Discussion Paper on the Proposed Odour Requirements for the Air and Noise Emissions EASR

Transcription

1 Discussion Paper on the Proposed Odour Requirements for the Air and Noise Emissions EASR Executive Summary In 2016, the ministry proposed the development of an Air and Noise Emissions Environmental Activity and Sector Registry (EASR) Regulation (formally known as the Plant and Production Processes with Air and Noise Emissions EASR (PPP EASR)). More information on the proposed Air and Noise Emissions EASR Regulation can be found on the Ontario Environmental Registry. People engaging in prescribed activities would be required to register those activities in the Air and Noise EASR, and meet operating requirements specified in the Regulation with regards to emissions, facility management, and other factors. The proposed odour requirements described in this discussion paper have been developed to support the ministry s approach to addressing odour from facilities engaging in proposed Air and Noise Emissions EASR prescribed activities. The proposed approach includes Operational Requirements (ORs) to address odour in the Air and Noise Emissions EASR Regulation, as well as guidance material that will be developed by the ministry to assist facilities in completing any additional odour-related requirements. The ministry will also be developing a separate discussion paper to support the ministry s approach to addressing odours for facilities that would not be eligible to register under the proposed Air and Noise Emissions EASR Regulation. This discussion paper is to be completed in P age

2 Table of Contents Executive Summary Introduction Background Proposed Odour-based Operational Requirements for the Air and Noise Emissions EASR Identification of Activities with Potential to Cause Adverse Effects due to Odour Odour Screening Procedure Tier Determination for Activities that Screen In Resources Odour Screening Form BMPP Technical Bulletin Example Odour Control Reports (OCRs) Discussion Paper for Facilities Requiring an ECA Appendix A Odour Screening Procedure Appendix B B.1 BMPP Potential Operating Requirements B.2 OCR Potential Operating Requirements P age

3 1. Introduction Odorous impacts can be caused by a single contaminant; however, in most cases they are caused by a mixture of contaminants. Section 14 of the Environmental Protection Act (EPA) prohibits a person from discharging or causing or permitting a discharge of a contaminant (which includes odour) into the natural environment, if the discharge causes or may cause an adverse effect. Adverse effect is also defined by the EPA, and includes the potential to cause harm or material discomfort to people, loss of enjoyment of normal use of property, and interference with the normal conduct of business. In some instances, the public will react to odorous episodes they find objectionable by registering complaints with the facility or Ministry of the Environment and Climate Change (the ministry). Complaints due to odours are a major source of public complaints to regulatory agencies in North American and European communities. In Ontario during a 3 year period from , odour complaints accounted for 57% of all Pollution Incident Reports (or more than 6,000 complaints from numerous facilities over this three year period) recorded by ministry district or regional offices. As communities continue to expand and encroach on industrial facilities, it is anticipated that complaints due to odours, will continue to be an issue. Odour is a subjective experience and individual responses to strength and offensiveness are highly variable and are dependent on many factors. Generally, the impact of an odour results from a combination of factors collectively known as FIDOL (frequency (F), intensity (I), duration (D), offensiveness (O), and location (L)). This paper outlines the approach the ministry has proposed to address potentially odorous emissions by persons registering to the Air and Noise Emissions Environmental Activity and Sector Registry (EASR) Regulation formerly described as the Plant and Production Processes with Air and Noise Emissions EASR (PPP EASR). It should be noted that in addition to the proposed approach outlined in this paper, the Environmental Protection Act allows the ministry to undertake additional actions to address odour if necessary. 3 P age

4 2. Background Contaminant is defined in the EPA to include odour and as a result odour should be addressed and included when preparing an Emission Summary and Dispersion Modelling (ESDM) report. To support the consideration of odour, the ministry has previously developed several contaminant-specific odour-based standards and guidelines (e.g. hydrogen sulphide). The ministry has also developed guidance to clarify technical issues associated with air dispersion modelling and the use of odour based standards or guidelines with 10-minute averaging period which can be found on the ministry s website. This guidance also clarifies how to assess odours at places frequented by humans, and considers frequency of exceedances at those locations. Adverse effects due to odours are typically caused by mixtures of various contaminants rather than individual contaminants. The odorous effects of individual contaminants have been well studied; however, this is not so for mixtures. In some cases, odour in mixtures can be additive, or in others, mixing can be synergistic. To date, the ministry has not developed any standards, guidelines, technical bulletins or guidance documents to address odour mixtures. When issuing an Environmental Compliance Approval (ECA), the Director may include site-specific terms and conditions in the ECA to address odour at the facility. ECA terms and conditions may require a facility to reduce the potential for odour emissions. These terms and conditions may include: the requirement to develop odour mitigation/abatement plans, mandatory source testing to properly characterize odour sources, requirements for odour control equipment and process operation, odour concentration limits, specific requirements for facility operations (e.g. keep all doors/windows closed, or operate under negative pressure). When there are odour complaints from a facility, the complaints are typically directed to the local district office and/or the facility. Ministry local district offices respond to the complaints and resolve issues through discussions with the owner or operator of the facility and the community, and may issue orders or notices to the owner or operator of the facility to reduce odour emissions as needed. In 2011, the ministry implemented the Environmental Activity and Sector Registry (EASR) as part of its risk-based environmental approvals program requiring persons engaging in prescribed activities to register their activities in the EASR instead of seeking a ministry approval through an application and review process. The EASR is an online self-registration system and is part of Ontario s Business Growth Initiative to 4 P age

5 reduce regulatory burden, eliminate duplication and improve the delivery of government services. Currently, the ministry is consulting on the development of the proposed Air and Noise Emissions EASR Regulation which would require persons engaged in prescribed activities to register their activities in the Air and Noise Emissions EASR, provided the activities meet the eligibility criteria. More information on the proposed Air and Noise Emissions EASR Regulation can be found on the Ontario Environmental Registry. Persons engaging in prescribed Air and Noise EASR activities would be required to follow the operational requirements in the Regulation. Operational requirements to support managing effects from odour would be proposed in the Regulation for facilities identified as having potential odorous emissions. These proposed operational requirements are described in the following section. 3. Proposed Odour-based Operational Requirements for the Air and Noise Emissions EASR The proposed odour-based Operational Requirements (ORs) have been developed to support the ministry s approach to addressing odour for activities that would be prescribed in the proposed Air and Noise Emissions EASR Regulation. As well, guidance material would be developed by the ministry to assist facilities in completing any additional odour-based requirements as part of the implementation for the proposed EASR. 3.1 Identification of Activities with Potential to Cause Adverse Effects due to Odour The first step in the development of the odour operating requirements was to identify activities with a high potential to cause adverse effects due to odour. These activities would be excluded from the Air and Noise EASR process and would continue to require an ECA. An analysis of eligible activities that may cause an adverse effect due to odours was carried out. The ministry reviewed ECAs with specific terms and conditions for controlling odour emissions, as well as the Ministry s source testing database. The ministry also reviewed facility complaint histories and requests for leave to appeal over the last 10 years. Based on this analysis, some activities have been proposed as being excluded from the Air and Noise EASR process. This includes facilities with significant equipment used to reduce odour emissions, or detailed site-specific ECA terms and conditions related to odour (including source testing conditions), or a significant volume of odour complaints. As proposed in the Eligibility Requirement EC-1 of the Air and Noise Emissions EASR technical paper posted on June 30 th, 2016 on the Environmental Bill of Rights, activities 5 P age

6 engaged in at facilities that are identified in NAICS codes set out in Schedules 4 and 5 of Ontario Regulation 419/05 Local Air Quality would not be prescribed activities for the purposes of the EASR regime based on the toxicity of the contaminants those sectors typically release. In developing the proposed Air and Noise Emissions EASR Regulation, the ministry also identified additional NAICS codes not in Schedules 4 or 5 including those with known odour related issues, or which are likely sources of odour based on equipment, process or products produced at the facility that would be excluded from the EASR process. Activities engaged in at facilities that are described in the following NAICS codes would not be included in the proposed Air and Noise Emissions EASR Regulation based on considerations including odour: NAICS Code Asphalt Paving, Roofing and Saturated Materials Manufacturing NAICS Code 5629 Remediation and Other Waste Management Services NAICS Code Animal Slaughtering and Processing (including Rendering and Meat Processing from Carcasses) NAICS Code Sewage Treatment Facilities NAICS Code Waste Treatment and Disposal NAICS Code Starch and Vegetable Fat and Oil Manufacturing Based on further review by the ministry, the following activity was reviewed and would also be excluded from the Air and Noise EASR process based on consideration of odour: NAICS Code Waste Collection (This does not apply to activities that are eligible for registration under O.Reg. 351/12 Registrations Under Part II.2 of the Act - Waste Management Systems) In addition, the following NAICS codes that are not found in Schedule 4 or 5 have also been excluded for reasons other than odour as outlined in the June 30 th, 2016 technical paper: NAICS Code Cement Manufacturing NAICS Code Cemeteries and Crematoria NAICS Code Forging and Stamping NAICS Code Lime Manufacturing NAICS Code Non-Metallic Mineral Mining and Quarrying NAICS Code Ready-mix Concrete Manufacturing NAICS Code Rubber Products Manufacturing NAICS Code Sawmills (except shingle and shake mills) NAICS Code Veneer, Plywood and Engineered Wood Product Manufacturing 6 P age

7 Differentiating activities with significant known odour issues from those considered lowrisk and unlikely to cause an adverse effect allows the ministry to continue to implement site-specific odour terms and conditions through ECAs, as needed, while developing Air and Noise Emissions EASR requirements for odour. 3.2 Odour Screening Procedure For activities that are subject to the Air and Noise Emissions EASR Regulation, the proposed operating requirement to addressing odour would first require facilities to complete an Odour Screening Procedure. The odour screening procedure would use facility information to determine if there is a potential for an adverse effect due to odour from the facility. The proposed odour screening procedure will use the following facility-specific information: Distance to nearest odour receptor (e.g. residential zoning, park) Facility/activity NAICS code for both primary and secondary activities Are there any odorous processes at the facility Other facility information (e.g. process rate, if applicable) For facility activities that screen out (i.e. there is a low potential for an adverse effect due to odours), no further action is required. For activities that screen in (i.e. there is a potential for adverse effect due to odours), the facility may have to meet additional operating requirements and complete additional documentation. The goal of the odour screening procedure is to only screen in activities that truly have the potential to cause an adverse effect, and to not include additional requirements for all facilities unnecessarily. The ministry is also preparing an Odour Screening Form that will assist facilities in following the proposed Regulation by helping determine if they screen in or out. Additional information about the odour screening procedure and the Odour Screening Form, including definitions and identification of odorous processes, are included in Appendix A Tier Determination for Activities that Screen In Through the odour screening procedure, facilities and activities that screen in (based on facility odorous processes and activity NAICS code) would be categorized into one of two tiers based on the potential for odorous emissions. All activities and processes that screen in have the potential to cause an adverse effect due to odours; however, Tier 2 activities and processes are designated as having a higher risk of causing an adverse effect due to odours compared to Tier 1. The 7 P age

8 categorization based on tiers was developed based on a review of ECA applications, complaint histories as well as ministry experience. To further evaluate facilities, setback distances (the distance from the facility to the nearest odour receptor) were developed for each activity and process that have the potential to be odorous. These setback distances were developed by analyzing setback distances from other jurisdictions and an internal analysis of complaint data received by the Ministry. In instances where facility operations contain more than one odorous activity or process, the highest tier, with the highest setback, would be applied. The screening process is further explained in Appendix A. Table 1: Tier 1 Air and Noise EASR Activities that Screen In NAICS Setback Description Tier Code Distance (m) Other animal food manufacturing Rice Milling and Malt Manufacturing Breakfast cereal manufacturing Non-chocolate confectionery manufacturing Chocolate and chocolate confectionery manufacturing from cacao beans Confectionery manufacturing from purchased chocolate Fruit and vegetable canning, pickling and drying Fluid milk manufacturing Butter, cheese, and dry and condensed dairy product manufacturing Ice cream and frozen dessert manufacturing Seafood product preparation and packaging Cookie and cracker manufacturing Roasted nut and peanut butter manufacturing Other snack food manufacturing Coffee and tea manufacturing Flavouring syrup and concentrate manufacturing Seasoning and dressing manufacturing All other food manufacturing Breweries (< 20 ML/yr [annual production rate]) Distilleries Wood preservation Leather and hide tanning and finishing Paper bag and coated and treated paper manufacturing Polystyrene foam product manufacturing Motor vehicle plastic parts manufacturing Table 2: Tier 2 Air and Noise EASR Activities that Screen In NAICS Setback Description Tier Code Distance (m) Dog and Cat Food Manufacturing Sugar manufacturing Breweries ( 20 ML/yr [annual production rate]) P age

9 Table 3: Tier 1 Odorous Processes that Screen In (note, these processes are further described in the Appendix) Odorous Process Tier Setback Distance (m) Solvent-Based Spraying Operations (<10 L/hr) Water-based and Other Paint Operations Wastewater Treatment Covered Clarifiers Scented Products Manufacturing Printing (printing rates > 100 kg/hr, and 400 kg/hr) see note below Plastic Extrusion or Melting Using Phenolic Resin Note - Does not include water-based printing operations. Table 4: Tier 2 Odorous Processes that Screen In (note, these processes are further described in the Appendix) Odorous Process Tier Setback Distance (m) Solvent-based Spraying Operations (>10 L/hr) Wastewater Treatment Lagoons, Uncovered Clarifiers, Sludge Management Food Frying Cooking or Drying Animal Products Printing (printing rates > 400 kg/hr) see note below Note - Does not include water-based printing Best Management Practices Plan (BMPP) for Odour It is proposed that all Tier 1 activities and processes that do not meet their applicable setback distance and all Tier 2 activities and processes will be required to complete a Best Management Practices Plan (BMPP) for odour. For these activities and processes, the person engaging in the activities or processes would be required to have a BMPP for odour developed by a qualified person (QP). This includes identifying all sources of odour and developing on-site procedures to minimize the likelihood of odorous emissions. The purpose of this odour BMPP is for the person engaging in the activities to be aware of all odorous sources at their facility and to implement procedures to minimize odours, including inspection and maintenance procedures. The person engaging in the activity would be required to have the BMPP at the facility at all times when engaging in the activity. The BMPP would need to be made available to the ministry upon request. It is proposed that the Regulation would require the person engaging in the activity to maintain a record of what changes were made to a BMPP to address any comments the facility receives from the ministry. It should be noted that the definition of QP for the purpose of the BMPP for odour will be consistent with the QP definition in the final Air and Noise Emissions EASR. An example illustrating the requirements of the BMPP is listed in Appendix B. 9 P age

10 Odour Control Report In addition to a BMPP for odour, persons engaging in Tier 2 activities and processes that do not meet their applicable setback distance would also be required to have a QP prepare an Odour Control Report (OCR) and have a copy of that report at the facility at all times when engaging in the activity. The OCR would include a review of other odour control options used at facilities in the same industrial sector, or used at facilities where similar activities are performed. The OCR would compare the controls at the facility to the options reviewed and determine whether the controls currently in place (or soon to be in place) are adequate. This can help the person engaging in the activities at the facility to identify if there are any deficiencies or improvements that could be made with respect to odour control. When preparing the OCR, the QP would also be required to: Consider other sectors and other jurisdictions and include an assessment of the possibility of using similar technology/controls at the facility, Consider less odorous processes/practices that can be used at their facility, List all technically feasible pollution control options for all sources at their facility, Identify best available technologies for all sources at the facility. This report would also need to be made available to the Ministry upon request. The ministry will prepare and make available further guidance material and support related to the development of the BMPP and OCR. This includes preparing sample OCRs for Tier 2 facilities. Additional details are included in section 3.3 and in Appendix B. 3.3 Resources In order to assist persons through the registration and application process the Ministry will be preparing additional guidance that could be used with the proposed Regulation Odour Screening Form The ministry will develop an Odour Screening Form that will assist facilities with following the proposed odour screening procedure found in the operating requirements. The form will assist facilities with determining if there is a potential for an adverse effect due to odour from the facility, and if they are required to comply with additional odour operating requirements BMPP Technical Bulletin The ministry will prepare a BMPP Technical Bulletin will that would provide guidance for a facility required to complete a BMPP. The Technical Bulletin will outline the key elements that are proposed to be included in a BMPP. 10 P age

11 3.3.3 Example Odour Control Reports (OCRs) Example OCRs would be developed by the ministry for sectors that would be required to complete an OCR as part of the proposed Air and Noise Emissions EASR operating requirements. The example OCRs will demonstrate what is required in an OCR, as well as provide useful information for these sectors. This should reduce the effort and cost for facilities that are required to complete OCRs. Example OCRs would be completed for the following activities and processes: Dog and Cat Food Manufacturing (NAICS ) Sugar Manufacturing (NAICS ) Breweries ( 20 ML/yr) (NAICS ) Spraying Operations (>10 L/hr) Wastewater Treatment Lagoons, Uncovered Clarifiers, Sludge Management Food Frying Cooking or Drying Animal Products Printing (printing rates > 400 kg/hr) 3.4 Discussion Paper for Facilities Requiring an ECA A discussion paper would be developed to standardize and improve the ministry s approach to odorous emissions from facilities that require an ECA, and to clarify what is required during the environmental application process with respect to odour. The discussion paper would also identify additional guidance material that will be prepared by the ministry. It is anticipated that this discussion paper will be developed in P age

12 Appendix A Odour Screening Procedure For activities that are subject to the Air and Noise Emissions EASR Regulation, the proposed operating requirement to addressing odour will first require facilities to complete an Odour Screening Procedure. The odour screening procedure would be used to determine, based on specific facility information, if there is a potential for an adverse effect due to odour. For activities that screen in (i.e. there is a potential for adverse effect due to odours), the facility may have to follow additional operating requirements and complete additional documentation. The Ministry is also developing an Odour Screening Form to assist facilities in determining if they screen in and if additional odour operating requirements are applicable. Persons engaging in prescribed activities would be required to have a completed Odour Screening Form at the facilities at all times. The person engaging in the activity would be required to ensure the Odour Screening Form is up-to date and reflects current operations at the facility. In the event of a conflict between the Odour Screening Form and the proposed Air and Noise EASR Regulation, the regulatory requirements shall determine the appropriate approach. The odour screening procedure consists of the following steps: Step 1: Step 2: Step 3: Step 4: Identify the primary and secondary NAICS Code of the facility Determine what types, and if any, odorous processes are present at the facility If required, determine the shortest setback distance from a facility odour source to an odour receptor Identify next steps and requirements from the facility as set out in the Regulation. For facilities that screen in through the odour screening procedure, additional Air and Noise EASR operating requirements may be required. 12 P age

13 Odour Screening Form Question 1 What is the Primary and Secondary NAICS Code of the facility? Two drop-down menus, with all possible NAICS Codes, are provided to allow selection of primary and secondary activities at the facility. Correct primary and secondary activity NAICS Codes are required to be selected from each menu. Question 2 Do any of the following Odorous Processes take place at the facility? All odorous processes of interest are listed with check boxes. All Odorous Processes that occur at the facility are required to be selected.. Question 3 What is the shortest distance from an odour source at your facility to an odour receptor? A text box is provided to enter the setback distance. A zoning map or equivalent may be required to be kept on file with the Odour Screening Form to verify the shortest distance. Result The screening form would evaluate the responses provided and would assist the person determine whether, based on the requirements of the Regulation, the person 1) does not need to complete any additional documentation, 2) must complete a BMPP, or 3) must complete a BMPP and OCR 13 P age

14 Odour Screening Form Information and Instructions Step 1: Identify the primary and secondary NAICS Code The North American Industry Classification System (NAICS) classifies industrial establishments based on the activity in which they are primarily engaged. In most cases, a facility may only require a primary NAICS code to describe the activities at the facility. However, larger facilities often have supplementary activities at the facility and are therefore required to identify these supplementary activities as a secondary NAICS code. The person engaging in the activity is required to identify the Primary and Secondary North American Industry Classification System (NAICS) Code based on the activities engaged in at the facility. The NAICS Code description is in accordance with the Statistics Canada publication North American Industry Classification System (NAICS) Canada For more information on determining the NAICS Code for an activity please see Only activities with NAICS Codes listed in Tables 1and 2 are classified as activities that may potentially Screen In and may be required to complete additional documentation. These NAICS Codes were identified through statistical analyses as activities with a potential to cause adverse effects from odorous emissions. Step 2: Determine odorous processes at the facility The ministry has identified certain odorous processes which are responsible for causing adverse effects from odorous emissions at facilities. The person engaging in the activity is required to identify whether any of these processes occur at the facility and may be required to specify the extent of the process. A complete list of these odorous processes which cause a facility to Screen In can be found in Tables 3 and 4. Specific requirements to define these odorous processes are found below: Spraying Operations refers to all processes requiring the application of paints, coatings, or other substances through spraying. Automotive Refinishing facilities which meet the requirements stated in O. Reg. 347/12 Registrations Under Part II.2 of the Act Automotive Refinishing will be required to register for the Automotive Refinishing EASR. If the facility is ineligible under O. Reg. 347/12, the facility may register for the Air and Noise Emissions EASR. All water-based paint spraying facilities are classified as Tier 1. Maximum hourly application rates at the facility should be used to determine the correct tier of the facility. 14 P age

15 Wastewater Treatment refers to any on-site process at the facility used to treat wastewater and does not include wastewater treatment facilities classified under NAICS Sewage Treatment Facilities. Wastewater treatment processes of interest to the ministry for the Air and Noise Emissions EASR include the use of clarifiers, lagoons, and sludge management. Any other wastewater treatment processes need not be considered when stating the types of processes which occur at the facility. Scented Products Manufacture refers to the manufacturing of various products whose purpose is to emit an odour, or the utilization of these products in the manufacturing process (ex. candle making or soap making). Printing refers to commercial printing facilities including lithographic, flexographic, digital, gravure, and screen printing. Printing Facilities which meet the requirements in O. Reg. 349/12 Registrations Under Part II.2 of the Act Printing will be required to register for the Commercial Printing Facilities EASR. If the facility is ineligible under O. Reg. 349/12, the facility may register for the Air and Noise Emissions EASR. Maximum application rates at the facility should be used to determine the correct tier of the facility. Plastic Extrusion or Melting refers to manufacturing processes which involve the melting or extrusion of plastics. This process includes all plastics including PE, PVC, ABS, HDPE, and others. Using Phenolic Resin refers to manufacturing processes which require the use of phenolic (PF) resin to complete the process, and does not include the manufacturing of phenolic resin itself. Food Frying refers to industrial processes which prepare edible foods using edible oils or fats. This process does not include any equipment, apparatus, mechanism or thing that is used for the preparation of food or beverages in restaurants or other locations identified in O. Reg. 524/98 Environmental Compliance Approvals Exemptions from Section 9 of the Act. Cooking or Drying Animal Products refers to industrial processes which heat or remove moisture from animal products to create animal food or animal products. This process does not include food for human consumption. 15 P age

16 Step 3: Determine the shortest setback distance from a facility odour source to an odour receptor The applicant must identify and locate the closest odour receptor affected by any odorous emissions that may arise from the operations at the facility. An odour source and odour receptor are defined below: Odour Source The source of an odour located within the property lines of a facility, including a fugitive source, that has the potential to contribute to an adverse effect at an odour receptor. Odour Receptor Any of the following locations at which odour emitted from a facility is received: 1. A building or structure that contains one or more dwellings. 2. A building used for institutional purposes, including an educational facility, a day nursery, a health care facility, a community centre or a place of worship. 3. A portion of a property used for recreational purposes that is not accessory to a building or structure mentioned in A portion of a property that is used for as a campsite or campground at which overnight accommodation is provided by or on behalf of a public agency or as part of a commercial operation. An odour receptor does not include a location on a parcel of land if any part of the facility is or will be located on that parcel of land. For the purposes of the screening form it is only required to identify the closest odour receptor from the source of the odorous emissions. The setback distance is calculated as the shortest distance from any odour source to any odour receptor. For rural receptors in Class 3 Areas, where properties may be larger and may include areas that would not be considered odour-sensitive, setback distances may instead be calculated to the nearest point of a dwelling. Zoning information provided by the local municipality should be used to determine the setback distance and a figure displaying this distance should be retained by the applicant. Step 4: Identify next steps and requirements from the facility Based on the information entered in the previous steps there are two documents which the applicant may be required to complete, a Best Management Practices Plan (BMPP) and an Odour Control Report (OCR). See section for more details. 16 P age

17 Appendix B Following are brief examples of potential operating requirements for the BMPP and OCR B.1 BMPP Potential Operating Requirements The Best Management Practices Plan shall include, but not be limited to: (1) Identification of sources, including fugitive, of odour emissions such as: (a) dedicated process stacks (b) general ventilation exhausts (b) open doors / windows; (d) material stock piles; (e) loading/unloading areas and loading/unloading techniques; (f) material spills; (h) exposed openings in process and storage buildings; and (i) wastewater treatment areas. (2) Potential causes for high odour emissions resulting from these sources; (3) Preventative and control measures in place or under development to minimize the likelihood of odour emissions from the sources identified above. Details of the preventative and control measures shall include: (a) a description of the control equipment to be installed; (b) a description of the preventative procedures to be implemented; and/or (c) the frequency of occurrence of periodic preventative activities. (4) An implementation schedule for the Best Management Practices Plan, including training of facility personnel; (5) Inspection and maintenance procedures and monitoring initiatives to ensure effective odour preventative and control measures; and (6) A list of all Ministry comments received, if any, on the development of the Best Management Practices Plan, and a description of how each Ministry comment was addressed in the Best Management Practices Plan. (7) The person shall implement the Best Management Practices Plan for the control of odour emissions to reduce any potential sources of odour emissions resulting from the operation of the Facility. 17 P age

18 B.2 OCR Potential Operating Requirements The Odour Control Report shall include, but not be limited to: (1) A comparison of methods used by other facilities within the same or similar industrial sector to reduce odour emissions from all sources of odour, and justification as to why current odour prevention and controls for the facility are adequate. This must consider both non-negligible sources reduction methods and overall facility reduction methods. (2) A review of requirements and pollution control strategies, from other jurisdictions (e.g., the United States and Europe, etc), that are relevant to the facility and will reduce odour emissions and contribute to reduced concentrations at all sensitive receptors. (3) An assessment of the possibility of transferring technology and control strategies from other industrial sectors using the same or similar contaminants (4) A consideration of inherently less odorous processes/practices, including pollution prevention and changes in materials used within and produced by the facility (5) A list of all technically feasible pollution control options for all sources (including fugitive) of odour including: material substitution, process change, or add-on controls (6) An identification of Best Available Control Techniques for each source of odour, including fugitive sources, and justification as to why the Best Available Control Technique in not feasible or required, if not proposed or installed 18 P age