Final Performance Report – Reaction products of 2-propanone with diphenylamine (PREPOD): pollution prevention planning notice

This pollution prevention planning notice (P2 notice) targets facilities in the chemical manufacturing sector or the rubber products manufacturing sector. The risk management objective (RMO) for this P2 notice is to reduce the presence of PREPOD in industrial effluents by reducing the concentration of the diisopropyldimethylacridan (DIPDMA) component below 0.12 ng/L. To date, three facilities in Canada have reported being subject to the notice and have submitted declarations of preparation, interim reports, and declarations of implementation. This performance report summarizes the information received.

Summary

To protect the environment, this pollution prevention (P2) planning notice was published in 2019 with the RMO to reduce the presence of PREPOD in industrial effluents by reducing the concentration of the DIPDMA component below 0.12 ng/L. Three facilities were subject to the P2 notice and have implemented P2 plans with a 2020 baseline year. These facilities are AirBoss of America Corp. (Airboss), Lanxess Canada Co./Cie (Lanxess), and Infinity Rubber Technology Group (Infinity). All three facilities have ceased their manufacture and/or use of PREPOD entirely. While no facility met the RMO by the implementation date of July 1, 2023, both Lanxess and Infinity met the RMO by the fall of 2023. This was confirmed through supplemental voluntary sampling undertaken by these two facilities.

Objectives and results

The RMO for this P2 notice is to reduce the presence of PREPOD in industrial effluents by reducing the concentration of the DIPDMA component below its level of quantification (LoQ) of 0.12 ng/L. DIPDMA is a component of PREPOD and is used as an indicator for the presence of PREPOD in industrial effluents.

The following information was submitted by facilities through the Government of Canada’s Single Window Information Manager (SWIM) to meet their reporting obligations under the P2 notice:

1. Declaration of preparation (Schedule 1)
2. Interim progress report (Schedule 4)
3. Declaration of implementation of the P2 plan (Schedule 5)

Some information submitted through SWIM has been identified as confidential business information and has therefore been masked or excluded from this report.  

As a factor to consider in preparing their P2 plans, facilities were asked to perform sampling of the industrial effluent in advance of submitting their Schedule 1, Schedule 4, and Schedule 5 reports. Airboss and Lanxess provided results for sampling undertaken in 2020, 2021 and 2022 in their Schedule 1, Schedule 4, and Schedule 5 submissions respectively. Infinity rubber did not perform sampling for 2020, however they took samples for their Schedule 4 submission in 2022, and for their Schedule 5 submission in 2023. Additional voluntary sampling beyond that required to be considered under the P2 notice was completed by Lanxess and Infinity in fall 2023. Figure 1 illustrates the change in concentration of the DIDPMA component of PREPOD in industrial effluent between the first, second and third sampling events that occurred under the P2 notice, and the additional voluntary sampling event that occurred in the fall of 2023.

Figure 1: On-site sampling results for DIPDMA concentrations in industrial effluent

Based on the results shown in the Schedule 5 reports, none of the facilities subject to the P2 notice that submitted reports were successful in meeting the RMO to reduce the concentration of DIDPMA in their effluent to below the LoQ of 0.12 ng/L by the implementation date of July 1, 2023. However, based on the results of additional voluntary effluent samples provided to ECCC, both Lanxess and Infinity were successful in meeting the RMO by the fall of 2023.

Despite Lanxess having stopped the manufacture and use of PREPOD, DIPDMA concentrations increased between their Schedule 4 and Schedule 5 sampling events. Lanxess believes that this is due to residual DIPDMA in the facility’s wastewater treatment system. Between the second and third sampling event, municipal limits for pH of effluent released were increased from 9.5 to 10.5. This increase in pH may have resulted in the accumulated DIPDMA in the wastewater treatment system to partition from the sediments into the effluent leading to higher effluent concentrations. Since effluent concentrations dropped below the RMO in fall 2023, no further action is required at this time.

AirBoss indicated that they did not meet the RMO because they are using BLS 75, a product that has similar components to PREPOD, as a substitute material for Aminox 1414, a product that contains PREPOD. Additionally, the phase-out of Aminox 1414 was not scheduled to be complete until December 31, 2022, therefore at the time of sampling, PREPOD was still in use at the facility. AirBoss declined to participate in the fall 2023 voluntary sampling.

Figure 2 displays the change in PREPOD usage between each facility’s Schedule 1, Schedule 4, and Schedule 5 reports. Reported usage values found in Figure 2 for AirBoss and Infinity represent the use of products containing PREPOD in the manufacture of rubber products.

Reported usage values in the Schedule 1, Schedule 4, and Schedule 5 reports submitted by Lanxess represent the PREPOD-containing products manufactured on site and a portion of those products subsequently used at the facility to create secondary products. In 2020 and 2021, Lanxess both manufactured and used products containing PREPOD at their facility. However, as of 2022, Lanxess stopped both the use and manufacture of PREPOD products. Primary products manufactured on-site decreased from 227 tonnes in 2019 to 0 tonnes in 2021.

Figure 2: Reported usage of PREPOD per year

Actions taken to achieve the objective

P2 methods focus on avoiding the creation of pollutants, rather than trying to manage them after they have been created. P2 activities include substituting materials or feedstock; redesigning or reformulating products; changing equipment or processes; preventing spills and leaks; changing inventory management and purchasing practices; reusing, recycling and recovering on-site; and improving operating practices and providing training.

The Government of Canada believes that P2 methods are the most effective means of protecting the environment, eliminating costly waste, and promoting sustainable development. As a factor to consider in preparing the P2 plan, facilities were asked to give priority to P2 activities over treatment and/or disposal methods in order to reach the objective of the P2 notice. Those preparing P2 plans were provided with a description of P2 activities on the webpage how your business can prevent pollution. In 2021, 87.5% of all the reported actions being implemented by the subject facilities were P2 methods (Figure 3), of which material or feedstock substitution and equipment or process modifications led the way (25% each) followed by product design or reformulation, spill and leak prevention, and good operating practices or training (12.5% each).

All the facilities subject to the P2 notice claimed that PREPOD would be phased out once their P2 plans are fully implemented. 

Figure 3: Distribution of P2 methods chosen by the facilities subject to the P2 notice to reduce emissions of PREPOD

Conclusion and next steps

In accordance with the P2 notice, full implementation of the P2 plan was required by July 1, 2023. All subject facilities met this implementation date. In accordance with their P2 plans, all facilities ceased their manufacture and/or use of PREPOD containing products.
While no facility met the RMO by the implementation date, voluntary sampling conducted by Lanxess and Infinity in the fall of 2023 provided analytical results demonstrating concentrations below the RMO. Although sampling results from AirBoss did not meet the RMO, the concentrations of DIPDMA did decrease with the decrease in their use of PREPOD containing products. Since all facilities subject to the notice have ceased their use and/or manufacture of PREPOD containing products, no further action will be taken at this time.

The P2 notice continues to remain in effect. If any new facilities meet the requirements of the P2 notice, they will also be required to prepare and implement a P2 plan and submit reports for schedules 1, 4 and 5. Should that happen, this performance report will be updated accordingly.

Background

PREPOD was found to be toxic under section 64 of the Canadian Environmental Protection Act (CEPA) and PREPOD was added to the List of Toxic Substances in Schedule 1 of CEPA on December 14, 2016. A P2 planning notice was selected as the instrument to respond to the requirements of CEPA for this toxic substance.

On June 15, 2019, Environment and Climate Change Canada (ECCC) published a final P2 planning notice in respect of PREPOD in Canada Gazette, Part 1. The P2 notice applies to any person or class of persons who, on the date of publication of the P2 notice or any time thereafter, owns or operates an industrial facility that

1. is in the chemical manufacturing sector or rubber product manufacturing sector
2. releases an industrial effluent at one or more of its final points of discharge; and
3. manufactures or uses greater than 100 kg of PREPOD either alone or in a mixture or compound containing PREPOD in one calendar year

Persons subject to the notice must prepare and implement a P2 plan, based upon consideration of all the factors to consider listed in the P2 notice, including the RMO to reduce the presence of PREPOD in industrial effluents by reducing the concentration of the DIPDMA component below its LoQ of 0.12 ng/L. In addition, information must be submitted to ECCC three times during the implementation of the P2 notice: a Declaration of Preparation (Schedule 1 report), an interim report (Schedule 4 report), and a final report (Schedule 5 report). The timelines for these submissions can be viewed at Timeline for pollution prevention planning, sampling and reporting for PREPOD.

Submissions are available to the public on the Government of Canada’s pollution prevention planning reports webpage. The information presented in this document is derived from these submissions.

Sources

Pollution Prevention Planning Online Reporting Tool and Database: Online search - Canada.ca