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Isoprene
Responses to Comments - PartIV: Comments on Proposed Schedules of the Working Document
Comment:
Recommended a question asking if the facility is already participating in an Environmental Management System, with recognition to CIAC’s Responsible Care program be added to Schedule 1 of the Notice. If a facility is member in good standing of Responsible Care, Environment Canada should identify what reductions in burden are possible from the P2 plan.
Response:
Those subject to a Notice who already have a P2 plan or environmental management system (EMS) in place must evaluate the current plan or system to determine if it meets all the requirements set out in the Notice. If the plan does meet all the requirements of the Notice, it is not necessary to prepare a new plan; however, the required information (Schedules 1, 4 (if necessary), and 5 of the Notice) still needs to be filed.
If an existing plan or system doesn't meet all the requirements of the Notice, it can be amended or an additional P2 plan that covers the remainder of the requirements of the Notice can be prepared. These provisions are set out in section 57 of CEPA 1999.
Comment:
In Schedule 1, part 1.0, it is suggested the Facility Technical Contact include both a Name and a Title, similar to the General Contact Information for the facility. Is it required that the Facility Contact and the Technical Contact be separate persons, so there is more than one contact to the facility?
Response:
The Technical Contact and General Contact can be the same person or different persons.
Comment:
Part 3.0 of the Schedules 1, 4 and 5, in identifying the Substance and Activity, if facilities indicate “Isoprene & Any other activity within the resin and synthetic rubber manufacturing sector that involves the use of isoprene” then there should be a text box to explain the “other activity”.
Response:
A comment line has been included in the appropriate parts of the schedules in the proposed P2 Planning Notice so persons may specify when they select other.
Comment:
In Schedule 1, part 4.0(c), the preparation year is presented as 2012, but it is possible the P2 plans be put in place in 2011 or more likely in 2013.
We suggest an allowance be made in the final forms for the different potential timelines, for instance, be left blank on the forms and the facilities fill in. This would also be applicable to any facility that joins subsequently and has a different base year.
Response:
Part 4.0(c) allows persons subject to the Notice to have a preparation year other than 2012 in cases they were granted a time extension to prepare a plan or they became subject to the Notice after the date of its final publication.
Comment:
In Schedule 1, part 4.1, the options are called “Nature of Activity”. This terminology may be confusing, as activities are already used in part 3 of the Schedule and in the Notice itself. Suggested these options be called “Substance Actions or Uses or Applications”.
Recommended each subgroup in part 4.1 have and “Other (specify)” option, as it is possible that a substance use may not be described by any of these options. If some of these options in this part are already excluded from the P2 plan e.g. distribution, why are they included in the Schedule? Recommended to review what activities need to be listed in Schedule 1 based on what isoprene activities are actually specified as being involved in the P2 Plan process.
Response:
The Schedules were prepared considering all possible set of activities carried out within the manufacturing process of synthetic rubber that potentially require the use of isoprene, and potentially pose a risk of releases of isoprene to the environment, and therefore also pose a risk to human health.
These activities are standard in all Notices but facilities are only required to check off those that apply.
Comment:
Several parts in the schedules require facilities to indicate the Basis of Estimate Code for substance uses or non emission types of estimates, based on estimation methods presented in part 4.0(b) of Schedule 1. However, the estimation methods in part 4.0(b) are for emission calculations, so other methods are more appropriate than the ones listed.
It is suggested to modify the list in 4.0(b) to reflect the methods most commonly used to estimate usage volumes or non-emission types of estimates. Alternatively, "Other - explanation" could be added to part 4.0(b) OR a separate pick list could be identified for this subpart OR the respondent could be free to identify a method with a text explanation and not be restricted to a pick list code. Also, in recent P2 Plan consultations, the assertion was made that the estimation methods are "listed in declining order of expected accuracy’' -this was misleading and arguably incorrect. lt is positive that this assertion or phrase on expected accuracy was not included in the isoprene plan.
Response:
Part 4(b) has been modified to address these comments.
Comment:
In Schedule 1, Part 4.4.2 Off-Site Transfer for Disposal, the text includes the explanation: "Report only the net mass of the substance that was sent off site, not the total mass of the mixture containing the substance". This explanation is useful to build understanding and should also be inserted in other relevant parts e.g. 4.4.I (& others).
Response:
Explanatory text was included in part 4.4.2 and 4.4.3 of the schedule because it is applicable to individual net mass rather than the net total mass required in this part. At this moment, it is not considered that similar text is applicable to other parts of the schedules.
Comment:
In parts 4.4.2 and 4.4.3 of Schedule 1, the facility is asked to identify what type of treatment activity the off-site transfer will be subject to. It is suggested this be written in the context of "if known’’ by the facility. In part 4.4.1 it is recognized disposal activity may not be known to the facility and "if known" is indicated.
Response:
Text in parts 4.4.2 and 4.4.3 of Schedule 1 is consistent with the reporting of type of transfers as defined by the NPRI.
Comment:
In Schedule 1, part 4.5.1, the first question asks what the annual operating time of the facility is in hours. The need for this data or information is questioned. It is suggested this question be deleted.
Facilities should provide information on their type of processes and operations.
Response:
Annual operation time is a useful information to help understand how Canadians living around the surrounding of facilities are exposed to emissions of isoprene in a year.
Text has been added to part 4.5.1 of the Schedules 1, 4 and 5 to include a request of information from the facilities on their processes and operations.
Comment:
It is recommended to remove from part 4.5.1 of the schedules 1, 4, and 5 the requirement to report on accidental or non-routine releases such as spills. In the P2 Plan air emissions are the concern and as such only reflect "normal conditions of operation". Besides, the Notice itself does not require consideration of accidental or non-routine conditions, so it is inappropriate for the report form itself to introduce any new requirements.
Response:
Spills of isoprene could lead to releases of isoprene to air and consequently should be taken into account when predicting the maximum 24-hour average concentration of isoprene at or beyond the fence line using AERMOD.
Text has been added to the proposed Notice to include accidental or non-routine spills as a factor to consider when preparing the plan.
Comment:
In Schedule 1, part 4.5.1; the column 5 of table identifies Typical or Current Isoprene
Concentration in Extracted Air [mg/m3]. It is recommended to clarify if "Extracted Air" refers to ambient or stack concentration. Also, the units in the table are mg/m3, whereas elsewhere in the document ug/m3 are used. Is the request for mg/m3 correct? The same discrepancy between ug/m3 and mg/m3 is present in part 5.1.3.
Also, a number of entries in this table are pre-populated with n/a -not applicable. In a number of entries for column 5, it is believed the concentration of isoprene is available from the method and the n/a is inappropriate and should be removed. This potential knowledge of the ambient concentrations of isoprene can be extrapolated to the table in part 5.3.1.
Response:
The word “Extracted” was removed and the text was replaced in the Schedules 1, 4, and 5 of the proposed Notice by ”Typical/Current Concentration of Isoprene released to Air”.
Environment Canada uses mg/m3 for stack as the concentration at this source could differ by orders of magnitude from the concentration at or beyond the fence line.
The “not applicable (n/a)” was also removed from the table in the Schedules 1, 4, and 5 of the proposed Notice.
Comment:
In Schedule 1, part 4.5.2 requires a discussion about the AERMOD simulations. At this time it should be noted that facilities will not likely be operating this model but will be dependent on specialized consultants. As such, Environment Canada should recognize that facilities maybe delayed due to consultants and consultants will have some of the liability in the certification of a report from a facility.
Response:
It is the responsibility of the facility to meet the requirements of the P2 Planning Notice.
However, under subsection 56(3) of CEPA 1999, a person subject to the Notice may apply for an extension of the period published in the Notice for the preparation and/or implementation of a P2 Plan by submitting a written request for an extension before the expiry of the period referred to in the Notice or any extended period.
Comment:
ln part 5.3.2 of the declaration forms there is a reference to "annual on-site releases of isoprene in mg/m3. We believe this is an error since the modeling is conducted on a 24-hour averaging basis. We recommend striking the word "annual" from the text.
Also, it is not clear what is being requested in part 5.1.5. Some clarifications in wording, and/or examples would be helpful.
Response:
Change has been incorporated in the proposed Notice.
The “baseline elements affected” requested in this part of the Schedules refer to on-site uses, actual on-site releases of isoprene to air, off-site transfers for product distribution, off-site transfers for disposal, and off-site transfers for recycling. Additional information and instructions will be provided with the Final Notice that will specify the information required in Part 5.1.5 and other parts of the reporting schedules.
Comment:
In Schedule 1, part 5.1 and 5.1.1, a facility can have more than one activity underway at any one time. The Schedules should be flexible enough to allow for reporting on multiple activities.
Response:
For each activity identified in Part 3.0 of the Schedule 1, the facility will have to complete all the information required in Part 5.1 of the reporting schedules. In addition, Parts 5.1.1 through 5.1.6 must be completed separately for each anticipated action in the P2 plan (i.e. Part 5.1 of the Schedule will be completed as many times as there are anticipated actions to report). This has been made clear in the instructional text provided within this part of the reporting schedules.
Comment:
Given that the objective of the P2 plan is to improve/reduce health and environmental risk by reducing exposures or emissions, it is recommended that facilities report on the Environmental Objective (or the Health Objective) in addition to reporting on the Risk Management Objective in part 7.0 of the Schedules 1, 4 and 5. It is suggested to include a part 7a to report on the Risk Management Objective, a part 7b to report on the Health Objective, and a part 7c to report on the Environmental Objective.
Response:
The risk management objective for isoprene addresses both the environmental and human health objectives stated in the Risk Management Approach for isoprene. Facilities subject to the P2 Planning Notice are required to describe in the reporting schedules how they have met the risk management objective for isoprene.
Comment:
In Schedule 1, Part 8.0, there is a reference to the ability for a facility to gain a waiver, and the Notice includes an entire schedule to request a waiver (Schedule 2). This is the first apparent mention of the ability to gain a waiver. We recommend that the ability to be granted a waiver be explicitly referenced early in the text of the Notice. In the same spirit, we recommend that the Notice explicitly reference the ability to be granted a time extension.
Response:
Section16 of the proposed P2 Planning Notice “Application for waiver of factors to consider” presents information on the option to request a waiver and points at Schedule 2 as the written report that must be submitted by facilities that wish to request a waiver of a factor to consider when preparing a Plan.
Similarly, section 15 of the proposed P2 Planning Notice “Extension of time” presents information on the option to request an extension of time for the preparation of the plan and/or for the implementation of the plan, and points at Schedule 3 as the written report that must be submitted by facilities that wish to request an extension of time to prepare or to implement a Plan.
Comment:
It is understood that the schedules will be completed on-line and not manually with paper copies. It is questioned if that is acceptable in the case for the certifications. Can they be done electronically OR will they need to be mailed in separately with a signature?
Also, can legal documents be exclusively done on-line with no recourse with completing paper copies?
Response:
Environment Canada encourages that Schedules be submitted through the Pollution Prevention Planning Online Reporting Tool. However facilities are still required to mail/fax or email a copy of their entire Schedule in which the certification Part has been signed by the duly authorized personnel for that facility.
Comment:
In Schedule 2, Part 2, it is not understood why a facility must “exactly” identify the factors. Clarify or provide an explanation for the use of the word “exactly”.
Response:
Schedule 2 has been revised and the word “exactly” has been removed.
Comment:
In Schedule 2, Part 3, last text box –this schedule is to request a waiver to considering a factor. Yet, this box asks what additional factors the facility will consider. The connection between the waiver request and additional factors to consider is not apparent. It is suggested the information in the third box is inappropriate to ask when considering a waiver and should be deleted.
Response:
The last question in Part 3 of Schedule 2 gives facilities who are requesting to waive a factor the option to identify if there is an alternative “factor to consider” to the one for which they are requesting a waiver.
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