Environmental Code of Practice for integrated steel mills: section 4
Section 4: Recommended Environmental Protection Practices
- 4.1 Atmospheric Emissions Management
- 4.1.1 Targets and Schedules for Release Reductions
- 4.1.2 Release Guidelines for Particulate Matter
- 4.1.3 Environmental Performance Indicators
- 4.1.4 Collection of Furnace Emissions
- 4.1.5 Control of Fugitive Emissions
- 4.1.6 Chlorinated Solvents Used in Solvent Degreasing
- 4.1.7 Ambient Air Quality Monitoring
- 4.2 Cokemaking
- 4.2.1 Coke Ovens
- 126.96.36.199 Charging Operations
- 188.8.131.52 Coke Oven Doors
- 184.108.40.206 Topside Port Lids
- 220.127.116.11 Offtake Systems
- 18.104.22.168 Coke Pushing
- 22.214.171.124 Coke Wet Quenching
- 126.96.36.199 Bypass/Bleeder Stacks
- 4.2.2 Coke By-Product Plant
- 188.8.131.52 Storage Tanks
- 184.108.40.206 Fugitive Emissions
- 220.127.116.11 Benzene Transfer Operations
- 18.104.22.168 Process Cooling Water
- 22.214.171.124 Open Trenches and Sumps
- 126.96.36.199 Containment of Process Pumps and Tanks
- 4.2.1 Coke Ovens
- 4.3 Water and Wastewater Management
- 4.3.1 Effluent Guidelines
- 4.3.2 Environmental Performance Indicator
- 4.3.3 Wastewater Collection
- 4.3.4 Water Use/Reuse
- 4.3.5 Wastewater Containment Sizing
- 4.3.6 Environmental Effects Monitoring
- 4.4 Waste Management
- 4.5 Best Environmental Management Practices
- 4.5.1 Implementation of an Environmental Management System
- 4.5.2 Environmental Policy Statement
- 4.5.3 Environmental Assessment
- 4.5.4 Emergency Planning
- 4.5.5 Pollution Prevention Planning
- 4.5.6 Decommissioning Planning
- 4.5.7 Environmental Training
- 4.5.8 Environmental Facility Inspection
- 4.5.9 Monitoring and Reporting
- 4.5.10 Environmental Auditing
- 4.5.11 Environmental Performance Indicators
- 4.5.12 Life Cycle Management
- 4.5.13 Community Advisory Panel
- 4.5.14 Other
This section presents recommended mitigative measures for activities of potential environmental concern. These recommendations were derived from regulatory and non-regulatory standards, in particular on environmental practices, published by various agencies and organizations.
The overall objective of the Code is to identify minimum environmental performance standards for new integrated steel mills and to provide a set of environmental performance goals for existing mills to achieve through continual improvement over time.
Application of the recommendations to individual mills may involve practices that are not mentioned in this Code of Practice but achieve an equivalent or better level of environmental protection.
Site-specific municipal, provincial, federal, legal, and non-legal requirements must be met where they exist.
The Strategic Options Report (SOR) recognized that the measurement or calculation of some emissions is particularly difficult, for example for benzene and PAHs, and that the data reported and the ARET commitments made by individual facilities vary. SOR recommendations concerning benzene and PAHs included the development of standardized emission measuring, monitoring, and reporting practices. The CSPA has developed such practices. The targets for release reductions presented in Recommendation RI101 reflect the results of this development.
4.1 Atmospheric Emissions Management
The targets and schedules recommended for benzene and PAH releases are based on the recommendations advanced by the SOR for the steel sector. The guidelines recommended for particulate matter are based on the application of demonstrated control technologies and are generally considered technically and economically feasible for application to integrated steel mills. These guidelines are consistent with standards and practices currently in place in Canada, the United States, Europe, and other jurisdictions. More stringent criteria may be required by local regulatory authorities where deemed appropriate to the circumstances.
The effective control of benzene, PAH, and particulate emissions, in combination with the management practices recommended in RI104, RI105, and RI106, will significantly reduce the overall environmental impact associated with air releases of CEPA toxics by the steel sector.
4.1.1 Targets and Schedules for Release Reductions
Recommendation RI101 All by-product coke oven plants should implement plans to achieve the SOR targets and schedules for:
PAH releases from coke ovens and coke by-product plants should be reduced in accordance with the following:
- to an industry production-based average of 13.2 g/tonne of coke produced in 2000;
- to a maximum for any coke oven battery of 9.8 g/tonne of coke produced in 2005;
- to a maximum for any coke oven battery of 8.2 g/tonne of coke produced in 2015 or later.
The measurement and calculation of PAH releases should be undertaken in accordance with the CSPA PAH Measurement Protocol contained in Environmental Best Practice Manual for Coke Producers - Controlling and Reducing Emissions of Polycyclic Aromatic Hydrocarbons (PAH) from Metallurgical Coke Production in the Province of OntarioFootnote 11.
Benzene releases from coke ovens and coke by-product plants should be reduced in accordance with the following:
- to an industry production-based average of 120 g/tonne of coke produced in 2000;
- to a maximum of 71.7 g/tonne of coke produced in 2005;
- to a maximum of 62.7 g/tonne of coke produced in 2015 and later.
The measurement and calculation of benzene releases should be undertaken in accordance with the CSPA Benzene Measurement Protocol contained in Benzene Environmental Best Practice Manual for Coke Producers in Ontario - Controlling and Reducing Fugitive Benzene Emissions from Coke Production By-Product ProcessFootnote 12.
Benzene and PAH emission data for the 1993 base line, 1997 reported emissions, and ARET commitments for 2000 are contained in Appendix A.
4.1.2 Release Guidelines for Particulate Matter
Recommendation RI102 Each facility should target on achieving the following emission guidelines for particulate matter after the emission control device:
- sinter plants: 50 mg/Nm3;
- blast furnaces: 50 mg/Nm3;
- basic oxygen furnaces: 50 mg/Nm3;
- electric arc furnaces: 20 mg/Nm3.
Emission testing should be carried out on an annual basis in a manner that is consistent with Environment Canada's Reference Methods for Source Testing: Measurement of Releases of Particulate from Stationary Sources,Footnote 13 as amended from time to time. In cases where the emission control system does not have a stack, emission testing should be carried out in a manner that is consistent with the U.S. Environmental Protection Agency Method 5D - Determination of Particulate Matter Emissions from Positive Pressure Fabric Filters Footnote 14. It is recognized that particulate emission estimates for facilities without stacks are typically less accurate than emission estimates for facilities equipped with stacks and that relative accuracy must be taken into account in assessing the results of tests conducted in accordance with Method 5D.
More stringent criteria may be required by local regulatory authorities where deemed appropriate to the circumstances.
4.1.3 Environmental Performance Indicators
Recommendation RI103 Each facility should target on limiting particulate emissions in accordance with the following:
- sinter plants: less than 200 grams per tonne of sinter produced;
The calculation of this Environmental Performance Indicator should be undertaken in accordance with the methodology outlined in Section B.1 of Appendix B.
- blast furnaces: less than 100 grams per tonne of liquid iron produced;
The calculation of this Environmental Performance Indicator should be undertaken in accordance with the methodology outlined in Section B.2 of Appendix B.
- basic oxygen furnaces: less than 100 grams per tonne of raw steel produced;
The calculation of this Environmental Performance Indicator should be undertaken in accordance with Section B.3 of Appendix B.
- electric arc furnaces: less than 150 grams per tonne of raw steel produced.
The calculation of this Environmental Performance Indicator should be undertaken in accordance with Section B.4 of Appendix B.
4.1.4 Collection of Furnace Emissions
Recommendation RI104 Adequately sized facilities should be engineered and installed, and documented operating and maintenance procedures should be developed for the collection of emissions associated with:
- ironmaking including cokemaking, furnace operations, tapping and slagging operations, hot metal transfer operations, hot metal and slag runners, and hot metal desulphurization;
- primary steelmaking, including furnace operations, scrap and hot metal charging, and tapping and slagging operations;
- secondary steelmaking, including furnace operations, and continuous casting.
4.1.5 Control of Fugitive Emissions
Recommendation RI105 Adequately sized facilities should be engineered and installed, and documented operating and maintenance procedures should be developed for the control of emissions associated with:
- ironmaking, including materials handling and storage operations, the crushing and screening of coal and coke, cokemaking, the disposal of by-products and wastes including coke breeze, and the cooling and processing of slag;
- primary steelmaking operations, including materials handling and storage operations, hot metal transfer, and processing of slag; and
- secondary steelmaking operations, including transfer of hot metal and continuous casting operations.
These facilities and procedures should include:
- enclosure and/or hooding with emission controls, where appropriate, of those operations that are potential sources of fugitive emissions;
- operating practices that minimize fugitive emissions from those operations that are not amenable to enclosure or hooding; and
- criteria for building, working, and maintaining bulk-material storage piles.
4.1.6 Chlorinated Solvents Used in Solvent Degreasing
Recommendation RI106 Documented procedures for the control or elimination of chlorinated solvent emissions from degreasing operations should be developed and implemented in accordance with the multi-stakeholder Strategic Options Report and the associated regulations that may be promulgated from time to time.
4.1.7 Ambient Air Quality Monitoring
Recommendation RI107 An ambient air quality monitoring program should be developed and implemented by each facility, in consultation with the appropriate regulatory authorities, with the objective of enabling the facility to demonstrate that operations are being conducted in a manner that is consistent with the National Ambient Air Quality Objectives for Air ContaminantsFootnote 15 as amended from time to time. (Note that the National Ambient Air Quality Objectives for Air Contaminants may be superseded by Canada-Wide Standards in the future.) This program should include monitoring of particulate matter (total, PM10, and PM2.5), benzene, and PAHs, taking into account:
- the location of emission sources under the control of the facility operator; and
- local meteorological conditions such as the direction of prevailing winds.
The recommendations in this section are intended to provide general guidance on the issues and topics that should be addressed by site-specific procedures as a means of mitigating the environmental impact of cokemaking and associated operations. Individual coke plants have developed Standard Operating Practices (SOPs) for coke oven and coke by-product plant operating, maintenance, and training activities to minimize benzene and PAH emissions. These SOPs are identified in the CSPA documents Environmental Best Practice Manual for Coke Producers (PAHs) and Benzene Environmental Best Practice Manual for Coke Producers in Ontario.
4.2.1 Coke Ovens
188.8.131.52 Charging Operations
Recommendation RI108 Documented procedures should be developed and implemented for the control of coke oven charging operations including:
- the nature and frequency of equipment inspections;
- replacement or repair of emission control equipment, where applicable, and the method used to audit the effectiveness of the inspection and repair program;
- proper filling of larry car hoppers;
- alignment of larry cars over the oven to be charged;
- proper filling of the ovens (e.g. procedures for staged or sequential charging);
- proper leveling of coal in the ovens; and
- the inspection and cleaning of offtake systems (including standpipes, standpipe caps, goosenecks, dampers, and mains), oven roofs, charging holes, topside port lids, steam supply system, and liquor sprays.
184.108.40.206 Coke Oven Doors
Recommendation RI109 Documented procedures should be developed and implemented for the control of emissions from coke oven doors including:
- a program for the inspection, adjustment, repair, and replacement of coke oven doors and jambs, and any other equipment used to control emissions from coke oven doors;
- a defined frequency for door inspections;
- the method to be used to evaluate conformance with operating specifications for each type of equipment;
- the methods to be used to audit the effectiveness of the inspection and repair program;
- procedures for identifying leaks that indicate a failure of the emissions control technology to function properly;
- a clearly defined chain of command for communicating information on leaks and procedures for corrective action;
- procedures for cleaning sealing surfaces of doors and jambs which include the identification of equipment that will be used and a specified schedule or frequency for the cleaning of the sealing surfaces;
- procedures for use of supplemental gasketing and luting materials, and hand luting, if the operator elects to use such procedures;
- procedures for maintaining an adequate number of spare coke oven doors and jambs on-site;
- procedures for monitoring and controlling back pressure in the collecting main, which include corrective action if pressure control problems occur; and
- a program for identifying and adopting improved coke oven door and door sealing designs.
220.127.116.11 Topside Port Lids
Recommendation RI110 Documented procedures should be developed and implemented for the control of emissions from topside port lids including:
- the inspection and replacement or repair of topside port lids and port lid mating and sealing surfaces;
- the frequency of inspections;
- the method to be used to evaluate conformance with operating specifications for each type of equipment;
- the method to be used to audit the effectiveness of the inspection and repair program, where applicable; and
- procedures for sealing topside port lids after charging, for identifying topside ports that leak, and resealing.
18.104.22.168 Offtake Systems
Recommendation RI111 Documented procedures should be developed and implemented for the control of emissions from offtake system(s) including:
- the inspection and replacement or repair of offtake system components;
- the frequency of inspections;
- the method to be used to evaluate conformance with operating specifications for each type of equipment;
- the method to be used to audit the effectiveness of the inspection and repair program;
- procedures for identifying offtake system components that leak and sealing leaks that are detected; and
- procedures for dampering off ovens before a push.
22.214.171.124 Coke Pushing
Recommendation RI112 Documented procedures should be developed and implemented for the control of emissions from coke pushing and coke transfer to the quench station including:
- minimizing the occurrence and severity of "green" pushes;
- the inspection and replacement or repair of pushing emission control system components;
- the frequency of inspections;
- the method to be used to evaluate conformance with operating specifications for each type of equipment, where applicable;
- the method to be used to audit the effectiveness of the inspection and repair program, where applicable;
- minimizing emissions from the transfer of hot coke to the quench station; and
- procedures for identifying pushing emissions that indicate occurrences of incomplete coking or a failure of the emissions control technology to function properly, which include a clearly defined chain of command for communicating information on such occurrences and procedures for corrective action.
126.96.36.199 Coke Wet Quenching
Recommendation RI113 Documented procedures should be developed and implemented for the control of atmospheric emissions and wastewater discharges from coke quenching including:
- the inspection, repair, and replacement of quench tower components;
- the frequency of inspections;
- the method to be used to evaluate conformance with operating specifications, where applicable;
- the method to be used to audit the effectiveness of the inspection and repair program; and
- procedures for the quality control of quench water.
188.8.131.52 Bypass/Bleeder Stacks
Recommendation RI114 Documented procedures should be developed and implemented for the control of atmospheric emissions from coke oven gas flaring including:
- the method to be used to flare coke oven gas;
- the inspection, repair, and replacement of flare system components;
- the method to be used to evaluate conformance with operating specifications of the flare system; and
- procedures for reporting and correcting malfunctions of the flare system.
4.2.2 Coke By-Product Plant
184.108.40.206 Storage Tanks
Recommendation RI115 The recommendations advanced in the Canadian Council of Ministers of the Environment's (CCME's) Environmental Guidelines for Controlling Emissions of Volatile Organic Compounds from Aboveground Storage Tanks Footnote 16 should be applied to light oil and wash oil storage tanks.
220.127.116.11 Fugitive Emissions
Recommendation RI116 The recommendations advanced in the CCME's Environmental Code of Practice for the Measurement and Control of Fugitive VOC Emissions from Equipment Leaks Footnote 17 should be followed.
18.104.22.168 Benzene Transfer Operations
Recommendation RI117 A vapour collection system should be used to contain benzene vapours during the transfer of benzene-containing liquids to tank trucks or rail cars.
22.214.171.124 Process Cooling Water
Recommendation RI118 All process cooling should be by the use of indirect cooling, with no water in contact with process liquids or gases unless properly treated prior to discharge.
126.96.36.199 Open Trenches and Sumps
Recommendation RI119 All process trenches and sumps should be enclosed and the vapours collected for treatment.
188.8.131.52 Containment of Process Pumps and Tanks
Recommendation RI120 All process pumps and tanks should be installed on impervious pads with containment dykes and drainage to wastewater treatment facilities to contain spills. Refer also to Recommendation RI125, which would also apply as appropriate.
4.3 Water and Wastewater Management
Technologies capable of achieving the criteria recommended in RI121 and RI122 have been demonstrated and are considered technically and economically feasible for application to integrated steel mills. These criteria are consistent with standards and practices currently in place in Canada, the United States, Europe, and other jurisdictions.
Although limits have not been prescribed for all parameters of potential environmental concern, the application of technologies capable of achieving the specified criteria, in combination with the water and wastewater management practices recommended in RI123 through RI126, will reduce the overall environmental impact associated with water use and wastewater discharges. More stringent criteria may be required by local regulatory authorities where deemed appropriate to the circumstances.
4.3.1 Effluent Guidelines
Recommendation RI121 All wastewater treatment facilities approved for construction and operation after the publication of this Code of Practice should be designed, constructed, and operated to achieve the following effluent criteria prior to release to cooling water or to local receiving water body:
Wastewater treatment facilities approved by the appropriate regulatory authorities prior to the publication of this Code of Practice should be so operated that effluent quality is as close to satisfying the above-listed criteria as is practicably possible.
Wastewater testing should be carried out on a continuous basis for pH, on a daily basis for total suspended solids, and on a weekly basis for the balance of the substances. Toxicity testing should be conducted quarterly.
Wastewater sampling and analyses should be carried out in accordance with documented, performance-based standards approved by the appropriate regulatory authorities.On a continuous basis:
No more than 50% mortality in 100% effluent when tested in accordance with Environment Canada Reference Methods 1/RM/13Footnote 18 and 1/RM/14Footnote 19.
4.3.2 Environmental Performance Indicator
Recommendation RI122 Each facility should target on limiting total suspended solids discharges from wastewater to less than 100 grams per tonne of raw steel produced.
The calculation of this Environmental Performance Indicator should be undertaken in accordance with Section B.5 of Appendix B.
4.3.3 Wastewater Collection
Recommendation RI123 All wastewater streams that may exceed the effluent criteria specified in RI121 should be directed to an approved treatment facility prior to discharge to a local receiving water body. To the extent practicable, system designs should provide for the segregation and collection of similar wastewaters (e.g. oily, acid, cleaning, and sanitary wastes).
4.3.4 Water Use/Reuse
Recommendation RI124 Water use should be minimized through the reuse or recycling of water and the cascading of cooling water and wastewater between production processes. Facilities should target on achieving 90% reuse of water. Flow measurements should be carried out in accordance with documented, performance-based standards approved by the appropriate regulatory authorities. Engineering design data or estimates should be used where flow measurements are not feasible.
The calculation of this Environmental Performance Indicator should be undertaken in accordance with the methodology outlined in Section B.6 of Appendix B.
4.3.5 Wastewater Containment Sizing
Recommendation RI125 Wastewater collection and containment facilities constructed after the publication of this Code of Practice should be designed to contain the maximum volume of liquid that could reasonably be expected to be in storage prior to any of the following events, and:
- the maximum volume of wastewater that would be generated during the time required to shut down wastewater generating processes, plus 50%;
- 110% of the volume that could enter the containment facility in the event of a leak or spill; or
- the accumulated precipitation from a 50 year return period, 24-hour precipitation event that is collected in an outdoor containment (e.g. rain that falls on the open surface or inside the containment berm).
4.3.6 Environmental Effects Monitoring
Recommendation RI126 An environmental effects monitoring program should be developed and implemented where appropriate by each facility in consultation with the appropriate regulatory authorities. This program should be sufficiently comprehensive to enable the facility to:
- measure changes in receiving water quality, aquatic sediments, and important aquatic and terrestrial organisms; and
- assess the need to incorporate changes in operational activities and procedures affecting the receiving environment.
The frequency and duration of this monitoring activity should be assessed, in consultation with the appropriate regulatory authorities, on the basis of test results.
4.4 Waste Management
For the purposes of this Code "wastes" are defined as substances or objects that are disposed of, or are intended to be disposed of, or are required to be disposed of by the provisions of national, provincial, or municipal lawFootnote 20. The recommendations presented in this section are based on guidelines, practices, and procedures currently in place in Canada with regard to the management of wastes generated by industrial facilities. The nature of the waste material (e.g. hazardous, solid, liquid), local site conditions, and local regulatory requirements should be considered in the development of waste management plans and strategies. More stringent requirements may be stipulated by local regulatory authorities where deemed appropriate to the circumstances.
4.4.1 Location and Construction of Waste Disposal Sites
Recommendation RI127 Expansions to existing waste disposal sites that extend beyond the spatial bounds of areas that have been approved by the appropriate regulatory authority, before the publication of this Code of Practice, and location and construction of new sites should be undertaken so as to ensure that:
- the site plan is updated to show clearly the location and dimensions of the new or expanded site;
- the perimeter of the disposal area is far enough away from all watercourses to prevent contamination by runoff, seepage, or fugitive emissions;
- the surface drainage from off-site areas is diverted around the disposal area;
- the expanded area is hidden from view by fences, berms, or buffer zones to the extent practicable; and
- the beneficial uses of the site after closure have been considered.
4.4.2 Development of Solid Waste Disposal Sites
Recommendation RI128 Solid waste disposal sites should be developed in accordance with the following practices:
- the disposal area should be developed in modules or cells throughout its operational life;
- all wastes should be so placed that they have physical and chemical stability suitable for land reuse;
- contouring, capping, and reclamation of cells should be undertaken throughout the operating life of the site and, where feasible, should include the re-establishment of vegetation as a means of controlling fugitive emissions and the erosion of side slopes; and
- all disposal sites should be reclaimed for beneficial uses before final closure.
4.4.3 Management of Waste Disposal Sites
Recommendation RI129 All waste disposal sites should be managed throughout their operational life in accordance with documented, site-specific waste management plans approved by the appropriate regulatory authority so that:
- solid, liquid, and hazardous wastes are disposed of only in facilities specifically designed, approved, and operated for that purpose;
- access to the site is controlled and disposal activities are supervised by trained personnel; and
- records are maintained of the types, approximate quantities, and point of origin of the wastes.
4.4.4 Monitoring of Waste Disposal Sites
Recommendation RI130 A groundwater monitoring program should be developed, to the extent that is feasible, for all waste disposal sites in accordance with the following guidelines:
- a permanent system of appropriately located piezometers and wells should be provided for monitoring the quantity, quality, and flow direction of groundwater;
- a program of pre-operational monitoring of groundwater regimes that may be affected by new facilities should be initiated at least one year prior to the commencement of disposal activities;
- groundwater samples should be collected at least quarterly from all monitoring wells during the first two years of well operation and at a frequency based on the results of this test program in subsequent years; and
- each groundwater sample should be analyzed for pH, total dissolved solids, and other appropriate (site-specific) parameters.
4.4.5 Liquid Storage and Containment
Recommendation RI131 Liquid storage and containment facilities should be designed and constructed to meet the requirements of the appropriate standards, regulations, and guidelines of the pertinent regulatory agency. This recommendation applies to liquid fuels, acids, petroleum products, solvents, and other liquids that are combustible or potentially harmful to the environment.
4.4.6 Reduction, Reuse, and Recycling
Recommendation RI132 Each corporate entity responsible for the operation of an integrated steel mill should develop, implement, and maintain a reduction, reuse, and recycling program that:
- identifies opportunities for in-plant reduction, reuse, and recycling of wastes;
- develops and implements plans for the evaluation and implementation of reduction, reuse, and recycling opportunities;
- identifies and evaluates market opportunities for waste with a view to maximizing waste reduction, reuse, and recycling (this includes the sale of by-products such as slag that would otherwise be considered wastes); and
- develops and implements a research and development program for reducing, reusing, and recycling residual wastes.
4.5 Best Environmental Management Practices
In the context of this Code of Practice, Best Environmental Management Practices (BEMPs) can be broadly defined as those activities, actions, processes, and procedures that go beyond legal and technical requirements in helping to ensure that facilities have minimal impact on the environment in which they operate. The effective development and implementation of BEMPs will also facilitate efforts to achieve continual improvement in the overall environmental performance of integrated steel mills.
The recommendations presented in this section are based on the policies, principles, and commitments advanced by Environment Canada, the CCME, provinces, the Canadian Steel Producers Association, and the International Iron and Steel Institute.
4.5.1 Implementation of an Environmental Management System
Recommendation RI133 Each facility should develop, implement, and maintain an environmental management system that is consistent with the requirements of a nationally recognized standard such as ISO 14001.Footnote 21
4.5.2 Environmental Policy Statement
Recommendation RI134 Each facility should develop and implement an environmental policy statement. The International Iron and Steel Institute's Statement on Environment, provides a good example of the principles that should be considered in the development of the policy statement. The Canadian Steel Producers Association's Environmental Policy Statement is available on their website.
4.5.3 Environmental Assessment
Recommendation RI135 The development of new facilities and changes to existing facilities that could significantly increase releases to the environment should be subjected to an internal environmental assessment process, with the aim of identifying potential problems and formulating cost-effective solutions that address the concerns of stakeholders. This self-assessment process should be initiated during the early stages of pre-project planning and continue as an iterative process through the project design, construction, and operations phases. Consideration should be given to potential impacts on air quality, water quality, water supply and use, land use, flora and fauna, and local infrastructure.
4.5.4 Emergency Planning
Recommendation RI136 Each facility should develop and implement an Emergency Plan aimed at ensuring that facility management meets all legal requirements in developing, maintaining, exercising, and reporting emergency preparedness and resource activities. This plan should be consistent with a nationally recognized guideline such as the Canadian Standards Association's Emergency Planning for Industry Major Industrial EmergenciesFootnote 22. An appropriate emergency plan should:
- ensure the safety of workers, response personnel, and the public;
- reduce the potential for the destruction of property or for actual product losses;
- reduce the magnitude of environmental and other impacts;
- assist response personnel in determining and performing proper remedial actions quickly;
- reduce recovery times and costs; and
- inspire confidence in response personnel, industry, and the public.
4.5.5 Pollution Prevention Planning
Recommendation RI137 Each facility should develop and implement a Pollution Prevention Plan aimed at avoiding or minimizing environmental releases that is consistent with a nationally recognized guideline such as the Canadian Standards Association's Guideline for Pollution PreventionFootnote 23.
4.5.6 Decommissioning Planning
Recommendation RI138 Planning for decommissioning should begin in the design stage of the project life cycle for new facilities and as early as possible in the operating stage for existing facilities. Decommissioning should be carried out in a way that ensures that limited adverse risk to the environment or human health will remain after closure. All site closures and associated decommissioning activities should be undertaken in accordance with the CCME's National Guidelines for the Decommissioning of Industrial Sites.Footnote 24
4.5.7 Environmental Training
Recommendation RI139 Each facility should establish and maintain procedures to identify its environmental training needs and ensure that all personnel whose work may create a significant impact upon the environment have received appropriate training. The organization should also require that contractors working on its behalf are able to demonstrate that their employees have the requisite training. The environmental training program should include:
- a list by job title or classification of all personnel that require training; and
- an outline of the topics to be covered, the training methods to be used, and the required frequency of refresher training for each group of personnel.
4.5.8 Environmental Facility Inspection
Recommendation RI140 Each facility should develop and implement an environmental inspection plan that includes:
- documented procedures for the inspection of each environmental facility including air emission control equipment; wastewater treatment facilities; liquid handling, storage, and containment facilities; waste handling, storage, and containment facilities; and air emission and wastewater monitoring and control instrumentation;
- visual observations for air emission excursions and liquid leaks;
- a documented schedule for inspections including timing of inspections and identification of a responsibility centre;
- documented procedures for the reporting of inspection results to both internal management and external agencies; and
- documented procedures for follow-up to inspection reports.
4.5.9 Monitoring and Reporting
Recommendation RI141 Documented procedures should be developed and implemented for the monitoring and reporting of environmental performance data including:
- the identification of all parameters to be monitored and the associated sampling frequency;
- definition of the procedures and protocols to be followed in sample collection, preservation, handling, shipment, and analysis;
- action(s) to be undertaken when prescribed environmental criteria have been exceeded;
- the means by which data are to be reported to government agencies and other stakeholders;
- quality assurance/quality control of the monitoring data;
- reporting to the National Pollutant Release Inventory (NPRI) and, where applicable, the Accelerated Reduction/Elimination of Toxics (ARET) program; and
- reporting on the status of implementation of this Environmental Code of Practice.
4.5.10 Environmental Auditing
Recommendation RI142 Each facility should conduct periodic internal environmental audits throughout the operating life of the facility as a means of assessing environmental risk, ensuring conformance with regulatory, appropriate non-regulatory, and corporate requirements, and identifying opportunities for improving environmental performance. The recommendations advanced in this Code of Practice should be included in the audit criteria.
4.5.11 Environmental Performance Indicators
Recommendation RI143 Each facility should develop a set of environmental performance indicators that provide an overall measure of the facility's environmental performance. These indicators would include a broad and practical set of ecological and economic elements that offer significant opportunities to link environmental performance to financial performance. An Environmental Performance Data Sheet that could be used for the development of the environmental performance indicators is contained in Appendix C.
4.5.12 Life Cycle Management
Recommendation RI144 Each corporate entity should develop and implement a Life Cycle Management (LCM) Program aimed at minimizing the environmental burdens associated with the products used and produced by its steelmaking facilities over the product life cycle. The LCM Program should include consideration of:
- types of materials used;
- sources of supply of materials;
- sources of energy used;
- type and amount of packaging; and
- management of manufacturing by-products and wastes.
A summary of the International Iron and Steel Institute's Policy Statement on Life Cycle Assessment is available on their website.
4.5.13 Community Advisory Panel
Recommendation RI145 Each facility should establish a Community Advisory Panel to provide a forum for the review and discussion of facility operations, environmental concerns, emergency preparedness, community involvement, and other issues that the Panel may decide are important.
The range of constituency categories could include local residents.
The Panel should be an advisory group and not a decision-making body.
Other recommendations may follow.
Report a problem or mistake on this page
- Date modified: