Section 1: Introduction

• 1.1 Changes for 2000
  • 1.1.1 Clarification of the Terms “Used for” and “Engaged in
  • 1.1.2 Activities to Which the 20 000-hour Employee Threshold does not Apply
  • 1.1.3 New Substances and their Reporting Criteria
• 1.2 Consultations

The National Pollutant Release Inventory (NPRI) was created in 1992 by Environment Canada to provide Canadians with information on pollutants released to their environment. NPRI data also support a wide range of environmental initiatives, including pollution-prevention and -abatement activities.

On December 25, 1999, the "Notice with Respect to Substances in the National Pollutant Release Inventory for 2000" was published in the Canada Gazette, Part I, under the authority of subsection 16(1) of the Canadian Environmental Protection Act (CEPA), 1988. This notice specifies that any person owning or operating a facility that met the reporting criteria prescribed in the notice, provide this information to the Minister of the Environment by no later than June 1, 2001.

An amendment to the Canada Gazette notice was published on December 23, 2000, to provide clarification on the reporting criteria. The clarifications published in the amendment are included in this Supplementary Guide. In this document, all references to the 2000 Canada Gazette notice refer collectively to the notice published on December 25, 1999, and its amendment published on December 23, 2000.

The purpose of this Supplementary Guide is to assist owners and operators of facilities to understand the reporting criteria for substances with alternate thresholds, to determine if they must report for any of these substances, and to provide examples of how to estimate on-site releases and off-site transfers of these substances. The substances listed in the NPRI for 2000 with alternate reporting thresholds are:

• mercury (and its compounds)
• 17 individual polycyclic aromatic hydrocarbons (PAHs), and
• dioxins/furans and hexachlorobenzene (HCB).

The Guide for Reporting to the National Pollutant Release Inventory - 2000 (referred to as the Guide for Reporting) details the information that is required and explains how to complete an NPRI report for all NPRI-listed substances.

More information on the NPRI is available on Environment Canada's Web site at www.ec.gc.ca/pdb/npri.

Significant changes were made to the NPRI for the 2000 reporting year. These changes are outlined below and are discussed in detail in the subsequent chapters of this Supplementary Guide.

A facility is required to report to the NPRI if, during the 2000 calendar year:

• employees worked a total of 20 000 hours or more, or the facility was used for an activity to which the 20 000-hour employee threshold does not apply (employee criteria)

AND

• the facility met the reporting criteria for the given substance (substance criteria).

If a facility was "used for" one of the activities not required to meet the 20 000-hour employee threshold, that facility was used primarily or exclusively for that activity.

If a facility was "engaged in" an activity, then that facility was engaged in the activity at any time during the year, regardless of extent or the primary purpose of the facility.

In previous years, a facility was exempt from reporting to the NPRI if its employees worked less than 20 000 hours during the reporting year (equivalent to 10 full-time employees). Environment Canada has removed the 20 000-hour employee threshold for facilities used for certain types of incineration and for wood preservation (see Schedule 2, Part 5, of the 2000 Canada Gazette notice). This change was made because, although facilities used for these activities are known to release significant quantities of NPRI pollutants to the environment, they may not have been required to report to the NPRI since they did not meet the 20 000-hour employee threshold.

For the 2000 reporting year, the NPRI list of substances (see Appendix 3) is divided into four parts in Schedule 1 of the 2000 Canada Gazette notice, because there now are four sets of substance-specific reporting criteria (outlined in Schedule 2). These changes are summarized below.

Schedule 1, Part 1, Substances

For 2000, there are 248 substances listed in Schedule 1, Part 1, of the 2000 Canada Gazette notice. A facility is required to report on-site releases and off-site transfers of a substance listed in Schedule 1, Part 1, that was manufactured, processed, or otherwise used in a quantity equal to or greater than 10 tonnes. Only NPRI Part 1 substances at a concentration equal to or greater than 1% by weight, and NPRI by-products at a concentration of less than 1% by weight are included in the calculation of the 10-tonne threshold.

Four substances were added to Schedule 1, Part 1, of the 2000 Canada Gazette notice with the reporting criteria outlined above (10-tonne threshold). The substances and their Chemical Abstracts Service (CAS) registry numbers are:

• acrolein (CAS No. 107-02-8)
• 4-tert-octylphenol (CAS No. 140-66-9)
• oxirane, methyl-, polymer with oxirane, mono(nonylphenyl)ether (CAS No. 37251-69-7), and
• polymeric diphenylmethane diisocyanate, commonly referred to as PMDI (CAS No. 9016-87-9).

Schedule 1, Part 2, Substances [Mercury (and its compounds)]

Mercury has been on the substance list since the inception of the NPRI. The need to lower the reporting threshold was identified during consultations with stakeholders see (Chapter 3). Starting in the 2000 reporting year, a facility is required to report on-site releases and off-site transfers of mercury (and its compounds) if they were manufactured, processed or otherwise used, at any concentration, in a quantity of 5 kg or more.

Schedule 1, Part 3, Substances [Polycyclic Aromatic Hydrocarbons (PAHs)]

Seventeen polycyclic aromatic hydrocarbons (PAHs) were added to the NPRI for 2000 at an alternate threshold. These 17 PAHs are listed in Schedule 1, Part 3, of the 2000 Canada Gazette notice, and in Table 2 (Chapter 4) of this Supplementary Guide. The reporting criteria are based on quantities released or transferred rather than quantities manufactured, processed or otherwise used, except in the case of wood preservation using creosote.

Reporting of one or more of the 17 PAHs is required if:

• any individual PAH (listed in Table 2) was incidentally manufactured and the quantity of all PAHs released on site or transferred off site as a result of incidental manufacture together totalled 50 kg or more,

OR

• any of the 17 individual PAHs was released on site or transferred off site from a wood-preservation process using creosote.

You must consider these 17 PAHs together, as a group, in determining whether your facility met the 50-kg threshold and must report for one or more of the 17 listed PAHs. On-site releases and off-site transfers must be reported individually for each of the 17 PAH substances that was incidentally manufactured and released or transferred. The reporting criteria for PAHs are discussed in detail in Chapter 4.

Schedule 1, Part 4, Substances [Dioxins/Furans and Hexachlorobenzene (HCB)]

Environment Canada added polychlorinated dibenzo-p-dioxins (dioxins) and polychlorinated dibenzofurans (furans) to the NPRI for 2000. These substances must be reported together, and include the 17 most toxic dioxin and furan congeners. These substances are referred to in this Supplementary Guide as dioxins/furans. Hexachlorobenzene (HCB) was also added to the NPRI for 2000. Dioxins/furans and HCB are listed in the NPRI in Schedule 1, Part 4, of the 2000 Canada Gazette notice.

Facilities engaged in certain activities identified in Schedule 2, Part 4, of the 2000 Canada Gazette notice and Tables 4 and 5 (Chapter 5) are required to report dioxins/furans and HCB to the NPRI, and there is no substance-based quantitative reporting threshold. Some of the information that must be reported to the NPRI for dioxins/furans and HCB may differ from the information required in other NPRI substance reports. Further information is provided in Chapter 5.

In 1998, Environment Canada established the NPRI Multistakeholder Ad Hoc Work Group on Substances. The Work Group considered several substances for addition to the NPRI at alternate reporting thresholds. The substances considered pose serious risks to human health and/or the environment in relatively low quantities. Because very limited data, if any, would be reported to the NPRI at a 10-tonne manufacture, process or other use reporting threshold, alternate thresholds were implemented for these substances. The Work Group provided recommendations to Environment Canada regarding candidates for addition and discussed appropriate reporting criteria for these substances.

Mercury, PAHs, dioxins, furans and HCB are all on the List of Toxic Substances of the CEPA (1999). Dioxins, furans and HCB have been identified as Track 1 substances under the Toxic Substances Management Policy (TSMP) and are considered to be persistent, bioaccumulative and toxic substances. Further details on the consultations used to consider substances for addition to the NPRI at alternate thresholds are provided in Chapters 3 to 5, in Appendix 6, and on the NPRI Web site.