Guide for Reporting to the National Pollutant Release Inventory 2000: highlights

Highlights and Important Changes for 2000

• Report Due Dates
• Correspondence
• New Substances and Alternate Reporting Thresholds
• Supplementary Guide
• Mercury (and its compounds)
• Polycyclic Aromatic Hydrocarbons
• Dioxins/Furans and Hexachlorobenzene
• Employee Criteria
• Common Errors

Report Due Dates

Reporting deadlines for the NPRI are subject to change and should be verified each year.

Correspondence

Correspondence from the NPRI will be addressed to the company coordinator. If there is no coordinator, correspondence will be sent to the technical contact. Failure to provide correct telephone and facsimile numbers for the contacts could delay receipt of important notices from NPRI offices. See Section 3 - A4, A6 and A8.

New Substances and Alternate Reporting Thresholds

Many substances pose serious risks to human health or the environment in relatively low quantities. Very limited, if any, data for these substances would be reported to the NPRI at the original 10-tonne and 1% concentration reporting thresholds. In 1999, Environment Canada and the NPRI Multistakeholder Ad Hoc Work Group on Substances examined candidate substances for addition to the NPRI and at alternate reporting thresholds. The following changes were made to the NPRI for the year 2000.

• Four substances were added to the NPRI with the original 10-tonne and 1% concentration reporting thresholds - acrolein; 4-tert-octylphenol; oxirane, methyl-, polymer with oxirane, mono(nonylphenyl)ether; and polymeric diphenylmethane diisocyanate, commonly referred to as PMDI.
  
• The reporting threshold for mercury (and its compounds) was reduced from 10 tonnes to 5 kg and the 1% concentration threshold was removed.
  
• Seventeen polycyclic aromatic hydrocarbons (PAHs) were added at an alternate reporting threshold.
  
• Polychlorinated dibenzo-p-dioxins (dioxins) and polychlorinated dibenzofurans (furans) were added as a single substance group with alternate reporting criteria.
  
• Hexachlorobenzene (HCB) was added with alternate reporting criteria.
  
• The 20 000-hour employee threshold was removed for facilities used for wood preservation and certain types of incineration.

The consultations leading to these changes and the reporting criteria for the substances with alternate reporting thresholds are described in detail in the Supplementary Guide (see below) and on the NPRI Web site.

Supplementary Guide

The reporting criteria for substances with alternate reporting thresholds are explained fully in a companion document, Supplementary Guide for Reporting to the National Pollutant Release Inventory - Alternate Thresholds - 2000. Substances with alternate reporting thresholds include:

• mercury (and its compounds)
• 17 polycyclic aromatic hydrocarbons (PAHs), and
• dioxins/furans and hexachlorobenzene (HCB).

Both this Guide and the Supplementary Guide should be consulted by owners and operators of facilities to determine if they must report for any NPRI substances.

The Supplementary Guide contains:

• detailed explanations of the activities to which the 20 000-hour employee threshold does not apply
  
• detailed explanations of the reporting criteria for the alternate-threshold substances
  
• definitions of the activities for which facilities must report releases and transfers of alternate-threshold substances (including biomedical waste and hazardous waste)
  
• for facilities engaged in wood preservation, the reporting criteria for alternate-threshold substances
  
• examples of how to estimate releases of alternate-threshold substances and various reporting scenarios
  
• the history and intent of the NPRI consultative process
  
• potential sources of PAHs and mercury (and its compounds), as well as substances, products and materials known to contain mercury, and
  
• an overview of the NPRI emission factor database that was compiled to assist facilities to estimate their releases of alternate-threshold substances.

Mercury (and its compounds)

Starting in the 2000 reporting year, a facility is required to submit a report for mercury (and its compounds) if they were manufactured, processed or otherwise used, at any concentration, in a quantity of 5 kg or more. Further information is provided in Chapter 3 of the Supplementary Guide.

Polycyclic Aromatic Hydrocarbons

Seventeen polycyclic aromatic hydrocarbons (PAHs) were added to the NPRI at an alternate threshold. The reporting criteria are based on quantities incidentally manufactured and released or transferred rather than quantities manufactured, processed or otherwise used, except in the case of wood preservation using creosote. Reporting of the 17 PAHs is required if:

• any individual PAH was incidentally manufactured and the quantity of all PAHs released on site or transferred off site as the result of incidental manufacture together totalled 50 kg or more, or
  
• PAHs were released on site or transferred off site from a wood preservation process using creosote.

Further information is provided in Chapter 4 of the Supplementary Guide.

Dioxins/Furans and Hexachlorobenzene

Polychlorinated dibenzo-p-dioxins (dioxins) and polychlorinated dibenzofurans (furans) are listed together in the NPRI and are referred to as dioxins/furans. Hexachlorobenzene (HCB) was also added to the NPRI for 2000. Facilities engaged in certain activities are required to report dioxins/furans and HCB to the NPRI. There are no quantitative, substance-based reporting thresholds. Information to be reported for dioxins/furans and HCB differs from that required in other NPRI substance reports. Further information is provided in Chapter 5 of the Supplementary Guide.

Employee Criteria

In previous years, a facility was exempt from reporting to the NPRI if, during the reporting year, the total number of hours worked by all its employees was less than 20 000 hours (equivalent to 10 full-time employees). Starting with the 2000 reporting year, Environment Canada removed the 20 000-hour employee threshold for facilities used for certain types of incineration and for wood preservation (see Section 2). This change was made because, although facilities used for these activities are known to release significant quantities of NPRI pollutants to the environment, they may not have been required to report to the NPRI since they did not meet the employee threshold.

Common Errors

• Statement of Certification
  A number of facilities neglect to provide a signed Statement of Certification. This renders the report incomplete.
  
• NPRI Identification Number
  A number of facilities do not report the NPRI identification number assigned to the facility. Your assigned NPRI ID number is provided in your NPRI correspondence. NPRI ID numbers are between 0001 and 9999. Contact your regional NPRI office if you cannot find your ID number.
  
• Industrial Classification
  Many facilities report industrial classification codes that are inconsistent with their industrial activities. Facilities must verify that the Canadian SIC, U.S. SIC and NAICS Canada codes that they report best describe their activities. The NPRI software provides pick-lists for these codes. While there may be several choices because of differences in the classification systems, be certain to choose the classification that best describes the facility. If you have any doubts about selecting industrial classification codes, please contact your regional NPRI office.
  
• Software Problems
  Some facilities do not install and test the NPRI reporting software early enough. Technical problems encountered in installing or running the software may result in submission of a late report. Facilities are urged to ensure that the software is correctly installed well in advance of the June 1 reporting deadline.
  
• Administrative Problems
  Some facilities have replaced staff who prepared the previous year's NPRI report and, as a result, these new staff are unaware of the requirement to report, do not receive the NPRI reporting kit when it arrives at the facility, or cannot find the electronic data and records used to prepare the previous year's report. As a result, the facility may submit a late or incomplete report, or expend excess effort in completing the report on time. All facilities are encouraged to establish and maintain appropriate administrative procedures to ensure an orderly transition during staff and other corporate changes.