Instructions for completing schedules of bisphenol A pollution prevention planning notice: chapter C

C. Substance and activity information

The information described in this section is collected in Schedules 1, 4 and 5.

3.0 Substance and activity ("Type of Activity" page in reporting tool)

Indicate all the activities that apply to your facility (a) manufacture BPA; (b) use of BPA or use of any mixture containing BPA.

The term "manufacture" means to produce, prepare or compound the Substance. This also includes the incidental production of the Substance as a by-product as the result of the manufacture, process and use of other substances.

The term "use" refers to the use of the Substance or use of any mixture containing the Substance having a function or purpose in the production of products or as an intermediate used to manufacture products.

4.0 Baseline information prior to implementation of the pollution prevention plan ("Baseline Information" page in reporting tool)

Note a): Reporting Period

Each Schedule requires reporting of data for a full calendar year (e.g. January 1, 2012 to December 31, 2012).

Reference is made to three types of reporting years throughout these instructions:

1. The Preparation Year refers to the first year of reporting. If you are completing Schedule 1, the data you are reporting corresponds to the Preparation Year.
2. The Base Year refers to the year against which results will be compared.
3. The Reporting Year refers to the year you are reporting data for the Interim Progress Reports (Schedule 4). If you are completing Schedule 4, the data you are reporting corresponds to the Reporting Year for either the Interim Progress Report #1 or the Interim Progress Report #2.
4. The Implementation Year refers to the final year of reporting. If you are completing Schedule 5, the data you are reporting corresponds to the Implementation Year.

If you became subject after the date of publication of the Notice or if you have applied for and been granted a time extension that subsequently affects the year for which you must report, indicate the new year for which you are reporting. All references to the calendar year in the Schedules should correspond to the new year which you have identified.

Note b): Estimation Methods Codes

Estimation Methods codes provide information about how you determined the quantity of a substance that was used, released and/or transferred. Whenever a quantity is reported in a Schedule, an Estimation Methods code must be provided. The codes for the methods of estimating uses, releases and/or transfers are listed below (Note: the same codes are used for NPRI reporting. For more information, see the NPRI Reporting Guide).

M1 - Continuous Emission Monitoring Systems

Continuous Emission Monitoring Systems record emissions over an extended and uninterrupted period. Once the concentration and the flow rate have been determined, emission rates can be calculated by multiplying the concentration by the discharge flow rate or volumetric stack gas flow rate. Annual emissions of the substance can then be estimated by multiplying the concentration by the annual flow rate of the discharged effluent or gases in the stack or duct.

M2 - Predictive Emission Monitoring (PEM)

Predictive Emission Monitoring (PEM) is based on developing a correlation between substance emission rates and process parameters (e.g., fuel usage, steam production, furnace temperature). PEM may be considered a hybrid of continuous monitoring, emission factors and stack tests. A correlation test must first be performed to determine the relationship between emission rates and process parameters. Emissions can then be calculated or predicted using process parameters to predict emission rates based on the results of the initial source test.

M3 - Source Testing

Source Testing involves collecting a sample of the emission or effluent, then determining the concentration of one or more substances in the sample. The concentration of the substance(s) of interest is then multiplied by the volumetric flow rate to determine the amount of the substance(s) emitted over time. Source testing of air emissions generally involves inserting a sample probe into the stack or duct to collect a volume of exhaust effluent isokinetically. The substances collected in or on various media are subsequently analyzed. For liquid effluents, grab samples or 24-hour composite samples are extracted from the effluent stream.

C - Mass Balance

Mass Balance involves applying the law of conservation of mass to a facility, process or piece of equipment. If there is no accumulation, then all the materials that go into the system must come out. Releases are determined from the difference in the input, output, accumulation and depletion of a substance.

E1 and E2 - Site-specific and Published Emission Factors

Generally, emission factors relate the quantity of substances emitted from a source to some common activity associated with those emissions. Emission factors may be published or developed by facilities using emission-testing data and source-activity information. For a particular piece of equipment, specific emission factors may be available from the manufacturer or sales centre. When completing the report, you must specify whether a site-specific emission factor (E1) or published emission factor (E2) was used.

O - Engineering Estimates

In many cases, sound engineering assessment is the most appropriate approach to determining process factors and base quantity values. Releases can be estimated from engineering principles and judgment by using knowledge of the chemical and physical processes involved, the design features of the source, and an understanding of the applicable physical and chemical laws. The reliability of these estimates depends on the complexity of the process and the level of understanding of its physical and chemical properties.

X - Other

Please specify. If none of the codes listed above describe the method for estimating uses, releases and/or transfers, please specify the method used in the field provided

Note: If more than one Estimation Method is used to calculate a single quantity, enter the Estimation Method corresponding to the method that applies to the largest portion of the estimated use, releases or transfers.

Note c): National Pollutant Release Inventory (NPRI)

The NPRI is partially used as a basis for developing the requirements for the baseline information collected in Parts 4.1, 4.2, 4.3 and 4.4 of Schedules 1, 4 and 5. If you already report to the NPRI, you may find that data previously collected for NPRI reporting can be used to complete some or all of these Parts.

4.1 Nature of activity ("Manufacture and Use Information" page in reporting tool)

Identify the nature of activity(ies) and quantity(ies) in kg for activity(ies) identified in Part 3.0 of the Declarations or Interim Progress Reports, and indicate the Estimation Methods code (see section 4.0, note B) used to derive the value for the nature of activity(ies).

If the activity selected in Part 3.0 is "Manufacture of BPA", please complete Part 4.1.1 by indicating the nature of the activity and the quantity in kg of the Substance manufactured for the year(s) you are reporting.

If the activity selected in Part 3.0 is "Use of BPA or any mixture that contains BPA", please complete Part 4.1.2 by indicating the nature of activity and the quantity in kg for the year(s) for which you are reporting.

Note: more than one activity or nature of activity may be applicable.

4.1.1 Manufacture of BPA

If this facility manufactured the Substance, select at least one of the following natures of activity:

• For on-site use: Substance was manufactured and then further processed or used at the same facility.
• For sale/distribution: Substance was manufactured specifically for sale or distribution outside the facility.
• As a by-product: Substance was produced incidentally and released to the environment or transferred off-site for disposal.
• As an impurity: Substance was produced incidentally and remained in the product destined to be distributed in commerce.
• Other: Provide a description to further clarify the identified nature of activities.

4.1.2 Use of BPA or any mixture that contains BPA to process or manufacture

If this facility uses the Substance, select at least one of the following natures of activity:

• Adhesives or Sealants
• Paints or Coatings
• Polyvinyl Chloride
• Brake Fluids
• Electrical Wire or Cable Coatings
• Thermal Paper
• Tires
• Epoxy or Alkyd Resins
• Investment Casting Waxes
• Can Coatings
• Reactant or Intermediate: if the substance is used to manufacture or process a reactant or intermediate, provide a description to further clarify the type of reactant or intermediate. Possible reactants and intermediates may include:
  • Curing Agent: Substance added to a polymer or epoxy to promote or control the curing reaction
  • Inhibitor or Terminating Agent: Substance used to restrain, block, or suppress the chemical reaction
  • Antioxidant: Substance used to retard oxidation and deterioration
  • Filler: Substance used to fill a gap or cavity to improve dimensional stability, finish or strength
  • Accelerator: Substance used as a catalyst to speed up a chemical process
  • Binding Agent: Substance that solidifies as it dries and thereby serves to bind the particles and develop adhesion to a surface
  • Colour Developer: Weak acid used in thermal paper to change surface from light to dark after heating
• Other: Provide a description to further clarify the identified nature of activities

4.2 Total quantity of BPA manufactured or used in the Preparation Year ("Total Quantity Manufactured or Used" page in reporting tool)

Indicate the total quantity of the Substance as it relates to the activities identified in 3.0 for the year in which you are reporting. If the Substance was manufactured report the total quantity manufactured as reported in Manufacture of BPA. If the Substance, or any mixture containing the Substance, was used, report the total quantity used.

4.3 On-site releases: Effluent releases at final discharge points ("On-Site Releases" page in reporting tool)

Indicate if this facility released the Substance at final discharge points of the facility in the reporting year(s). If yes, proceed to On-Site Releases to water. If no, proceed to Off-Site Transfers for Disposal.

4.3.3 Releases to water ("On-Site Releases to water" page in reporting tool)

Report the total quantity of the Substance released to waters (e.g. streams, rivers, lakes, bays, inlets, etc.) or to a Wastewater system (e.g. municipal wastewater treatment plant). Also indicate the Estimation Methods code (see section 4.0, note B) for the method used to derive that value.

Types of Releases to Water:

• Surface water: Releases directly to a receiving body of water.
• Wastewater System: Releases to an off-site wastewater system where "wastewater system" means any work or undertaking, at least part of which is located on land, that is used for the collection and deposit of wastewater, whether or not the wastewater is treated, and includes a site that contains a wastewater lagoon.

4.4 Off-site transfers

4.4.2 Off-Site transfers for disposal

Report the total quantity of all transfers of the Substance from this facility for off-site for disposal in the reporting year(s), indicating the Estimation Method used to derive that value. Indicate the type, quantity and location of transfers for disposal in the appropriate boxes; types of transfers for disposal are described in the box below. Location should include the name of the off-site facility and its complete address.  

Note: Report the quantity of the Substance that was sent off-site for disposal and not the total weight of the mixture containing the Substance. Report transfers to the first off-site location only and not any subsequent transfers by the waste disposal company or by any other entity.

Types of off-site disposal:

• Landfill: Report the quantity transferred off-site to landfill sites
• Hazardous waste facility: Report the quantity transferred off-site to a facility which handles hazardous waste
• Returned to distributor: Report the quantity returned to the distributor of the substance

4.5 Additional baseline information

4.5.1 Sampling and analysis

Report the results from at least four sampling events representative of the Final discharge point as described in subsection 4(5) of the Notice during the reporting year. In the event that there is more than one final discharge point, a minimum of four samples should be taken at each location.

For the activity identified in Part 3.0 of the Declaration, indicate the following:

• Temperature (degree Celsius) of the effluent at the time of sampling
• pH of the effluent at the time of sampling
• Concentration of substance following sample collection and laboratory analysis in the appropriate units (µg/L)
• Date for each sampling event
• Date of the laboratory analysis (the date during which the samples were analysed by the laboratory)
• Laboratory information including the name of the laboratory, their location and their accreditation number under the International Organization for Standardization standard ISO/IEC 17025:2005

If analytical results of the samples are below the laboratory detection limit for BPA, please report with the sign "<" followed by the detection limit to indicate that the analysis results were non-detectable.

Note: Sampling should take place at the final discharge point. However, if sampling at this point is not possible, sampling can be taken earlier or later in the process provided that effluent at the sampling location is as close as possible to the expected concentration of BPA resulting from normal operating conditions or could lead, by using an estimation method, to the concentration of BPA at the final discharge point.

This table should present actual sampling concentration results of BPA at the selected sampling location, not the predicted concentration at the final discharge point. However, facilities are expected to record and report sampling site information such as the site location in relation to final discharge point, the rationale for the site location, and the predicted concentration of BPA at the final discharge point as a result of any removal or treatment of BPA by the industrial facility. This information should be reported under part 8.0 "Factors to Consider" of schedules 1, 4 and 5 (see section 8.0 of this document for more details).

4.5.2 Wastewater system name and location

For facilities that send their effluent to a wastewater system (e.g. municipal wastewater treatment plant), please indicate the name, the address and, if known, the level of treatment (primary, secondary, tertiary, etc.) of the wastewater system.

5.0 Actions and results ("Actions and Releases" page in reporting tool)

These instructions are designed to provide direction for completing Schedules 1, 4 and 5. Titles and headings in this part of the instructions represent those found in all Schedules. Therefore, headings in a particular Schedule may be slightly different from those found in these instructions to reflect the type of data required in that Schedule (e.g., anticipated results, results achieved to date and results achieved).

• In Schedule 1, this Part requires you to enter the "anticipated" changes to uses, releases and/or transfers that you intend to achieve through implementing a pollution prevention plan
• In Schedule 4, this Part requires you to enter the changes you have achieved as of the date that you submit this report, to illustrate the progress you have made in implementing the plan
• In Schedule 5, this Part requires you to report the final changes to uses, releases and/or transfers achieved by the pollution prevention plan, after completing the implementation of the plan

Parts 5.1.1 to 5.1.6 must be completed separately for each individual action identified in the P2 plan, i.e. this section will be completed as many times as there are actions to report.

5.1 Anticipated/achieved to date/achieved actions ("List of Anticipated/Achieved To Date/Achieved Actions" page in reporting tool)

This Part summarizes the actions that you plan to take or have already taken in implementing the pollution prevention plan in order to work towards achieving the risk management objective as specified in the Canada Gazette Notice. Please add and complete for each action that is in your plan.  Actions reported in Schedule 1 will be carried over to Schedule 4 and 5 where you will be asked for updates or have the opportunity to report new actions. The following is a description of the information required in each field.

For each activity identified in Part 3.0 of this schedule, describe the current status of the action taken to date in implementing the pollution prevention plan. Indicate if the action is:

• "Planned/To be initiated"
• "In progress"
• "Completed"
• "Discontinued"

If the action is "Discontinued", please provide the reason why you will no longer be carrying out this action. (Note: the "Discontinued" option applies to Schedules 4 and 5 only).

5.1.1 Anticipated/achieved to date/achieved action

Describe each action that you plan to implement or have already implemented in the pollution prevention plan (for example, replaced to alternative substance, located solvent storage tanks away from sources of heat, and installed overflow alarms and relief valves).

For each Interim Progress Report, provide an update of the new actions taken since your last report. For example; when completing the second Interim Progress report you must report actions taken since you submitted the first Interim Progress Report and not all actions taken to date in implementing your plan. However, you must report updates, if there are any, on all actions taken to date.

Similarly, in Schedule 5, you must report those actions taken since your last Interim Progress Report or Declaration of Preparation and not all actions taken to date in implementing your plan. However, you must report updates, if there are any, on all actions taken to date.

Note: If the action includes the use of alternative substances, please include the chemical name, common name or CAS number of the alternative substance in the description of the actions.

Actions can either be Pollution Prevention Methods (5.1.2) or Environmental Protection Methods (5.1.3). Only select the type that applies. More than one action may be applicable for each type.

5.1.2 Type of pollution prevention method(s)

If the action identified in 5.1.1 utilizes a pollution prevention (P2) method, indicate the type of method used, choosing from the list provided. More than one P2 method can be used. Alternatively, no P2 method may be applicable. P2 methods are described in the box below.

Types of Pollution Prevention Methods:

Materials or feedstock substitution

Materials or Feedstock Substitution deals with the substances and products you use. It involves replacing them with more environmentally friendly alternatives. Materials or Feedstock Substitution completely eliminates the use of a given substance or product.

Product design or reformulation

Product Design or Reformulation deals with improving the overall environmental impact of your product. It involves looking at the whole life cycle of your product (from cradle to grave) and then either designing a new product or reformulating an existing one to prevent pollution.

Equipment or process modifications

Equipment or Process Modification deals with how you make whatever it is you make or do whatever it is you do, whether it be manufacturing chemicals or simply running a household. It involves using new equipment or processes, or altering existing equipment or processes to:

• improve efficiency
• reduce or eliminate pollution
• reduce material, water or energy use

Spill and leak prevention

Spill or Leak Prevention deals with making sure you do not pollute accidentally. It involves trying to limit spills and leaks from happening in the first place, and having measures in place to limit the damage if there is a spill or leak.

On-site reuse, recycling or recovery

Sometimes waste is unavoidable. On-site Reuse, Recycling or Recovery (ORRR) deals with what you do with your waste and waste by-products. It involves using your waste and waste by-products instead of just throwing them away (often at a cost) or otherwise losing them.

Note: Reuse, recycling or recovery that takes place off site is not considered P2. While collecting your recyclable materials and having them recycled (by the city or another recycling company) is definitely a good thing to do, it is not P2 because it transfers your pollutants elsewhere.

Inventory management or purchasing techniques

Inventory Management or Purchasing Techniques (IMPT) deals with how you store your goods/materials and how you buy your goods/materials. It involves having a strategy in place to reduce the amount of stock you have to throw out because it is expired, damaged or no longer needed. It also involves having a strategy in place to ensure you take the environment into account when buying goods.

Good operating practices or training

Good Operating Practices or Training deals with the human element of your operations. It does not matter how state-of-the-art your equipment is if you or your employees do not know how to use it properly or in the most efficient manner. It involves using best practices and training to minimize waste and increase efficiency.

Other (specify)

Other methods that result in preventing or avoiding the creation of pollutants and waste. If you select Other, please specify.

Please visit the pollution prevention techniques web page for more information and examples of these P2 methods.

5.1.3 Type of environmental protection method(s)

If the action identified in 5.1.1 utilizes an environmental protection method other than a P2 method, indicate the type of method used, choosing from the list provided. More than one environmental protection method can be used. Alternatively, no other environmental protection method may be applicable. Descriptions of the other environmental protection methods are listed below.

Type of environmental protection methods:

Energy recovery

Using a waste with sufficient energy content as a fuel for energy recovery to offset the need for additional energy (for example, recovery of methane from landfills).

Off-site recycling

Recycling of materials at a place outside the property boundaries of where an activity has taken place (for example, transfer of paper products to another facility for recycling into new paper products).

Incineration with energy recovery

Thermal treatment of wastes and recovery and use of the resulting energy to offset the need for additional energy (for example, incinerating waste and using the resulting heat to heat building air and/or water).

Waste treatment

Processing of waste to render it less harmful or harmless to the environment (for example, bio-oxidation, evaporation, precipitation, neutralization).

On-site wastewater treatment

Use of a wastewater sanitation system intended to treat and dispose of effluent on the same property as the facility that produces the wastewater.

Pollution control

Addition of equipment to the end of a system to collect pollutants prior to their release into the environment (for example, addition of filters to collect dust prior to release).

Disposal

Final disposal in such a way as to cause the least amount of harm to the environment (for example, landfill of biodegradable materials, containment of wastes containing the Substance).

Other

Other methods that result in environmental protection.

5.1.4 Anticipated, achieved to date and achieved change(s)

Report the anticipated (Schedule 1) achieved to date (Schedule 4) or achieved (Schedule 5) annual increase or decrease in the quantity in kilograms (kg) or concentration in micrograms (µg/L) of BPA released from the facility as a result of the implementation of the action described in Part 5.1.1, if possible. Use a negative sign ("-") before the quantity or concentration to denote a decrease or a positive sign ("+") to denote an increase. For example, if this facility implemented an action that resulted in an annual decrease of 100 kilograms of the Substance released to a wastewater system, this would be reported as  "-100 kg." Note that predicting a quantitative change for some actions, such as employee training, may not be possible. In such cases, this field may be left blank.

5.1.5 Baseline element(s) affected

Describe which baseline elements are affected by the changes reported in the previous Part (Anticipated/Achieved Changes). More than one baseline element may be chosen, as many actions will affect more than one baseline element.  Baseline elements are listed below.

Baseline element affected:

• total quantity manufactured or used on-site
• total quantity released to water (surface water or wastewater system)
• total quantity transferred for disposal off-site (landfill, hazardous waste facility, or return to distributor)
• effluent concentration, temperature or  pH
• other (If selected, please provide a short description)

5.1.6 Planned completion date

Provide the date on which the action is anticipated to be or was fully implemented.

5.3 Total anticipated/achieved to date/achieved releases

Reporting results are based on the Preparation Year

• Anticipated results should be included in Schedules 1 "Declaration of Preparation"
• Achieved To Date results should be included in Schedules 4 "Interim Progress Reports"
• Achieved results should be included in Schedule 5 "Declaration of implementation.

Report the relative change in release of BPA to surface water or wastewater systems based on the implementation of the actions.

In the second column, report the change in quantity (i.e. increase or decrease) in (kg) of BPA release to water in relation to the preparation year. In the third column, report the change in average concentration (µg/L) of release of the BPA to water. Report all reductions with negative sign ("-") and all increases with a positive sign ("+").