On April 6, 2023, Environment and Climate Change Canada (ECCC) hosted an Information Session detailing the changes to reporting requirements for the National Pollutant Release Inventory (NPRI), starting with the 2022 reporting year. Below is a summary of the updates. If you have any questions about these changes, or your organization's regulatory compliance, please contact us.
Substances
New substance: Chlorhexidine (CHX) and its salts (CAS RN 55-56-1)
- Reporting thresholds: 100 kg/1% concentration manufacture, process or otherwise use
Deleted substances:
- Hexachlorocyclopentadiene (CAS RN 77-47-4)
- Methyl iodide (CAS RN 74-88-4)
Changes to all substances:
- The reason a substance is being reported for the first time must now be reported
- Facilities are now required to report any applicable identification number(s) for their provincial or territorial:
- Operating permit
- Approval
- Authorization
- License
- Certificate
- Any other applicable program identifier(s)
- Two new bases of estimate have been added
- Remote quantification
- Speciation profile
Changes to release to air categories
Changes to release to air categories 1
- The “storage or handling releases” category has been changed to “storage tank and related handling releases”
- Previous definition: releases to air from storage or handling of materials
- New definition: Releases from the storage of liquids in tanks, releases associated with liquid storage tank operations, releases from the transfer, loading and unloading of liquids to and from storage tanks, losses associated with the storage of liquids in tanks, and losses associated with the cleaning, degassing and maintenance of storage tanks
All other releases that result from storage or handling should be reported as either stack or point releases or fugitive releases.
Changes to release to air categories 2
- “Spills” has been changed to “spills or other accidental releases.”
- “Road dust” has been changed to “unpaved road dust.”
- These are changes to the names of the categories only – releases that were previously reported under these categories will continue to be reported under these categories
Changes to release to air categories 3
- Facilities are strongly encouraged to determine how their releases fit into the five air release categories and to not report releases under the “Other non-point releases” category
- Facilities reporting releases under the “Other non-point releases” category are now required to provide a comment specifying the nature of the releases
Changes to an exemption for Parts 1-3 substances
- Exemption from reporting Parts 1-3 substances from “research and testing” activities has been re-worded to “research and development”
- Change in wording only
- Exempted activities remain the same
- New wording is intended to clarify the activities to which it applies
Stacks/flares
Assigning releases to individual stacks and flares
- Changes have been made to the requirements for Part 4 criteria air contaminants (CACs) and Part 5 speciated VOCs in order to increase individual stack/flare reporting
- Exempted stacks:
- Horizontal or non-vertical stacks (e.g., gooseneck shape)
- Stacks/vents from storage tanks
- Stacks/flares at Case 3 and Case 4 oil and gas facilities
Stack/flare height threshold
Old height threshold: 50m
New height threshold: 25m
- The physical height of the stack or the effective height of the flare from ground level
- If a stack or flare is located on top of a building, the height of the building must be added to the height of the stack or flare
Stack/flare exit temperature threshold
Old temperature threshold: n/a
New temperature threshold: 50°C
- The annual average temperature [in degrees Celsius (°C)] of the released gas when it exits the stack or the effective temperature of the released gas when it exits the flare
- The threshold for the average annual exit temperature can only be applied if the exit temperature is determined through measurement
- Estimations, values supplied by manufacturers, values used for the purposes of obtaining an operating approval or permit and default values cannot be used to verify if the temperature threshold is met
Reporting the annual average stack exit temperature
- For stacks, facilities can report:
- Annual average temperature [in degrees Celsius (°C)] of the released gas when it exits the stack
- Annual average stack exit temperature that was used for the purposes of obtaining a current approval or a permit
- That the annual average exit temperature is unknown
- Due to the wide variety of possible non-flare stacks, ECCC does not recommend a default exit temperature for stacks
Reporting the annual average flare exit temperature
- For flares, facilities can report:
- Annual average temperature [in degrees Celsius (°C)] of the released gas when it exits the flare
- Annual average exit temperature that was used for the purposes of obtaining a current approval or a permit
- A default value of 1000°C
- That the annual average exit temperature is unknown
Stack/flare air release thresholds
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Criteria air contaminant (CAC)
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Old release threshold (tonnes)
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New release threshold (tonnes)
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Carbon monoxide (CO)
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5
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10
|
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Nitrogen oxides (expressed as nitrogen dioxide) (NOx)
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5
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10
|
|
Particulate matter ≤ 2.5 micrometres (PM2.5)
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0.15
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0.25
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Particulate matter ≤ 10 micrometres (PM10)
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0.25
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0.5
|
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Total particulate matter (TPM)
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5
|
25
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Sulphur dioxide (SO2)
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5
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25
|
|
Total volatile organic compounds (total VOCs)
|
5
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5
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Combustion and fuel
Combustion and fuel use sources
Old requirement: Total quantities of a CAC released from a stack or flare were reported
New requirement: Quantities of a CAC released from a stack or flare must be reported separately in 5 categories of combustion and fuel use source types
Combustion and fuel use source types
Quantities of CACs released from each stack and flare must be reported separately for each of the following source types:
- Stationary fuel combustion for energy purposes
- Combustion of fuels for non-energy purposes
- Flaring
- Use of fuels for non-energy products
- Releases from all other sources not included in the above categories
- Releases from all sources, if releases from the separate sources were not able to be calculated
Fuel types
Old requirement for each stack or flare: Fuel type not required
New requirement for each stack or flare: Fuel type must be reported
- For the purposes of reporting to the NPRI, fuels are categorized as follows:
- Solid fossil fuels
- Liquid fossil fuels – refined petroleum products
- Gaseous fossil fuels
- Natural gas liquids
- Industrial production by-products used as fuel
- Biomass/biofuels
- Waste materials
- Other fuels
- All fuel types that apply must be selected in the system
- Some fuel types require that a comment also be provided
Basis of estimate
Old requirement for each stack or flare: No basis of estimate required
New requirement for each stack or flare: Basis of estimate must be reported
Condensable particulate matter (PM)
- Starting with the 2022 reporting year and for future years, facilities reporting stack or point releases of PM2.5, PM10 or total particulate matter must now indicate if their reported releases include condensable PM
- Filterable particulate matter is particles that are directly emitted by a source as a solid or liquid (aerosol) at stack or release conditions and that are captured on the filter of a stack test sampling train. Filterable PM is a component of primary PM
- Condensable particulate matter (CPM) is material that is a vapor at stack conditions, but that condenses and/or reacts upon cooling and dilution in ambient air to form solid or liquid PM immediately after discharge from the stack. CPM is a component of primary PM. All CPM is assumed to be in the PM2.5 fraction
Changes to the thresholds for reporting part 5 speciated volatile organic compounds (VOCs) - facilities
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Old requirements
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New requirements
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To determine whether a facility is required to report a speciated VOC:
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1. Total VOCs releases from the facility are ≥10 tonnes
AND
2. Releases of a speciated VOC from the facility are ≥1 tonne
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1. Releases of a speciated VOC from the facility are ≥1 tonne
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Changes to the thresholds for reporting part 5 speciated volatile organic compounds (VOCs) - stacks and flares
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Old requirements
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New requirements
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To determine whether reporting on releases of a speciated VOC is required for a stack or flare:
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1. Total VOCs releases from the facility are ≥10 tonnes
AND
2. Releases of a speciated VOC from the facility are ≥1 tonne
AND
3. Total VOCs releases from the stack or flare are ≥5 tonnes |
1. Releases of a speciated VOC from the facility are ≥1 tonne
AND
2. Releases of a speciated VOC from the stack or flare are ≥0.25 tonnes
|
Pollution Prevention Changes
Starting with the 2021 reporting year:
- Report ONLY the pollution prevention activities that occurred during the current reporting year
- P2 activities are now required to be associated to a specific substance
- Explanation on what/how activities reduced pollution required at the activity level
- Comments on why a substance is removed due to P2 activities are now required
Reasons Removed from Report
- Ability to associate a P2 activity to 1 substance or ALL substances at once
- Option of “Pollution prevention activities” listed for reason as to why a substance no longer being reported
- System now requires a comment to be provided as an enhancement to the system based on feedback from users
- Users were unable to identify how their P2 activities resulted in a substance NOT meeting NPRI reporting requirements
Pollution Prevention Activities
- System now has 2 trigger questions on the General Reporting Questions page for Pollution Plans AND Activities
- Activities trigger question IS NOT pre-filled, as reportable activities are to be reported annually
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