Guide for Reporting to the National Pollutant Release Inventory 2000: section 1

Section 1: Criteria for Reporting to the National Pollutant Release Inventory

• Introduction
• Understanding the Canada Gazette Notices
• General Reporting Criteria
• Exempt Facilities
• Employee Criteria
• Schedule 1, Part 1, Substances
• Schedule 1, Part 2, Substances [Mercury (and compounds)]
• Schedule 1, Part 3, Substances [Polycyclic Aromatic  Hydrocarbons (PAHs)]
• Schedule 1, Part 4, Substances [Dioxins/Furans and Hexachlorobenzene (HCB)]

Introduction

The NPRI changed significantly for the 2000 reporting year with the introduction of alternate reporting thresholds. Many substances pose serious risks to human health or the environment in relatively low quantities. Very limited data, if any, would be reported to the NPRI for these substances at the original 10-tonne and 1% concentration reporting thresholds. The new reporting criteria for substances with alternate reporting thresholds are explained fully in a companion document, Supplementary Guide for Reporting to the National Pollutant Release Inventory - Alternate Thresholds - 2000. Substances with alternate reporting thresholds include:

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

This Guide differs from the Supplementary Guide because it is intended for the majority of facilities reporting to the NPRI which meet the 10-tonne and 1% concentration thresholds for manufacturing, processing or otherwise using an NPRI substance. These reporting criteria are explained in Section 2. Section 3 explains what information is required and how to complete the reporting form.

This Guide, together with the Supplementary Guide, should be consulted by owners and operators of facilities to determine if they must report for any NPRI substances.

Understanding the Canada Gazette Notices

On December 25, 1999, a "Notice with Respect to Substances in the National Pollutant Release Inventory for 2000" was published under the authority of subsection 16(1) of the Canadian Environmental Protection Act (CEPA) 1988, in the Canada Gazette, Part I (Canada Gazette, December, 1999). This notice specified that any person who owned or operated a facility during the calendar year 2000, under the conditions prescribed in the notice, provides certain 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 clarify some of the reporting requirements. Notices are published annually in the Canada Gazette, Part I. Changes may be made to the notice from year to year.

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 2000 Canada Gazette notice encompasses a wide range of substances, alternate thresholds and reporting criteria. It is divided into four schedules with several parts in each. Its contents are outlined below.

If you have any difficulties interpreting the requirements of the NPRI notice, please consult the Questions and Answers in Section 6 or contact your regional NPRI office listed inside the front cover of this guide. More information is available on Environment Canada's NPRI Web site.

General Reporting Criteria

The reporting criteria for all substances listed in the NPRI are summarized in the flowchart in Figure 1. What follows is a brief walk through the flowchart. The criteria for the substances listed in Schedule 1, Part 1, of the 2000 Canada Gazette notice (10-tonne manufacture, process or other use threshold) are explained in this Guide while the Supplementary Guide provides details on the reporting criteria of the alternate-threshold substances listed in Schedule 1, Parts 2, 3 and 4, of the 2000 Canada Gazette notice.

Exempt Facilities

Certain facilities are exempt from reporting to the NPRI. These exemptions apply to every substance in the NPRI. These exemptions also apply to any part of the facility that is used exclusively for one or more of the activities listed in the flowchart. Beginning with the 2000 reporting year, a new exemption was added for the practice of dentistry because of the reduction of the quantity threshold for mercury (and its compounds) from 10 tonnes to 5 kilograms and removal of the 1% concentration threshold.

Employee Criteria

In previous years, a facility was exempt from reporting if, during the reporting year, the total number of hours worked by all its employees was less than 20 000 hours (equivalent to 10 full-time employees). Beginning with the 2000 reporting year, this 20 000-hour employee threshold does not apply to facilities used for wood preservation and certain types of incineration (see Table 1, Section 2). This applies only to facilities that were used mainly or exclusively for one of these activities.

A facility is not required to report to the NPRI if, during the 2000 calendar year:

• the total number of hours worked by all employees was less than 20 000 hours, and
• the facility was not used for any of the activities listed in the flowchart, for which the 20 000-hour employee threshold does not apply .

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. Further information is provided in Chapter 2 of the Supplementary Guide.

Schedule 1, Part 1, Substances

This section of the flowchart refers to the 248 substances listed in Schedule 1, Part 1, of the 2000 Canada Gazette notice to which the original NPRI reporting requirements still apply. If a facility met the employee criteria described above, it must report on-site releases and off-site transfers of an NPRI Part 1 substance if:

• the facility manufactured, processed or otherwise used 10 tonnes (10 000 kg) or more of an NPRI Part 1 substance in the 2000 calendar year, and
• the NPRI Part 1 substance was manufactured, processed or otherwise used at a concentration greater than or equal to 1% by weight, with the exception of NPRI substances considered to be by-products. The total weight of by-products must also be included in the calculation of the 10-tonne threshold for each NPRI Part 1 substance.

Further information is provided in Section 2 of this Guide.

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

If a facility met the employee criteria described above, it is required to report releases and transfers for mercury (and its compounds) if they were manufactured, processed or otherwise used, at any concentration, in a quantity of 5 kg or more in the 2000 calendar year. Further information is provided in Chapter 3 of the Supplementary Guide.

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. 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, during the 2000 calendar year:

• the employee criteria were met, and
• any individual PAH was incidentally manufactured and the quantity of all of the PAHs released on site or transferred off site as the 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.

Further information is provided in Chapter 4 of the Supplementary Guide.

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

Polychlorinated dibenzo-p-dioxins (dioxins) and polychlorinated dibenzofurans (furans) are listed together in the NPRI for 2000 and are referred to as dioxins/furans. Hexachlorobenzene (HCB) was also added to the NPRI for 2000. Facilities engaged in certain activities are required to report dioxins/furans and HCB to the NPRI. There are no quantitative, substance-based reporting thresholds. Information to be reported for dioxins/furans and HCB differs from that required in other NPRI substance reports. Refer to Chapter 5 of the Supplementary Guide for further details.

Figure 1: Criteria for Reporting to the NPRI for 2000