Metal Finishers - Industry Standard under the Local Air Quality Regulation (O. Reg. 419/05)
Local Air Quality Regulation (O. Reg. 419/05)
Bill or Act:
Environmental Protection Act, R.S.O. 1990
Summary of Decision:
As a result of consultation on this proposal, there are two significant additions to the Metal Finishers - Industry Standard.
Facilities that operate in multi-tenant buildings will now have the option to use both a fume suppressant or wetting agent and an air pollution control device with local exhaust ventilation to minimize emissions or to replace make-up air filters, as per the original proposal.
Maintaining Negative Building Pressure:
Maintaining a negative pressure in key areas of the building will minimize fugitive emissions and improve the capture efficiency of the fume hoods so as to improve the control of emissions from processes in the building. The original proposal required facilities to maintain a negative pressure in the metal finishing tank areas and to assess this by maintaining a table of air flows entering and exiting the facility or area. Any facility will now have the option to either maintain a table of these air flows or to measure building pressure differential in 30 minute block averages. If the building pressure differential over a 30 minute block average is positive, facilities must make operational adjustments to self-correct. If there is a second measurement of a 30 minute block average showing positive pressure in the same day, this would be considered non-compliance and the facility is required to notify the ministry at the end of the calendar day of all the positive 30 minute block averages of the calendar day.
The publication entitled: "Technical Standards to Manage Air Pollution" ("Technical Standards Publication") has been updated to include the Metal Finishers - Industry Standard. The Technical Standard Publication is available on the ministry's website and through the ministry's Public Information Centre.
May 20, 2015
Summary of Proposal:
In 2011, the Canadian Association for Surface Finishing (CASF) approached the Ministry of the Environment and Climate Change (MOECC) with a request to develop a proposed Technical Standard under the Local Air Quality Regulation (O. Reg. 419/05: Air Pollution - Local Air Quality) for chromium compounds (hexavalent forms) and nickel and nickel compounds. Air standards for both of these contaminants will come into effect July 2016. The ministry formed a technical committee with members of CASF and has been meeting regularly since 2011.
Technical standards can be used to manage air emissions for multiple facilities within one or more sectors and can include a wide range of contaminants. The key contaminants of interest for the metal finishing sector include: chromium compounds (hexavalent forms); and, nickel and nickel compounds.
When the ministry develops a proposed technical standard, representative facilities in the sector are compared to other facilities' requirements around the world to determine whether or not the same can be required of Ontario facilities. In addition, development of a technical standard includes a better understanding of the specific sources of contaminant(s) for that sector, benchmarking technology to address the sources of contaminant(s), and consideration of economic issues that relate to the sector.
The dominant sources of key contaminants from this sector include the following sources:
- decorative and hard chromium electroplating;
- chromium anodizing and reverse etching;
- nickel plating;
- electroless nickel plating; and
- general ventilation.
A summary of the proposed requirements are included in the attached rationale document. Highlights include:
- requirements for specified technologies for chromium compounds (hexavalent forms) for fume suppressants, local exhaust ventilation and air pollution control equipment or tank covers;
- requirements for specified technologies for nickel and nickel compounds for wetting agents or local exhaust ventilation and air pollution control;
- operating and monitoring requirements;
- inspection and maintenance requirements;
- tracking of deviations and complaints;
- a ventilation program;
- requirements for facilities located in multi-tenant buildings;
- no back-sliding requirements for existing air pollution controls at the facility not specified in the proposed technical standard;
- more stringent air pollution control requirements for new sources that result in facility expansions; and
- reporting, notification and recordkeeping requirements.
Embedded in the proposed Metal Finishers - Industry Standard are a combination of compliance approaches that link together to form a strategy ensuring that:
- facilities have greater accountability for self-assuring compliance and driving continuous improvement;
- Ministry oversight is applied by including triggers that require notification to the ministry, and follow up actions, when necessary,and
- reporting to the highest ranking employee.
Once the technical standard is published, any facility in the sector (that may or may not meet the air standard) could apply to register under this compliance approach. Such registration would involve a posting on the Environmental Registry and may involve a public meeting. The goal is to have a more efficient tool to better manage air emissions and reduce overall exposure from various industrial and commercial facilities in a sector.
Ministry of the Environment and Climate Change
Standards Development Branch
40 St. Clair Avenue West
Phone: (416) 327-6292
March 9, 2016