Implementation guidelines for Environmental Emergency Regulations: appendix 5

Appendix 5: determination of container capacity and substance quantity

Introduction

Appendix 5 provides guidance on how to calculate:

• the maximum capacity of the single largest container in which the substance is stored
• the total quantity of the substance on site

Appendix 5 also shows how the Environmental Emergency Regulations (E2 regulations) apply to pure substances and mixtures for both above-mentioned calculations.

Before you start calculating the quantities of a substance on your site, you first need to verify if your substance(s) is captured by the exclusion in section 2 of the E2 regulations, which states:

2. For the purposes of the definition "substance" in section 193 of the act, the list of substances consists of the substances set out in column 1 of Schedule 1 in their pure form or in a mixture that has a concentration equal to or greater than the applicable concentration set out in column 2 but does not include

(a) a substance set out in column 1 of Part 1 of Schedule 1 that is a component of a mixture that has a flash point equal to or greater than 23°C or a boiling point equal to or greater than 35°C;

(b) a substance set out in column 1 of Part 2 of Schedule 1 when the substance is a gas or a liquid that is a component of a mixture and the partial pressure of the substance is equal to or less than 10 mm of mercury;

(c) a substance set out in column 1 of Part 1 of Schedule 1 that is a component of natural gas in its gaseous form;

(d) a substance that is subject to the Transportation of Dangerous Goods Act, 1992, or the Canada Shipping Act, 2001, unless the substance is being loaded or unloaded at a facility; and

(e) solid nickel oxide in particles that measure more than 10 microns (μm) in diameter.

The threshold quantity and concentration for each regulated substance are listed in Appendix 3 of the implementation guidelines. You must first verify whether the threshold concentration applies to you. If yes, then you determine whether the total quantity of each regulated substance at the place, or the maximum capacity of the container in which the substance is stored is equal to or greater than, the listed threshold quantity. If the substance quantity or the maximum capacity exceeds the listed threshold quantity, the regulatee must comply with the E2 regulations for that substance.

Important: Note that, in the E2 regulations,

• the threshold quantity for each substance listed is based on its pure form
• if a mixture is identified by a Chemical Abstracts Service (CAS) registry number listed in Schedule 1 of the E2 regulations, it must be considered a substance, not a mixture
• if the substance is a pure substance under Part 1, Part 2 or Part 3 of Schedule 1 of the E2 regulations, the weight of the substance, in tonnes, must be used to determine the quantity of substance

1. Maximum capacity of the largest container

Maximum capacity

The maximum capacity of the largest container is determined by the maximum quantity of the substance required to fill the container to 100% capacity. No consideration is given to the administrative controls to limit the quantity within the tank, or to industrial standards for maximum design capacity and therefore are not acceptable for calculating the maximum capacity of the container.

This approach differs from a risk management program (RMP) process, which allows for administrative controls of the maximum container capacity. Environment and Climate Change Canada chose this approach after accidents occurred in which containers were inadvertently filled above the allowable limit. For example, on a hot day in Quebec in the summer of 2005, a propane tank was filled over the provincial limit. The hot temperatures caused expansion and a leak in the tank’s bleeder valve, which led to an explosion.

Thus, it is unacceptable to:

• use the safety level to calculate the maximum capacity of the container, or
• take into account administrative controls in determining the largest quantity

Maximum capacity of interconnected tanks

If interconnected containers each have one or more shut-off valves, then each segregated container is considered a separate container, because a leak in one container will not release the entire contents of all the interconnected containers.

If there are no shut-off valves between the interconnected containers, then one must consider the entire quantity within that system (including pipes) to be one single large container. By the same token, closed-loop systems must also be treated as a single process or a single container.

In situation 1, it is possible to isolate each tank due to the location of the valve.

To determine the maximum capacity of the largest container in situation 1, you should take into account the capacity of the largest tank without including the capacity of the connected pipes. Therefore, you must consider the tank with the largest capacity to determine the worst-case scenario.

In situation 2, it is possible to isolate each tank due to the location of the valve.

To determine the maximum capacity of the largest container in situation 2, you should take into account the capacity of the largest tank and the capacity of the pipes connected between the tank and the valve. Therefore, you must consider the tank with the largest capacity and the relevant pipes (A or B) to determine the worst-case scenario.

In situation 3, due to the location of the valve, it is impossible to isolate either of the tanks if you have a leak on a pipe between the valve and the tanks.

To determine the maximum capacity of the largest container in situation 3, you should take into account the capacity of the two tanks and the capacity of the pipes connected between the tanks and the valve. Therefore, you must consider these two tanks with the relevant pipes (A, B and C) as a single system when evaluating the worst-case scenario.

In calculating a worst-case accident scenario, you must consider the potential release of the greatest possible quantity of the substance, from the largest container, for which the impact distance is the greatest. Environment Canada, like the U.S. Environmental Protection Agency (EPA), advises that, in calculating the worst-case scenario for an accidental release, you should use the contents of the largest container (U.S. EPA 2009) .

2. Maximum quantity of a substance on site

The “maximum quantity of a substance” means more than the quantity found in a single container. Rather, it means the maximum quantity of a substance found during the calendar year in all the storage places and processes, including pipes, that are within the borders of the facility.

Volume to weight conversion

Often the capacity of the container is expressed in volume (for example, litres, cubic metres or U.S. gallons). To calculate the maximum quantity and capacity of a substance stored in a container, the volume must be converted into weight (tonnes) by using the density of the substance. This allows for comparison with the threshold quantity indicated in the E2 Regulations. The density is generally available in the product’s MSDS.

Below are examples provided in order to help determine the maximum quantity of a pure substance. Please note that specific exceptions exist in subsection 3(2) of the E2 regulations.

2.1 Calculation of the quantity of a pure substance

Pure substances - Part 1

Example 1

A pure substance implies that the concentration of cyclohexane, in this example, is in its purest form. Therefore, the concentration is over 1% and closer to 100% purity.

In E2 regulations: Cyclohexane (CAS #: 110-82-7); Column 2: minimum concentration 1%; Column 3: threshold quantity 550 t

Quantities of cyclohexane at a site:

• 4 tanks each filled with a total quantity of 180 t (maximum capacity of each tank is 200 t)
• one tank filled with 54 t (maximum capacity of 60 t)
• an additional 10 t found in the process stream

Calculation determining the total tonnage of cyclohexane at the site:

(Number of tanks × quantity in tanks) + Additional quantity on site =
(4 tanks × 180 t per tank) + (1 tank × 54 t) + 10 t in process =
(720 t) + (54 t) + (10 t) = 784 t

E2 website reporting

Compare the column 3 threshold for cyclohexane with the quantities found at the site.

Maximum capacity of single largest container = 200 t
200 t (at site) < 550 t (in E2 regulations)

Total quantity on site = 784 t
784 t (on site) = 550 t (in E2 regulations)

In this example, a Notice of identification and place (Schedule 2) and Certification (Schedule 3), must be submitted because only one criterion was met.

The following example shows how the information would be reported using ECCC's online notification.

Figure 1: Example of an online notification using the above example for cyclohexane

Example 2

In E2 regulations: Benzene (CAS #: 71-43-2); Column 2: minimum concentration 1%; Column 3: threshold quantity 10 t

Quantities of benzene at a site:

• 3 tanks each filled with a total quantity of 90 000 L (maximum capacity of each tank is 100 000 L)
• one tank filled with 450 L (maximum capacity of 500 L)
• an additional 1000 L found in the process stream

Calculation determining the total tonnage of benzene at the site:

The volume of benzene must be converted from litres into tonnes using the density of the substance. Knowing that the density of benzene is 0.879 kg/L, the following equation can be used to determine the total quantity of the substance on site.

(Number of tanks × quantity in tanks) + additional quantity on site =
(3 tanks x 90 000 L per tank) + (1 tank × 450 L) + 1000 L in process =
(270 000 L) + (450 L) + (1000 L) = 271 450 L

Total quantity (litres) × density (kg/L) =

Calculated maximum capacity of the single largest container:

The largest container at 100 000 L would also require conversion from litres to tonnes.

E2 website reporting:

Compare column 3 threshold for benzene with quantities found at the site.

Maximum capacity of single largest container = 87.9 t
87.9 t (at site) ≥ 10 t (in E2 regulations)

Total quantity on site = 238.6 t
238.6 t (at site) ≥ 10 t (in E2 regulations)

In this example, a Notice of identification of substance and place (Schedule 2), Certification (Schedule 3), the Report of preparation (Schedule 4), and the Notice of implementation and testing of an E2 plan (Schedule 5), must be submitted.

The following example shows how the information would be reported using ECCC’s online notification.

Figure 2: Example of an online notification using the above example for benzene

Pure substances - Part 2

Example 3

In E2 regulations: Allylamine (CAS #: 107-11-9); Column 2: minimum concentration 10%; Column 3: threshold quantity 4.5 tonnes

Quantities of allylamine at a site:

• 1 tank filled with a total quantity of 1700 US gallons (maximum capacity of tank is 2000 US gallons)

Calculation determining the total tonnage of allylamine at the site and the maximum capacity:

The volume of allyamine must be converted from US gallons into tonnes using the density of the substance. Knowing that the density of allylamine is 0.760 kg/L, and that one US gallon equals 3.7854 L, the following equation can be used to determine the total quantity of the substance on site.

E2 website reporting:

Compare column 3 threshold for allyamine with quantities found at the site.

Maximum capacity of single largest container = 5.75 t
5.75 t (at site) ≥ 4.5 t (in E2 regulations)

Total quantity on site = 4.89 t
4.89 t (at site) ≥ 4.5 t (in E2 regulations)

In this example, a Notice of identification of substance and place (Schedule 2), Certification (Schedule 3), the Report of preparation (Schedule 4), and the Notice of implementation and testing of an E2 plan (Schedule 5), must be submitted.

The following example shows how the information would be reported using ECCC’s online notification.

Figure 3: Example of an online notification using the above example for allylamine

Example 4

In E2 regulations: Sulphur dioxide (CAS #: 7446-09-5); Column 2: minimum concentration 10%; Column 3: threshold quantity 2.27 t

Quantities of sulphur dioxide at a site:

• 1 tank filled to 80% capacity (maximum capacity of tank is 20 000 US gallons)

Sulphur dioxide is stored under pressure in the liquefied state.

Calculation determining the total tonnage of sulphur dioxide at the site and the maximum capacity:

The density must be used to determine the total quantity of substance on site. Knowing that the density of sulphur dioxide is 1.430 kg/L and that one US gallon equals 3.7854 L, the quantity of sulphur dioxide, in tonnes, can be calculated:

Filled to 80% capacity: 0.8 x 20 000 = 16 000 US gallons

E2 website reporting:
Compare column 3 threshold for sulphur dioxide with quantities found at the site.

Maximum capacity of single largest container = 108.3 t
108.3 t (at site) ≥ 2.27 t (in E2 regulations)

Total quantity on site = 86.69 t
86.6 t (at site) ≥ 2.27 t (in E2 regulations)

In this example, a Notice of identification of substance and place (Schedule 2), Certification (Schedule 3), the Report of preparation (Schedule 4), and the Notice of implementation and testing of an E2 plan (Schedule 5), must be submitted.

The following example shows how the information would be reported using ECCC’s online notification.

Figure 4: Example of an online notification using the above example for sulphur dioxide

Pure substances - Part 3

Example 5

In E2 Regulations: Trichloroethylene (CAS #: 79-01-6); Column 2: minimum concentration 1%; Column 3: threshold quantity 1.13 t

Quantities of trichloroethylene at a site:

• 2 tanks each filled with a total quantity of 3000 L (maximum capacity of each tank is 3800 L)
• one tank filled with 50 L (maximum capacity of 65 L)
• an additional 500 L found in the process stream

Calculation determining the total tonnage of trichloroethylene at the site:
The volume of trichloroethylene must be converted from litres into tonnes using the density of the substance. Knowing that the density of trichloroethylene is 1.46 g/cm³, the following equation can be used to determine the total quantity of the substance on site.

(Number of tanks × quantity in tanks) + additional quantity on site =
(2 tanks × 3000 L per tank) + (1 tank × 50 L) + 500 L in process =
(6000 L) + (50 L) + (500 L) = 6550 L

Total quantity (litres) × density (g/cm³) =

Calculated maximum capacity of the single largest container:

The largest container at 3800 L would also require conversion from litres to tonnes.

E2 website reporting:
Compare column 3 threshold for trichloroethylene with quantities found at the site.

Maximum capacity of single largest container = 5.548 t
5.548 t (at site) ≥ 1.13 t (in E2 regulations)

Total quantity on site = 9.563 t
9.563 t (at site) ≥ 1.13 t (in E2 regulations)

In this example, a Notice of identification of substance and place (Schedule 2), Certification (Schedule 3), the Report of preparation (Schedule 4), and the Notice of implementation and testing of an E2 plan (Schedule 5), must be submitted.

2.2 Calculation of the Quantity of a Substance in a Mixture

Mixtures - Part 1

The volatility of a substance is taken into account by the flash point and boiling point criteria. “Flash point” is defined as the lowest temperature at which a substance gives off sufficient vapour to form an ignitable mixture with air near its surface or within a vessel.

If the chemical has a flash point of less than 23°C and a boiling point of less than 35°C , then the substance is capable of causing a vapour cloud explosion. If the substance does not have a flash point, or if the substance sublimes, or decomposes, below the cut-off temperatures, then the substance will not be considered flammable or combustible. A mixture is considered non-flammable when either the flash point or boiling point does not meet the flammability criteria described above. For this reason, a non-flammable mixture that includes a substance found in Part 1 of Schedule 1 is excluded from the E2 regulations.

The threshold quantity for a vapour cloud explosion is set at 4.5 t (metric tonnes) (10 000 lbs) because, in the event of an explosion, this quantity would result in an approximate overpressure of 3 pounds per square inch (psi) at a distance of 100 m (J.P. Lacoursière 2002). The calculation is performed using the TNT model with Process Hazard Analysis Software Tools (PHAST) software.

Gasoline and natural gas are exceptions found in Schedule 1 of the E2 regulations since they are composed of several substances. In the context of the E2 regulations, these listed substances are to be considered as single pure substances.

The following example illustrates how the calculations are performed for substances within mixtures under Part 1. It is recommended that one still consider creating an E2 plan to deal with any emergencies related to this mixture, even if the substance is not subject to the E2 regulations.

Mixtures - Part 2

The partial pressure of the regulated substance within the mixture must be measured or estimated and documented. If the substance within the mixture has a partial pressure less than 10 millimetres of mercury, or 10 mmHg (133 kPa), the substance within the mixture is excluded for the purpose of the E2 regulations.

However, if the substance in the mixture has a partial pressure greater than 10 mmHg, the mass of the regulated substance within the mixture must be determined and used to calculate the total quantity of regulated substance on site and the capacity of the largest container.

Example 6

In E2 regulations: Hydrochloric acid (CAS#: 767-01-0); Column 2: minimum concentration 30%; Column 3: threshold quantity 6.8 t

Example 7

In E2 regulations: Ammonia, solution (CAS #: 7664-41-7); Column 2: minimum concentration 20%; Column 3: threshold quantity 9.10 tonnes

Quantities of ammonia, solution at a site:

• 5 tanks each filled with a total quantity of 8 t (maximum capacity of each tank is 10 t)
• concentration at site is 25%

Calculation determining the total tonnage of ammonia at the site and the maximum capacity:

Total quantity of mixture= 5 x 8 = 40 t

But the mixture is not pure; it is at 25%. Therefore, the following equation should be used:

Quantity of regulated substance = Quantity of mixture × Concentration (%) of regulated substance

Quantity of ammonia = 40 t mixture x 25% = 10 t

Total capacity of single largest container = 5 x 10 = 50 t
50 t x 25% = 12.5 t

E2 website reporting:

Compare column 3 threshold for ammonia, solution with quantities found at the site.

Maximum capacity of single largest container = 12.5 t
12.5 t (at site) ≥ 9.10 t (in E2 regulations)

Total quantity on site = 10 t
10 t (at site) ≥ 9.10 t (in E2 regulations)

In this example, a Notice of identification of substance and place (Schedule 2), Certification (Schedule 3), the Report of preparation (Schedule 4), and the Notice of implementation and testing of an E2 plan (Schedule 5), must be submitted.

The following example shows how the information would be reported using ECCC’s online notification.

Figure 5: Example of an online report using the above example for ammonia solution

Example 8

In E2 regulations: Ammonia, solution (CAS #: 7664-41-7); Column 2: minimum concentration 20%; Column 3: threshold quantity 9.10 t

Quantities of ammonia, solution at a site:

• 1 tank filled with a total quantity of 16 t (maximum capacity of each tank is 20 t)
• the concentration at the site is 44%

Calculation determining the total tonnage of ammonia, solution at the site and the maximum capacity:

Total quantity of mixture = 16 t

But the mixture is not pure; it is at 44%. Therefore, the following equation should be used:

Quantity of regulated substance = Quantity of mixture × Concentration (%) of regulated substance

E2 website reporting:

Compare column 3 threshold for ammonia, solution with the quantities found at the site.

Maximum capacity of single largest container = 8.8 t
8.8 t (at site) < 9.10 t (in E2 regulations)

Total quantity on site = 7.04 t
7.04 t (at site) < 9.10 t (in E2 regulations)

In this example, the quantity of substance on site does not exceed the threshold quantity indicated in column 3 of Schedule 1 for this substance. Moreover, the largest container (8.8 t) is also smaller than the threshold quantity mentioned above. Therefore, no notice has to be submitted.

Example 9

In E2 regulations: Hydrochloric acid (CAS #: 7647-01-0); Column 2: minimum concentration 30%; Column 3: threshold quantity 6.80 t

Quantities of Hydrochloric acid at a site:

• 1 tank filled with a total quantity of 40 000 L (maximum capacity is 50 000 L)
• the concentration at site is 31%

Calculation determining the total tonnage of Hydrochloric acid, solution at the site and the maximum capacity:

The quantity of the mixture, in tonnes, must first be determined by taking into account the density of the mixture. If the density of Hydrochloric acid equals 1.16 kg/L, then the quantity of the mixture in tonnes is:

The maximum possible weight of the pure substance must now be calculated. The solution of 31% hydrochloric acid (HCl) is composed of 69% water and 31% hydrogen chloride. We are interested in the hydrogen chloride part of the solution.

Quantity of HCI = 46.4 tonnes x 31% = 14.4 tonnes

Maximum capacity = 58 tonnes x 31 % = 18.0 tonnes of HCI

E2 website reporting:

Compare column 3 threshold for hydrochloric acid with quantities found at the site.

Maximum capacity of single largest container = 18 t
18 t (at site) ≥ 6.80 t (in E2 regulations)

Total quantity on site = 14.4 t
14.4 t (at site) ≥ 6.80 t (in E2 regulations)

In this example, a Notice of identification of substance and place (Schedule 2), Certification (Schedule 3), the Report of preparation (Schedule 4), and the Notice of implementation and testing of an E2 plan (Schedule 5), must be submitted.

The following example shows how the information would be reported using ECCC’s online notification.

Figure 6: Example of an online report using the above example for hydrochloric acid

Mixture - Part 3

Example 10

In E2 regulations: Nickel acetate (CAS #: 373-02-4); Column 2: minimum concentration 10%; Column 3: threshold quantity 0.22 t

References

J.P. Lacoursière Inc. 2002. Rationale for the development of a List of regulated substances under CEPA Section 200 and their threshold quantities. Prepared for Environment Canada, National Program Directorate, Environmental Emergencies Branch, Ottawa. Project No. P00092.

U.S. EPA (2009) United States Environmental Protection Agency, Office of Solid Waste and Emergency Response, Risk Management Program Guidance For Offsite Consequence Analysis, EPA 550 B-99-009, March 2009. Available at https://www.epa.gov/rmp/rmp-guidance-offsite-consequence-analysis