The Ministry of Environment, Conservation and Parks (MECP) has recently emboldened their enforcement efforts for some requirements included in O. Reg. 419/05. This regulation requires facilities to develop and maintain Emission Summary, and Dispersion Modelling (ESDM) reports that capture all sources of air emissions. It’s common practice for facilities to update their ESDM reports when they make significant changes to operations that affect air emissions.
Section 24 of this regulation sets out the requirements for when ESDMs need to be updated. This section, until recently, has been not well understood or subscribed to by the regulated community but requires that facilities update their ESDMs annually. These updates are required even if there are no changes to your facility’s emissions profile.
Under section 24 annual updates are to be completed by March 31st and be current as of December 31st of the previous calendar year.
The recent enforcement efforts on this regulatory requirement can be largely attributed to the growing number of cases of facilities letting their ESDMs fall out of date. Minor changes to facility operations (feedstock changes, raw material formulations, machinery changes, etc.) can and often do affect your facility emissions. The MECP also makes updates to emission Point of Impingement (POI) limits and Atmospheric Dispersion Modelling System (AERMOD) version updates on a regular basis.
EKG recommends updating your facility ESDM reports at the time of National Pollutant Release Inventory (NPRI) reporting. While the report may simply require only a new date, with little to no information updated, each facility will need to ensure that the information relied upon in the ESDM is current to guarantee that all current sources of emissions are accounted for.