National Pollutant Release Inventory reporting requirements: questions and answers

Under NPRI, a facility can be a contiguous facility, a portable facility, a pipeline installation or an offshore installation (see Section 3.4.2 “Definition of facility” in the guide for reporting to the NPRI for the definitions of these facility types). A ship is not a contiguous facility or a portable facility as defined under the Notice, because it is not stationary nor is it located on a single site. It is not a portable facility, as “portable facility” means portable PCB destruction equipment, portable asphalt plants and portable concrete batching plants only. Further, a ship cannot be classified as a pipeline installation. The definition of offshore installation does include ships, but only if the ship is directly related to the exploitation of oil and gas; since the ships in question are in the fish industry, they are not offshore installations. Therefore, there is no requirement to report since none of the facility definitions apply to the ships in question.

The facility is processing (recycling) the chemicals and therefore, if the mass and concentration threshold criteria for reporting are met, you must submit a report. Releases during vacuuming must be reported, as well as releases from related activities such as spills and equipment cleaning.

Routine cleaning of the exterior of the barge is considered maintenance of a vehicle and is therefore exempt; however, painting and/or stripping the barge would require reporting NPRI substances.

Releases/Disposals/Transfers

MPO

All staff employed at a facility, regardless of function or location, count toward the employee threshold determination. Staff employed at a facility include students, part-time and term employees, owners of the facility who performed work on site at the facility, clerical staff, sales staff, and persons such as contractors who performed on-site work related to the operation of the facility.

Calculate the total of hours worked by all people, including contractors who are performing work related to the operations of the facility. The total number of hours worked includes paid vacation, overtime and sick leave. If the total is 20,000 hours or more per year, the criterion for the number of full-time employees has been met and all NPRI substances must be considered.

However, if the facility was used for incineration, wood preservation or terminal operations, or was a municipal wastewater collection system discharging an annual average of 10 000 m3 or more per day into surface waters or is a pit or quarry where the annual production exceeds 500 000 tonnes, all NPRI substances must be considered, regardless of the hours worked by employees.

Furthermore, if the total employee hours are less than 20,000,  CACs from stationary combustion equipment must still be considered and reported as required. However, it is possible for a facility with less than 20,000 employee hours to be exempt from reporting to NPRI for CACs if all three of the following criteria are met:

• the only releases to air occurred from stationary external combustion equipment,
• the cumulative nameplate capacity of that equipment was less than 10 million BTU/hour;

and

• the only fuel combusted in that equipment was commercial grade natural gas, liquefied petroleum gas, No. 1 or 2 fuel oil, or any combination thereof.

In addition, facilities with less than 20,000 employee hours that are classified under the NAICS code 211110, are required to consider if they meet the Case 3 or Case 4 reporting requirements outlined in the NPRI’s Oil and gas industry guide.

Yes. You must consider all overtime, paid vacation and sick leave in the 20,000 hour threshold. An employee includes a person employed at the facility, an owner of the facility who performed work on site at the facility and a person such as a contractor, who performs work at the facility that is related to the operations of the facility, for the period of time the person performed that work.

The person who owns or operates the facility as of December 31 of the calendar year is responsible for submitting­ the report for that year if the criteria for reporting are met. When transfers of ownership occur, the original owner should ensure that information for NPRI reporting for the entire calendar year is available to the person reporting. The original owner is strongly encouraged to notify Environment and Climate Change Canada (ECCC) of the change in ownership -- this can be done by submitting an Ownership Change (Sale/Closure/Purchase) report in the online reporting system. This notification allows ECCC to maintain a current list of reporters and assists in tracking compliance.

The Canada Gazette Notice requires a person who owns or operates a facility to report information to which the person has access or can reasonably be expected to have access. This is usually the operator­; however, both the owner and the operator are subject to the Notice. If no report is received from a facility that met the reporting requirements, both persons may be held liable.

Legal Requirements/Gazette

The “parent company” means the highest-level company or group of companies that owns or directly controls the reporting facility. The parent companies of interest to NPRI are those Canadian companies that have greater than 10% ownership in the company. For example, CNS Corporation has five owners, but one of the owners is American and the other four are Canadian. In this case, only the Canadian companies would be shown as parent companies, provided they each owned more than 10% of CNS Corporation.

When determining thresholds and reporting, the two facilities must be considered separately because the operations were carried out at two distinctly separate physical sites. Threshold determinations must be made for the period of time during which each facility operated. A new NPRI ID number will be assigned to the new facility.

XYZ Oil Corporation is the parent company because it is the highest-level company that directly controls Acme Plastics.

Two sites owned or operated by the same company that function as a single integrated site, but are separated by a railway, would be considered adjacent sites since they are physically adjacent to one another except for a public right-of-way. Therefore, reporting thresholds would be determined by the combined quantities of substances manufactured, processed or otherwise used at both sites. The 20,000 hour threshold would be determined by the sum of hours worked at both sites.

The facilities are not adjacent to one another so a report is required for each facility that met the NPRI reporting criteria; their activities cannot be combined.  

The methanol is listed under Part 1A with MPO  (Manufacture, Process or Otherwise Use) threshold of 10 tonnes.

In this case, the plant in Ontario will not have to report releases, disposals, and transfers for methanol under Part 1A, but the other two plants will since the 10 tonnes MPO threshold is met. 

In addition, since methanol is a volatile organic compound (VOC), you must include any methanol released to air in the calculation of the facility-wide total VOC air emissions reported under Part 4 and also report the amount of methanol released to air (if greater than 1.0 tonne) under Part 5 of NPRI.  

When contractors working at a facility supply their own materials and supplies, such as solvents containing NPRI substances, should these substances be included in the threshold determination and reported?

Yes. You must include all quantities of NPRI substances manufactured, processed or otherwise used by contractors in your threshold calculations if those activities are relevant to the purpose of the facility. You must also include any contractor vehicles kilometres-travelled on-site in determining the threshold for the reporting of road dust if the contractor’s vehicle was brought on site as a result of a request by the facility owner/operator. The road dust created by these vehicles is a result of the facility operations and should therefore be included.

An NPRI substance is the working fluid in our heat-transfer equipment. Must the quantity of the NPRI substance be accounted for in determining the reporting threshold?

Yes. Heat-transfer equipment is not considered an article, since NPRI substances can be released under operating conditions. Therefore, the fluid within the heat-transfer equipment is considered to be an “other use” of the NPRI substance, relevant to the purposes of the facility as defined in the Canada Gazette Notice. All NPRI substances in the heat-transfer equipment must be included in the threshold calculation. If additional fluid is used in refilling the process equipment, it must also be included in the threshold calculation.

Technical

If a facility disposes of some of its waste in a landfill site that belongs to the company but is in a different location, is this an on-site or off-site disposal?

This would be considered an off-site disposal because the landfill is not adjacent to or contiguous with the facility.

Releases/Disposals/Transfers

Our company sorts scrap metal and compresses it into bales to be sold to secondary metal producers. Most of the metal we recover contains some NPRI substances (such as zinc and chromium, excluding hexavalent) in excess of 1% concentration. The process does not release any NPRI substances; it only compresses the pieces into bales. Are we required to submit a report?

No. In this case, the items being handled would retain their status as articles as long as there are no on-site releases to the environment or any disposals.

Technical

Release/Disposal/Transfer

If a substance is spilled one year, and will result in air emissions over time in the following year, how should it be reported?

The portion of the spill not cleaned up must be reported as a release the year it occurred. It must be reported as a release to the environmental media affected (air, water, land). Further migration between media does not need to be reported.

For example, if 100 L of an NPRI substance is spilled and 80 L is recovered, a release of 20 L must be reported. If the 80 L is returned to the process, no further action is required. However, if it is sent off-site for treatment or disposal, it must be reported accordingly.

Can a facility use its own software to report electronically to NPRI?

Environment and Climate Change Canada (ECCC) supplies an online system for reporting, which does not have the ability to incorporate a user’s own software. However, ECCC also has a bulk upload tool. If a user wishes to use the bulk upload tool, they can download the schema provided by ECCC and use their own software to populate file(s) to upload.

We use a 50% methanol solution in one part of the plant. The annual consumption of methanol exceeds 10 tonnes. In another part of the plant, a completely separate process produces a few tonnes of methanol, which are released through a stack. Do we have to estimate methanol releases from the stack even if they are from a different process?

Yes. Because your facility uses more than 10 tonnes of methanol, you are required under Part 1A substance requirements to report all releases, disposals and transfers off-site of methanol, regardless of the process stream.

In addition, since methanol is a VOC, you must include any methanol released to air in the calculation of the facility-wide total VOC air emissions reported under Part 4.

You would be required to report the amount of methanol released to air (if greater than 1.0 tonne) under Part 5 of NPRI.

You may be required to break down the releases for each stack greater than or equal to 25 metres above grade if the stack-specific release threshold is met for Part 4 or Part 5. For example, if the facility has a stack greater than 25 metres above grade, and both the 10 tonne reporting criteria for Part 4 total VOCs as well as the 5 tonne stack threshold are met, then the emission quantity of the total VOCs  (i.e., including the 2 tonnes of methanol released through this stack) from this stack, together with this stack’s physical parameters must be reported. Under this example, the 2 tonnes of methanol must also be reported for this stack as it meets the NPRI stack release threshold for Part 5 of 0.25 tonnes.

We have a provincial waste permit to discharge sulphuric acid at a pH between 5.8 and 6.6. How do we report our releases of sulphuric acid if we met all the reporting requirements?

Releases of mineral acids at a pH of 6.0 or greater are considered neutralized and must be reported as zero. The portion of sulphuric acid discharged at a pH of less than 6.0 will constitute a reportable release and must be calculated and reported.

Yes, there is a difference between calculating thresholds and reporting recycling activities for NPRI substances sent off site for recycling and for substances regenerated on site. 

For off-site recycling, if the recovered substance is being processed or used it would have to be included in the threshold calculation since it is the same as new material being processed or used. For example, a facility process uses a catalyst that contains an NPRI substance. When the catalyst is spent, it is sent off site for recovery, then returned to the facility for reuse. The NPRI substance in the catalyst would be included in threshold calculations each time it was brought on site and processed or used. So if the catalyst was bought new at the beginning of the reporting year and was sent off site for recovery and returned to the facility for re-use twice in the calendar year, the amount of the NPRI substance in the catalyst would be counted three times. If the reporting threshold is met, then all releases, disposals and transfers or disposals for recycling of the substance must be reported. Therefore, the owner/operator would need to report the quantity of the NPRI substance in the spent catalyst as an off-site transfer for recovery recycling. The amount reported would be calculated by adding the amount of the NPRI substance in the spent catalyst for both transfers.

On-site recycling of an NPRI substance does not affect the total mass amount of the substance at the facility and the threshold calculations will therefore not be affected by the regeneration of the substance. For example, if a facility processes 13 tonnes of an NPRI substance contained in a catalyst in a year, and recycles 5 tonnes of that substance on site, the facility would only account for the total amount of 13 tonnes for threshold calculations. All release and disposal quantities of the NPRI substance would be reportable, but on-site recycling quantities would not be reportable to the NPRI program.

Yes, as the lead mass and concentration thresholds are met (50 kg and 0.1%). The entire electrode assembly is considered to be an “other use” of lead, relevant to the purposes of the facility as defined in the Canada Gazette Notice. The entire quantity of lead in the electrode assembly, 60 kg, must be used in the threshold calculation, not just the 20 kg consumed in the process. You would then be required to submit a report for the amount of lead that was released or transferred from the site.

MPO

Metal parts, sheets or wire lose their article status when releases to the environment, disposals or transfers for recycling occur.

An article is a manufactured item that does not release an NPRI substance when it undergoes normal processing or use. When an article is processed or used and there are no resulting releases, disposals or transfers for recycling, the NPRI substances in that article do not need to be included in the threshold calculation.

Metal parts, sheets or wires containing Part 1A substances that generate waste during processing or use, such as turnings or blanks, will retain their article status if the waste generated is recycled with due care. Due care is considered to have been exercised if no more than 1 kg (0.001 tonne) of a Part 1A NPRI substance is released during the calendar year as a result of the processing or other use of an article. Due care does not apply to Part 1B substances because of their low reporting thresholds.

Typical metal-processing activities that do not revoke article status (assuming due care is exercised in ensuring recycling of Part 1A substances), and which normally generate limited releases of NPRI substances, include mechanical cutting, stamping, bending, punching, machining, shearing and cold extrusion. This only applies to metal processing involving metals that are in a solid state and stable.

Other metal-processing activities such as welding (with or without welding rods), soldering, and quenching, etching and dry grinding generally do not revoke article status of the base metal, but any releases of NPRI substances during these activities would need to be included in calculation of mass reporting thresholds, if they can reasonably be estimated. Note also that article status does not apply to the welding rods themselves, or filler materials used. Refer to the Arc welding, cutting and spraying activities: guide to reporting available in the NPRI Toolbox for more information on reporting to the NPRI for welding activities.

In this case, welding rods lose their article status since they are consumed during the welding process and would, therefore, be reportable if the threshold for those substances are met. The welded metal parts retain their article status, so the NPRI substances contained in them do not have to be included in the threshold calculations. Refer to the Arc welding, cutting and spraying activities: guide to reporting available in the NPRI Toolbox for more information on reporting to the NPRI for welding activities.

NPRI substances contained in the paints and glues would be reportable if the threshold criteria are met. The reporting requirements for VOCs (Parts 4 and 5 substances) should be checked in particular since VOCs can constitute a major part of paint and glue formulations.

No. The use of fuel is not implicitly exempt from NPRI reporting requirements. The combustion of fuel in stationary combustion equipment (e.g. for power generation) must also be considered when calculating the release thresholds for Parts 4 and 5 substances.

Retail sale, storage and fuel distribution are exempt except as part of terminal operations. Refueling of motor vehicles is also covered by this exemption even if the vehicle is refueled from a tank on company property. Mobile sources such as vehicles and earth-moving equipment are not stationary items considered as part of a facility; therefore, their fuel use is not to be included in the calculation of the reporting threshold.

While CCA is not an NPRI substance, copper (Cu), chromium (Cr), arsenic (As) and their compounds­ are on the list. A threshold calculation must be performed for each individual substance. Furthermore, since the chromium in CCA is hexavalent, the 50 kg threshold is the one which applies.

A typical bulk solution of CCA (50% concentrate) contains 12.30% Cr, 7.39% Cu and 11.09% As, by weight. A facility process using 407 kg, would need to report for Cr only. If the facility used 451 kg, both Cr and As reports would be required. Finally, if 136 tonnes were used, the facility would be required to report for Cr, As and Cu.

Regardless of the number of employees, all wood preservation facilities must report for all substances that meet reporting thresholds. However, facilities using creosote for wood preservation must report polycyclic aromatic hydrocarbons (PAHs) regardless of PAH quantity thresholds. Facilities using pentachlorophenol (PCP) must report for dioxins, furans and hexachlorobenzene (HCB). Wood preservation facilities using creosote or PCP are not obligated to report on other substances if mass thresholds are not met.

Substances that are pumped into tailings impoundments are considered on-site disposals, however only the net quantity of these substances added to tailings impoundments would be reported as disposals each year, and not the total quantity included in recycled streams.

The total quantity of substances removed from the tailings impoundment and transferred off-site for disposal, treatment or recycling would be reported separately under the applicable category and any other quantities of substances leaving the tailings impoundment would be reported as releases to air, water or land, as applicable.

No. Refractory bricks would retain their status as articles as long as they do not release any NPRI substances during use. However, the refractory bricks lose their article status if during conditions of use they degrade and release NPRI substances. In that event, the total quantity of NPRI substances in the refractory lining must be used in the calculation of the reporting thresholds for each substance.

Yes. Process equipment maintenance using materials such as grease, oils or lubricants, disinfectants or paint is not exempt and must be considered for the purposes of NPRI reporting. For the purpose of Part 1 substances, the use of greases and fuels in this situation would be considered “other use.” The air releases emitted by these materials would have to be considered for Parts 4 and 5 substance reporting requirements.

Substances/Chemicals

Yes. Reporting of NPRI Part 1A substances is based on quantity manufactured, processed or otherwise used, not on quantities released. You must perform your threshold calculations based on the amount of cyanide ion used or processed and submit a report if you met or exceeded the 10 tonne threshold. Since non-ionic forms of cyanide are not on the NPRI substance list, you would report a zero release of cyanide ion.

Yes. If the amount of copper met or exceeded the 10 tonne reporting threshold, you would submit a report for “copper (and its compounds)” and report a release of zero for this process. All other releases, transfers or disposals of copper from your facility would also have to be reported.

Substances/Chemicals

Report only the metal portion of the compounds. In this example, the total weight of zinc in all of the compounds would be reported under “zinc (and its compounds).”

Substances/Chemicals

A facility used exclusively for the education or training of students, such as colleges, universities and schools, is exempt from reporting Part 1A, 1B, 2 and 3 substances. For the purposes of the education and training of students exemption, fire-fighters and fire-fighter trainees are not considered to be students. The CAC releases from the combustion of fuel for fire-training, including extinguishing structure fires, and other stationary combustion sources, must be included in CAC release threshold calculations, and reported if thresholds are met. Any Part 1-3 NPRI substances manufactured, processed, or otherwise used during the training must also be considered in the threshold calculations.

combustion equipment; exemption; fuel; training

No. A warehouse does not meet reporting requirements if it does not manufacture, process or otherwise use NPRI substances. If there is transfer of NPRI substances between containers, this is considered processing and thresholds would have to be calculated by the warehouse facility. Wholesale distribution­ is exempt, provided there are no releases of NPRI substances.

The following activities are considered processing or otherwise using for NPRI purposes: transfer of substances between containers, mixing or blending substances prior to packaging, and movement of substances from a pipeline to a tank or vice versa. The quantity of substance in the largest container or in bulk would be considered in determining threshold calculations.

The following activities are NOT considered processing or otherwise using of NPRI substances: relabeling, redistribution or storage of containers, where containers remain unopened and no repackaging occurs.

For Part 1A, 1B, 2, 4 and 5 substances, you are required to report a value based on the best available information in your possession if you know that the substance is being released or transferred. You must collect your facility information and identify the substances for which a report is required. You should report “zero” releases, disposals or transfers only if it is known that these substances were not released, disposed of or transferred. If no information is available from any source which would allow you to estimate releases, disposals or transfers of a substance, you may report “zero” releases and add comments on the unavailability of data or emission factors for your specific process. An example of this would be in the case of a specific welding process which is not listed in the Electric Arc Welding Emission Estimation Calculator spreadsheet or in any other tools available to you.

If the reporting criteria for the individual dioxins and furans and HCB (Part 3 substances) is met, but you have no data and cannot find emission factors, you are required to report “No information available” for any releases, disposals and transfers expected to contain these substances (e.g., releases to air from a combustion­ process that generates dioxins and furans).

Metal cleaning and metal plating baths are considered an “other use” of an NPRI substance, relevant to the purpose of the facility as defined in the Canada Gazette Notice. The entire quantity of the individual NPRI substance(s) in the metal cleaning or plating bath and any quantity used to refill the bath must be used in the threshold calculation, not just the quantity consumed in the process. If the threshold is exceeded, you would only report releases, disposals and transfers of the individual NPRI substance(s), even if releases, disposals and transfers are determined to be zero.

No. Polyvinyl chloride is a polymer made from vinyl chloride. It is not the same substance and is not listed in the NPRI; therefore, it is not reportable. Only the free vinyl chloride monomer is reportable. Some formulations of pre-polymers may contain a percentage of free monomers. If you purchase pre-polymers which contain free vinyl chloride monomers, add this to the threshold calculation.

The CAS No. 1332-21-4 is defined as “Asbestos, a greyish, non-combustible fibrous material. It consists primarily of impure magnesium silicate.” Asbestos with the CAS No. 1332-21-4 is the general CAS No. for a number of specific types of asbestos including those listed above. Those types of asbestos would be reportable if they are in friable form.

In vacuum deposition, the metal is converted to a vapour state under low pressure. The vapour condenses­ on the material to be coated. Vapours are not fumes. A metal fume consists of finely divided particulate matter dispersed in a gas (smoke). Because vapours and fumes are different, this process would not be considered a reportable activity unless the deposition creates fumes or dust.

Routine janitorial or other facility grounds-maintenance activities that use NPRI substances contained in cleaners, fertilizers or pesticides are exempt.

Process equipment maintenance using materials such as grease, oils or lubricants, disinfectants or paint is not exempt and must be considered for NPRI reporting.

Yes. Items such as grinding wheels are, by their nature and use, intended to wear down and release substances. They are designed to be replaced and are subject to reporting.

Yes. Degreasing of equipment for maintenance is not considered routine maintenance and is not exempt. It would be reported as “other use” (Part 1 substances) or as air releases (Part 4 and 5 substances).

Research and testing activities are exempt from reporting Parts 1A, 1B, 2 and 3 substances, and therefore certain laboratories may be exempt. However, if a laboratory operates stationary­ combustion equipment, then it must report for Parts 4 and 5 substances released from the stationary combustion equipment that exceeded the release threshold.

Examples of research and testing laboratories include laboratories found at universities, and research facilities that perform functions not associated with the manufacturing or processing activities of a facility.

The following examples of activities are not considered research and testing and are therefore not exempt activities: activities that support manufacturing operations such as quality control laboratories; commercial and institutional laboratories; manufacturers of specialty chemicals; pilot-scale studies; environmental and medical laboratories; and photo development laboratories.

Reporting requirements

Because you met the 10 tonne threshold for chlorine gas, you are required to report any releases, disposals­ and transfers for recycling of chlorine gas. Because you manufacture chlorine dioxide at a concentration greater than 1%, you are required to report any releases, disposals and transfers of chlorine dioxide. The subsequent dilution of the chlorine dioxide does not affect the threshold calculation­.

A solvent received from a recycling operation located off site counts as new material and must be included in the threshold calculation. The quantity sent off site for distillation must be reported as material sent for recycling.

NPRI substances sent off site for fuel blending or that add energy to a heat-recovery activity must be reported as a transfer for energy recovery. Other releases, disposals or transfers of toluene must also be reported. In addition, any toluene released to air must be included in the calculation of the facility-wide total VOC air emissions under Part 4 (Part 4 threshold for total VOCs is 10 tonnes released to air). It would also have to be included under Part 5 if the quantity of toluene released to air was greater than 1.0 tonne.

Paint-booth cleaning is not considered a routine janitorial activity and would be reportable under the classification “other use” (Part 1 substances) or as air releases (Part 4 and 5 substances).

A facility is defined in the Canada Gazette Notice as a contiguous facility, a portable facility, a pipeline installation or an offshore­ installation. A contiguous facility includes all buildings or structures located on a single site or on adjacent sites which are owned or operated by the same person and function as a single integrated site.

Plants must report separately if they manufacture, process or otherwise use unrelated products and if they do not share common operations as part of an integrated site. Characteristics of an integrated site include, but are not limited to, common shipping/receiving equipment, common administrative staff, common management or common contact information.

If the criteria for reporting are met, then reporting to the NPRI is mandatory as per section 46 under CEPA. It is the responsibility of each person who owns or operates a facility to determine whether they are required to report after examining the Canada Gazette Notice and CEPA, and to report before the reporting deadline There is a Compliance and Enforcement Policy for CEPA , which dictates how regulations and notices are enforced. The Canada Gazette Notice, CEPA and the above-mentioned policy are available on the CEPA Registry Internet site.

A wastewater treatment facility owned or operated by the company or parent company and connected to the pulp mill by any combination of a permanent continuous pipe, conveyor, tunnel or sluiceway, and which functions as part of a single integrated facility shall be considered part of the pulp mill for the purposes of NPRI reporting.

In this case, the wastewater treatment facility is an integral part of the pulp mill and is connected to it by a permanent, continuous connection. Both facilities are operated by the same company as a single integrated site. This represents a contiguous facility, and the company’s report to the NPRI must include the activities at the wastewater treatment facility. In determining whether the employee threshold is met, the total number of employee hours at the pulp mill and the wastewater treatment facility must be considered.

If the companies are owned or operated by the same person or controlling parties and function as a single integrated site, they must report as one facility. If they do not meet both of the above conditions, they must perform separate threshold calculations and report as separate facilities.

A substance cannot be considered exempt from reporting to the NPRI based on it being regulated under other legislation. Exemptions from reporting to the NPRI must be based solely on those reasons indicated in the Notice with respect to the substances in the NPRI, published in the Canada Gazette, Part I.

Solid waste landfills may provide final disposal for NPRI substances. For Parts 1 to 3 substances, the definition of “other use” includes disposals or releases of that substance which are not included in the definition of “manufacture” or “process.” For Parts 4 and 5, all stationary­ sources of CACs must be considered at the landfill sites. If the facility meets all threshold criteria for these substances, it is required to report. Additionally, landfills can generate by-products such as ammonia in their leachate or VOC releases to the atmosphere. A report is needed for these substances if the threshold criteria are met.

Unloading, transferring, blending and repackaging are forms of processing which can trigger NPRI reporting. All releases, disposals and transfers resulting from these activities are reportable. Substances that arrived in sealed containers and were only stored in a warehouse prior to distribution would not be included. The filling and emptying of storage tanks is also considered processing, and fugitive releases from those tanks must be included when calculating CAC release thresholds. In addition, CACs released from the stationary combustion equipment used at the chemical distribution facility must also be included in the CAC mass release threshold calculations.

Approximately 30-36 tonnes of chromium (excluding hexavalent chromium) were used in processing the ore. The threshold criteria for reporting for chromium (and its compounds) have been met and you are required to report any releases, disposals and recycling of the chromium (and its compounds), even if those quantities are zero.

Yes. Reporting to the NPRI would be required if the HVAC systems and refrigerant equipment within a facility had a total holding capacity of 10 tonnes or greater. (Note: This does not refer to the cooling capacity of the system, which may also be expressed in tonnes. The equipment nameplate should also indicate the halocarbon capacity of each unit.)

The 10 tonne threshold calculation should be completed for each halocarbon within the facility (i.e., if the chillers contain CFC-11 but the condensers and evaporators contain HCFC-22, they are not to be included in the same calculation). Also, calculations should include the quantity of halocarbon that was in the system at the beginning of the year plus any additional halocarbons that were added during refilling throughout the calendar year (i.e., during an annual leak test). Halocarbons used in office and plant air conditioning systems must be included in the 10 tonne threshold calculation. Halocarbons used by employees for personal use (i.e., refrigerators in lunch rooms/cafeteria, water fountains, vending machines) are not to be included.

Halon in a fire-suppression system is considered to be an “other use” of an NPRI substance. If the fire-suppression system contains Halon 1211 or Halon 1301 in quantities equal to or greater than 10 tonnes at a concentration equal to or greater than 1%, the facility would be required to report to the NPRI (provided the employee threshold is also met). The threshold calculations should include the quantity of halon that was used in the system at the beginning of the year, plus any additional halon added during refilling (i.e., after use or during maintenance). The type and quantity of halon will be listed on the equipment nameplate. Halons in storage are not in use and do not need to be included in a threshold calculation. Although if leaks occur from a particular storage vessel, the entire amount of the halon in the vessel is then considered “otherwise used and released” and must be included in the threshold calculation. The leaked amount must be reported if the thresholds have been met.

No. An article is “a manufactured item that does not release an NPRI substance when it undergoes processing or other use.” Even though the pellets themselves appear to meet the definition of an article, there will be releases (dust emissions, spills, etc.) as a result of normal handling in installation or charging, removal for disposal, regeneration or recycling, and operational use of the catalyst. Therefore, the article exemption does not apply in this case. All NPRI substances present in the catalyst must be included in the threshold calculation for each substance, provided the concentration thresholds are met. If the thresholds are met, all releases, disposals and transfers for recycling must be reported, regardless of the quantities or concentrations.

While asbestos is used as insulation and emits no on-site releases it is considered an article and is exempt from reporting. However, if asbestos (friable form) is removed from any part of the facility it loses its article status and is considered to be “otherwise used.” In this case, the asbestos must be included in determining whether the facility met the 10 tonne manufacture, process or otherwise use threshold for this substance. Once the facility meets the 10 tonne threshold, a report must be submitted­ for asbestos, and the quantity removed from any part of the facility must be reported. This information should be reported under “other use” as “ancillary or other use.”

Portable facilities are defined as portable polychlorinated biphenyls (PCB) destruction equipment, portable asphalt plants and portable concrete batching plants. If you operate any of these three types of facilities, then you are required to report if the thresholds are met. The thresholds shall be based on the cumulative values for all the “portable” locations during the year.

Owners/operators of portable facilities will be required to submit release/disposal/transfer information once for the entire calendar year by adding up releases/disposals/transfers from all operating locations, and submitting the totals in the online reporting system (one value per substance). In the reporting system, you will create a report for the location where the portable facility operated for the longest period of time in the year. This is also the location that you must provide latitude and longitude coordinates in the reporting system. For all other locations where the portable facility operated during the year, enter the dates, addresses and latitude/longitude coordinates in the facility level comment section of the reporting system.

No, the NPRI requires that emission values be calculated each year. The stack test data from four years ago can be used to create facility specific emission factors for each substance tested. These emission factors can then be used along with the facility’s current year’s production data to calculate new emission values, provided the stack test data is still the best available and applicable data accessible to the facility.

For the two years where the projectiles remain in the berm, the facility would report the amount of projectiles fired as a release to land. So, if in the first year 1 tonne of lead projectiles were spent and in the second year 3 tonnes of lead projectiles were spent, the facility would report 1 and 3 tonnes respectively as being a release to land, which would be identified in the online reporting system as “other releases to land.” Then, if in the third year an additional 2 tonnes of lead projectiles were spent for a total of 6 tonnes over the three years and the berms were cleaned and yielded 5.5 tonnes of lead projectiles, then he facility would report 0.5 tonnes of lead as being released to land and 5.5 tonnes of lead transferred off-site for recycling, under “recovery of metal and metal compounds.”

Yes. Although the NPRI has a concentration threshold for a majority of its substances, a facility can always decide to go beyond what is required and include all concentrations in their threshold calculations. Remember that once the MPO threshold is met, all occurrences of the substance (regardless of concentration) need to be considered when calculating the releases, disposals and transfers for that substance, not just those greater than or equal to 1%. 

Any NPRI substances manufactured, processed or otherwise used during the extraction and processing of the rock or ore (e.g., during primary and secondary crushing, milling, concentrating, smelting, and refining) would be reportable if the thresholds were met. This would include, but not be limited to, NPRI substances found in the ore, solvents, acids, flotation agents, flocculation agents, dust suppressants, fuels used in power generation, particulate matter and combustion contaminants (e.g., NO_x, SO₂). Listed substances in tailings or waste rock must also be reported. Particulate matter releases from vehicular traffic on unpaved roads within the facility must also be considered, if the total number of kilometres traveled on those roads is greater than 10 000 kilometres. For more information on the reporting requirements related to mining activities, please consult the Guidance for the Reporting of Tailings and Waste Rock to the National Pollutant Release Inventory.

In general, a facility must start reporting only when it enters production or starts operating for the purpose for which it was designed.

However, if an existing, operational facility undergoes an expansion, the facility must consider all substances/activities related to the construction of the expansion, in addition to the substances/activities that are part of regular facility operation when reporting to the NPRI.

Yes, an NPRI report may be required prior to the mine becoming operational, if the reporting requirements are met.

Once the construction of the open pit or underground mine starts, a report may be required if the reporting criteria and thresholds are met. In this case, the NPRI report would include reporting on the substances in waste rock produced during the development (construction) phase, including waste rock from the sinking of shafts or the construction of open pits. The reporting of waste rock would be captured only if the waste rock is not specifically excluded, as per the NPRI notice. For more information on reporting for waste rock, please consult the Guidance for the Reporting of Tailings and Waste Rock to the National Pollutant Release Inventory.

During the development (construction) phase, all of the NPRI reporting requirements apply (e.g., Criteria Air Contaminant emissions from stationary combustion equipment, releases to water from waste rock piles or other effluent sources, road dust, etc.) if the applicable reporting criteria are met.

Yes, you may need to submit a report for a facility that is under decommissioning, under care or in maintenance mode, or where remediation activities are taking place if the employee and/or substance-specific reporting criteria have been met.

During this phase, all of the NPRI reporting requirements apply (e.g., Criteria Air Contaminant emissions from stationary combustion equipment, releases to water from waste rock piles or other effluent sources, road dust, etc.) if the applicable reporting criteria are met.

Wells connected to the central processing plant by a pipe, and owned or operated by the same company or parent company, are considered to be contiguous. The central processing plant and well pads are considered to function as an integrated site because of the cyclic production process, i.e., the central processing plant processes the bitumen or crude oil emulsion generated at the well pads, and regenerates steam, solvent and/or polymers for the wells.

Therefore, the well pads and the central processing plant shall be considered as a single facility in determining whether the employee threshold is met, and report to the NPRI for both the activities at the wells and the central processing plant in a single report.

If during a calendar year, more of the substance is injected than recovered, the portion of the substance that remains underground at the end of the calendar year, must be reported under the category “other releases to land that are not disposals”, and the nature of the release (e.g., “injection underground to enhance the recovery of bitumen”) must be specified in the  “Nature of "Other" land release comments” field. For example, if 700 tonnes of an NPRI substance are injected during the year, and 500 tonnes are recovered, an “other release to land” of 200 tonnes must be reported. If the 500 tonnes recovered are returned to the process, no further action is required for that year. However, if they are disposed of or sent off-site for recycling, they must be reported accordingly.

Items, such as batteries, which contain NPRI substances that are not being released during use, are considered “articles” and are not subject to reporting. However, the item loses its article status if NPRI substances are released. In addition, if you recycle lead-acid batteries by crushing and removing the lead, the batteries lose article status and the NPRI substances they contain must be considered in the threshold calculation.

A sealed glass bulb containing mercury used in a levelling switch meets the definition of an article. However, the quantity of mercury in the switch must be included in a facility’s calculation of the reporting threshold if the item loses its article status (e.g., the bulb is broken during waste management operations, thus allowing a release of mercury). As long as the bulbs remain intact, they are considered articles and are therefore not included in calculating the reporting threshold.

In conclusion, you do not have to include intact items in your MPO calculation and you only need to account for damaged batteries and damaged fluorescent lights.

Yes. NPRI substances that are released as fugitive emissions must be reported. For mines, this might include the individual metals in the dust, as well as the dust itself as a reportable particulate.

There are two sets of calculations that facilities must perform. First, in order to determine if a substance report is required, facilities must calculate the quantities of a substance that is manufactured, processed or otherwise used (MPO). If the mass threshold based on these MPO quantities is met, then facilities must report for that substance. MPO calculations only apply to Part 1 substances. Facilities do not report MPO quantities to the NPRI.

Secondly, if the mass threshold based on the MPO quantities is met, facilities are required to calculate all quantities that are released, disposed of and recycled, regardless of concentration or quantity and regardless of whether or not the quantity was used in the threshold calculation. The release, disposal and recycling quantities must be reported to the NPRI, even if those quantities are zero. The only exception to this is for disposals of Part 1A substances in waste rock where the substance is at a concentration of less than 1%. In the case of waste rock, the 1% concentration threshold for Part 1A substances applies to both the threshold calculation and the disposal calculation.

It is possible for a facility to meet the MPO mass threshold of a substance and not have any releases, disposals or recycling (e.g., if the substance is completely contained in the final product). Reporting is deliberately set up this way as it helps with the objective of improving public understanding – e.g., community members may want to know what substances are being used at a facility, even if there are no releases. It can also help in the event of an emergency or an accidental spill.

It is important to remember that the quantity otherwise used includes all releases and disposals of an NPRI substance. For example, the quantity of the NPRI substance contained in dust released to air from materials stored on site would be included, whether or not the material is used for a specific purpose at the facility. Another example would be a spill to water or land during storage or handling.

Assuming you met the 10-tonne threshold for manufacture, processing or other use of chlorine, you must file a report. For a facility that treats water to produce drinking water, a report must be submitted if the threshold is met, but the quantity of residual chlorine in the drinking water shipped off site would not be reportable since this is a product of the facility. Chlorine (Cl2), when added to water, will no longer exist as a reportable substance in most circumstances, resulting in a report of zero release. However, if the pH of the treated water falls below 6.5, you must consider the equilibrium of chlorine and hydrochloric acid (HCl) when performing the threshold calculation for each substance.

Yes, stevedoring facilities are required to report to the NPRI if reporting requirements are met. If one or more NPRI substances was manufactured, processed or otherwise used (MPO) at the facility during the year, and the total number of hours worked at the facility exceeded the 20,000 hour employee threshold (approximately 10 full-time employees), the total amount of each NPRI substance MPO at the facility during that calendar year will need to be determined.

A report is required for fuel terminal operations regardless of the number of employees. Also, facilities that operate stationary combustion equipment must report for criteria air contaminants (Part 4 substances), regardless of employee hours, if the release thresholds are met.

Pulp and Paper facilities that report releases of mercury and/or criteria air contaminants to air and who meet the following electricity generating requirements, must assign those releases to each unit:

1. The unit has a capacity of 25 MW or more
2. The unit distributes or sells to the grid 33% or more of its potential electrical output

An electricity generation unit means physically connected equipment that operates together to produce electricity for sale or distribution to the grid by means of thermal energy and is stationary when used, and is not in or on a machine that is self-propelled. The following are examples of physically connected equipment that form a unit:

1. A single boiler producing steam that is sent to one or more steam turbines to produce electrical power or combined heat and electrical power.
2. Multiple boilers producing steam that is collected through a common header and sent to one or more steam turbine(s) to produce electrical power or combined heat and electrical power.

Only substances having emissions associated with electricity generation should be included when reporting at the unit-level. The emissions related to the steam portion used only for industrial process and doesn’t go to the turbine(s) should not be accounted.

• Include all emissions associated with electricity generation, not just those that are associated with electricity sold or distributed to the grid.
• Emissions should be allocated to electricity generation based on using heat input/output values. Hence, only emissions – calculated based on heat that went into boilers for producing steam that produced electricity - associated with electric output of the unit should be used for reporting of emissions.

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