresholds (URT) listed in Schedule 6 of the Regulation, see Chapter 12.3 Upper Risk Thresholds of this Procedure Document.

12.2 Contaminants without Ministry POI limits

There are many more compounds that meet the definition of a contaminant under the Ontario EPA than there are contaminants with ministry POI Limits. Persons preparing an ESDM report are accountable for the assessment of all contaminants that are discharged from the facility regardless of whether or not a ministry POI Limit is available.

The ministry has published a “Jurisdictional Screening Level (JSL) List - A Screening Tool for Ontario Regulation 419: Air Pollution – Local Air Quality” (PIBS # 6547e) to assist in the assessment of contaminants with no ministry POI Limits. The ESDM report must provide an indication of the likelihood and nature of any adverse effect that may be caused by a contaminant with no ministry POI Limit. This may be addressed as follows:

1. If a facility emits a contaminant that does not have an ministry POI Limit, it is strongly recommended that the modelled POI concentration be compared to the JSL list. A contaminant that has a POI concentration below its respective JSL does not require further assessment but must be documented in the Emission Summary Table of the ESDM Report. If the JSL is exceeded, or the contaminant is not listed on the JSL, further assessment must be done.
2. If the ESDM Report is submitted as part of the ECA process, this further assessment will occur with input from ministry scientists as part of the ministry’s review and acceptance of a Maximum Ground Level Concentration. This acceptance then appears in the Emission Summary Table upon completion of the review process. The location with zoning information and identification of sensitive receptors is also helpful to have during the GLC review process.
3. If the ESDM Report is being prepared under:
   1. sections 23 and 25 of the Regulation - facility is part of sector on Schedules 4 or 5 where the ESDM report is kept on-site and is up- dated annually; or
   2. section 24 of the Regulation - a facility is required to submit an ESDM report based upon a Notice from a ministry Director; or
   3. section 32 (request for a Site-Specific Standard), then the information on these contaminants without ministry POI limits should also be assessed against the JSL list.

   And there is no value on the JSL list or the JSL is exceeded, then this can be dealt with at the next available opportunity for ministry review. The next review could occur as part of an application for an ECA, or if ministry requests a copy of the ESDM report prepared under sections 23 or 25 of the Regulation.

4. The de minimus or threshold concentrations were also developed to screen out contaminants that are emitted in negligible amounts. Details on this screening tool are outlined in Appendix B of this guideline.

12.3 Upper risk thresholds

Upper Risk Thresholds (URTs) represent a concentration of a contaminant in air above its air standard. If a URT is exceeded anywhere off property, timely actions are required.

Subsections 30 (1) through 30 (7) of the Regulation state:

The Director must be notified at the earliest stage where there is reason to believe, based on any relevant information, that discharges of a contaminant may result in an exceedence of an URT listed in Schedule 6 of the Regulation.

ESDM reports that are required as a result of an exceedence of an URT are only required to consider those contaminants for which an URT is predicted to be exceeded (see s.30 (6.1) of the Regulation). It is also important to note that:

URTs can be used to manage risks both during and after the phase-in period of an air standard and is also used during the evaluation of requests for site-specific standards. URTs are NOT standards. See Chapter 3 of the ministry document, “Guideline for the Implementation of Air Standards in Ontario” (as amended) for guidance on determining appropriate action in relation to upper risk thresholds.

URTs listed in Schedule 6 of the Regulation are not standards. URTs have separate and distinct regulatory and notification requirements. These requirements are set out in section 30 of the Regulation. During the phase-in period of a new air standard, emitters must ensure, as a minimum, that they do not exceed the concentration set out in Schedule 6 of the Regulation. If the existing standard or guideline was less stringent than a URT, then the old standard or guideline would be removed from the ministry POI List. During the phase-in of the new standards, applications under section 20.2 of the Environmental Protection Act for an ECA and ESDM reports prepared in accordance with the Regulation, will be assessed against the URTs rather than the less stringent old standards or guidelines.

12.4 Assessment values for contaminants with annual standards

“Assessment values” are being introduced for exclusive use with annual standards. Annual average standards are based on an annual operating scenario and a typical annual emission rate, which averages out peak exposures over the year. However, POI concentrations can be influenced on a day-to-day basis by variations in emissions as well as weather conditions. These variations may cause elevations in exposure and therefore may be of concern depending on the length of time and concentration of the contaminant. The ministry has introduced “assessment values” in order to assess possible and occasional periods of elevated exposure that may occur during the year.

Assessment values would only be used if a facility is assessing against the annual standard in Schedule 3 (i.e. would not be used by a facility assessing against a standard in Schedule 2). Assessment values are values that do not appear in the Regulation, but if exceeded, may lead to a further assessment to determine if any further action is necessary or not.

Assessment values are available for use with modelling as well as monitoring results.

For further information on assessment values, please refer to the technical bulletin “Methodology For Assessment of Contaminants with Annual Average Standards under O. Reg. 419/05” (as amended) and available on the ministry website.

12.5 Contaminants registered to technical standards

A facility may be registered for an industry standard, an equipment standard or a combination of industry standard and equipment standard. If a person is registered for a technical standard(s) in respect of a facility and contaminant(s), but all sources of the contaminant at the facility are not addressed by theses technical standard(s) (i.e. there are sources of contaminant at the facility that are part of other NAICS codes), the person 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.

If the person is registered with respect to a sufficient number of industry standards, equipment standards or a combination of industry standard and equipment standards to address all sources of that contaminant at their facility, then this person is exempt from Part II of the Regulation for a contaminant. Registering for and complying with technical standard(s) is an alternative to complying with the air standards and associated ESDM requirements. In this case, no ESDM report is required to be submitted for the relevant contaminants. The Emission Summary Table of this ESDM report should clearly state if the contaminant (either whole or in part) is registered to a Technical Standard.

Note: An assertion or information on compliance with other relevant regulations or guidelines (such as guideline A9 and A5 etc.) needs to be included in the ECA application package. Currently all such compliance assessments are provided within the body of the ESDM Report.