National Pollutant Release Inventory: regional synopsis for the Atlantic provinces, chapter 2

The NPRI

• Reporting Requirements
• Exempt Activities

Reporting Requirements

Each year, the Minister of Environment publishes a Notice respecting the NPRI in the Canada Gazette, under the authority of section 46 of the CEPA, 1999.

For the 2000 reporting year, the Notice requires the owners or operators of facilities which meet certain criteria to file a report with Environment Canada declaring the amounts of any of the 268 NPRI pollutants released on-site to the environment or transferred off-site for disposal or recycling / recovery.

For the 'core' 248 NPRI substances, facilities must submit a report if they meet all three of the following reporting criteria:

• employees at the facility work 20,000 hours or more in a calendar year, and;
• the facility manufactures, processes or otherwise uses 10 tonnes (10,000 kg) or more of an NPRI substance, and;
• the substance is at a concentration of 1% or greater, unless produced as a by-product. By-products must be considered at any concentration.

Facilities that incinerate waste or are used for wood preservation must submit a report, regardless of the number of hours their employees work, provided that the facility meets the second and third criteria listed above for the 'core' NPRI substances.

For the purposes of the NPRI, incineration includes:

• biomedical or hospital waste incineration of 100 tonnes or more of waste per year,
• non-hazardous solid waste incineration of 100 tonnes or more of waste per year, including small combustion units, conical burners and beehive burners;
• hazardous waste incineration (any quantity); and
• sewage sludge incineration (any quantity).

As of 2000, facilities in certain sectors are required to submit reports for 20 substances that have lower reporting thresholds which differ from the original NPRI reporting criteria, as listed above. These substances with lower or alternate reporting thresholds are mercury (and its compounds), polycyclic aromatic hydrocarbons (PAHs), hexachlorobenzene (HCB), and dioxins / furans.

For mercury (and its compounds), facilities must report if they meet both of the following criteria:

• employees at the facility work 20,000 hours or more in a calendar year, and;
• the facility manufactures, processes or otherwise uses 5 kg or more of mercury and its compounds, regardless of concentration.

Facilities that incinerate waste or are used for wood preservation must file a report, regardless of the number of employees, provided that the facility meets the second criteria listed above for mercury.

For polycyclic aromatic hydrocarbons (PAHs), facilities must report if they meet the following criteria:

• employees at the facility work 20,000 hours or more in a calendar year, and;
• the facility incidentally manufactures a single PAH and releases or transfers 50 kg or more total PAHs.

Facilities that incinerate waste or are used for wood preservation other than using creosote must file a report if they incidentally manufacture a single PAH and they release or transfer 50 kg or more total PAHs, regardless of the number of hours their employees work.

Wood preserving facilities that use creosote must submit a report regardless of the number of employee-hours worked or quantity of PAHs produced.

For hexachlorobenzene (HCB) and dioxins/ furans (PCDD/Fs), facilities engaged in the following activities must submit a report if their employees work 20,000 hours or more at:

• base metal smelting;
• smelting of secondary lead or secondary aluminum,
• operation of electric arc furnaces in steel foundries or steel manufacturing;
• manufacturing of portland cement;
• production of chlorinated organic solvents or chlorinated monomers;
• 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 more of electricity;
• production of magnesium;
• combustion of fuel in kraft liquor boilers in the pulp and paper sector; or
• combustion of hog fuel originating from logs that were transported or stored in salt water in the pulp and paper sector.

Facilities that are used primarily for incineration or wood preservation must file a report for HCB and dioxins/furans, regardless of the number of hours their employees work.

Wood preserving facilities that use pentachlorophenol must submit a report, regardless of the number of employees or quantity of HCB and dioxin/furans produced.

Note: Facilities must submit a NPRI report if the above-noted reporting criteria are triggered, even if they do not release any NPRI substances or do not have sufficient information to estimate a release.

Exempt Activities

Certain facilities are exempt from reporting to the NPRI. These exemptions apply to every substance in the NPRI. Substances used exclusively for the following activities are not included in determining whether a facility meets the NPRI reporting criteria:

• educating or training students, such as universities, colleges and schools;
• research or testing;
• maintenance and repair of transportation vehicles, such as automobiles, trucks, locomotives, ships or aircraft;
• distribution, storage or retail sale of fuels;
• 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;
• retail sale of NPRI substances;
• growing, harvesting or managing renewable natural resources, such as fisheries, forestry or agriculture, but not those facilities which process or otherwise use renewable natural resources;
• mining, but not include those facilities which process or otherwise use mined materials;
• drilling or operating wells to obtain oil and gas products, but not those facilities which process or otherwise use oil and gas products, or;
• the practice of dentistry.