Guide for reporting to National Pollutant Release Inventory 2001: step 1

Step 1: determine whether a report is required for your facility

The first step is to determine whether your facility is required to report to the National Pollutant Release Inventoryn (NPRI) for any substances. This section outlines the reporting criteria for all substances listed in the NPRI for 2001. If you are required to report, refer to the other sections in the guide for a description of the reporting requirements and how to use the 2001 NPRI reporting software.

Refer to Step 2 for details on where to find guidance and information on the substances listed in the NPRI. The sources of information identified in Step 2 can be used to determine if you met the quantitative substance threshold and, if so, assist you to determine the quantities released and transferred that must be reported to the NPRI.

Overview of reporting criteria

The substances listed on the 2001 NPRI are divided into four groups, according to their differing set of reporting criteria. The complete list of NPRI substances is provided in Appendix 1, and is subdivided into these four parts.

It is the facility's obligation to review the NPRI reporting criteria and requirements annually as they are subject to change.

Figure 1 provides an overview of the reporting criteria for the 2001 NPRI. Detailed explanations of the reporting criteria and requirements for each group of substances follow the figure.

Facility criteria

A "facility" refers to all buildings, equipment, structures and other stationary items that are located on a single site or on contiguous or adjacent sites that are owned or operated by the same person and function as a single integrated site.

Exempt facilities

A facility is exempt from reporting a substance to the NPRI if the only source or use of that NPRI substance at the facility was one or more of the activities listed in Table 1.

In cases where a facility met the reporting criteria for a substance based on sources other than those listed in Table 1, it should not include the quantity of that same substance from any exempt activities (listed in Table 1) when reporting release or transfer quantities to the NPRI.

Table 1: activities not considered when reporting to the NPRI

• educating or training students, such as at universities, colleges and schools
• research or testing
• the maintenance and repair of transportation vehicles, such as automobiles, trucks, locomotives, ships or aircraft
• the distribution, storage or retail sale of fuels
• the wholesale or retail sale of articles or products which contain NPRI substances, provided that the substances are not released to the environment during normal use at the facility
• the retail sale of NPRI substances
• growing, harvesting or managing renewable natural resources, such as fisheries, forestry or agriculture, but not those facilities that process or otherwise use their products
• mining, but not those facilities that further process or otherwise use mined materials
• drilling or operating wells to obtain oil and gas products, but not those facilities that further process or otherwise use these oil and gas products, or
• the practice of dentistry.

Figure 1: criteria for reporting to the NPRI for 2001

Exclusions

A facility should not include the quantity of a substance from any sources listed in Table 2 when calculating thereporting thresholds or when reporting release or transfer quantities to the NPRI.

Table 2: sources not considered when reporting to the NPRI

• articles that are processed or otherwise used
• materials used as structural components of the facility - the exclusion of structural components of the facility from the reporting threshold is limited to building and other fixed structures but does not include process equipment
• materials used in routine janitorial or facility grounds maintenance - the maintenance of processing equipment is not considered "routine janitorial" or "facility grounds" maintenance. For example, if manufacturing or processing equipment is cleaned with a solvent, the amount of the NPRI substance(s) contained in the solvent should be included in the threshold calculation.
• materials used for personal use by employees or other persons
• materials used for the purpose of maintaining motor vehicles operated by the facility
• in intake water or intake air - this refers to water used for process cooling or air used either as compressed air or for combustion.

Employee criteria

Before determining whether the facility met the substance-specific threshold for any substances listed in the NPRI, the facility must determine if it met the employee criteria. A facility is not required to report to the NPRI if, during the 2001 calendar year:

• the total number of hours worked by all employees was less than 20,000 hours,

and

• the facility was not used mainly or exclusively for one of the following activities:
  • non-hazardous solid waste incineration of 100 tonnes or more of waste per year, including small combustion units, conical burners and beehive burners
  • biomedical or hospital waste incineration of 100 tonnes or more of waste per year
  • hazardous waste incineration
  • sewage sludge incineration, or
  • wood preservation

Both of these thresholds are further explained below.

20,000-hour employee threshold

This threshold depends specifically on the number of hours worked by all employees at the facility during the calendar year and not on the number of persons working. To determine if your facility met the 20,000-hour employee threshold, include all hours worked by:

• persons employed at the facility, including students, part-time and term employees
• owner(s) who performed work on site at the facility
• persons who performed work on site at the facility on a routine basis related to the normal operation of the facility, for the period of time the person performed that work, such as contractors

The total number of hours worked includes paid vacation and sick leave.

Activities to which the 20,000-hour employee threshold does not apply

If your facility was used mainly or exclusively for one or more of the activities listed in Table 3, you must submit a report for any NPRI substance that met its respective reporting criteria, regardless of the number of hours worked by employees. The employee threshold does not apply because facilities used for these activities are known to release significant quantities of NPRI pollutants to the environment, but often were not required to report to the NPRI since they did not meet the 20,000-hour employee threshold.

Table 3: activities to which the 20,000-hour employee threshold does not apply

Waste incineration activities

• (a) non-hazardous solid waste incineration of 100 tonnes or more of waste per year, including small combustion units, conical burners and beehive burners
• (b) biomedical or hospital waste incineration of 100 tonnes or more of waste per year
• (c) hazardous waste incineration
• (d) sewage sludge incineration

Wood preservation activity

• (e) wood preservation (using heat or pressure treatment, or both)

Waste incineration activities

The first four activities listed in Table 3 are forms of waste incineration. Waste incineration, for the purposes of the NPRI, only includes incineration that takes place in a waste incinerator.Waste incineration does not include open burning of wastes.

A waste incinerator is a device, mechanism or structure constructed primarily to thermally treat (for example, combust or pyrolyze) a waste for the purpose of reducing its volume, destroying a hazardous chemical present in the waste, or destroying pathogens present in the waste. This includes facilities where waste heat is recovered as a by-product from the exhaust gases from an incinerator (for example, energy-from-waste incinerators). This also includes conical burners and beehive burners. This does not include industrial processes where fuel derived from waste is fired as an energy source, such as industrial boilers.

a) non-hazardous solid waste incineration of 100 tonnes or more of waste per year, including small combustion units, conical burners and beehive burners

Non-hazardous solid waste means any waste, regardless of origin, which might normally be disposed of in a non-secure manner, such as at a sanitary landfill site, if not incinerated. It includes clean wood waste, that is, waste from woodworking or forest product operations, including bark, where the wood waste has not been treated with preservative chemicals (for example, pentachlorophenol) or decorative coatings. Non-hazardous solid waste incineration includes incineration of residential and other municipal wastes in conical burners, and clean wood waste in beehive burners.

A facility used for the incineration of 100 tonnes or more of non-hazardous solid waste per year is required to report to the NPRI if it met the substance criteria, regardless of the number of hours worked by employees.

b) biomedical or hospital waste incineration of 100 tonnes or more of waste per year

Biomedical waste is defined fully in Appendix 3. Biomedical or hospital waste refers to waste that is generated by:

• human or animal health-care facilities
• medical or veterinary research and testing establishments
• health-care teaching establishments
• clinical testing or research laboratories
• facilities involved in the production or testing of vaccines

Biomedical or hospital waste includes human anatomical waste and animal waste. It also includes microbiology laboratory waste, human blood and body fluid waste, and waste sharps that have not been disinfected or decontaminated. It does not include waste from animal husbandry, or waste that is controlled in accordance with the Health of Animals Act (Canada).

Wastes that are household in origin, or that are generated in the food production, general building maintenance and office administration activities of those facilities to which this definition applies, are not considered to be biomedical or hospital waste but rather to be non-hazardous solid waste.

A facility used for the biomedical or hospital waste incineration of 100 tonnes or more of waste per year is required to report to the NPRI if it met the substance criteria, regardless of the number of hours worked by employees.

c) Hazardous waste incineration

Hazardous waste is defined fully in Appendix 4. Hazardous waste includes those wastes that are potentially hazardous to human health and/or the environment because of their nature and quantity, and that require special handling techniques. Hazardous waste incinerators must be licensed or authorized by the responsible jurisdiction. Hazardous waste incinerated in a mobile incinerator temporarily located at your facility must be included as part of this activity.

A facility used for the incineration of hazardous waste is required to report to the NPRI if it met the substance criteria, regardless of the number of hours worked by employees or the quantities incinerated.

d) Sewage sludge incineration

Sludge means a semi-liquid mass removed from a liquid flow of wastes. Sewage sludge means sludge from a facility treating wastewater from a sanitary sewer system. The drying of sludge to reduce water content is part of the incineration stage.

A facility used for the incineration of sewage sludge is required to report to the NPRI if it met the substance criteria, regardless of the number of hours worked by employees or the quantities incinerated.

Wood preservation activities

Wood preservation (using heat or pressure treatment, or both)

A facility used for wood preservation is required to report to the NPRI for Schedule 1, Part 1, substances and mercury (and its compounds) if it met the substance criteria, regardless of the number of hours worked by employees.

Wood preservation using creosote

A facility used for wood preservation must report for any of the 17 individual polycyclic aromatic hydrocarbons (PAH)s released on site or transferred off site from a wood-preservation process using creosote, regardless of the number of hours worked by employees. This reporting criterion is found in Schedule 2, Part 3, of the 2001 Canada Gazette notice. Refer to "Reporting criteria for Schedule 1, Part 3, substances" for details.

Wood preservation using pentachlorophenol

A facility used for wood preservation using pentachlorophenol must report for dioxins/furans and hexachlorobenzene (HCB), regardless of the number of hours worked by employees or the quantities of dioxins/furans and HCB released or transferred. This reporting criterion is found in Schedule 2, Part 4, of the 2001 Canada Gazette notice. Refer to "Reporting criteria for Schedule 1, Part 4, substances" for details.

Reporting criteria for Schedule 1, Part 1, substances

Substances

The changes to the NPRI list of substances for 2001 include:

• the addition of N,N-Dimethylformamide (CAS No. 68-12-2) to Schedule 1, Part 1, of the 2001 Canada Gazette notice
• the amalgamation of the individual isomers of cresol (m-, o-, and p-cresol) under the "cresol (all isomers)" listing
• the change in the qualifier for vanadium to "(except when in an alloy) and its compounds" from "fume or dust", and
• the de-listing of phosphoric acid (CAS No. 7664-38-2).

You must confirm that one or more of the 245 substances listed in Schedule 1, Part 1, were manufactured, processed or otherwise used at your facility. The NPRI substances are listed in alphabetical order in Appendix 1. Most of the substances have CAS numbers associated with them. The NPRI substances are listed by CAS number in Appendix 2. Substances that do not have a unique CAS number are noted with an asterisk (*).

Some groups of substances and individual substances are qualified in terms of their specific physical or chemical form, state or particle size. These qualifiers will determine whether your facility will be required to report for a given substance:

• fume or dust
  This qualifier for aluminum refers to solids with particle diameters of 0.001 to 1 micron for fumes and 1 to 100 microns for dust particles.
  
• fibrous forms
  This qualifier, applied to aluminum oxide, excludes the more common granular, powdered or fumed forms of alumina.
  
• salts
  Weak acids and bases are listed with this qualifier. Although the CAS number that appears on the NPRI list is specific to the acid or base, all salts of these listed substances must be reported as an equivalent weight of the acid or base.
  
• compounds
  Twelve NPRI Part 1 elements have this qualifier - antimony, arsenic, cadmium, chromium, cobalt, copper, lead, manganese, nickel, selenium, silver and zinc. The pure element and any substance, alloy or mixture must be reported as the equivalent weight of the element. No CAS number is provided for these substances.
  
  Note that "tetraethyl lead" and "lead (and its compounds)" both appear on the NPRI list. Exclude tetraethyl lead when completing a report for lead (and its compounds). Complete a separate report for tetraethyl lead. Apply the reporting criteria to each substance separately.
  
• (except when in an alloy) and its compounds
  This qualifier applies only to vanadium. The pure element and any substance or mixture must be reported as the equivalent weight of the element. No CAS number is provided for these substances. Do not include vanadium contained in an alloy. An alloy includes metal products containing two or more elements as a solid solution, intermetallic compounds and/or mixtures of metallic phases.
  
  This change to the qualifier for vanadium was made, beginning in the 2001 reporting year, to capture all forms of vanadium and its compounds released from the combustion of fuel.
  
• friable form
  Asbestos is the general name for several fibrous minerals and products. Only asbestos that is brittle and readily crumbled should be reported.
  
• mixed isomers
  This qualifier is used for mixtures of isomers which have the same chemical formula but different chemical structures. The substances with this qualifier are dinitrotoluene, n-nonylphenol and toluenediisocyanate. Substances with this qualifier are usually found as mixtures. The total quantity of all isomers must be used in calculating the 10-tonne threshold quantity. Do not apply the 10-tonne reporting threshold to each individual isomer unless the pure isomer alone is manufactured, processed, otherwise used or is an NPRI by-product.
  
• all isomers
  This qualifier is applied to cresol, xylene and three hydrochlorofluorocarbons (HCFC-122, HCFC-123 and HCFC-124). Each of these substances should be reported as an aggregate of the individual isomers that have the same chemical formula but different chemical structures. The total quantity of all isomers must be used in calculating the 10-tonne threshold. Refer to Appendices 1 and appendix2.
  
• ionic
  This qualifier, applied to cyanides, includes the salts of hydrogen cyanide but excludes organocyanides, nitriles and organometallic cyanide compounds such as ferrocyanide. In the mining industry, ionic cyanide is equivalent to "weak acid dissociable" cyanide.
  
• total
  For aqueous solutions of ammonia, this means both NH₃and NH₄⁺ expressed as ammonia.
  
• yellow or white
  This qualifier is the general description for the common allotropes of elemental phosphorus.
  
• in solution at a pH of 6.0 or greater
  This distinguishes nitrate ion in neutral or basic solution from nitric acid (pH of less than 6.0). If nitric acid is neutralized to a pH of 6.0 or greater, you must submit a report for both nitric acid and for nitrate ion in solution. Your release or transfer of nitric acid would be "zero" and your release or transfer of nitrate ion would reflect the quantity of neutralized nitric acid reported as nitrate ion in solution at a pH of 6.0 or greater.

In most cases, consider only the substances and the CAS numbers listed. For example, "styrene" is listed with its corresponding CAS number "100-42-5". The chemical description which corresponds to this CAS number does not include "polystyrene". There are no polymers on the NPRI list, only monomers.

Material safety data sheets (MSDSs) are an important source of information on the composition of purchased products. Suppliers of hazardous materials are required, as part of the Workplace Hazardous Material Information System (WHMIS), to supply MSDSs on request.

Units

Report on-site releases and off-site transfers of NPRI Part 1 substances in units of tonnes.

Reporting criteria

In general, any person who owns or operates a facility must submit a report to the NPRI for a substance listed in Schedule 1, Part 1, of the 2001 Canada Gazette notice only if all of the following criteria are met:

• employee criteria (see previous section)
  
• the facility manufactured, processed or otherwise used 10 tonnes (10 000 kg) or more of an NPRI Part 1 substance in the 2001 calendar year, and
  
• the NPRI Part 1 substance was manufactured, processed or otherwise used at a concentration greater than or equal to 1% by weight, with the exception of NPRI substances considered to be by-products. The total weight of by-products must also be included in the calculation of the 10-tonne threshold for each NPRI Part 1 substance.

Figure 2 illustrates the steps to follow to determine if your facility is required to submit a report to the NPRI for a given NPRI Part 1 substance. A facility must meet all the reporting criteria before it is required to report on-site releases and transfers off site for disposal or recycling of the Part 1 substance.

Once you have determined that your facility is required to submit a report for an NPRI Part 1 substance, all on-site releases and all off-site transfers for disposal or recycling of that substance are reportable, regardless of their concentration or quantity (including "zero" releases and transfers).

For guidance on estimating releases and transfers, refer to Step 2 and Appendix 5.

Nature of activities

The terms "manufacture", "process" and "other use" are defined in Schedule 4 of the 2001 Canada Gazette notice. These activities are part of the reporting criteria. An NPRI Part 1 substance at a concentration equal to or greater than 1% or an NPRI Part 1 by-product at a concentration of less than 1%, are only included in the calculation of the 10-tonne reporting threshold if they had been manufactured, processed or otherwise used. An NPRI report does not have to be submitted for a substance that was never manufactured, processed or otherwise used at the facility during the reporting year.

Manufacture

The term "manufacture" means to produce, prepare or compound an NPRI substance. It also includes the incidental production of an NPRI substance as a "by-product" resulting from the manufacture, processing or other use of other substances.

The production of chlorine dioxide by a chemical plant is an example of manufacturing. The production of hydrochloric acid during the manufacture of chlorofluorocarbons is an example of incidental production.

Figure 2: Reporting criteria for Schedule 1, Part 1, substances

Process

The term "process" means the preparation of an NPRI substance, after its manufacture, for distribution in commerce. Processing includes preparation of a substance with or without changes in physical state or chemical form. The term also applies to the processing of a mixture or formulation that contains an NPRI substance as one component, as well as the processing of "articles" (see below).

The use of chlorine (an NPRI substance) to manufacture hypochloric acid (not an NPRI substance) is an example of processing of chlorine. The use of toluene and xylenes to blend paint solvent mixtures is an example of processing without changes in chemical form.

Other use

The terms "other use" and "otherwise used" encompass any use of an NPRI substance at a facility that does not fall under the definitions of "manufacture" or "process". This includes the use of the substance as a chemical processing aid, manufacturing aid or some other ancillary use. The use of trichloroethylene in the maintenance of equipment used for manufacturing and processing is considered an "other use". "Other use" does not include routine janitorial or facility grounds maintenance.

By-products

By-products are included in the calculation of the 10-tonne reporting threshold for Part 1 substances to capture large-volume, low-concentration releases and transfers. The inclusion of by-products when reporting affects facilities that release to the environment or transfer for disposal large quantities of NPRI Part 1 substances, but at concentrations of less than 1%. By-products are not included in the calculation of reporting thresholds for NPRI Part 2, 3 or 4 substances. Some examples of affected sectors include, but are not limited to, power generation, aluminum smelting, and pulp and paper production.

Normally, only NPRI Part 1 substances in concentrations equal to or greater than 1% are included in the threshold calculations. The 1% concentration limit is consistent with the reporting requirements under the WHMIS. Minor constituents (with some exceptions) are not included on MSDS. However, NPRI Part 1 by-products at less than 1% concentration by weight must be included in the calculation of the 10-tonne reporting threshold.

The NPRI applies to any person who possesses or who may reasonably be expected to have access to the types of information requested. This reasonable expectation limits the reporting liability of facilities which cannot easily determine minor amounts of NPRI substances in their feedstock or process.

To determine if an NPRI Part 1 substance is a by-product, all elements of the by-product definition must be considered.

A “by-product” is an NPRI substance that is incidentally manufactured, processed or otherwise used at the facility at a concentration of less than 1% by weight, and is released on site to the environment or transferred off site for disposal.

The NPRI Part 1 substance is not relevant to the manufacture, processing or other use of substances at the facility. It may be the product of an unwanted side-reaction or an impurity in a feedstock material. If the NPRI by-product was absent, there would be no effect on the process. As with substances reportable to the NPRI, it must have been manufactured, processed or otherwise used at the facility.

The NPRI Part 1 substance was manufactured, processed or otherwise used at a concentration of less than 1% by weight.

NPRI Part 1 substances which meet the above criteria are only considered by-products if they are released to the environment or transferred off site for disposal. Substances that are recycled or that remain in the final product are excluded from the by-product definition.

Example 1
Hydrogen fluoride is incidentally manufactured during aluminum smelting. For some large facilities, more than 10 tonnes may be released to the atmosphere at concentrations of less than 1%. The weight of the hydrogen fluoride by-product must be used in the calculation of the 10-tonne reporting threshold.

Example 2
Chromium and nickel are incidentally present in coal. During combustion, a portion of these metals is concentrated in the ash which is transferred off site for disposal and a portion of the metals is released in stack emissions. The weight of the heavy metal by-products must be included in the calculation of the 10-tonne reporting threshold.

Example 3
An NPRI Part 1 substance is present in trace amounts in a product that is repackaged for retail sale. The quantity of this substance released through spillage or through fugitive air emissions cannot be determined because the formulation of the product is proprietary or the substance concentration is not listed on the MSDS and more detailed information cannot be obtained from the supplier or manufacturer. Although this NPRI substance is considered a by-product, it is not included in the calculation of the 10-tonne reporting threshold because it is an unreasonable expectation that the facility could obtain information on the substance identity, concentration or quantity.

Article

An "article" is defined as a manufactured item that does not release an NPRI substance under normal conditions of processing or use.When articles such as metal sheets and bars are processed (punched, cut or sheared) and there are no releases, or the releases such as metal shearings or pieces are recycled 100% or with due care, the NPRI substances in that article need not be included in the threshold calculation. Exercising "due care" in ensuring 100% recycling means that the facility generated less than 1 kg of the NPRI Part 1 substance as waste during the calendar year.Materials that are welded lose their article status since there are releases from the article during welding.

Calculating the 10-tonne reporting threshold

The 10-tonne reporting threshold is based on the quantity of an NPRI Part 1 substance manufactured, processed or otherwise used at the facility at concentrations equal to or greater than 1% plus the quantity of the same NPRI Part 1 substance, at less than 1% concentration, that is considered to be a by-product which is released on site to the environment or transferred off site for disposal.

When calculating the 10-tonne reporting threshold, include the quantity of an NPRI Part 1 substance that is:

• manufactured at a concentration equal to or greater than 1%
• processed at a concentration equal to or greater than 1%
• otherwise used at a concentration equal to or greater than 1%
• a by-product, at less than 1% concentration, released on site to the environment
• a by-product, at less than 1% concentration, transferred off site for disposal

Any NPRI substances that are recycled off site and returned to the facility should be treated as the equivalent of newly-purchased material for the purposes of NPRI threshold determinations. Since an NPRI Part 1 substance may undergo many processes in a facility, care should be taken not to double-count process streams when calculating the reporting threshold.

NPRI Part 1 substances equal to or greater than 1% concentration

The total quantity of an NPRI Part 1 substance manufactured, processed or otherwise used at concentrations greater than or equal to 1%, at any time or in any part of the facility, must be used in the calculation of the 10-tonne reporting threshold.

The quantity of a substance received by a facility at 30% concentration and then diluted to less than 1% for use, is included in the threshold calculation. A substance received at the facility at less than 1% and subsequently concentrated to 5% would also be included in the threshold calculation.

Facilities that blend or formulate NPRI Part 1 substances such as solvents, must include the total quantity of the substance blended or mixed in the reporting threshold calculation since blending, mixing and formulating are considered processing, which is a reportable activity.

Facilities that repackage or transfer NPRI Part 1 substances between containers need only consider the total quantity of the substance repackaged or transferred.

If only a range of concentrations is available for a substance present in a mixture, use the average of the range for threshold determinations.

NPRI Part 1 substances of less than 1% concentration

The total quantity of a by-product released on site to the environment or transferred off site for disposal must be used in the calculation of the 10-tonne reporting threshold. This is the only circumstance under which the quantity of an NPRI Part 1 substance at a concentration of less than 1% is used in calculating the 10-tonne reporting threshold. However, once the reporting criteria have been met, all on-site releases and off-site transfers for disposal or recycling must be reported, regardless of the substance's concentration.

The following examples illustrate application of the by-product definition:

Example 1
A facility uses a pre-polymer mixture which contains unreacted di-n-octyl phthalate monomer at a concentration of less than 1%. The monomer remains in the final product after the processing is complete. The polymer is used to make articles sold for distribution. The unreacted monomer is not released and remains in the product distributed in commerce and therefore is not included in calculating the 10-tonne threshold.

Example 2
Gases produced during coking of coal are recovered and used to supply heat and are therefore not considered by-products. The quantity produced at concentrations of less than 1% should not be used in the calculation of the reporting threshold.

Example 3
Many industrial processes involve separation but not all create by-products. Distillation of crude oil, for example, produces a number of secondary substances intended for distribution in commerce or further use. These are not by-products for the purpose of reporting to the NPRI.

Example 4
Metal cuttings, transferred off site for disposal, contain alloyed chromium at a concentration of less than 1%. The chromium is an essential component of the alloy, therefore it is not incidentally processed and is not considered to be a by-product. The chromium in the metal cuttings is not included in the calculation of the 10-tonne reporting threshold.

Example of calculating the reporting threshold

The following example illustrates the calculation of the 10-tonne reporting threshold. This facility has several processes in which an NPRI Part 1 substance is manufactured, processed or otherwise used.

1. In the first process, NPRI substance "A" is present at 5% concentration and is included in the threshold calculation.
2. In the second process, a raw material added to the process is pure substance "A". It is also included in the threshold calculation, regardless of any subsequent dilution in the process. This also applies to a substance received at the facility at less than 1% which is subsequently concentrated to more than 1% in the process.
3. The weight of substance "A" in the raw material used in process 3 is not included in the threshold calculation because the concentration is less than 1%. Note, however, that since the facility in this example must report because it meets the 10-tonne reporting threshold, it is required to take into account and report releases and transfers from all processes including those, such as process 3, which were not used in the threshold calculations.
4. The weight of substance "A" produced and released from process 4 is included in the calculation because it is a by-product. The concentration criterion does not apply to by-products.

In this example, the facility would be required to submit a report to the NPRI (assuming it also met the 20,000-hour employee threshold) because the total amount of substance "A" manufactured, processed or otherwise used at the facility exceeded 10 tonnes for the calendar year.

Reporting criteria for Schedule 1, Part 2, substance - mercury (and its compounds)

Overview

Mercury and mercury compounds are micro-pollutants which have significant environmental and human health impacts at relatively low levels. Mercury (and its compounds) occur naturally in the environment, but human activities can concentrate them to levels that are toxic to human health and the environment. Because minimal releases of mercury (and its compounds) may result in significant adverse effects and can reasonably be expected to significantly contribute to exceeding the lower thresholds, Environment Canada removed the 1% concentration exemption for mercury (and its compounds) and lowered the reporting threshold.

Substance

Mercury (and its compounds) are listed in Schedule 1, Part 2, of the 2001 Canada Gazette notice. The pure element and any substance, alloy or mixture must be reported as the equivalent weight of the element. No unique CAS number is provided for this listing.

Units

Report on-site releases and off-site transfers of mercury (and its compounds) in units of kilograms (kg).

Reporting criteria

The reporting criteria for mercury (and its compounds) are outlined in Schedule 2, Part 2, of the 2001 Canada Gazette notice and in Figure 3.

A facility is required to report on-site releases and off-site transfers of mercury (and its compounds) if, during the 2001 calendar year:

• employees worked a total of 20 000 hours or more or the facility was used for an activity to which the 20 000-hour employee threshold does not apply (listed in Table 3),

AND

• mercury (and its compounds) were manufactured, processed or otherwise used at any concentration in a quantity of 5 kg or more.

The 1% concentration exemption included in the 10-tonne manufacture, process or other use threshold for Schedule 1, Part 1, substances does not apply to mercury (and its compounds).

A Material safety data sheet (MSDS) is an important source of information on the composition of a purchased product. Suppliers of hazardous materials are required, as part of the Workplace Hazardous Materials Information System (WHMIS), to supply MSDSs on request.

Once you have determined that your facility is required to submit a report for mercury (and its compounds), all on-site releases and all off-site transfers for disposal or recycling of that substance are reportable, regardless of their concentration or quantity (including "zero" releases and transfers).

An example of estimating releases and transfers of mercury (and its compounds) is provided in Appendix 6. Appendix 10 lists various materials and products known to contain mercury. The emission factor database discussed in Appendix 11 contains a list of substances known to contain mercury and emission factors for mercury (and its compounds).

Definitions

The terms "manufacture", "process" and "other use" are defined in the previous section (for Part 1 substances) and in Schedule 4 of the 2001 Canada Gazette notice.

Figure 3: Reporting criteria for mercury (and its compounds)

Article

An "article" is defined as a manufactured item that does not release an NPRI substance under normal conditions of processing or use. This is further explained in the previous section for Part 1 substances. However, there is no quantitative measure of "due care" in recycling mercury (and its compounds) because even minimal releases of mercury can cause significant adverse effects and can reasonably be expected to contribute to exceeding the low threshold of 5 kg. Therefore, if an "article" containing mercury (and its compounds) is processed and there are releases, the mercury (and its compounds) must be included in the threshold calculation.

Example

A fluorescent lamp meets the definition of an article. The mercury content of a fluorescent lamp is only included in a facility's calculation of the 5-kg reporting threshold if the item loses its article status, that is, the lamp is broken, thus allowing a release of mercury. Therefore, as long as fluorescent lamps remain articles, they are not included in calculating the reporting threshold.

Reporting criteria for Schedule 1, Part 3, substances - polycyclic aromatic hydrocarbons (PAHs)

Overview

Polycyclic aromatic hydrocarbons (PAHs) may be used as commercial chemicals or incidentally manufactured. PAHs are listed as a group on the List of Toxic Substances under the Canadian Environmental Protection Act, 1999 (CEPA). PAHs as a group have been assigned Track 2 status under the CEPA, because many sources are natural rather than resulting from human activity.

The inclusion of these 17 PAHs in the NPRI is based on the PAHs classified as persistent, bioaccumulative and toxic substances by Environment Canada's Accelerated reduction/elimination of toxics (ARET) program, known as ARET Group A. Since these 17 PAHs are predominantly incidentally manufactured and released or transferred from facilities, rather than used as commercial chemicals, Environment Canada set alternate reporting criteria based on releases and transfers resulting from incidental manufacture.

There continue to be two Part 1 substances in the NPRI that are considered PAHs - anthracene (CAS No. 120-12-7) and naphthalene (CAS No. 91-20-3). These substances are commercial chemicals used in significant quantities, and are less toxic than the 17 PAHs added to the NPRI at an alternate threshold in 2000. Environment Canada has retained the 10-tonne manufacture, process and other use reporting threshold for anthracene and naphthalene.

Substances

The 17 individual PAHs with an alternate reporting threshold are listed in Schedule 1, Part 3, of the 2001 Canada Gazette notice and in Table 4. These 17 PAHs are listed individually in the NPRI.

Table 4: seventeen PAH substances listed at an alternate threshold

The NPRI has added an additional substance listing in the NPRI reporting software - "PAHs, total Schedule 1, Part 3" - which refers to all 17 PAHs or any combination thereof listed in Schedule 1, Part 3, of the 2001 Canada Gazette notice. The 17 PAHs may be reported under the substance listing titled "PAHs, total Schedule 1, Part 3" only if you do not have information available to estimate releases and transfers for any of the individual PAHs.

Anthracene and naphthalene are listed in Schedule 1, Part 1, of the 2001 Canada Gazette notice and the reporting criteria differ from those discussed in this section. Anthracene and naphthalene must not be considered when you are determining whether your facility met the reporting criteria for the 17 alternate-threshold PAHs, nor in calculating on-site releases or off-site transfers of the 17 PAHs. Anthracene and naphthalene are not included under the "PAHs, total Schedule 1, Part 3" listing.

Units

Report on-site releases and off-site transfers of individual PAHs listed in Schedule 1, Part 3, or "PAHs, total Schedule 1, Part 3" in units of kilograms (kg).

Reporting criteria

The 17 PAHs listed in Part 3 of the NPRI are predominantly incidentally manufactured and released or transferred from facilities, rather than used as commercial chemicals. For this reason, Environment Canada set alternate reporting criteria based on releases and transfers resulting from incidental manufacture.

Except for the activity of wood preservation using creosote, the reporting criteria for PAHs are different from other NPRI-listed substances in the following ways:

• reporting the 17 PAHs is based on the quantities of the substances incidentally manufactured and released or transferred, not on the quantities manufactured, processed, or otherwise used
• you must consider the quantities of all 17 individual PAHs incidentally manufactured together in determining if your facility met the reporting threshold, and
• the reporting threshold is 50 kg.

The substance-specific reporting criteria for the 17 PAHs listed in Table 4 are outlined in Schedule 2, Part 3, of the 2001 Canada Gazette notice and in Figure 4. On-site releases and off-site transfers must be reported for the individual PAH substances even though the 50-kg reporting threshold applies to the total releases and transfers of all 17 alternate-threshold PAHs.

With the exception of the activity of wood preservation (see below), you must submit substance reports on one or more of the 17 PAHs listed in Table 4 that were incidentally manufactured if, during the 2001 calendar year:

• employees worked a total of 20,000 hours or more, or the facility was used for an activity to which the 20,000-hour employee threshold does not apply (listed in Table 3)

and

• any individual PAH (listed in Table 4) was incidentally manufactured, and the quantity of all of the PAHs incidentally manufactured and released on site or transferred off site together totalled 50 kg or more.

Wood preservation using creosote

Wood preservation means the preservation of wood using heat or pressure treatment, or both. There is no 50-kg reporting threshold for PAHs released or transferred from a wood-preservation process using creosote because the PAHs are contained in the creosote and not incidentally manufactured.

PAHs can constitute up to 90% of creosote, and for this reason, may be released or transferred from most wood-preservation activities using creosote.

A facility used for wood preservation must submit a report for each/any of the 17 individual PAHs released on site or transferred off site from a wood-preservation process using creosote, regardless of the quantity of PAHs released or transferred or the number of hours worked by employees. All PAHs released on site or transferred off site from wood-preservation processes using creosote must be reported, regardless of the quantity.

Environment Canada has prepared a technical guide to assist facilities using creosote for wood preservation to estimate their releases. Refer to the "References and bibliography" section of this guide.

Figure 4: Reporting criteria for the 17 PAHs listed at an alternative threshold

Reporting criteria for Schedule 1, Part 4, substances - dioxins/furans and hexachlorobenzene (HCB)

Overview

Polychlorinated dibenzo-p-dioxins (PCDD or dioxins), polychlorinated dibenzofurans (PCDF or furans) and hexachlorobenzene (HCB) are released primarily as by-products of industrial and combustion processes, but are also found as contaminants in certain pesticides or chlorinated solvents. HCB may also be found as a contaminant in ferric chloride used for water or wastewater treatment. These substances have been identified as Track 1 toxic substances under the CEPA, and as such are slated for virtual elimination^{Footnote 1} of releases to the environment.

Because of the persistent and bioaccumulative nature of dioxins/furans and HCB, and their classification as Track 1 substances, Environment Canada has enhanced the reporting requirements for these substances. Environment Canada must be able to set priorities, to implement short-term management strategies, to determine which sectors and which facilities have to virtually eliminate these substances, and to track progress toward the long-term goal of virtual elimination. A quantitative reporting threshold for dioxins/furans and HCB does not address the two requirements related to virtual elimination; as a result, Environment Canada implemented an activity-based reporting threshold.

All facilities engaged in identified activities (see Table 6 and 7) have the potential to incidentally manufacture dioxins/furans or HCB and are therefore required to submit a report to the NPRI. The identified activities were selected by Environment Canada to cover all main point sources of dioxins/furans and HCB releases being targetted by the Canada-Wide Standards initiatives for dioxins/furans and HCB. Reporting by limited sectors known to release these substances will capture all significant releases from such facilities, while minimizing reporting burden on other facilities reporting to the NPRI.

Substances

Dioxins/Furans

Dioxins/furans are listed in Schedule 1, Part 4, of the 2001 Canada Gazette notice as "polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans". There is no CAS number provided for the dioxin/furan group since the listing includes the 17 most toxic dioxin and furan congeners. A congener is a compound belonging to a family of compounds having similar chemical skeletons, but differing in the number and position of hydrogen substitutes. The 17 congeners and their CAS numbers are referenced in Schedule 1, Part 4, of the 2001 Canada Gazette notice in a footnote to the "polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans" listing, and below in Table 5.

Because these 17 congeners have related toxic effects that are cumulative, report on-site releases and off-site transfers of dioxins/furans together as a group, in grams of toxicity equivalent (TEQ) to the most toxic congener of dioxin (2,3,7,8-tetrachlorodibenzo-p-dioxin). You estimate the quantity in grams of TEQ of dioxins/furans released or transferred by adding the individual units of TEQ for each congener. A more detailed description of TEQ and its calculation is provided in Step 2.

Table 5: dioxin and furan congeners included in the NPRI dioxins/furans group

Hexachlorobenzene (HCB)

Hexachlorobenzene (HCB) has the CAS No. 118-74-1 and is listed in Schedule 1, Part 4, of the 2001 Canada Gazette notice.

Units

Dioxins/furans

Report quantities of dioxins/furans released on site and transferred off site in units of grams of toxic equivalents (g TEQ) of the 17 congeners listed in Table 5. Units of grams TEQ are further discussed in Step 2.

HCB

You must report the quantities of HCB released on site and transferred off site in units of grams (g).

Reporting criteria

The reporting criteria for dioxins/furans and HCB are outlined in Schedule 2, Part 4, of the 2001 Canada Gazette notice, and are summarized in Figure 5.

If a facility was "used for" one of the activities not required to meet the 20,000-hour employee threshold, that facility was used primarily or exclusively for that activity.

If a facility was "engaged in" an activity, then that facility was engaged in the activity at any time during the year, regardless of extent or the primary purpose of the facility.

You must submit substance reports for dioxins/furans and HCB if your facility met one or more of the following criteria, regardless of the quantity of dioxins/furans or HCB released on site or transferred off site:

• your facility was used for one or more of the activities in Table 6, regardless of the 20,000-hour employee threshold
• your facility was engaged in one or more of the activities in Table 6 or table7, and your facility met the 20,000-hour employee threshold, and/or
• your facility was used for wood preservation using pentachlorophenol, regardless of the 20,000-hour employee threshold.

Table 6 lists the activities for which substance reports are required for dioxins/furans and HCB, regardless of the total number of hours worked by employees at the facility in the 2001 calendar year.

Figure 5: Reporting criteria for dioxins/furans and HCB

If your facility was used for one or more of the activities set out in Table 6, you must submit substance reports for dioxins/furans and HCB. Only report on-site releases and off-site transfers that resulted from the incidental manufacture of dioxins/furans or HCB while engaging in the listed activities. A description of the activities listed in Table 6 is provided below.

Table 6: activities for which dioxins/furans and HCB reports are required (20,000-hour employee threshold does not apply)

Activity

1. Non-hazardous solid waste incineration of 100 tonnes or more of waste per year, including small combustion units, conical burners and beehive burners
2. Biomedical or hospital waste incineration of 100 tonnes or more of waste per year
3. Hazardous waste incineration
4. Sewage sludge incineration

If your facility engaged in one or more of the activities set out in Table 7, and your facility met the 20,000-hour employee threshold in the 2001 calendar year, you must submit substance reports for dioxins/furans and HCB. A description of the activities listed in Table 7 is provided below.

Table 7: activities for which dioxins/furans and HCB reports are required (20,000-hour employee threshold applies)

Activity

1. Non-hazardous solid waste incineration of 100 tonnes or more of waste per year, including small combustion units, conical burners and beehive burners
2. Biomedical or hospital waste incineration of 100 tonnes or more of waste per year
3. Hazardous waste incineration
4. Sewage sludge incineration
5. Base metals smelting (this refers to copper, lead, nickel and zinc)
6. Smelting of secondary lead
7. Smelting of secondary aluminum
8. Manufacturing of iron using a sintering process
9. Operation of electric arc furnaces in steel manufacturing
10. Operation of electric arc furnaces in steel foundries
11. Production of magnesium
12. Manufacturing of portland cement
13. Production of chlorinated organic solvents or chlorinated monomers
14. Combustion of fossil fuel in a boiler unit, for the purpose of producing steam for the production of electricity, with a generating capacity of 25 megawatts or greater of electricity
15. Combustion of hog fuel originating from logs that were transported or stored in salt water in the pulp and paper sector
16. Combustion of fuel in kraft liquor boilers used in the pulp and paper sector

A description of what and how you must report is given in Step 2; examples of estimation methods and reporting scenarios are provided in Appendix 6. There are special reporting requirements for dioxins/furans and HCB, outlined in Step 2.

Wood preservation using pentachlorophenol

Wood preservation means the preservation of wood using heat or pressure treatment, or both. If your facility was used for wood preservation using pentachlorophenol, you must submit substance reports for dioxins/furans and HCB, regardless of the number of hours worked by employees.

Description of activities listed in Tables 6 and 7

Incineration activities

The first four activities listed in Tables 6 and table7 are forms of waste incineration.Waste incineration, for the purposes of the NPRI, only includes incineration that takes place in a waste incinerator.Waste incineration does not include open burning of wastes.

A waste incinerator is a device, mechanism or structure constructed primarily to thermally treat (for example, combust or pyrolyze) a waste for the purpose of reducing its volume, destroying a hazardous chemical present in the waste, or destroying pathogens present in the waste. This includes facilities where waste heat is recovered as a by-product from the exhaust gases from an incinerator (for example, energy-from-waste incinerators). This also includes conical burners and beehive burners. This does not include industrial processes where fuel derived from waste is fired as an energy source, such as industrial boilers. Refer to Table 7 if you combust wastes in industrial boilers, as your facility may meet dioxins/furans and HCB reporting criteria for another activity.

a) Non-hazardous solid waste incineration of 100 tonnes or more of waste per year, including small combustion units, conical burners and beehive burners

Non-hazardous solid waste means any waste, regardless of origin, which might normally be disposed of in a non-secure manner, such as at a sanitary landfill site, if not incinerated. It includes clean wood waste, that is, waste from woodworking or forest product operations, including bark, where the wood waste has not been treated with preservative chemicals (for example, pentachlorophenol) or decorative coatings. Non-hazardous solid waste incineration includes incineration of residential and other municipal wastes in conical burners, and clean wood waste in beehive burners.

A facility engaged in the incineration of 100 tonnes or more of non-hazardous solid waste per year must submit substance reports for dioxins/furans and HCB.

b) Biomedical or hospital waste incineration of 100 tonnes or more of waste per year

Biomedical waste is defined fully in Appendix 3. Biomedical or hospital waste refers to waste that is generated by:

• human or animal health-care facilities

• medical or veterinary research and testing establishments

• health-care teaching establishments

• clinical testing or research laboratories

• facilities involved in the production or testing of vaccines

Biomedical or hospital waste includes human anatomical waste and animal waste. It also includes microbiology laboratory waste, human blood and body fluid waste, and waste sharps that have not been disinfected or decontaminated. It does not include waste from animal husbandry, or waste that is controlled in accordance with the Health of Animals Act (Canada).

Wastes that are household in origin, or that are generated in the food production, general building maintenance and office administration activities of those facilities to which this definition applies are not considered to be biomedical or hospital waste but rather to be non-hazardous solid waste.

A facility engaged in the biomedical or hospital waste incineration of 100 tonnes or more of waste per year must submit substance reports for dioxins/furans and HCB.

c) Hazardous waste incineration

Hazardous waste is defined fully in Appendix 4. Hazardous waste includes those wastes that are potentially hazardous to human health and/or the environment because of their nature and quantity, and that require special handling techniques. Hazardous waste incinerators must be licensed or authorized by the responsible jurisdiction. Hazardous waste incinerated in a mobile incinerator temporarily located at your facility must be included as part of this activity.

A facility engaged in the incineration of hazardous waste must submit substance reports for dioxins/furans and HCB, regardless of the quantities incinerated.

d) Sewage sludge incineration

Sludge means a semi-liquid mass removed from a liquid flow of wastes. Sewage sludge means sludge from a facility treating wastewater from a sanitary sewer system. The drying of sludge to reduce water content is part of the incineration stage.

A facility engaged in the incineration of sewage sludge must submit substance reports for dioxins/furans and HCB, regardless of the quantities incinerated.

Smelting activities

Smelting includes the melting of raw or scrap materials (containing metals) to produce metal for further processing into metal products (that is, castings, ingots, sheets, etc.). The smelting process is typically accompanied by a chemical change in which impurities are removed (that is, the addition of flux to separate metals from other contaminants).

e) Base metals smelting

Base metals refers to copper, lead, nickel and zinc. This activity does not include smelting of aluminum or any other metals. It also does not include the smelting of secondary lead, which is a separate activity listed in Table 7 (see description below).

f) Smelting of secondary lead

Secondary lead refers to lead-bearing scrap or lead-bearing materials, other than lead-bearing concentrates derived from a mining operation. Facilities engaged in smelting of lead-bearing concentrates derived from a mining operation are considered to be base metals smelters (see description above).

g) Smelting of secondary aluminum

Secondary aluminum refers to aluminum-bearing scrap or aluminum-bearing materials. Secondary aluminum smelting involves two processes - pre-cleaning and smelting - both of which may produce emissions of dioxins/furans.

Other activities

h) Manufacturing of iron using a sintering process

Sintering is the welding together and growth of contact area between two or more initially distinct particles at temperatures below the melting point, but above one-half of the melting point (in degrees Kelvin). In sintering operations, dioxins/furans may be formed as unwanted by-products during high-temperature decomposition and combustion of raw materials containing chlorine and organic compounds.

i) Operation of electric arc furnaces in steel manufacturing

In an electric arc furnace, material is heated by the heat energy released from an electric arc. The electric arc is a component of an electric circuit, like a resistor, but with its own peculiar characteristics. Dioxins/ furans may be formed as unwanted by-products during high-temperature decomposition and combustion of raw materials containing chlorine and organic compounds.

j) Operation of electric arc furnaces in steel foundries

In an electric arc furnace, material is heated by the heat energy released from an electric arc, during which dioxins/furans and HCB may be formed.

k) Production of magnesium

Production of magnesium from magnesium chloride by electrolysis may result in the generation of dioxins/furans and HCB.

l) Manufacturing of portland cement

Portland cement is a fine greyish powder consisting of four basic materials - lime, silica, alumina and iron compounds. Cement production involves heating (pyroprocessing) the raw materials to a very high temperature in a rotating kiln to induce chemical reactions that produce a fused material called clinker. The cement clinker is further ground into a fine powder, then mixed with gypsum to form portland cement.

m) Production of chlorinated organic solvents or chlorinated monomers

This activity is limited to the intentional manufacturing of chlorinated organic solvents or chlorinated monomers, and does not include coincidental production.

n) Combustion of fossil fuel in a boiler unit, for the purpose of producing steam for the production of electricity, with a generating capacity of 25 megawatts or greater of electricity

Fossil fuel means a fuel that is in a solid or liquid state at standard temperature and pressure, such as coal, petroleum or any liquid or solid fuel derived from such. This activity includes electric power-generation utilities and large industrial facilities co-generating electric power using waste heat from industrial processes. It does not include combustion of natural gas or other fuels that are gaseous in form at ambient pressure and temperature. It also does not include diesel generators, which are not boiler units.

o) Combustion of hog fuel originating from logs that were transported or stored in salt water in the pulp and paper sector

Pulp and paper boilers burning salt-laden wood are unique to British Columbia. Dioxins/furans are emitted from the burning of salt-contaminated hog fuel. Logs transported and stored in salt water take up chlorine into the bark. The bark is stripped from logs and ground up with other waste wood to produce hog fuel. The material is then used as boiler fuel to produce heat and electrical energy for pulp and paper processes. The Canada-Wide Standards for Dioxins and Furans state that every boiler covered by the Standards will be tested twice each year to determine the emissions of dioxins/furans to air for the years prior to 2003, and annually for the year 2003 and beyond.

p) Combustion of fuel in kraft liquor boilers used in the pulp and paper sector

A kraft liquor boiler burns black liquor, composed mostly of lignin, the residue from the digester in a kraft (sulphate) pulping process. The boiler recovers chemical products from the combusted black liquor, which are later recycled, and also produces steam which is used in mill process operations.

You now have completed Step 1 and should know whether you are required to report to the NPRI and, if so, for which substances.

Note that if your facility met the reporting criteria, you must submit a report even if the on-site releases or off-site transfers for disposal or recycling of NPRI substances were zero.

Threshold calculations do not need to be reported to the NPRI. Their purpose is to determine the substance for which a facility is required to report on-site releases and transfers off site for disposal or recycling. Keep this information in your files.

If you are not required to report

If you have concluded that you are not required to report for your facility, either because it is an exempt facility or it does not meet all the reporting criteria, advise your regional NPRI office (listed on the inside front cover) to update its records and mailing lists.

If you are required to report

If you have concluded that you are required to report for your facility, continue with Steps 2 through step7 to complete and submit your NPRI report. You will need a copy of the NPRI reporting software, available on the NPRI reporting software CD. Contact your NPRI regional office (listed on the inside front cover) should you have any questions.

You are legally required to submit your NPRI report and a signed statement of certification to your regional NPRI office, postmarked, courier-dated or e-mailed no later than June 1, 2002. If you do not have access to a computer, a paper reporting form can be provided by your regional NPRI office. Extra copies of the reporting package can also be ordered from your regional NPRI office.