All comments received during the comment period, whether by email, regular mail, or the Environmental Registry website were considered as part of the decision making process by the Ministry of the Environment and Climate Change (MOECC).
Two comments were received: one (1) from industry and one (1) from public health.
In addition, in June 2015, the ministry hosted a stakeholder meeting which included industry, public health units and environmental non-government organizations. An overview of the proposed Foundries – Industry Standard was provided with an opportunity for stakeholders to provide comments and ask questions of the ministry.
1. Eliminating the requirement for an Emission Summary and Dispersion Modelling (ESDM) report for a larger number of contaminants
Concerned with the availability of a large number of contaminants to which prospective applicants may register and that those contaminants would no longer be evaluated via an Emission Summary and Dispersion Modelling (ESDM) report.
The technical standard can reduce regulatory burden by not requiring ESDM reports. If a foundry is registered for all the contaminants it emits, they would no longer need to have an ESDM report. The ministry has maintained the authority to request an ESDM report (under section 24 of the regulation) at any time, if warranted.
It is important to understand that under the Foundries-Industry Standard, actions taken to reduce emission of contaminants such as suspended particulate matter will have the co-benefit of reducing other contaminants like chromium and chromium compounds (metallic, divalent and trivalent), lead and lead compounds, manganese and manganese compounds, and nickel and nickel compounds as well. If these sources are being better controlled, the need for an ESDM report is diminished. The money that would have been spent to update these reports annually could be redirected to complying with the technical standard requirements and reducing emissions.
Additionally, the ministry continues to seek out better information on emissions data.
2. Industry clarification on various requirements
Industry requested clarification on various technical aspects of the proposal. However, in general, industry representatives support the sector-based approach and some see it as a way to reallocate resources to prevention and process improvement.
The ministry considered industry’s comments on the Foundries-Industry Standard which is intended to focus on the prevention of pollution through technical requirements such as operational and management practices and pollution control technologies.
One recommendation from the foundry sector was to re-evaluate the validity of the proposed rules pertaining to the installation of an afterburner when foundries are recycling used sand. Subsequent discussions with a manufacturer of sand reclamation devices revealed that this rule was not practical since the sand reclamation device has a suitably high operating temperature and adequate residence time for the safe combustion of volatile organic compounds.
3. Building Differential Pressure
Adding an alternative approach to assess building differential pressure.
Most foundries use a table of volumetric air flows into and out of the building to assess building differential pressure. FIS will now have the same options as the Metal Finishers – Industry Standard which includes the following two options:
- To prepare and update a table of volumetric air flows into and out of the building; or
- To take and record measurements of building differential pressure in 30 minute block averages.
4. Facilities should be required to demonstrate continuous improvement over time
The ministry should include a mechanism to assess continuous improvement over time.
More stringent requirements are included for new facilities and facilities that undergo a major modification. This approach will ensure continuous improvements over time.
A technical standard can also be updated if new cost-effective technology becomes available in the future. The ministry is currently considering when and how to ensure technical standards in general continue to be kept up to date. The Technical Standards Publication (see chapter 1.4 Updating of Technical Standards) acknowledges that updates to technical standard should be considered if new technically and/or economically feasible approaches become commercially available.
Registration Process for Technical Standards:
Facilities that are part of the foundry sector can decide whether or not to register for contaminants of interest under this compliance approach. There are 13 foundries presently registered under the 2009 Foundries – Industry Standard. These facilities do not need to reapply. Instead, they will continue to be registered and may request an amendment to their registration if they choose to add additional contaminants. Upon making such a request, the facility will need to meet any associated requirements which may be triggered for the additional contaminants they are seeking to append to their registration. Where appropriate, requirements have been phased-in to allow for an easier transition to the newly published FIS.
Information forms related to registration are available on the ministry website.