Code of practice for managing particulate matter emissions in the potash sector: chapter 5

Official title: Code of practice for the management of PM2.5 emissions in the potash sector in Canada

5. Implementation of the code of practice

Implementing the code should result in controlling and minimizing particulate matter and PM2.5 emissions for the facilities concerned. Successfully achieving this includes an implementation plan and self-monitoring by the facilities. This section outlines an approach to developing individual work methods, applying them and following up on them on a regular basis to improve or maintain performance (Figure 5-1). The facility concerned could take a different approach depending on its needs and structure.

Figure 5-1: General approach to implementing best practices by a potash facility subject to the code of practice

General approach to implementing best practices by a potash facility subject to the vode of practice (see long description below).
Description of figure 5-1

This figure is a block diagram (a series of boxes connected by arrows) which is separated onto two groupings (planning and application) and depicts an approach to developing individual work methods, applying them and following up on them on a regular basis to improve or maintain performance.

In the upper grouping entitled planning, there are 5 coloured boxes that highlight components of the planning stage. The first box is split in two parts. The first part is “analyze methods currently used to monitor PM2.5 emission abatement equipment”, the second is “establish baseline operating ranges of PM2.5 monitoring devices”. Once a facility has analyzed its PM2.5 monitoring methods they should proceed to the next step, contained in the box directly to the right, which is to “develop improved procedures based on the code of practice and current work methods”. The next step, listed in the box directly below, is to “prepare training plan for affected employees”.

Following the establishment of baseline operating ranges listed in the second box, the next step, on the left hand side of the figure directly below the first two boxes, is to “develop protocol for auditing the effectiveness of improved monitoring of PM2.5 emission abatement equipment”.

In the lower grouping entitled application, there are 4 coloured boxes in a closed-loop configuration that highlight components of the application stage of the recommendation contained in the code. The box on the far right of the figure suggests that the facility “inform affected employees of improved monitoring procedures based on training plan”. Following this step the box at the bottom of the grouping states “implementation of improved monitoring procedures by employees”. The box on the left hand side, is split into two parts. The first part is “audit the effectiveness of improved monitoring” and the second is “developing corrective measures as needed”.

5.1 Initial planning

It is advisable to analyze the current situation in the plant to carry out individual procedures based on the recommendations of the code. After the new practices are implemented, it is important to ensure that they are effective and are yielding the expected results. Such analysis should follow a predetermined protocol for auditing on-site activities relating to the new practices.

5.1.1 Analysis of current situation

The purpose of the initial analysis is to obtain not only relevant information and data on the technologies in place, but especially the operating, control and maintenance methods of the plant in question. A questionnaire or checklist would be an appropriate tool for this task.

5.1.2 Development of custom procedures

Based on the results of the initial analysis, opportunities for improvement in the monitoring of PM2.5 emissions abatement equipment could be identified. The facility could thus develop their own procedures (in a custom document) on the basis of recommendations provided in the code and the plant’s unique characteristics. The development of custom procedures may mean adopting practices that are not mentioned in the code but would nonetheless control PM2.5 emissions, according to the facility’s analysis. The code is not restrictive in this regard.

Consultation with employees should facilitate the implementation of the new procedures at the appropriate time and prevent problems that might arise if employees are not consulted.

5.1.3 Employee training plan

From a strategic standpoint, it is advisable to prepare a training plan for employees required to modify or implement new procedures. Successful training depends on properly prepared documents and training as well as on the standardization of the new procedures.

5.1.4 Protocol for reviewing the effectiveness of custom procedures

New or modified procedures should be monitored regularly to ensure they are yielding the desired results. A review should preferably be carried out using a protocol developed alongside the procedures. The best approach is to prepare a checklist with qualitative and quantitative questions to assess the current situation properly. Where applicable, this checklist should contain the baseline ranges established following the initial analysis. This protocol should also provide for a consistent review methodology.

Annex A offers a recordkeeping template that facilities may choose to use for this purpose.

Baseline operating ranges of monitoring and control devices are typically established during initial equipment installation and commissioning, periodic stack testing, performance testing, and/or periodic calibration as specified by the manufacturer.

5.2 Implementation of the code

It is to be expected that the results of new procedures will not be optimal at the beginning and that corrections will probably have to be made after the initial review. This review-correction cycle should be applied periodically even when the level of monitoring is deemed satisfactory by the facility.

5.2.1 Performance review of improved procedures

It is recommended that a review of the new procedures be carried out quite frequently at the beginning (for example, 6-12 months) according to the protocol developed for that purpose (Section 5.1.4) to fine-tune the procedures. When all the procedures are diligently followed by the staff concerned, reviews could be undertaken less frequently. They will nonetheless have to be maintained at a reasonable frequency for quality control purposes.

Each potash facility using the Code should retain, for a reasonable period of time, all this recorded information which will demonstrate that the objectives of this Code are being met. This log will help determine the overall effectiveness of the Code and will identify future opportunities for improvement.

5.2.2 Reporting

To assess the degree of implementation of this Code and to monitor levels of PM2.5 emissions, potash facilities will annually submit total emissions of PM2.5 by source, as well as the methodology used to quantify those emissions to Environment and Climate Change Canada.

For those facilities in operation prior to December 31, 2017,

  • the first annual report for reporting year 2017 (Jan 1 to Dec 31) will be due on or before June 1, 2018
  • for reporting year 2018 (Jan 1 to Dec 31), facilities will submit details, on or before June 1 of 2019, regarding implementation of the recommendations in this code, and every two years thereafter

For those facilities that commence operations after December 31, 2017,

  • annual reports will be due on or before June 1 of the year immediately following the first full or partial calendar year of operation
  • details regarding the implementation of the recommendations in this code will be due on or before June 1 of the second year immediately following the first full or partial calendar year of operation, and every two years thereafter

Reports are to be provided to Environment and Climate Change Canada to the following email address:

ec.cop-cdp.ec@canada.ca

A sample of the information that would be included in the reports is provided in Annex B.

Facilities should use standard methods to quantify PM2.5 emissions, such as those listed below. Where the use of these methods is not possible or practical, facilities may use quantification methodologies currently used to report to federal or provincial regulatory programs.

  • Measurement of Releases of Particulate from Stationary Sources. Environment Canada, reference Method EPS 1/RM/8, December, 1993.
  • Reference Method for Source Testing: Measurement of Releases of Fine Particulate Matter from Stationary Sources. Environment Canada, Method G: Determination of Filterable PM2.5 and Filterable Particulate Matter, reference Method EPS 1/RM/55, December 2013
  • Reference Method for Source Testing: Measurement of Releases of Fine Particulate Matter from Stationary Sources. Environment Canada, Method H: Determination of Condensable Particulate Matter (CPM), reference Method EPS 1/RM/55, December 2013
  • U.S. Environmental Protection Agency. Federal Reference Methods 201a and 202. Methods for Measurements of Filterable PM10 and PM2.5 and Measurement of Condensable PM Emissions from Stationary Sources, 40 CFR Part 51.
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