ARCHIVED — Vol. 145, No. 48 — November 26, 2011

DEPARTMENT OF THE ENVIRONMENT

CANADIAN ENVIRONMENTAL PROTECTION ACT, 1999

Notice requiring the preparation and implementation of pollution prevention plans in respect of specified substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, related to the polyurethane and other foam sector (except polystyrene)

Pursuant to section 91 of the Canadian Environmental Protection Act, 1999 (hereinafter referred to as the “Act”), the Minister of the Environment published in the Canada Gazette, Part Ⅰ, on July 3, 2010, the Proposed notice requiring the preparation and implementation of pollution prevention plans in respect of specified substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, implicated in the polyurethane and other foam sector (except polystyrene).

Whereas persons were given the opportunity to file comments with respect to the proposed Notice for a comment period of 60 days; and

Whereas the Minister of the Environment has considered all comments received,

Notice is hereby given that, under subsection 56(1) of the Act, the Minister of the Environment requires any person or class of persons described in section 2 of the Notice to prepare and implement a pollution prevention plan in respect of the substances listed in this Notice which are specified on Schedule 1 of the Act.

The Government of Canada is taking action on chemical substances through the Chemicals Management Plan. Therefore, the Minister may amend the Notice from time to time. Amendments may include adding additional substances which are listed on Schedule 1 of the Act or other amendments to the Notice or the Schedules, as required.

More information on pollution prevention planning can be found in the Pollution Prevention Planning Provisions of Part 4 of the Canadian Environmental Protection Act, 1999: Guidelines for Implementation. These guidelines and other information related to pollution prevention and pollution prevention planning can be found in the “Pollution Prevention Planning” section of Environment Canada’s Web site at www.ec.gc.ca/planp2-p2plan.

PETER KENT
Minister of the Environment

NOTICE REQUIRING THE PREPARATION AND IMPLEMENTATION OF POLLUTION PREVENTION PLANS IN RESPECT OF SPECIFIED SUBSTANCES ON SCHEDULE 1 OF THE CANADIAN ENVIRONMENTAL PROTECTION ACT, 1999, RELATED TO THE POLYURETHANE AND OTHER FOAM SECTOR (EXCEPT POLYSTYRENE)

Notice is hereby given that, pursuant to the provisions of Part 4 of the Act, the Minister of the Environment requires any person or class of persons, described in section 2 of the Notice, to prepare and implement a pollution prevention plan in respect of the substances listed in the Table provided in section 3 of the Notice (hereinafter referred to as the “Table”) which are also specified on Schedule 1 of the Act.

1. Definitions

The definitions in this section apply to the Notice.

  • “Act” means the Canadian Environmental Protection Act, 1999 (CEPA 1999).
  • “Minister” means the Minister of the Environment.
  • “Normal operating conditions” means the range of operating conditions under which the facility expects to operate and that result in the highest level of emissions.
  • “Notice” means the Notice requiring the preparation and implementation of pollution prevention plans in respect of specified substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, related to the polyurethane and other foam sector (except polystyrene).
  • “Plan” means a pollution prevention plan.
  • “Polyurethane and other foam sector (except polystyrene)” comprises facilities that purchase, import or use one or more of the substances listed in column 2 of the Table, in quantities that equal or exceed the purchase, import or use threshold listed in column 4 of the Table, and engage in any or all of the activities listed in column 5 of the Table to produce all types of foam (except polystyrene). The word “other” in “polyurethane and other foam sector (except polystyrene)” refers to all foam made of materials that are different from polyurethane and polystyrene.

In “Best available techniques economically achievable,” the word “techniques” includes both the facility equipment used in the process and how the process is operated. It includes, but is not limited to, matters such as the number of employees, their qualifications and experience, working methods, training, supervision and the manner the process is operated. It also includes the design, construction, lay-out and maintenance of the facility and buildings.

2. Person or class of persons required to prepare and implement a plan

(1) The Notice applies to any person or class of persons who, on the date of publication of the Notice or anytime thereafter,

  • (a) owns or operates a facility within the polyurethane and other foam sector (except polystyrene) which, at any time, purchases, imports or uses one or more of the substances listed in column 2 of the Table, in quantities that equal or exceed the purchase, import or use threshold listed in column 4 of the Table (if applicable); and
  • (b) is involved in any or all of the substance-specific activities listed in column 5 of the Table in the Notice.

(2) The Notice applies to any person or class of persons who is the successor or assign of the persons identified in subsection 2(1).

3. Substance-specific activities and risk management objectives in relation to which the plan is to be prepared

The Minister requires any person or class of persons identified in section 2 of the Notice to prepare and implement a plan in relation to the substance-specific activities, risk management objectives, and factors to consider listed below involving the substances and their corresponding thresholds (if applicable).

The Table provided in this section lists the substances addressed within the Notice, along with

  • their item number and substance-specific notice reference code;
  • their Chemical Abstracts Service (CAS) Registry Number (see footnote 1);
  • their purchase/import/use threshold (if applicable);
  • substance-specific activities for which the plan is to be prepared;
  • substance-specific risk management objectives;
  • the base year (if applicable); and
  • deadlines.

1

2

3

4

Item Number and Substance-specific Notice Reference Code

Substance Name

CAS Registry Number(see footnote 2)

Substance Purchase/ Import/
Use Threshold (if Applicable)

(1) P2POF-TDI

Toluene Diisocyanates (TDIs) refer to one or more of the following substances:

  • — Benzene, 1,3-diisocyanato-2-methyl- or 2,6-TDI;
  • — Benzene, 2,4-diisocyanato-1-methyl- or 2,4-TDI; or
  • — Benzene, 1,3-diisocy anatomethyl- or mixtures
    of 2,6-TDI and 2,4-TDI.

91-08-7

584-84-9

26471-62-5

100 kg/year


5

6

7

8

Activities for Which the Plan Is to Be Prepared

Substance-specific Risk Management Objective

Base Year (if Applicable)(see footnote 3)

Deadlines(see footnote 4)

  • — Manufacturing of flexible slabstock foam (including TDI storage in tanks and cutting and shaping of foam)
  • — Manufacturing of flexible moulded foam (including TDI storage in tanks and cutting and shaping of foam)
  • — Manufacturing of rigid foam (including TDI storage in tanks and cutting and shaping of foam)
  • — Manufacturing of structural foam (including TDI storage in tanks and cutting and shaping of foam)
  • — Rebonding of foam (including cutting and shaping of foam)

To reduce human exposure to TDIs through the reduction of industrial TDI emissions to the environment to the greatest extent practicable, using best available techniques economically achievable.

Not applicable

  • — Deadline for preparing the plan: November 26, 2012
  • — Interim Progress Report No. 1 (Schedule 4) due November 26, 2013
  • — Interim Progress Report No. 2 (Schedule 4) due November 26, 2014
  • — Deadline for implementing the plan: November 26, 2015

4. Substance-specific factors to consider in preparing the plan

4(1) TDIs

  • (a) It was concluded that TDIs met the criterion of paragraph 64(c) of the Act, and they were added to Schedule 1 of the Act on May 12, 2010. According to the final Screening Assessment Report, TDIs are entering or may enter the environment in a quantity or concentration or under conditions that constitute or may constitute a danger in Canada to human life or health. The final Screening Assessment Report is available on the CEPA Environmental Registry of Environment Canada’s Web site.
  • (b) The risk management objective for TDIs, as stated in the above Table, is to reduce human exposure to TDIs through the reduction of industrial TDI emissions to the environment to the greatest extent practicable, using the best available techniques economically achievable.
  • (c) In order to ensure that environmental releases of TDIs and human health risks due to exposure to TDIs are adequately addressed, the person or class of persons subject to the Notice must consider, in determining industrial TDI emissions to air, either the factor as stated below in subparagraph 4(1)(c)(i); or the factors as stated below in subparagraphs 4(1)(c)(ii), 4(1)(c)(iii) and 4(1)(c)(iv), during normal operating conditions:
    • (i) Conducting air dispersion modelling of TDIs in ambient air once every year over a four-year period from the date the person or class of persons becomes subject to the Notice. Air dispersion modelling should be conducted at or beyond the facility boundaries at locations that ensure the prediction of maximum concentration of TDIs, by using the latest available version of the air dispersion model called AERMOD. It is recommended that the provincial or territorial guidelines for compliance with the AERMOD dispersion model requirements be taken into account, wherever applicable. AERMOD is available on the United States Environmental Protection Agency’s (U.S. EPA) Web site, as amended from time to time.
    • (ii) Conducting sampling and analysis of TDIs from stack releases once every year over a four-year period from the date the person or class of persons becomes subject to the Notice, including exhaust air volume rates and typical/current concentration of TDIs released to air. The sampling and analysis of TDIs should be performed by a laboratory that is accredited under the International Organization for Standardization ISO/IEC 17025 standard titled General requirements for the competence of testing and calibration laboratories, as amended from time to time, and whose accreditation includes the analysis of TDIs within its scope of testing. The sampling and analysis of TDIs should be done using the latest available version of one or more of the following sources, as amended from time to time:
  • (e) Establishing and implementing a leak detection and repair (LDAR) program which includes the use of the latest available version of one of the following sources, as amended from time to time:
  • (g) Adopting standards and operating practices for controlling air emissions as outlined in the latest available version of one or more of the following sources, as amended from time to time:
    • U.S. EPA Conditional Test Method 036 — Method for Measurement of Isocyanate Compounds in Stack Emissions;
    • U.S. EPA Conditional Test Method 036A — Analysis of Isocyanates;
    • U.S. EPA Test Method 207 — Method for Measuring Isocyanates in Stationary Source Emissions.
    • (iii) Measuring or estimating emissions of TDIs to air from storage tanks once every year over a four-year period from the date the person or class of persons becomes subject to the Notice, by taking into account the latest available version of one or more of the following sources, as amended from time to time:
    • U.S. EPA AP-42, Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources, Chapter 7 — Liquid Storage Tanks;
    • U.S. EPA TANKS Emissions Estimation Software;
    • Australian Government, Department of the Environment, Water, Heritage and the Arts, and National Pollutant Inventory (NPI) Emission Estimation Technique Manual for Fuel and Organic Liquid Storage.
    • (iv) Measuring or estimating fugitive emissions of TDIs to air once every year over a four-year period from the date the person or class of persons becomes subject to the Notice, by taking into account the latest available version of the following sources, as amended from time to time:
      • U.S. EPA Method 21 — Determination of Volatile Organic Compound Leaks, as specified in Title 40 of the Code of Federal Regulations (CFR), Part 60, Appendix A, with a leak definition and monitoring procedure and frequency as specified in U.S. EPA, Title 40 CFR Part 63, Subpart H — National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks; or U.S. EPA Alternative Work Practice for Monitoring Equipment for Leaks, as specified in Title 40 CFR Part 63, Subpart A, paragraphs (c), (d) and (e) of section 63.11; and
      • U.S. EPA Emission Inventory Improvement Program, Technical Report Series,Volume II: Point Sources, Chapter 16 — Methods for Estimating Air Emissions from Chemical Manufacturing Facilities.

Additional factors are applicable when

  • the quantity of TDIs released to air by the facility is more than 100 kg per year; or
  • the maximum 24-hour average concentration of TDIs in ambient air at or beyond the facility boundaries is greater than 0.2 µg/m3.

In accordance with the data resulting from considering the factor stated in paragraph 4(1)(c), and in order to reduce releases of TDIs to the environment, the following additional factors stated in paragraphs 4(1)(d), 4(1)(e), 4(1)(f) and one or more of the factors stated in paragraph 4(1)(g) must be considered by facilities that, at any time within the period to implement the plan, release to air more than 100 kg per year of TDIs or have a maximum 24-hour average concentration of TDIs at or beyond the facility boundaries greater than 0.2 µg/m3.

  • (d) Using the best available techniques economically achievable to prevent or control the release of TDIs to air from the following emission sources: stack or point, storage or handling, fugitive, and accidental or non-routine spills.
  • (e) Establishing and implementing a leak detection and repair (LDAR) program which includes the use of the latest available version of one of the following sources, as amended from time to time:
    • U.S. EPA Leak Detection and Repair — A Best Practices Guide; or
    • U.S. EPA, Title 40 CFR Part 63, Subpart H — National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks.
  • (f) Adopting the recommended practices contained in The DOW Chemical Company VoranateTM T-80 Toluene Diisocyanates Safe Handling and Storage Guide.
  • (g) Adopting standards and operating practices for controlling air emissions as outlined in the latest available version of one or more of the following sources, as amended from time to time:
    • U.S. EPA ManualBest Management Practices for Pollution Prevention in the Slabstock and Molded Flexible Polyurethane Foam Industry;
    • Allport, D. C. (Editor), Gilbert, D. S. (Editor), and Outterside, S. M. (Editor). MDI & TDI: Safety, Health and the Environment — A Source Book and Practical Guide, Wiley Editions;
    • European Commission, Integrated Pollution Prevention and Control (IPPC), Reference Document on Best Available Techniques in the Large Volume Organic Chemical Industry;
    • Federal Ministry for the Environment, Nature Conservation and Nuclear Safety Technical Instructions on Air Quality Control — TA Luft, Germany;
    • U.S. EPA, Title 40 CFR Part 63, Subpart Ⅲ — National Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Production;
    • U.S. EPA, Title 40 CFR Part 63, Subpart MMMMM — National Emission Standards for Hazardous Air Pollutants: Flexible Polyurethane Foam Fabrication Operations; or
    • Canadian Council of Ministers of the Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile Organic Compounds for Aboveground Storage Tanks.

5. Other factors to consider in preparing the plan

In addition to the applicable substance-specific factors to consider in section 4, the Minister requires any person or class of persons identified in section 2 of the Notice to also consider the following general factors when preparing their plan:

  • (1) The use of pollution prevention planning as a means of addressing the release to the environment of substances on Schedule 1 of the Act, or other pollutants. In preparing a plan, a person or class of persons subject to the Notice is to give priority to pollution prevention activities. “Pollution prevention” (P2), as defined in section 3 of the Act, means “the use of processes, practices, materials, products, substances or energy that avoid or minimize the creation of pollutants and waste and reduce the overall risk to the environment or human health.”
  • (2) The evaluation, by the Minister, of the effectiveness of the Notice with respect to the risk management objectives set out in section 4 of the Notice. This evaluation will determine whether other measures, including regulations, are needed to further prevent or reduce negative impacts on the environment and human health from the releases of substances listed in the Notice.

6. Period within which the plan is to be prepared

  • (1) For a person or class of persons subject to the Notice or to an amendment to the Notice on the date of publication in the Canada Gazette, Part Ⅰ, the Minister requires that the plan be prepared and implementation initiated no later than 12 months from the date of publication of the Notice or any amendments to the Notice, as referenced in column 8 of the Table.
  • (2) For a person or class of persons becoming subject to the Notice or to an amendment to the Notice after the date of publication in the Canada Gazette, Part Ⅰ, the Minister requires that the plan be prepared and implementation initiated within 12 months from becoming subject to the Notice or any amendments to the Notice, as applicable.

7. Period within which the plan is to be implemented

  • (1) For a person or class of persons subject to the Notice or to an amendment to the Notice on the date of publication in the Canada Gazette, Part Ⅰ, the Minister requires that the plan be implemented no later than 48 months from the date of publication of the Notice or any amendments to the Notice, as referenced in column 8 of the Table.
  • (2) For a person or class of persons becoming subject to the Notice or to an amendment to the Notice after the date of publication in the Canada Gazette, Part Ⅰ, the Minister requires that the plan be implemented no later than 48 months from becoming subject to the Notice or any amendments to the Notice, as applicable.

8. Content of the plan

A person or class of persons identified in section 2 of the Notice is to determine the appropriate content of that person’s plan; however, the plan must meet all the requirements of the Notice and any amendments to the Notice. The plan must also contain the information required to file the Declaration of Preparation referred to in section 10 of the Notice and have the capacity to generate the information required to file the Declaration of Implementation referred to in section 11 and the Interim Progress Reports referred to in section 13 of the Notice.

9. Requirement to keep the plan and record keeping

Under section 59 of the Act, any person or class of persons identified in section 2 of the Notice must keep a copy of the plan at the place in Canada in relation to which the plan is prepared. Where a single plan is prepared for more than one facility, a copy of that plan must be kept at each location.

Any person or class of persons identified in section 2 of the Notice must keep the plan and any records pertaining to the plan for a minimum of five years following the period referred to in section 7 of the Notice.

10. Declaration of Preparation

Under subsection 58(1) of the Act, any person or class of persons identified in section 2 of the Notice must file, within 30 days after the end of the period within which the plan is to be prepared as specified in section 6 or extended under section 15, a written “Declaration that a Pollution Prevention Plan Has Been Prepared and Is Being Implemented — Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) [Subsection 58(1) of CEPA 1999].” This Declaration must be submitted to the Minister, using the form that the Minister provides and that contains the information set out in Schedule 1 of the Notice. Where a person or class of persons has prepared a single plan for several facilities, a separate Declaration of Preparation must be filed for each facility.

If the Notice is amended to add other substances, a separate Schedule 1 specified by the substance name may be published, if necessary, as a part of the amendment.

11. Declaration of Implementation

Under subsection 58(2) of the Act, any person or class of persons identified in section 2 of the Notice must file, within 30 days after the end of the period within which the plan is to be implemented as specified in section 7 or extended under section 15, a written “Declaration that a Pollution Prevention Plan Has Been Implemented — Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) [Subsection 58(2) of CEPA 1999].” This Declaration must be submitted to the Minister using the form that the Minister provides that contains the information set out in Schedule 5 of the Notice. Where a person or class of persons has prepared a single plan for several facilities, a separate Declaration of Implementation must be filed for each facility.

If the Notice is amended to add other substances, a separate Schedule 5 specified by the substance name may be published, if necessary, as a part of the amendment.

12. Filing of amended declarations

Under subsection 58(3) of the Act, where a person or class of persons specified in section 2 has filed a Declaration of Preparation or a Declaration of Implementation, referred to in sections 10 and 11 of the Notice, and the Declaration contains information that, at any time after the filing, has become false or misleading, that person or class of persons must file an amended Declaration to the Minister within 30 days after the time that the information became false or misleading, using the appropriate form referred to in section 10 or 11 of the Notice.

13. Interim Progress Reports

A person or class of persons identified in section 2 of the Notice must file to the Minister, no later than the dates below, a written “Interim Progress Report — Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene),” using the form that the Minister provides and that contains the information set out in Schedule 4 of the Notice. If a Declaration of Implementation is submitted before an Interim Progress Report is due, the requirement to submit such an Interim Progress Report is nullified.

  • (1) For a person or class of persons subject to the Notice on the date of publication in the Canada Gazette, Part Ⅰ,
    • — Interim Progress Report No. 1 — deadline: 24 months after the date of publication of the Notice in the Canada Gazette, as referenced in column 8 of the Table; and
    • — Interim Progress Report No. 2 — deadline: 36 months after the date of publication of the Notice in the Canada Gazette, as referenced in column 8 of the Table.
  • (2) For a person or class of persons becoming subject to the Notice or to an amendment to the Notice after the date of publication in the Canada Gazette, Part Ⅰ,
    • — Interim Progress Report No. 1 — deadline: 24 months after the date the person or class of persons becomes subject to the Notice; and
    • — Interim Progress Report No. 2 — deadline: 36 months after the date the person or class of persons becomes subject to the Notice.

Each Interim Progress Report will report data pertaining to its corresponding reporting year. Where a person or class of persons has prepared a single plan for several facilities, a separate Interim Progress Report must be filed for each facility.

If the Notice is amended to add other substances, a separate Schedule 4 specified by the substance name may be published, if necessary, as a part of the amendment.

14. Use of a plan prepared or implemented for another purpose

Under subsection 57(1) of the Act, a person or class of persons may use a pollution prevention plan prepared or implemented for another purpose to satisfy the requirements of sections 2 to 9 of the Notice or any amendments to the Notice. Under subsection 57(2) of the Act, where a person or class of persons uses a plan that does not meet all the requirements of the Notice or any amendments to the Notice, the person or class of persons must either amend the plan so that it meets all of those requirements or prepare an additional plan that meets the remainder of those requirements. A person or class of persons using existing plans must still file the Declaration of Preparation referred to in section 10 of the Notice, the Declaration of Implementation referred to in section 11 of the Notice, and any amended declarations under section 12 of the Notice, where applicable, and any Interim Progress Reports required under section 13 of the Notice.

15. Extension of time

Under subsection 56(3) of the Act, where the Minister is of the opinion that further time beyond the period referred to in section 6 is needed to prepare the plan, or that further time beyond the period referred to in section 7 is needed to implement the plan, the Minister may extend the period for a person or class of persons who submits a written “Request for Time Extension — Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) [Subsection 56(3) of CEPA 1999].” The written request must be submitted using the form that the Minister provides, contain the information set out in Schedule 3 of the Notice, and be made before the expiry of the date referred to in the applicable section 6 or section 7 of the Notice or before the expiry of any extended period.

If the Notice is amended to add other substances, a separate Schedule 3 specified by the substance name may be published, if necessary, as a part of the amendment.

16. Application for waiver of factors to consider

Under subsection 56(5) of the Act, the Minister may waive the requirement for a person or class of persons to consider a factor specified in the applicable factors to consider in preparing the plan in section 4 or section 5, where the Minister is of the opinion that it is neither reasonable nor practicable to consider that factor on the basis of reasons provided by that person or class of persons when submitting a written “Request for Waiver of the Requirement to Consider a Factor or Factors — Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) [subsection 56(5) of CEPA 1999].” The written request must be submitted using the form that the Minister provides and must contain the information set out in Schedule 2 of the Notice. Such a request must be made before the expiry of the period within which the plan is to be prepared as referred to in section 6 of the Notice or before the expiry of any extended period.

If the Notice is amended to add other substances, a separate Schedule 2 specified by the substance name may be published, if necessary, as a part of the amendment.

17. More information on pollution prevention planning

Additional information and guidance on preparing plans may be obtained from

18. Notice Reference Code: P2POF

For administrative purposes, all communication with Environment Canada concerning the Notice should refer to the following Notice Reference Code: P2POF.

19. Public disclosure of information and forms

The Minister intends to publish the information submitted in response to the Notice in Schedules 1, 4 and 5 in the Pollution Prevention Planning section of Environment Canada’s Web site.

Under section 313 of the Act, all persons submitting information to the Minister are entitled to submit a written request that specific information be treated as confidential. Persons submitting such a request should include the reasons for that request.

The Notice for the polyurethane and other foam sector (except polystyrene) may be amended from time to time as appropriate for the purpose of adding substances which are specified on Schedule 1 of the Act, along with any other required amendments. If the Notice is amended to add other substances, a separate set of substance-specific schedules may be published, if necessary, as a part of the amendment.

The Notice includes the following forms:

  • Schedule 1: Declaration that a Pollution Prevention Plan Has Been Prepared and Is Being Implemented (subsection 58(1) of CEPA 1999);
  • Schedule 2: Request for Waiver of the Requirement to Consider a Factor or Factors for Preparation of a Pollution Prevention Plan (subsection 56(5) of CEPA 1999);
  • Schedule 3: Request for Time Extension for Preparation or Implementation of a Pollution Prevention Plan (subsection 56(3) of CEPA 1999);
  • Schedule 4: Interim Progress Report concerning the Implementation of a Pollution Prevention Plan; and
  • Schedule 5: Declaration that a Pollution Prevention Plan Has Been Implemented (subsection 58(2) of CEPA 1999).

Forms referred to in the Notice (Schedules 1 to 5) are published as part of the Notice and are to be filled out electronically using the Pollution Prevention Planning Online Reporting Tool found on Environment Canada’s Web site at www.ec.gc.ca/planp2-p2plan.

The Schedules (1 to 5) to be used for each substance listed in the Notice are identified by the Notice Reference Code (P2POF), followed by a dash and the substance name abbreviation (i.e. P2POF-XXX).

20. Environment Canada contact information

For technical questions about the Notice, please contact or send queries to

Director
Chemical Production Division
Environment Canada
200 Sacré-Cœur Boulevard
Gatineau, Quebec
K1A 0H3
Telephone: 819-994-4404
Fax: 819-994-5030
Email: pgpc-cmp.dppc-cpd@ec.gc.ca

For more information about pollution prevention planning, please contact

Innovative Measures Section
Regulatory Innovation and Management Systems
Environment Canada
351 Saint-Joseph Boulevard
Gatineau, Quebec
K1A 0H3
Telephone: 819-994-0186
Fax: 819-953-7970
Email: LCPEPlansP2-CEPAP2Plans@ec.gc.ca

EXPLANATORY NOTE

(This note is not part of the Notice.)

Compliance with the Canadian Environmental Protection Act, 1999 (hereinafter referred to as the “Act”) is mandatory under subsection 272(1) of the Act. Subsection 272(2) of the Act defines the penalties for persons who commit offences under the Act. Subsections 273(1) and 273(2) further outline the terms and penalties of those persons providing false or misleading information. Penalties under both subsections 272(2) and 273(2) include fines of not more than $1 million, imprisonment for a term of not more than three years, or both.

For additional information on the Act, the Compliance and Enforcement Policy for the Canadian Environmental Protection Act, 1999 and the applicable penalties, please contact the Enforcement Branch by email at environmental.enforcement@ec.gc.ca. The Policy is available at www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=954B7684-1.

NOTE: Do not fill out this form as it appears in the Canada Gazette. Please contact Environment Canada for more information about electronic reporting, as provided in sections 19 and 20 of the Notice.

Schedule 1: Declaration That a Pollution Prevention Plan Has Been Prepared and Is Being Implemented — Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) — Toluene Diisocyanates (TDIs) [Subsection 58(1) of CEPA 1999]

Notice Reference Code: P2POF-TDI

For guidance on how to complete this Declaration, please refer to the “Instructions for Completing the Schedules Required by the Pollution Prevention Planning Notice for the Polyurethane and Other Foam Sector (except Polystyrene) — TDIs.” These instructions can be found in the Pollution Prevention (P2) Planning section of Environment Canada’s Web site at www.ec.gc.ca/planp2-p2plan/default.asp?lang=En&n=D41F25DE-1.

Is this an amendment to a Declaration previously submitted? check box Yes check box No

If yes, please specify the amended parts and reasons below. In addition, please complete Parts 1.0 and 9.0 and any other parts of this Declaration for which previously reported information has become false or misleading. Previously reported information that is unchanged need not be resubmitted.

If no, please proceed to Part 1.0 of this Declaration.

Amendment Part(s)

Please specify the parts of the Declaration that you would like to amend.

 

Amendment Reason(s)

Please specify the reason for each of the amendments that you would like to make.

 

1.0 Information on the Person or Class of Persons Subject to the Notice

Name of the Person or Class
of Persons Subject to the Notice: ____________________________

Facility Name: ____________________________

Street Address of Facility: ____________________________

City: ____________________________ 

Province/Territory: ____________________________ 

Postal Code: ____________________________

Telephone Number: ____________________________
(with area code)

Email: ____________________________

Mailing Address of Facility
(if different from Street Address): ____________________________

City: ____________________________ 

Province/Territory: ____________________________ 

Postal Code: ____________________________

National Pollutant Release Inventory ID
(if no ID, leave blank): ____________________________

Six-digit North American Industry Classification
System (NAICS) Code (if no Code, leave blank): ____________________________

Facility Technical Contact: ____________________________

Email: ____________________________

Telephone Number: ___________________________
(with area code)

Fax Number (if available): ___________________________
(with area code)

Please enter the name of a General Contact for the facility. This contact information will be used by Environment Canada to correspond with your facility on items related to your submission, including your facility registration and password required for login and reporting online.

General Contact Information

First Name: ________________________________________________

Last Name: ________________________________________________

Email: ____________________________________________________

Position / Job Title: __________________________________________

Telephone Number: __________________________________________
(with area code)

Fax Number (if available): ____________________________________
(with area code)

2.0 Use of Plans Prepared or Implemented for Another Purpose

Is the Pollution Prevention Plan used to fulfill the obligations of the Notice:

  • a Pollution Prevention Plan that was previously prepared on a voluntary basis?
     check box Yes  check box No
  • a Pollution Prevention Plan that was previously prepared for another government or under another Act of Parliament? check box Yes  check box No

If yes, identify the other government requirement(s) or Act of Parliament

 

Parts 3.0 through 7.0 must be completed separately for each combination of Substance and Activity selected in Part 3.0 below.

3.0 Substance and Activity

Substance and Activity for which information is required (choose all that apply):

  • check box TDIs & Manufacturing of flexible slabstock foam (including TDI storage in tanks and cutting and shaping of foam)
  • check box TDIs & Manufacturing of flexible moulded foam (including TDI storage in tanks and cutting and shaping of foam)
  • check box TDIs & Manufacturing of rigid foam (including TDI storage in tanks and cutting and shaping of foam)
  • check box TDIs & Manufacturing of structural foam (including TDI storage in tanks and cutting and shaping of foam)
  • check box TDIs & Rebonding of foam (including cutting and shaping of foam)

4.0 Baseline Information Prior to Implementation of the Pollution Prevention Plan

Notes:

  • a) Wherever possible, the data collected in Parts 4.1 and 4.4 of this Declaration are consistent with the reporting requirements of the National Pollutant Release Inventory (NPRI).
  • b) In Part 4, where indicated, use the following Basis of Estimate Codes to describe how each quantity reported in this part of the Declaration was determined:
    • M1 Continuous Emission Monitoring Systems
    • M2 Predictive Emission Monitoring
    • M3 Source Testing
    • C Mass Balance
    • E1 Site-specific Emission Factor
    • E2 Published Emission Factor
    • O Engineering Estimates
    • X Other (please specify)
  • c) This Declaration requires reporting of data from the 2012 Preparation Year (from November 26, 2011, to November 25, 2012).

If you are reporting data for a year other than the above specified year, check all those that apply.

check box Person or class of persons subject to the Notice has been granted a time extension to prepare a plan that results in a Preparation Year other than 2012

OR

check box Person or class of persons became subject to the Notice after the date of publication that results in a Preparation Year other than 2012

If either of the above is applicable, indicate the new Preparation Year for which you are reporting: ___________. Please provide your start and end date representing one full year’s duration (e.g. 2015-07-23 to 2016-07-22): _____________________ to __________________________. All references to the Preparation Year 2012 throughout this Declaration will be replaced by this new Preparation Year.

4.1  Nature of Activity

For the activity identified in Part 3.0 of this Declaration, indicate whether the substance was manufactured, processed, distributed or otherwise used, and the nature of such activity at the facility for the Preparation Year 2012. More than one nature of activity may be identified. Select all that apply.

Manufacture:
  • check box For on-site use/processing
  • check box For sale/distribution
  • check box As a by-product
  • check box As an impurity
  • Description: ___________________________
Distribution:
  • check box Sold or distributed on its own
  • check box Sold or distributed as part of a product
  • Description: ___________________________
Process:
  • check box As a reactant
  • check box As a formulation component
  • check box As an article component
  • check box Repackaging only
  • check box As a by-product
  • Description: _____________________________
Other use:
  • check box As a physical or chemical processing aid
  • check box As a manufacturing aid
  • check box Ancillary or other use
  • check box As a by-product
  • Description: _____________________________
4.2  On-site Uses

For the activity identified in Part 3.0 of this Declaration, did this facility use the substance on-site in the Preparation Year 2012? check box Yes  check box No

If yes, report the total quantity of all on-site uses of the substance, in kilograms (kg), for that year, and the Basis of Estimate Code (see Part 4.0, Note b) in the appropriate field below. Indicate how the substance was used.

If no, proceed to Part 4.3 of this Declaration.

Total Quantity of all On-site Uses for the Preparation Year
(kg)

Basis of Estimate Code

Type of On-site Use

     
4.3  On-site Releases: On-site releases data to be reported in Part 4.5 of this Declaration
4.4  Off-site Transfers

4.4.1 Off-site Transfers for Distribution

For the activity identified in Part 3.0 of this Declaration, did this facility transfer the substance off-site for distribution as a product or part of a product in the Preparation Year 2012?  check box Yes  check box No

If yes, report the quantity of all off-site transfers of the substance for distribution, in kg, for that year, as a product or part of a product and the Basis of Estimate Code (see Part 4.0, Note b) in the appropriate field below. Indicate the expected use of the substance and the expected disposal method, if known.

If no, proceed to Part 4.5 of this Declaration.

Type of Transfers for Distribution

Quantity Transferred for the Preparation Year (kg)

Basis of Estimate Code

Expected Use
(if known)

Expected Disposal Method
(if known)

a) Substance on its own

       

b) As a component of or ingredient in a product

       

TOTAL

       

4.4.2 Off-site Transfers for Disposal — No data required for Part 4.4.2 of this Declaration

4.4.3 Off-site Transfers for Recycling — No data required for Part 4.4.3 of this Declaration

4.5  Additional Baseline Information — On-site Industrial TDI Emissions

Indicate the annual operation time of the facility, in hours (h), for the Preparation Year 2012: _____________

For the Preparation Year 2012, indicate if the facility has

  • check box A continuous operation
  • check box A batch operation
  • check box A multi-process location where TDIs are involved
  • check box TDIs used continuously in grades or products
  • check box TDIs used in some different grades or products
  • check box Other (please specify): _____________

For the activity identified in Part 3.0 of this Declaration, did this facility release the substance on-site in the Preparation Year 2012?

  • check box Yes    If yes, proceed to Part 4.5.1 of this Declaration.
  • check box No     If no, proceed to Part 5.0 of this Declaration.

4.5.1 Measurement or Estimation of Industrial TDI Emissions to Air

Which option stated in paragraph 4(1)(c) of the Notice did your facility choose to measure or estimate industrial TDI emissions to air for the Preparation Year 2012?

check box 4(1)(c)(i) Predicting TDI concentration in ambient air at or beyond the facility boundaries using AERMOD. (Proceed to Part 4.5.2 of this Declaration.)

OR

check box 4(1)(c)(ii) Conducting sampling and analysis of TDIs from stack releases, and

4(1)(c)(iii) Measuring or estimating emissions of TDIs to air from storage tanks, and

4(1)(c)(iv) Measuring or estimating fugitive emissions of TDIs to air.

(Proceed to Part 4.5.3 of this Declaration.)

4.5.2 Air Concentration of TDIs at or Beyond the Facility Boundaries

If you chose the option to predict TDI concentration in ambient air using AERMOD stated in subparagraph 4(1)(c)(i) of the Notice, fill out the following two tables to report information for the Preparation Year 2012.

AERMOD Model-predicted Data

Maximum 24-hour Average Concentration of TDIs at or Beyond the Facility Boundaries (µg/m3)

Average Distance from the Emission Sources to the Facility Boundaries (m)

Distance from the Facility Boundaries to the Location at which the Maximum 24-hour Average Concentration of TDIs is Predicted (m)

Date Simulation was Completed (YYYY-MM-DD)

For the Preparation Year

       

In the field below, report the additional input data related to operating conditions and emission sources considered for the application of the AERMOD model and used to estimate the maximum 24-hour average concentration of TDIs at or beyond the facility boundaries in the Preparation Year 2012. Briefly describe the scenario considered for the simulation.

Additional Input Data Used in AERMOD and Description of
Scenario Simulation for the Preparation Year

4.5.3 Actual On-site Releases of TDIs to Air

If you chose the option to measure or estimate actual on-site releases of TDIs to air stated in subparagraphs 4(1)(c)(ii), 4(1)(c)(iii), and 4(1)(c)(iv) of the Notice, fill out the following table to report information for the Preparation Year 2012.

Type of Releases to Air

Quantity Released to Air for the Preparation Year (kg)

Actual Exhaust Air Volume Rate (m3/s)

Tempera-
ture of the Gas Emitted from the Stack
(°C)

Typical/
Current Concentra-
tion of TDIs Released to Air (mg/m3)

Measure-
ment Method or Estimation Method
(see footnote 5)

Date Stack Test was Completed (YYYY-MM-DD)

a) Stack or point releases (including process building vents) [Factor stated in subpara-
graph 4(1)(c)(ii) of the Notice]

           

b) Storage tanks or handling releases [Factor stated in subpara-
graph 4(1)(c)(iii) of the Notice]

 

n/a

n/a

   

n/a

c) Fugitive releases [Factor stated in subpara-
graph 4(1)(c)(iv) of the Notice]

 

n/a

n/a

   

n/a

d) Spills

 

n/a

n/a

   

n/a

e) Other releases (please specify)

         

n/a

TOTAL

 

n/a

n/a

n/a

n/a

n/a

5.0 Anticipated Actions and Results

5.1  Anticipated Action

Parts 5.1.1 through 5.1.6 must be completed separately for each anticipated action in the P2 Plan, i.e. Part 5.1 will be completed as many times as there are anticipated actions to report.

Describe, for the activity identified in Part 3.0 of this Declaration, the status of the anticipated action to be taken in implementing the Pollution Prevention Plan.

What is the current status of this Action?

  • check box Planned/to be initiated
  • check box In progress
  • check box Completed

In Part 5.1.1, describe, for the activity identified in Part 3.0 of this Declaration, the anticipated action to be taken in implementing the Pollution Prevention Plan.

5.1.1 Anticipated Action: ____________________________________________

In Parts 5.1.2 and 5.1.3, identify whether the anticipated action represents a pollution prevention method(s) or other environmental protection method(s) by selecting from the list of options provided below.

5.1.2 Types of Pollution Prevention Methods:

For a detailed description of pollution prevention methods, please refer to the Pollution Prevention Planning Handbook (www.ec.gc.ca/planp2-p2plan/default.asp?lang=En&n=56875F44-1).

  • check box Material or feedstock substitution 
  • check box Product design or reformulation
  • check box Equipment or process modification
  • check box Spill and leak prevention
  • check box On-site reuse, recycling or recovery
  • check box Inventory management or purchasing techniques
  • check box Good operating practices or training
  • check box Other: _________________________________

5.1.3 Other Types of Environmental Protection Methods:

  • check box Energy recovery
  • check box Off-site recycling
  • check box Incineration with energy recovery
  • check box Waste treatment
  • check box Pollution control
  • check box Disposal
  • check box Other: _________________________________

In Part 5.1.4, report, where possible, the corresponding change in annual uses, releases or transfers of the substance anticipated to be achieved by implementing that action in kg and in mg/m3. Indicate a decrease with a negative sign (“–”) and an increase with a positive sign (“+”) in front of the reported quantity. Note that predicting a quantitative change for some anticipated actions, such as training, may not be possible.

5.1.4 Anticipated Changes: _______________________________________

In Part 5.1.5, describe which baseline elements identified in Part 4 (total on-site uses, total off-site transfers for distribution or on-site industrial TDI emissions) are affected by the changes reported in Part 5.1.4. For more information, please refer to the Instructions for Completing the Schedules.

5.1.5 Baseline Elements Affected: _______________________________________

In Part 5.1.6, identify the planned completion date for the anticipated action.

5.1.6 Planned Completion Date (YYYY-MM-DD): ________________________

This ends Parts 5.1.1 through 5.1.6 that must be completed separately for each anticipated action in the P2 Plan.

5.2  Total Anticipated Results

The table below summarizes, for the activity identified in Part 3.0 of this Declaration, the total anticipated change in annual uses and transfers of the substance, in kg and as a percentage, relative to the Preparation Year 2012.

Report the total changes anticipated to be achieved by implementing only the anticipated actions described in Part 5.1 of this Declaration.

Important: Indicate a decrease with a negative sign (“–”) and an increase with a positive sign (“+”) in front of the reported quantity.

Type of Use/Release/Transfer

Total Anticipated Change Relative
to the
Preparation Year
(kg)

Total Anticipated Change Relative
to the
Preparation Year
(%)

5.2.1 On-site uses (related to Part 4.2)

   

5.2.2 On-site releases

To be reported in Part 5.3.2 of this Declaration

To be reported in Part 5.3.2 of this Declaration

5.2.3 Off-site transfers for distribution (related to Part 4.4.1)

   

5.2.4 Off-site transfers for disposal

n/a

n/a

5.2.5 Off-site transfers for recycling

n/a

n/a

5.3 Detailed Anticipated Results Information

For the activity identified in Part 3.0 of this Declaration, complete the following part of the Declaration that is applicable to your facility, based on your responses to Part 4.5.1 of this Declaration.

5.3.1  Detailed Anticipated Results for the Air Concentration of TDIs at or Beyond the Facility Boundaries

If you chose the option to predict TDI concentration in ambient air using AERMOD stated in subparagraph 4(1)(c)(i) of the Notice, use the results of TDI concentration in ambient air identified in Part 4.5.2 to fill out the following table and report information relative to the Preparation Year 2012. Report the total changes anticipated to be achieved by implementing only the anticipated actions described in Part 5.1 of this Declaration.

If not, proceed to Part 5.3.2 of this Declaration.

Important: Indicate a decrease with a negative sign (“–”) and an increase with a positive sign (“+”) in front of the reported quantity.

Air Concentration of TDIs at or Beyond the Facility Boundaries

Total Anticipated Change Relative to the Preparation Year
(µg/m 3)

Total Anticipated Change Relative to the Preparation Year
(%)

AERMOD Model-predicted Data

Maximum 24-hour Average Concentration of TDIs at or Beyond the Facility Boundaries

   

5.3.2 Detailed Anticipated Results for Actual On-site Releases of TDIs to Air

If you chose the option to measure or estimate actual on-site releases of TDIs to air stated in subparagraphs 4(1)(c)(ii), 4(1)(c)(iii), and 4(1)(c)(iv) of the Notice, use the results of actual on-site releases of TDIs to air identified in Part 4.5.3 to fill out the following table and report information relative to the Preparation Year 2012. Report the total changes anticipated to be achieved by implementing only the anticipated actions described in Part 5.1 of this Declaration.

Important: Indicate a decrease with a negative sign (“–”) and an increase with a positive sign (“+”) in front of the reported quantity.

Type of Releases to Air

Total Anticipated Change to On-site Releases of TDIs to Air Relative to the Preparation Year
(kg)

Total Anticipated Change to On-site Releases of TDIs to Air Relative to the Preparation Year
(%)

Total Anticipated Change in the Typical/Current Concentration of TDIs Released to Air Relative to the Preparation Year
(mg/m3)

Total Anticipated Change in the Typical/Current Concentration of TDIs Released to Air Relative to the Preparation Year
(%)

a) Stack or point releases (including process building vents) [Factor stated in subparagraph 4(1)(c)(ii) of the Notice]

       

b) Storage tanks or handling releases [Factor stated in subparagraph 4(1)(c)(iii) of the Notice]

       

c) Fugitive releases [Factor stated in subparagraph 4(1)(c)(iv) of the Notice]

       

d) Spills

       

e) Other releases (please specify)

       

TOTAL

 

n/a

n/a

n/a

6.0 Monitoring and Reporting

Describe the anticipated monitoring and reporting that will be used to track progress in implementing the Pollution Prevention Plan.

 

7.0 Risk Management Objective

Describe how the elements of the Pollution Prevention Plan will meet the risk management objective for TDIs identified in column 6 of the Table in section 3 of the Notice. If you anticipate that this plan will not meet the risk management objective, explain why.

 

This ends Parts 3.0 through 7.0 of this Declaration to be completed separately for each combination of Substance and Activity specified in Part 3.0 above.

8.0 Factors to Consider

Describe what was done in the Preparation Year 2012 to take into account the “Substance-specific factors to consider in preparing the plan” in paragraphs 4(1)(b) and 4(1)(c) of the Notice and the “Other factors to consider in preparing the plan” in subsections 5(1) and 5(2) of the Notice, except those factors for which a waiver has been granted by the Minister of the Environment.

 
8.1   Exceedance of Emission or Concentration Thresholds for TDIs

Did your facility, at any time within the period to prepare the plan, release to air more than 100 kg per year of TDIs OR have a maximum 24-hour average concentration of TDIs at or beyond the facility boundaries greater than 0.2 µg/m3, as reported in Part 4.5 of this Declaration? check box Yes  check box No

If yes, describe what was done in the Preparation Year 2012 to take into account each of the following “Substance-specific factors to consider in preparing the plan” to reduce industrial TDI emissions to the environment, except those factors for which a waiver has been granted by the Minister of the Environment.

4(1)(d) Using the best available techniques economically achievable to prevent or control the release of TDIs to air from the following emission sources: stack or point, storage or handling, fugitive, and accidental or non-routine spills.

 

4(1)(e) Establishing and implementing a leak detection and repair (LDAR) program, as further described in paragraph 4(1)(e) of the Notice.

 

4(1)(f) Adopting the recommended practices contained in The DOW Chemical Company VoranateTM T-80 Toluene Diisocyanates Safe Handling and Storage Guide.

 

4(1)(g) Adopting standards and operating practices for controlling air emissions, as further described in paragraph 4(1)(g) of the Notice. Indicate which of the source(s) listed in this paragraph you considered.

 

9.0 Certification

I hereby certify that a Pollution Prevention Plan has been prepared and is being implemented in respect of TDIs and that the information provided in this Declaration is true, accurate and complete.

_____________________________________________________

Signature of the Person Subject to the Notice or
Duly Authorized Representative

_____________________________________________________

Date

Name: ________________________________________________________________

Please Print

Title/Position: ___________________________________________________________

Please Print

NOTE: Do not fill out this form as it appears in the Canada Gazette. Please contact Environment Canada for more information about electronic reporting, as provided in sections 19 and 20 of the Notice.

Schedule 2: Request for Waiver of the Requirement to Consider a Factor or Factors Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) Toluene Diisocyanates (TDIs)
[Subsection 56(5) of CEPA 1999]

Notice Reference Code: P2POF-TDI

For guidance on how to complete this Request, please refer to the “Instructions for Completing the Schedules Required by the Pollution Prevention Planning Notice for the Polyurethane and Other Foam Sector (except Polystyrene) — TDIs.” These Instructions can be found in the Pollution Prevention (P2) Planning section of Environment Canada’s Web site at www.ec.gc.ca/planp2-p2plan/default.asp?lang=En&n=D41F25DE-1.

Is this an amendment to a Request previously submitted? check box Yes  check box No

If yes, please specify the amended parts and reasons below. In addition, please complete Parts 1.0 and 4.0 and any other parts of this Request for which previously reported information has become false or misleading. Previously reported information that is unchanged need not be resubmitted.

If no, please proceed to Part 1.0 of this Request.

Amendment Part(s)

Please specify the parts of the Request that you would like to amend.

 

Amendment Reason(s)

Please specify the reason for each of the amendments that you would like to make.

 

1.0 Information on the Person or Class of Persons Subject to the Notice

Name of the Person or Class of
Persons Subject to the Notice: _________________________________

Facility Name: _________________________________

Street Address of Facility: _________________________________

City: _________________________________ 

Province/Territory: _________________________________ 

Postal Code: _________________________________

Telephone Number: _________________________________ 
(with area code)

Email: _________________________________

Mailing Address of Facility
(if different from Street Address): _________________________________

City: _________________________________ 

Province/Territory: _________________________________ 

Postal Code: _________________________________

National Pollutant Release Inventory ID
(if no ID, leave blank): _________________________________

Six-digit North American Industry
Classification System (NAICS) Code
(if no Code, leave blank): _________________________________

Facility Technical Contact: _________________________________

Email: _________________________________

Telephone Number: _________________________________
(with area code)

Fax Number (if available): ________________________________
(with area code)

Please enter the name of a General Contact for the facility. This contact information will be used by Environment Canada to correspond with your facility on items related to your submission, including your facility registration and password required for login and reporting online.

General Contact Information

First Name: ______________________________________________

Last Name: _______________________________________________

Email: ___________________________________________________

Position / Job Title: ________________________________________

Telephone Number: ________________________________________
(with area code)

Fax Number (if available): __________________________________
(with area code)

2.0 Factor(s) for Which a Waiver is Being Requested

Identify for which factor(s) listed in the Notice a waiver is being requested.

 

3.0 Rationale for Request

Explain why it would not be reasonable or practicable to consider each factor for which a waiver is being requested.

 

Explain how the outcome of the Pollution Prevention Plan will be affected if this or these “factor(s) to consider” is (are) not taken into account.

 

Identify which, if any, additional factor(s) you propose to consider in preparing the Pollution Prevention Plan (optional).

4.0 Certification

I hereby certify that the information provided in this Request in respect of TDIs is true, accurate and complete.

_____________________________________________________

Signature of the Person Subject to the Notice or
Duly Authorized Representative

_____________________________________________________

Date

Name: _______________________________________________________

Please Print

Title/Position: __________________________________________________

Please Print

NOTE: Do not fill out this form as it appears in the Canada Gazette. Please contact Environment Canada for more information about electronic reporting, as provided in sections 19 and 20 of the Notice.

Schedule 3: Request for Time Extension Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999 Related to the Polyurethane and Other Foam Sector (except Polystyrene) — Toluene Diisocyanates (TDIs) [Subsection 56(3) of CEPA 1999]

Notice Reference Code: P2POF-TDI

For guidance on how to complete this Request, please refer to the “Instructions for Completing the Schedules Required by the Pollution Prevention Planning Notice for the Polyurethane and Other Foam Sector (except Polystyrene) — TDIs.” These Instructions can be found in the Pollution Prevention (P2) Planning section of Environment Canada’s Web site at www.ec.gc.ca/planp2-p2plan/default.asp?lang=En&n=D41F25DE-1.

Is this an amendment to a Request previously submitted? check box Yes  check box No

If yes, please specify the amended parts and reasons below. In addition, please complete Parts 1.0 and 4.0 and any other parts of this Request for which previously reported information has become false or misleading. Previously reported information that is unchanged need not be resubmitted.

If no, please proceed to Part 1.0 of this Request.

Amendment Part(s)

Please specify the parts of the Request that you would like to amend.

 

Amendment Reason(s)

Please specify the reason for each of the amendments that you would like to make.

 

1.0 Information on the Person or Class of Persons Subject to the Notice

Name of the Person or Class of
Persons Subject to the Notice: _________________________________

Facility Name: _________________________________

Street Address of Facility: _________________________________

City: _________________________________ 

Province/Territory: _________________________________ 

Postal Code: _________________________________

Telephone Number: _________________________________ 
(with area code)

Email: _________________________________

Mailing Address of Facility
(if different from Street Address): _________________________________

City: _________________________________ 

Province/Territory: _________________________________ 

Postal Code: _________________________________

National Pollutant Release Inventory ID
(if no ID, leave blank): _________________________________

Six-digit North American Industry
Classification System (NAICS) Code
(if no Code, leave blank): _________________________________

Facility Technical Contact: _________________________________

Email: _________________________________

Telephone Number: ________________________________
(with area code)

Fax Number (if available): _________________________________
(with area code)

Please enter the name of a General Contact for the facility. This contact information will be used by Environment Canada to correspond with your facility on items related to your submission, including your facility registration and password required for login and reporting online.

General Contact Information

First Name: ________________________________________________

Last Name: ________________________________________________

Email: ____________________________________________________

Position / Job Title: __________________________________________

Telephone Number: _________________________________________
(with area code)

Fax Number (if available): ____________________________________
(with area code)

2.0 Request for Time Extension

Identify for which of the following a time extension is being requested (choose one):

check box to prepare a Pollution Prevention Plan

check box to implement a Pollution Prevention Plan

For the person or class of persons identified in Part 1.0, it is requested that the date be extended to: _____________________ (specify exact date — YYYY-MM-DD)

3.0 Rationale for Request

Explain why additional time is needed to prepare or implement a Pollution Prevention Plan.

 

5.0 Certification

I hereby certify that the information provided in this Request in respect of TDIs is true, accurate and complete.

_____________________________________________________

Signature of the Person Subject to the Notice
or Duly Authorized Representative

_____________________________________________________

Date

Name: ____________________________________________________________

Please Print

Title/Position: ______________________________________________________

Please Print

NOTE: Do not fill out this form as it appears in the Canada Gazette. Please contact Environment Canada for more information about electronic reporting, as provided in sections 19 and 20 of the Notice.

Schedule 4: Interim Progress Report Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) Toluene Diisocyanates (TDIs)

Notice Reference Code: P2POF-TDI

For guidance on how to complete this Report, please refer to the “Instructions for Completing the Schedules required by the Pollution Prevention Planning Notice for the Polyurethane and Other Foam Sector (except Polystyrene) — TDIs.” These instructions can be found in the Pollution Prevention (P2) Planning section of Environment Canada’s Web site at www.ec.gc.ca/planp2-p2plan/default.asp?lang=En&n=D41F25DE-1.

Is this an amendment to a Report previously submitted? check box Yes  check box No

If yes, please specify the amended parts and reasons below. In addition, please complete Parts 1.0 and 9.0 and any other parts of this Report for which previously reported information has become false or misleading. Previously reported information that is unchanged need not be resubmitted.

If no, please proceed to Part 1.0 of this Report.

Amendment Part(s)

Please specify the parts of the Report that you would like to amend.

 

Amendment Reason(s)

Please specify the reason for each of the amendments that you would like to make.

 

1.0 Information on the Person or Class of Persons Subject to the Notice

Name of the Person or Class of
Persons Subject to the Notice: _________________________________

Facility Name: _________________________________

Street Address of Facility: _________________________________

City: _________________________________ 

Province/Territory: _________________________________ 

Postal Code: _________________________________

Telephone Number: _________________________________ 
(with area code)

Email: _________________________________

Mailing Address of Facility
(if different from Street Address): _________________________________

City: _________________________________ 

Province/Territory: _________________________________ 

Postal Code: _________________________________

National Pollutant Release Inventory ID
(if no ID, leave blank): _________________________________

Six-digit North American Industry
Classification System (NAICS) Code
(if no Code, leave blank): _________________________________

Facility Technical Contact: _________________________________

Email: _________________________________

Telephone Number: _________________________________
(with area code)

Fax Number (if available): ________________________________
(with area code)

Please enter the name of a General Contact for the facility. This contact information will be used by Environment Canada to correspond with your facility on items related to your submission, including your facility registration and password required for login and reporting online.

General Contact Information

First Name: ________________________________________________

Last Name: ________________________________________________

Email: ____________________________________________________

Position / Job Title: __________________________________________

Telephone Number: __________________________________________
(with area code)

Fax Number (if available): ____________________________________
(with area code)

2.0 Use of Plans Prepared or Implemented for Another Purpose — No data is required for Part 2.0 of this Report

Parts 3.0 through 7.0 must be completed separately for each combination of Substance and Activity selected in Part 3.0 below.

3.0 Substance and Activity

Substance and Activity for which information is required (choose all that apply):

  • check box TDIs & Manufacturing of flexible slabstock foam (including TDI storage in tanks and cutting and shaping of foam)
  • check box TDIs & Manufacturing of flexible moulded foam (including TDI storage in tanks and cutting and shaping of foam)
  • check box TDIs & Manufacturing of rigid foam (including TDI storage in tanks and cutting and shaping of foam)
  • check box TDIs & Manufacturing of structural foam (including TDI storage in tanks and cutting and shaping of foam)
  • check box TDIs & Rebonding of foam (including cutting and shaping of foam)

4.0 Progress Information During Implementation of the Pollution Prevention Plan

The Preparation Year refers to the year identified in your Schedule 1 submission — “Declaration that a Pollution Prevention Plan Has Been Prepared and Is Being Implemented — Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) — Toluene Diisocyanates (TDIs).”

Notes:

  • a) Wherever possible, the data collected in Parts 4.1 and 4.4 of this Report are consistent with the reporting requirements of the National Pollutant Release Inventory (NPRI).
  • b) In Part 4, where indicated, use the following Basis of Estimate Codes to describe how each quantity reported in this part of the Report was determined:
    • M1 Continuous Emission Monitoring Systems
    • M2 Predictive Emission Monitoring
    • M3 Source Testing
    • Mass Balance
    • E1 Site-specific Emission Factor
    • E2 Published Emission Factor
    • O Engineering Estimates
    • X Other (please specify)
  • c) If the person or class of persons is subject to the Notice on the date of publication of the Notice in the Canada Gazette, the Notice requires reporting of data in an Interim Progress Report for the following reporting years:

Interim Progress Report

Reporting Year

Reporting Period

Interim Progress Report No. 1

2013

From November 26, 2012,
to November 25, 2013

Interim Progress Report No. 2

2014

From November 26, 2013,
to November 25, 2014

Indicate the number of the Interim Progress Report for which you are reporting: ___________. Note that the Reporting Year associated with this Interim Progress Report Number is referred to as the Reporting Year throughout this Report.

  • d) If the person or class of persons became subject to the Notice after the date of publication in the Canada Gazette, reporting of data is required in two Interim Progress Reports as specified in the Notice.

Indicate the number of the the Interim Progress Report for which you are reporting: ___________ and the corresponding Reporting Year for which you are reporting: ___________. Please provide your start and end date representing one full year’s duration (e.g. 2016-07-23 to 2017-07-22): _____________________ to __________________________. All references to the Reporting Year throughout this Report will be replaced by this new Reporting Year.

4.1  Nature of Activity

For the activity identified in Part 3.0 of this Report, indicate whether the substance was manufactured, processed, distributed or otherwise used, and the nature of such activity at the facility in the Reporting Year. More than one nature of activity may be identified. Select all that apply.

Manufacture:
  • check box For on-site use/processing
  • check box For sale/distribution
  • check box As a by-product
  • check box As an impurity
  • Description: ____________________________
Distribution:
  • check box Sold or distributed on its own
  • check box Sold or distributed as part of a product
  • Description: ____________________________
Process:
  • check box As a reactant
  • check box As a formulation component
  • check box As an article component
  • check box Repackaging only
  • check box As a by-product
  • Description: ______________________________
Other use:
  • check box As a physical or chemical processing aid
  • check box As a manufacturing aid
  • check box Ancillary or other use
  • check box As a by-product

Description: ______________________________

4.2  On-site Uses

For the activity identified in Part 3.0 of this Report, did this facility use the substance on-site in the Reporting Year? check box Yes  check box No

If yes, report the total quantity of all on-site uses of the substance, in kilograms (kg), for that year, and the Basis of Estimate Code (see Part 4.0, Note b) in the appropriate field below. Indicate how the substance was used.

If no, proceed to Part 4.3 of this Report.

Total Quantity of all On-site Uses for the Reporting Year
(kg)

Basis of Estimate Code

Type of On-site Use

     
4.3  On-site Releases: On-site releases data to be reported in Part 4.5 of this Report
4.4  Off-site Transfers

4.4.1 Off-site Transfers for Distribution

For the activity identified in Part 3.0 of this Report, did this facility transfer the substance off-site for distribution as a product or part of a product in the Reporting Year? check box Yes  check box No

If yes, report the quantity of all off-site transfers of the substance for distribution, in kg, for that year, as a product or part of a product and the Basis of Estimate Code (see Part 4.0, Note b) in the appropriate field below. Indicate the expected use of the substance and the expected disposal method, if known.

If no, proceed to Part 4.5 of this Report.

Type of Transfers for Distribution

Quantity Transferred for the Reporting Year
(kg)

Basis of Estimate Code

Expected Use
(if known)

Expected Disposal Method
(if known)

a) Substance on its own

       

b) As a component of or ingredient in a product

       

TOTAL

       

4.4.2 Off-site Transfers for Disposal — No data required for Part 4.4.2 of this Report

4.4.3 Off-site Transfers for Recycling — No data required for Part 4.4.3 of this Report

4.5  Additional Progress Information — On-site Industrial TDI Emissions

Indicate the annual operation time of the facility, in hours (h),
for the Reporting Year: _____________

For the Reporting Year, indicate if the facility has

  • check box A continuous operation
  • check box A batch operation
  • check box A multi-process location where TDIs are involved
  • check box TDIs used continuously in grades or products
  • check box TDIs used in some different grades or products
  • check box Other (please specify): _____________

For the activity identified in Part 3.0 of this Report, did this facility release the substance on-site in the Reporting Year?

  • check box Yes    If yes, proceed to Part 4.5.1 of this Report.
  • check box No     If no, proceed to Part 5.0 of this Report.

4.5.1 Measurement or Estimation of Industrial TDI Emissions to Air

Which option stated in paragraph 4(1)(c) of the Notice did your facility choose to measure or estimate industrial TDI emissions to air in the Reporting Year?

check box 4(1)(c)(i) Predicting TDI concentration in ambient air at or beyond the facility boundaries using AERMOD. (Proceed to Part 4.5.2 of this Report.)

OR

check box 4(1)(c)(ii) Conducting sampling and analysis of TDIs from stack releases, and

4(1)(c)(iii) Measuring or estimating emissions of TDIs from storage tanks, and

4(1)(c)(iv) Measuring or estimating fugitive emissions of TDIs to air. (Proceed to Part 4.5.3 of this Report.)

4.5.2 Air Concentration of TDIs at or Beyond the Facility Boundaries

If you chose the option to predict TDI concentration in ambient air using AERMOD stated in subparagraph 4(1)(c)(i) of the Notice, fill out the following two tables to report information for the Reporting Year.

AERMOD Model-predicted Data

Maximum 24-hour Average Concentration of TDIs at or Beyond the Facility Boundaries (µg/m3)

Average Distance from the Emission Sources to the Facility Boundaries (m)

Distance from the Facility Boundaries to the Location at which the Maximum 24-hour Average Concentration of TDIs is Predicted (m)

Date Simulation Was Completed (YYYY-MM-DD)

For the Reporting Year

       

In the field below, report the additional input data related to operating conditions and emission sources considered for the application of the AERMOD model and used to estimate the maximum 24-hour average concentration of TDIs at or beyond the facility boundaries in the Reporting Year. Briefly describe the scenario considered for the simulation.

Additional Input Data Used in AERMOD and Description of Scenario Simulation for the Reporting Year

4.5.3 Actual On-site Releases of TDIs to Air

If you chose the option to measure or estimate actual on-site releases of TDIs to air stated in subparagraphs 4(1)(c)(ii), 4(1)(c)(iii), and 4(1)(c)(iv) of the Notice, fill out the following table to report information for the Reporting Year.

Type of Releases to Air

Quantity Released to Air for the Reporting Year
(kg)

Actual Exhaust Air Volume Rate
(m3/s)

Tempera-
ture of the Gas Emitted from the Stack
(°C)

Typical/
Current Concen-
tration of TDIs Released to Air
(mg/m3)

Measure-
ment Method or Estimation Method
(see footnote 6)

Date Stack Test Was Completed (YYYY-MM-DD)

a) Stack or point releases (including process building vents) [Factor stated in subparagraph 4(1)(c)(ii) of the Notice]

           

b) Storage tanks or handling releases [Factor stated in subparagraph 4(1)(c)(iii) of the Notice]

 

n/a

n/a

   

n/a

c) Fugitive releases [Factor stated in subparagraph 4(1)(c)(iv) of the Notice]

 

n/a

n/a

   

n/a

d) Spills

 

n/a

n/a

   

n/a

e) Other releases (please specify)

         

n/a

TOTAL

 

n/a

n/a

n/a

n/a

n/a

5.0 Action(s) Taken and Results Achieved to Date

5.1  Action Taken to Date

Parts 5.1.1 through 5.1.6 must be completed separately for each action taken to date in the P2 Plan, i.e. Part 5.1 will be completed as many times as there are actions taken to date to report.

Describe, for the activity identified in Part 3.0 of this Report, the current status of the action taken to date in implementing the Pollution Prevention Plan. Please complete for each action that was reported in your last submitted schedule.

What is the current status of this action?

  • check box Planned/to be initiated
  • check box In progress
  • check box Completed
  • check box Discontinued

If the action is “Discontinued,” please provide the reason why you will no longer be carrying out this action for the activity.

 

In Part 5.1.1, describe, for the activity identified in Part 3.0 of this Report, the action taken to date in implementing the Pollution Prevention Plan. For the purpose of this Report, “to date” refers to November 25 of the Reporting Year specified in Part 4.0 of this Report. For the first Interim Progress Report, report actions taken since initiating the implementation of the Pollution Prevention Plan. For all subsequent Interim Progress Reports, report actions taken since filing of the previous Interim Progress Report.

5.1.1 Action Taken to Date: ____________________________________________

In Parts 5.1.2 and 5.1.3, identify whether the action taken to date represents a pollution prevention method(s) or other environmental protection method(s) by selecting from the list of options provided below.

5.1.2 Types of Pollution Prevention Methods:

For a detailed description of pollution prevention methods, please refer to the Pollution Prevention Planning Handbook (www.ec.gc.ca/planp2-p2plan/default.asp?lang=En&n=56875F44-1).

  • check box Material or feedstock substitution
  • check box Product design or reformulation
  • check box Equipment or process modifications
  • check box Spill and leak prevention
  • check box On-site reuse, recycling or recovery
  • check box Inventory management or purchasing techniques
  • check box Good operating practices or training
  • check box Other: __________________________________

5.1.3 Other Types of Environmental Protection Methods:

  • check box Energy recovery
  • check box Off-site recycling
  • check box Incineration with energy recovery
  • check box Waste treatment
  • check box Pollution control
  • check box Disposal
  • check box Other: __________________________________

In Part 5.1.4, report, where possible, the corresponding change in annual uses, releases or transfers of the substance achieved to date by implementing this action, in kg and in mg/m3. Indicate a decrease with a negative sign (“–”) and an increase with a positive sign (“+”) in front of the reported quantity. Note that predicting a quantitative change for some actions taken, such as training, may not be possible.

5.1.4 Changes Achieved to Date: _____________________________________

In Part 5.1.5, describe which baseline elements identified in Part 4 (total on-site uses, total off-site transfers for distribution or on-site industrial TDI emissions) are affected by the changes reported in Part 5.1.4. For more information, please refer to the Instructions for Completing the Schedules.

5.1.5 Baseline Elements Affected: _____________________________________

In Part 5.1.6, identify the completion date for the action taken.

5.1.6 Completion Date (YYYY-MM-DD): __________________________________

This ends Parts 5.1.1 through 5.1.6 that must be completed separately for each action taken to date in the P2 Plan.

5.2  Total Results Achieved to Date

The table below summarizes, for the activity identified in Part 3.0 of this Report, the total change achieved to date in annual uses and transfers of the substance, in kg and as a percentage, relative to the Preparation Year 2012.

Report those changes achieved from ALL actions taken to date in implementing a Pollution Prevention Plan.

Important: Indicate a decrease with a negative sign (“–”) and an increase with a positive sign (“+”) in front of the reported quantity.

Type of Use/Release/Transfer

Total Change Achieved to Date Relative to the Preparation Year
(kg)

Total Change Achieved to Date Relative to the Preparation Year
(%)

5.2.1 On-site uses (related to Part 4.2)

   

5.2.2 On-site releases

To be reported in Part 5.3.2 of this Report

To be reported in Part 5.3.2 of this Report

5.2.3 Off-site transfers for distribution (related to Part 4.4.1)

   

5.2.4 Off-site transfers for disposal

n/a

n/a

5.2.5 Off-site transfers for recycling

n/a

n/a

5.3  Detailed Results Achieved to Date Information

For the activity identified in Part 3.0 of this Report, complete the following part of the Report that is applicable to your facility, based on your responses to Part 4.5.1 of this Report.

5.3.1  Detailed Results Achieved to Date for the Air Concentration of TDIs at or Beyond the Facility Boundaries

If you chose the option to predict TDI concentration in ambient air using AERMOD stated in subparagraph 4(1)(c)(i) of the Notice, use the results of TDI concentration in ambient air identified in Part 4.5.2 to fill out the following table and report information relative to the Preparation Year 2012. Report the total changes achieved by implementing ALL the actions taken to date as described in Part 5.1 of this Report.

If not, proceed to Part 5.3.2 of this Report.

Important: Indicate a decrease with a negative sign (“–”) and an increase with a positive sign (“+”) in front of the reported quantity.

Air Concentration of TDIs at or Beyond the Facility Boundaries

Total Change Achieved to Date Relative to the Preparation Year (µg/m3)

Total Change Achieved to Date Relative to the Preparation Year (%)

AERMOD Model-predicted Data

Maximum 24-hour Average Concentration of TDIs at or Beyond the Facility Boundaries

   

5.3.2 Detailed Results Achieved to Date for Actual On-site Releases of TDIs to Air

If you chose the option to measure or estimate actual on-site releases of TDIs to air stated in subparagraphs 4(1)(c)(ii), 4(1)(c)(iii), and 4(1)(c)(iv) of the Notice, use the results of actual on-site releases of TDIs to air identified in Part 4.5.3 to fill out the following table and report information relative to the Preparation Year 2012. Report the total changes achieved by implementing ALL the actions taken to date as described in Part 5.1 of this Report.

Important: Indicate a decrease with a negative sign (“–”) and an increase with a positive sign (“+”) in front of the reported quantity.

Type of Releases to Air

Total Change Achieved to Date to On-site Releases of TDIs to Air Relative to the Preparation Year
(kg)

Total Change Achieved to Date to On-site Releases of TDIs to Air Relative to the Preparation Year
(%)

Total Change Achieved to Date in the Typical/Current Concentration of TDIs Released to Air Relative to the Preparation Year
(mg/m3)

Total Change Achieved to Date in the Typical/Current Concentration of TDIs Released to Air Relative to the Preparation Year
(%)

a) Stack or point releases (including process building vents) [Factor stated in subparagraph 4(1)(c)(ii) of the Notice]

       

b) Storage tanks or handling releases [Factor stated in subparagraph 4(1)(c)(iii) of the Notice]

       

c) Fugitive releases [Factor stated in subparagraph 4(1)(c)(iv) of the Notice]

       

d) Spills

       

e) Other releases (please specify)

       

TOTAL

 

n/a

n/a

n/a

6.0 Monitoring and Reporting

Describe the monitoring and reporting used to track progress in implementing the Pollution Prevention Plan.

 

7.0 Risk Management Objective — No data is required for Part 7.0 of this Report

This ends Parts 3.0 through 7.0 of this Report to be completed separately for each combination of Substance and Activity specified in Part 3.0 above.

8.0 Factors to Consider

Describe any progress made in the Reporting Year towards taking into account the “Substance-specific factors to consider in preparing the plan” in paragraphs 4(1)(b) and 4(1)(c) of the Notice and the “Other factors to consider in preparing the plan” in subsections 5(1) and 5(2) of the Notice, except those factors for which a waiver has been granted by the Minister of the Environment.

 
8.1   Exceedance of Emission or Concentration Thresholds for TDIs

Did your facility, at any time during the Reporting Year, release to air more than 100 kg per year of TDIs OR have a maximum 24-hour average concentration of TDIs at or beyond the facility boundaries greater than 0.2 µg/m3, as reported in Part 4.5 of this Report? check box Yes check box No

If yes, describe what was done in the Reporting Year to take into account each of the following “Substance-specific factors to consider in preparing the plan” to reduce industrial TDI emissions to the environment, except those factors for which a waiver has been granted by the Minister of the Environment.

4(1)(d) Using the best available techniques economically achievable to prevent or control the release of TDIs to air from the following emission sources: stack or point, storage or handling, fugitive, and accidental or non-routine spills.

 

4(1)(e) Establishing and implementing a leak detection and repair (LDAR) program, as further described in paragraph 4(1)(e) of the Notice.

 

4(1)(f) Adopting the recommended practices contained in The DOW Chemical Company VoranateTM T-80 Toluene Diisocyanates Safe Handling and Storage Guide.

 

4(1)(g) Adopting standards and operating practices for controlling air emissions, as further described in paragraph 4(1)(g) of the Notice. Indicate which of the source(s) listed in this paragraph you considered.

 

9.0 Certification

I hereby certify that the information provided in this Report in respect of TDIs is true, accurate and complete.

_____________________________________________________

Signature of the Person Subject to the Notice or
Duly Authorized Representative

_____________________________________________________

Date

Name: ___________________________________________________

Please Print

Title/Position: ______________________________________________

Please Print

NOTE: Do not fill out this form as it appears in the Canada Gazette. Please contact Environment Canada for more information about electronic reporting, as provided in sections 19 and 20 of the Notice.

Schedule 5: Declaration that a Pollution Prevention Plan Has Been Implemented Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) Toluene Diisocyanates (TDIs) [Subsection 58(2) of CEPA 1999]

Notice Reference Code: P2POF-TDI

For guidance on how to complete this Declaration, please refer to the “Instructions for Completing the Schedules required by the Pollution Prevention Planning Notice for the Polyurethane and Other Foam Sector (except Polystyrene) — TDIs.” These instructions can be found in the Pollution Prevention (P2) Planning section of Environment Canada’s Web site at www.ec.gc.ca/planp2-p2plan/default.asp?lang=En&n=D41F25DE-1.

Is this an amendment to a Declaration previously submitted? check box Yes  check box No

If yes, please specify the amended parts and reasons below. In addition, please complete Parts 1.0 and 9.0 and any other parts of this Declaration for which previously reported information has become false or misleading. Previously reported information that is unchanged need not be resubmitted.

If no, please proceed to Part 1.0 of this Declaration.

Amendment Part(s)

Please specify the parts of the Declaration that you would like to amend.

 

Amendment Reason(s)

Please specify the reason for each of the amendments that you would like to make.

 

1.0 Information on the Person or Class of Persons Subject to the Notice

Name of the Person or Class of
Persons Subject to the Notice: _________________________________

Facility Name: _________________________________

Street Address of Facility: _________________________________

City: _________________________________ 

Province/Territory: _________________________________ 

Postal Code: _________________________________

Telephone Number: _________________________________ 
(with area code)

Email: _________________________________

Mailing Address of Facility
(if different from Street Address): _________________________________

City: _________________________________ 

Province/Territory: _________________________________ 

Postal Code: _________________________________

National Pollutant Release Inventory ID
(if no ID, leave blank): _________________________________

Six-digit North American Industry
Classification System (NAICS) Code
(if no Code, leave blank): _________________________________

Facility Technical Contact: _________________________________

Email: _________________________________

Telephone Number: _________________________________
(with area code)

Fax Number (if available): ________________________________
(with area code)

Please enter the name of a General Contact for the facility. This contact information will be used by Environment Canada to correspond with your facility on items related to your submission, including your facility registration and password required for login and reporting online.

General Contact Information

First Name: ________________________________________________

Last Name: ________________________________________________

Email: ____________________________________________________

Position / Job Title: __________________________________________

Telephone Number: __________________________________________
(with area code)

Fax Number (if available): ____________________________________
(with area code)

2.0 Use of Plans Prepared or Implemented for Another Purpose — No data required for Part 2.0 of this Declaration

Parts 3.0 through 7.0 must be completed separately for each combination of Substance and Activity selected in Part 3.0 below.

3.0 Substance and Activity

Substance and Activity for which information is required (choose all that apply):

  • check box TDIs & Manufacturing of flexible slabstock foam (including TDI storage in tanks and cutting and shaping of foam)
  • check box TDIs & Manufacturing of flexible moulded foam (including TDI storage in tanks and cutting and shaping of foam)
  • check box TDIs & Manufacturing of rigid foam (including TDI storage in tanks and cutting and shaping of foam)
  • check box TDIs & Manufacturing of structural foam (including TDI storage in tanks and cutting and shaping of foam)
  • check box TDIs & Rebonding of foam (including cutting and shaping of foam)

4.0 Information after Implementation of the Pollution Prevention Plan

The Preparation Year refers to the year identified in your Schedule 1 submission — “Declaration that a Pollution Prevention Plan Has Been Prepared and Is Being Implemented — Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) — Toluene Diisocyanates (TDIs),” hereinafter referred to as the “Declaration of Preparation.”

Notes:

  • a) Wherever possible, the data collected in Parts 4.1 and 4.4 of this Declaration are consistent with the reporting requirements of the National Pollutant Release Inventory (NPRI).
  • b) In Part 4, where indicated, use the following Basis of Estimate Codes to describe how each quantity reported in this part of the Declaration was determined:
    • M1 Continuous Emission Monitoring Systems
    • M2 Predictive Emission Monitoring
    • M3 Source Testing
    • C Mass Balance
    • E1 Site-specific Emission Factor
    • E2 Published Emission Factor
    • O Engineering Estimates
    • X Other (please specify)
  • c) This Declaration requires reporting of data from the 2015 Implementation Year (from November 26, 2014, to November 25, 2015).

If you are reporting data for a year other than the above specified year, check all those that apply.

check box Person or class of persons subject to the Notice has been granted a time extension to implement the plan that results in an Implementation Year other than 2015

OR

check box Person or class of persons became subject to the Notice after the date of publication that results in an Implementation Year other than 2015

If either of the above is applicable, indicate the new Implementation Year for which you are reporting: __________. Please provide your start and end date representing one full year’s duration (e.g. 2018-07-23 to 2019-07-22): _____________________ to __________________________. All references to the Implementation Year 2015 throughout this Declaration will be replaced by this new Implementation Year.

4.1  Nature of Activity

For the activity identified in Part 3.0 of this Declaration, indicate whether the substance was manufactured, processed, distributed or otherwise used, and the nature of such activity at the facility in the Implementation Year 2015. More than one nature of activity may be identified. Select all that apply.

Manufacture:
  • check box For on-site use/processing
  • check box For sale/distribution
  • check box As a by-product
  • check box As an impurity
  • Description: ___________________________
Distribution:
  • check box Sold or distributed on its own
  • check box Sold or distributed as part of a product
  • Description: ___________________________
Process:
  • check box As a reactant
  • check box As a formulation component
  • check box As an article component
  • check box Repackaging only
  • check box As a by-product
  • Description: _____________________________
Other use:
  • check box As a physical or chemical processing aid
  • check box As a manufacturing aid
  • check box Ancillary or other use
  • check box As a by-product
  • Description: _____________________________
4.2  On-site Uses

For the activity identified in Part 3.0 of this Declaration, did this facility use the substance on-site in the Implementation Year 2015? check box  Yes check box  No

If yes, report the total quantity of all on-site uses of the substance, in kilograms (kg), for that year, and the Basis of Estimate Code (see Part 4.0, Note b) in the appropriate field below. Indicate how the substance was used.

If no, proceed to Part 4.3 of this Declaration.

Total Quantity of all On-site Uses for the Implementation Year
(kg)

Basis of Estimate Code

Type of On-site Use

     
4.3  On-site Releases: On-site releases data to be reported in Part 4.5 of this Declaration
4.4  Off-site Transfers

4.4.1   Off-site Transfers for Distribution

For the activity identified in Part 3.0 of this Declaration, did this facility transfer the substance off-site for distribution as a product or part of a product in the Implementation Year 2015?  check box Yes check box No

If yes, report the quantity of all off-site transfers of the substance for distribution, in kg, for that year, as a product or part of a product and the Basis of Estimate Code (see Part 4.0, Note b) in the appropriate field below. Indicate the expected use of the substance and the expected disposal method, if known.

If no, proceed to Part 4.5 of this Declaration.

Type of Transfers for Distribution

Quantity
Transferred for the Implementation
Year (kg)

Basis of Estimate Code

Expected Use
(if known)

Expected Disposal Method
(if known)

a) Substance on its own

       

b) As a component of or ingredient in a product

       

TOTAL

       

4.4.2 Off-site Transfers for Disposal — No data required for Part 4.4.2 of this Declaration

4.4.3 Off-site Transfers for Recycling — No data required for Part 4.4.3 of this Declaration

4.5  Additional Information — On-site Industrial TDI Emissions

Indicate the annual operation time of the facility, in hours (h), for the Implementation Year 2015: _____________________________

For the Implementation Year 2015, indicate if the facility has

  • check box A continuous operation
  • check box A batch operation
  • check box A multi-process location where TDIs are involved
  • check box TDIs used continuously in grades or products
  • check box TDIs used in some different grades or products
  • check box Other (please specify): _____________

For the activity identified in Part 3.0 of this Declaration, did this facility release the substance on-site in the Implementation Year 2015?

  • check box Yes    If yes, proceed to Part 4.5.1 of this Declaration.
  • check box No     If no, proceed to Part 5.0 of this Declaration.

4.5.1 Measurement or Estimation of Industrial TDI Emissions to Air

Which option stated in paragraph 4(1)(c) of the Notice did your facility choose to measure or estimate industrial TDI emissions to air for the Implementation Year 2015?

check box 4(1)(c)(i) Predicting TDI concentration in ambient air at or beyond the facility boundaries using AERMOD. (Proceed to Part 4.5.2 of this Declaration.)

OR

check box 4(1)(c)(ii) Conducting sampling and analysis of TDIs from stack releases, and

4(1)(c)(iii) Measuring or estimating emissions of TDIs to air from storage tanks, and

4(1)(c)(iv) Measuring or estimating fugitive emissions of TDIs to air. (Proceed to Part 4.5.3 of this Declaration.)

4.5.2 Air Concentration of TDIs at or beyond the Facility Boundaries

If you chose the option to predict TDI concentration in ambient air using AERMOD stated in subparagraph 4(1)(c)(i) of the Notice, fill out the following two tables to report information for the Implementation Year 2015.

AERMOD Model-predicted Data

Maximum 24-hour Average Concentration of TDIs at or Beyond the Facility Boundaries (µg/m3)

Average Distance from the Emission Sources to the Facility Boundaries (m)

Distance from the Facility Boundaries to the Location at which the Maximum 24-hour Average Concentration of TDIs is Predicted
(m)

Date Simulation was Completed (YYYY-MM-DD)

For the Implementation Year

       

In the field below, report the additional input data related to operating conditions and emission sources considered for the application of the AERMOD model and used to estimate the maximum 24-hour average concentration of TDIs at or beyond the facility boundaries in the Implementation Year 2015. Briefly describe the scenario considered for the simulation.

Additional Input Data Used in AERMOD and Description of
Scenario Simulation for the Implementation Year

4.5.3 Actual On-site Releases of TDIs to Air

If you chose the option to measure or estimate actual on-site releases of TDIs to air stated in subparagraphs 4(1)(c)(ii), 4(1)(c)(iii), and 4(1)(c)(iv) of the Notice, fill out the following table to report information for the Implementation Year 2015.

Type of Releases to Air

Quantity
Released to
Air for the Implemen 
tation
Year
(kg)

Actual Exhaust Air Volume Rate
(m3/s)

Tempera-
ture of the Gas Emitted from the Stack
(°C)

Typical/
Current Concentra-
tion of TDIs Released to Air
(mg/m3)

Measure-
ment Method or Estimation Method
(see footnote 7)

Date Stack Test was Completed (YYYY-MM-DD)

a) Stack or point releases (including process building vents) [Factor stated in subparagraph 4(1)(c)(ii) of the Notice]

           

b) Storage tanks or handling releases [Factor stated in subparagraph 4(1)(c)(iii) of the Notice]

 

n/a

n/a

   

n/a

c) Fugitive releases [Factor stated in subparagraph 4(1)(c)(iv) of the Notice]

 

n/a

n/a

   

n/a

d) Spills

 

n/a

n/a

   

n/a

e) Other releases (please specify)

         

n/a

TOTAL

 

n/a

n/a

n/a

n/a

n/a

5.0 Action(s) Taken and Results Achieved

5.1  Action Taken

Parts 5.1.1 through 5.1.6 must be completed separately for each action taken in the P2 Plan, i.e. Part 5.1 will be completed as many times as there are actions taken to report.

Describe, for the activity identified in Part 3.0 of this Declaration, the current status of the action taken to date in implementing the Pollution Prevention Plan. Please complete for each action that was reported in your last submitted Interim Progress Report.

What is the current status of this action?

  • check box Planned/to be initiated
  • check box In progress
  • check box Completed
  • check box Discontinued

If the action is “Discontinued,” please provide the reason why you will no longer be carrying out this action for the activity.

 

In Part 5.1.1, describe, for the activity identified in Part 3.0 of this Declaration, the action taken in implementing the Pollution Prevention Plan. If you have previously filed an Interim Progress Report, report only those actions that have been taken since the last Interim Progress Report.

5.1.1 Action Taken: _________________________________________

In Parts 5.1.2 and 5.1.3, identify whether the action represents a pollution prevention method(s) or other environmental protection method(s) by selecting from the list of options provided below.

5.1.2 Types of Pollution Prevention Methods:

For a detailed description of pollution prevention methods, please refer to the Pollution Prevention Planning Handbook (www.ec.gc.ca/planp2-p2plan/default.asp?lang=En&n=56875F44-1).

  • check box Material or feedstock substitution
  • check box Product design or reformulation
  • check box Equipment or process modifications
  • check box Spill and leak prevention
  • check box On-site reuse, recycling or recovery
  • check box Inventory management or purchasing techniques
  • check box Good operating practices or training
  • check box Other: _________________________________

5.1.3 Other Types of Environmental Protection Method(s):

  • check box Energy recovery
  • check box Off-site recycling
  • check box Incineration with energy recovery
  • check box Waste treatment
  • check box Pollution control
  • check box Disposal
  • check box Other: _____________________________________________

In Part 5.1.4, report, where possible, the corresponding change in annual uses, releases or transfers of the substance achieved by implementing that action in kg and in mg/m3 where applicable. Indicate a decrease with a negative sign (“–”) and an increase with a positive sign (“+”) in front of the reported quantity. Note that estimating a quantitative change for some actions taken, such as training, may not be possible.

5.1.4 Changes Achieved: __________________________________

In Part 5.1.5, describe which baseline elements identified in Part 4 (total on-site uses, total off-site transfers for distribution or on-site industrial TDI emissions) are affected by the changes reported in Part 5.1.4. For more information, please refer to the Instructions for Completing the Schedules.

5.1.5 Baseline Elements Affected: ______________________________

Finally, in Part 5.1.6, identify the completion date for the action taken.

5.1.6 Completion Date (YYYY-MM-DD): ______________________________

This ends Parts 5.1.1 through 5.1.6 that must be completed separately for each action taken in the P2 Plan.

5.2  Total Results Achieved

The table below summarizes, for the activity identified in Part 3.0 of this Declaration, the total change achieved in annual uses and transfers of the substance, in kg and as a percentage, relative to the Preparation Year 2012, as reported in the Declaration of Preparation.

In the two columns, relative to Preparation Year 2012, report the total changes achieved from ALL actions taken as a result of implementing the Pollution Prevention Plan.

Important: Indicate a decrease with a negative sign (“–”) and an increase with a positive sign (“+”) in front of the reported quantity.

Type of
Use/Release/Transfer

Total Change
Achieved Relative
to the
Preparation Year
(kg)

Total Change
Achieved Relative
to the Preparation
Year
(%)

5.2.1 On-site uses (related to Part 4.2)

   

5.2.2 On-site releases

To be reported in Part 5.3.2 of this Declaration

To be reported in Part 5.3.2 of this Declaration

5.2.3 Off-site transfers for distribution (related to Part 4.4.1)

   

5.2.4 Off-site transfers for disposal

n/a

n/a

5.2.5 Off-site transfers for recycling

n/a

n/a

5.3  Detailed Results Achieved Information

For the activity identified in Part 3.0 of this Declaration, complete the following part of the Declaration that is applicable to your facility, based on your responses to Part 4.5.1 of this Declaration.

5.3.1   Detailed Results Achieved for the Air Concentration of TDIs at or Beyond the Facility Boundaries

If you chose the option to predict TDI concentration in ambient air using AERMOD stated in subparagraph 4(1)(c)(i) of the Notice, use the results of TDI concentration in ambient air identified in Part 4.5.2 to fill out the following table and report information relative to the Preparation Year 2012. Report the total changes achieved by implementing ALL the actions taken as a result of implementing the Pollution Prevention Plan, as described in Part 5.1 of this Declaration.

If not, proceed to Part 5.3.2 of this Declaration.

Important: Indicate a decrease with a negative sign (“–”) and an increase with a positive sign (“+”) in front of the reported quantity.

Air Concentration of TDIs at or Beyond the Facility Boundaries

Total Change Achieved Relative to the Preparation Year
(µg/m3)

Total Change Achieved Relative to the Preparation Year
(%)

AERMOD Model-predicted Data

Maximum 24-hour Average Concentration of TDIs at or beyond the Facility Boundaries

   

5.3.2 Detailed Results Achieved for Actual On-site Releases of TDIs to Air

If you chose the option to measure or estimate actual on-site releases of TDIs to air stated in subparagraphs 4(1)(c)(ii), 4(1)(c)(iii), and 4(1)(c)(iv) of the Notice, use the results of actual on-site releases of TDIs to air identified in Part 4.5.3 to fill out the following table and report information relative to the Preparation Year 2012. Report the total changes achieved by implementing ALL the actions taken as a result of implementing the Pollution Prevention Plan, as described in Part 5.1 of this Declaration.

Important: Indicate a decrease with a negative sign (“–”) and an increase with a positive sign (“+”) in front of the reported quantity.

Type of Releases to Air

Total Change Achieved to On-site Releases of TDIs to Air Relative to the Preparation Year
(kg)

Total Change Achieved to On-site Releases of TDIs to Air Relative to the Preparation Year
(%)

Total Change Achieved in the Typical/Current Concentration of TDIs Released to Air Relative to the Preparation Year
(mg/m3)

Total Change Achieved in the Typical/Current Concentration of TDIs Released to Air Relative to the Preparation Year
(%)

a) Stack or point releases (including process building vents) [Factor stated in subparagraph 4(1)(c)(ii) of the Notice]

       

b) Storage tanks or handling releases [Factor stated in subparagraph 4(1)(c)(iii) of the Notice]

       

c) Fugitive releases [Factor stated in subparagraph 4(1)(c)(iv) of the Notice]

       

d) Spills

       

e) Other releases (please specify)

       

TOTAL

 

n/a

n/a

n/a

6.0 Monitoring and Reporting

Describe the monitoring and reporting used to track progress in implementing the Pollution Prevention Plan.

 

7.0 Risk Management Objective

Describe how the elements of the Pollution Prevention Plan met the risk management objective for TDIs identified in column 6 of the Table in section 3 of the Notice. If this plan did not meet the risk management objective, explain why.

 

This ends Parts 3.0 through 7.0 of this Declaration to be completed separately for each combination of Substance and Activity specified in Part 3.0 above.

8.0 Factors to Consider

Describe any progress made in the Implementation Year 2015 towards taking into account the “Substance-specific factors to consider in preparing the plan” in paragraphs 4(1)(b) and 4(1)(c) of the Notice and the “Other factors to consider in preparing the plan” in subsections 5(1) and 5(2) of the Notice, except those factors for which a waiver has been granted by the Minister of the Environment.

 
8.1 Exceedance of Emission or Concentration Thresholds for TDIs

Did your facility, at any time during the Implementation Year 2015, release to air more than 100 kg per year of TDIs OR have a maximum 24-hour average concentration of TDIs at or beyond the facility boundaries greater than 0.2 µg/m3, as reported in Part 4.5 of this Declaration? check box Yes check box No

If yes, describe what was done in the Implementation Year 2015 to take into account each of the following “Substance-specific factors to consider in preparing the plan” to reduce industrial TDI emissions to the environment, except those factors for which a waiver has been granted by the Minister of the Environment.

4(1)(d) Using the best available techniques economically achievable to prevent or control the release of TDIs to air from the following emission sources: stack or point, storage or handling, fugitive, and accidental or non-routine spills.

 

4(1)(e) Establishing and implementing a leak detection and repair (LDAR) program, as further described in paragraph 4(1)(e) of the Notice.

 

4(1)(f) Adopting the recommended practices contained in The DOW Chemical Company VoranateTM T-80 Toluene Diisocyanates Safe Handling and Storage Guide.

 

4(1)(g) Adopting standards and operating practices for controlling air emissions, as further described in paragraph 4(1)(g) of the Notice. Indicate which of the source(s) listed in this paragraph you considered.

 

9.0 Certification

I hereby certify that a Pollution Prevention Plan has been implemented in respect of TDIs and that the information provided in this Declaration is true, accurate and complete.

_____________________________________________________

Signature of the Person Subject to the Notice or
Duly Authorized Representative

_____________________________________________________

Date

Name: _______________________________________________________

Please Print

Title/Position: __________________________________________________

Please Print

  • Footnote 1
    The CAS Registry Number is the property of the American Chemical Society and any use or redistribution, except as required in supporting regulatory requirements and/or for reports to the Government when the information and the reports are required by law or administrative policy, is not permitted without the prior, written permission of the American Chemical Society.
  • Footnote 2
    The CAS Registry Number is the property of the American Chemical Society and any use or redistribution, except as required in supporting regulatory requirements and/or for reports to the Government when the information and the reports are required by law or administrative policy, is not permitted without the prior, written permission of the American Chemical Society.
  • Footnote 3
    Base years may differ depending upon when the facility met the criteria in section 2 of the Notice.
  • Footnote 4
    These reporting deadlines are for a person or class of persons subject to the Notice on the date of publication in the Canada Gazette, Part Ⅰ. For the reporting deadlines applicable to a person or class of persons becoming subject to the Notice after the date of publication in the Canada Gazette, Part Ⅰ, please refer to sections 6, 7, and 13 of the Notice.
  • Footnote 5
    Indicate which of the methods was used to measure or estimate actual on-site releases of TDIs to air, from the ones stated in the “Substance-specific factors to consider in preparing the plan” in subparagraphs 4(1)(c)(ii), 4(1)(c)(iii), and 4(1)(c)(iv) of the Notice.
  • Footnote 6
    Indicate which of the methods was used to measure or estimate actual on-site releases of TDIs to air, from the ones stated in the “Substance-specific factors to consider in preparing the plan” in subparagraphs 4(1)(c)(ii), 4(1)(c)(iii), and 4(1)(c)(iv) of the Notice.
  • Footnote 7
    Indicate which of the methods was used to measure or estimate actual on-site releases of TDIs to air, from the ones stated in the “Substance-specific factors to consider in preparing the plan” in subparagraphs 4(1)(c)(ii), 4(1)(c)(iii), and 4(1)(c)(iv) of the Notice.