Proposal

Amendment to the Foundries - Industry Standard under the Local Air Quality Regulation (O. Reg. 419/05)

Regulation Number(s):
Local Air Quality Regulation (O. Reg. 419/05)
Instrument Type:
Proposal
Bill or Act:
Environmental Protection Act, R.S.O. 1990
Summary of Decision:
Since 2009, the sector, as represented by the Canadian Foundry Association, requested an update of this technical standard to include additional contaminants. The 2009 version of the FIS allowed for registration of up to 111 contaminants, whereas this amendment now includes an additional 195 contaminants, totaling 306 contaminants available for registration. The registration of all of a foundry's contaminants could eliminate the need for an annual Emission Summary and Dispersion Modelling (ESDM) report thereby reducing the regulatory burden for these small to medium sized enterprises (SMEs). Provisions in the technical standards will ensure that environmental performance in managing the releases of these contaminants is maintained.

The publication entitled: "Technical Standards to Manage Air Pollution" ("Technical Standards Publication") has been updated to include the amended Foundries - Industry Standard. The Technical Standard Publication is available on the ministry's website and through the ministry's Public Information Centre.
Further Information:
Proposal Number:
15-MOE009
Posting Date:
May 20, 2015
Summary of Proposal:
In general, this industry standard applies to Ferrous Metal Foundries, Iron Foundries, Steel Foundries, Non-ferrous Metal Foundries, Non-ferrous Die-casting Foundries and Non-ferrous Foundries (except Die-casting). In 2010, the Canadian Foundry Association (CFA) expressed interest in updating the Foundries - Industry Standard (FIS) by expanding the list of contaminants and sources. Since new air standards for some metals were introduced in 2011 (and take effect in 2016), the ministry also conducted a literature review and dominant source analysis of emissions of these new or updated air standards to determine if additional requirements could be proposed. The current version of the FIS allows for registration of up to 111 contaminants, whereas the proposed update would allow for an additional 195 contaminants, totaling 306 contaminants available for registration. The registration of all of a foundry's contaminants could eliminate the need for an annual ESDM report thereby reducing their regulatory burden for these small to medium sized enterprises (SMEs). Provisions in the technical standards will ensure that environmental performance in managing the releases of these contaminants is maintained.

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 foundry sector include: suspended particulate matter (SPM) including metals such as lead and cadmium. The FIS also includes other metals such as nickel, manganese, and chromium as well as Volatile Organic Compounds (VOCs) and sulphur dioxide. The proposed amendment includes additional contaminants many of which are emitted from the same sources already considered in the original technical standard. There is also a new proposed general requirement for facilities to maintain existing air pollution control systems to ensure that other air standards will continue to be met (referred to as the "no backsliding" requirement or "requirement to continue"). Additional requirements are also being proposed for some VOCs sources.

The significant sources of suspended particulate matter, including priority metals (as per the proposal), from this sector are from the following sources: metal melting; furnace tapping; molten metal pouring; cooling of castings; finishing including processes such as trimming, grinding, cutting or media blasting of castings; and sand reclamation.

A summary of the key changes in the proposed requirements are included in the attached rationale document. These include:
- updates to requirements for ventilation systems;
- a "no backsliding" requirement to continue with controlled sources;
- rules for multi-tenant buildings;
- minimizing SPM emissions from outdoor activities;
- ventilation and control requirements for newly installed Electric Arc Furnaces and Argon Oxygen Decarburizers;
- new requirements to ensure that exhaust stacks are installed with an upward orientation and that flow remains unimpeded;
- new provisions that allow for more technically sophisticated inspection and maintenance programs and baghouse leak detection systems.

Contact Address:
Nick Fragiadakis
Ministry of the Environment and Climate Change
Standards Development Branch
40 St. Clair Avenue West
Toronto, Ontario
M4V 1M2
Phone: (416) 327-6416
Effective Date:
March 9, 2016
Decision:
Approved