Section 6: Compliance and Emission Testing and Monitoring (Comments and Responses)

• 6.1 Compliance
• 6.2 Emission Testing and Monitoring

• When emission limits are exceeded, due to malfunctions, or operation during start-up or shut down, it should be required that the exceedances are reported immediately to the appropriate regulatory agency.

Environment Canada agrees that the appropriate regulatory agencies are best situated to receive notification of exceedances. In Section 10(2) of the proposed Guidelines (Section 12(2) of the revised Guidelines to be gazetted in 2002), it is recommended that notification of malfunctions and breakdowns, which may result in exceedances, are to be reported at least every calendar quarter. Environment Canada believes that the appropriate regulatory agencies are best situated to determine if immediate reporting is required.

• The requirements for monitoring and reporting should be removed from the Guidelines and implemented through jurisdictional permitting processes.

As indicated previously, the Guidelines are one part of a collaborative approach which recognizes that jurisdictions implement regulatory requirements for electric power plants. The Guidelines present Environment Canada's expectations for appropriate performance standards at the national level for emissions from new plants, and the federal Minister of the Environment recommends that jurisdictional air pollution control agencies adopt the Guidelines as practical baseline standards for their regulatory programs. Environment Canada considers monitoring and reporting to be integral to the performance standards.

Thus, Environment Canada considers it important to have, at the national level, consistent standards for both emissions performance and emissions monitoring and reporting. Recognizing that pollution does not respect borders, Canada needs a high level of accurate, reliable and consistent data on emissions from power plants in Canada to support its work with other jurisdictions to reduce the flow of transboundary pollution. Such data is also expected to be of value to the electricity industry in the increasingly integrated North American electricity market. Consistent monitoring and reporting of emissions data from new plants is one step on that direction.

Whereas Environment Canada agrees that requirements for monitoring and reporting should be implemented through jurisdictional permitting processes, it does not agree to removing provisions in the Guidelines calling for nationally consistent monitoring and reporting.

• Continuous Emission Monitors (CEMs) should be required for monitoring emissions from new plants.
• Clarification is needed for the definition of 'continuous monitoring system'. It is unclear if this refers to an actual CEM instrument, or if the use of software CEMS and/or predictive emissions monitoring systems (PEMS) would be acceptable.

Sections 8 and 9 of the proposed Guidelines (Sections 10 and 11 of the revised Guidelines to be gazetted in 2002) contain provisions for continuous emission monitoring (CEM). These provisions refer to Environment Canada report EPS 1/PG/7, "Protocols and Performance Specifications for Continuous Monitoring of Gaseous Emissions from Thermal Power Generation". As the title suggests, this report presents the CEM provisions in the form of performance specifications, not a particular instrument, and this means that any system meeting these performance specifications would be acceptable. For practical purposes however, software CEMS and PEMS would not fully meet the quality assurance performance specifications required in report EPS 1/PG/7.

• Is the reference to EPS 1/PG/7 appropriate in the section on emission testing in the Guidelines? This document is for CEM performance evaluation and does not specify methods for stack testing.

The report EPS 1/PG/7 provides specifications for the design, installation, certification and operation of CEM systems. No specific monitoring system has been designated in this report. Any system that meets initial certification criteria and additional specified parameters during each year of operation is acceptable.

• The phrase "...as amended from time to time...", in section 8 of the proposed Guidelines, should be removed. This phrase, describing the opacity reference method, seems ridiculous given that this method has not been revised since 1975.

The phrase "as amended from time to time" is a standard phrase added to references to methods, protocols or performance specifications for emissions monitoring in order that the many references do not have to be revised each time an amendment is made to the methods, protocols or performance specifications. Environment Canada does not plan to alter this standard practice and does not believe that this impairs the Guidelines.