Prpsed EASR Regulatin Standard Systems and Equipment AWMA Breakfast Sessins Fall 2013
What This Presentatin Will Cver New prpsed activities t be added t the EASR Prpsed exemptins t be added t O. Reg. 524/98 Prpsed regulatry changes t handle sites requiring bth an EASR and ECA Prpsed changes t EASR fr standby pwer systems Prpsed changes in requirements t transitin frm an ECA t an EASR Prpsed amendments fr requiring when existing EASRs must be updated Next steps 2
Cntext Standard Systems and Equipment EASR O. Reg. 346/12 (Registratins under part II.2 f the Act heating systems and standby pwer systems) currently allws businesses t register their heating systems and standby pwer systems T date 1,900+ registratins fr these activities have been filed: >1,300 Heating systems >600 Standby pwer systems On the basis f these results, it is prpsed that O. Reg. 346/12 be bradened and amended t achieve tw bjectives: 1. Expand EASR-eligible activities t capture mre facilities 2. Additinal amendments t reflect implementatin experience t date 3
Expanding Eligible Activities The gal f activity-type registratins is ultimately t capture entire less-cmplex facilities thrugh EASR and avid requiring bth EASR and ECA instruments at the same facility. Examples f less-cmplex facilities include: Multi-residential prperties such as apartments and cndminiums Retail peratins such as grcery stres Warehusing peratins Office buildings and ther cmmercial spaces Institutins such as schls, hspitals, and universities An expanded ffering t cver a range f standard systems and equipment will be included in a single registratin prcess where the registrant will select which systems and/r equipment are present at the site Tday, separate registratins must be filed fr each heating system and standby pwer generatr Single site-wide EASR registratin will require payment nly f ne registratin charge Existing registratins fr heating and standby pwer will be migrated int the standard systems and equipment framewrk thrugh transitin prvisins 4
Prpsed Standard Systems and Equipment EASR Summary Heating, ventilatin and air-cnditining HVAC systems Expands n heating systems t als include cling twers and refrigeratin Standby pwer systems Current EASR wuld be ffered as a general activity with sme amendments t prvide mre flexibility (amendments described further n in this presentatin) Dust cllectin systems at retail and schl lcatins Cmmnly fund at hardware stres, hme imprvement centres, elementary and secndary schls t cntrl particulate emissins frm resizing/shaping wd Fume hds at schl lcatins Secndary schls ften have 1 r 2 fume hds that are used n a lw intensity basis fr handling small quantities f cmmnly used chemicals (e.g. methanl) fr class demnstratins Applicatin t universities and hspitals nt included but under evaluatin fr future cnsideratin Arc welding equipment Welding fr maintenance/repair purpses nly at a facility nt fr mass prductin f gds 5
HVAC Systems Prpsed Eligibility Criteria The HVAC system must be used fr cmfrt heating and/r cling purpses nly Existing eligibility requirements in place fr heating systems remain unchanged If any cling twers are part f the HVAC system: They must be equipped with drift eliminatrs t cntrl particulate emissins frm water vapur The ttal capacity f all cling twers is limited depending n the efficiency f the drift eliminatrs 2,500 tns (cnds, small schls) fr lw efficiency drift eliminatrs 4,500 tns (larger schls, malls) fr high efficiency drift eliminatrs They must be lcated n the rf f the building r if n the grund be at least 50 m frm a receptr r have in place a nise barrier f a minimum density f 20 kg/m 2 blcking the line f site Prpsed Operating Requirements Cannt use chrmium-based water treatment chemicals fr the cling twers Equipment must be maintained accrding t manufacturers recmmendatins Drift eliminatrs must be inspected nce every six mnths Standard EASR dcument/recrd keeping and cmplaint ntificatin requirements 6
Dust Cllectin Systems Prpsed Eligibility Criteria The dust cllectin system can nly be lcated at a retail establishment r at a schl r private schl The system capacity cannt be greater than 4 m 3 /s Prpsed Operating Requirements Exhaust stack frm the dust cllectr must be riented vertically Equipment must be maintained accrding t manufacturers recmmendatins Standard EASR dcument/recrd keeping and cmplaint ntificatin requirements 7
Fume Hds Prpsed Eligibility Criteria Fume hd must be at a schl r private schl as defined in the Educatin Act (des nt include clleges r universities) Prpsed Operating Requirements Exhaust stack frm the fume hd must be riented vertically and lcated n the rf f the building Waste chemicals stred in the fume hd must be stred in a clsed and labeled cntainer (prevents smene frm using the fume hd t dispse f chemicals by cntinuusly venting t the atmsphere) Equipment must be maintained accrding t manufacturers recmmendatins Standard EASR dcument/recrd keeping and cmplaint ntificatin requirements 8
Arc Welding Prpsed Eligibility Criteria Welding must be dne inside a building r structure Welding rd cannt emit mre than 0.001 g f hexavalent chrmium (CrVI) per / kg f rd used Prpsed Operating Requirements Welding rd usage limited t 1 kg/hr Must maintain recrds n the type and amunts f welding rd used per mnth Equipment must be maintained accrding t manufacturers recmmendatins Standard EASR dcument/recrd keeping and cmplaint ntificatin requirements 9
Additinal Exemptins In additin t the amendments prpsed fr O. Reg. 346/12, the prpsal als includes amendments t O. Reg. 524/98 (Envirnmental Cmpliance Apprvals exemptins frm sectin 9 f the Act) Prpsed amendments exempting the fllwing frm needing Envirnmental Cmpliance Apprvals under Sectin 9 f the EPA: Equipment used fr battery charging Used at warehuses that perate battery pwered lift trucks and result in insignificant emissins Equipment used fr ripening f fruit and vegetables Grcery distributin centres can use lw cncentratins f ethylene t advance ripening f fruits and vegetables and this pses insignificant emissins Business cpy centres and ne-hur pht peratins Prvides further clarificatin fr printing EASR regulatin which des nt require these facilities t register due t insignificant emissins frm these businesses The ministry may seek t identify additinal activities that require clarificatin thrugh exemptin n an nging basis t supprt EASR develpment 10
Additinal Amendments: Reflecting Implementatin Experience t Date 11
EASR at Mre Cmplex Sites Sites with EASR activities and mre cmplex ECA activities must either perate with multiple instruments (EASR/ECA) r request a directr s rder (referred t as a 20.18 rder) t allw the site t mve ut f EASR and be cvered by a single ECA The requirement fr bth an ECA and EASR has lead t stakehlders requesting 20.18 rders t have all f their activities cvered by just the ECA Sme stakehlders view requiring bth EASR and ECA instruments as duplicative and the 20.18 prcess as an extra step in prcess Current Situatin Less Cmplex Facility Heating System Standby Pwer Cling Twer Maintenance Welding Mre Cmplex Facility Heating System Standby Pwer Manufacturing r ther Cmplex Air Surces EASR r 20.18 rder ECA EASR r 20.18 rder ECA 12
Prpsed Amendment EASR at Mre Cmplex Sites cnt d Remve the requirement t register r get a 20.18 rder by making sites ineligible fr EASR if they have any air/nise apprval requirements (Sectin 9, EPA) ther than thse cvered by the prpsed Standard Systems and Equipment EASR Prpse t transitin existing EASR registratins at cmplex sites s they are nt frced ut f the registry unless they make a request fr revcatin f their EASR Prpsed Less Cmplex Facility Heating System Standby Pwer Cling Twer Maintenance Welding Mre Cmplex Facility Heating System Standby Pwer Manufacturing r ther Cmplex Air Surces EASR ECA 13
Mdifying Standby Pwer Requirements Current Situatin Currently EASR applies t mst standby pwer generatrs up t 700 kw that burn diesel, prpane r natural gas Standby pwer systems that are eligible fr EASR must meet Tier 1 EPA emissin standards and nise specificatins (e.g. 75 dba at 7 m) as mandatry perating requirements Feedback indicates that there culd be situatins where existing standby pwer systems d nt meet the standards but can still be shwn t be within acceptable limits fr air/nise Fr instance, the generatr may be far away frm any ptential receptrs and will nt cause impacts Can lead t requests fr 20.18 rder t accunt fr these types f scenaris 14
Mdifying Standby Pwer Requirements Prpsed Amendment Make the Tier 1 EPA emissin standards and nise mitigatin part f the eligibility requirements that screen a system int EASR rather than a mandatry perating requirement If the generatr meets the standards, it is registered n EASR If nt, EASR desn t apply. An applicatin must be prepared fr an ECA and the ministry may apprve site specific cnditins Amendments will als prvide additinal flexibility fr nise in the EASR eligibility criteria by making systems eligible if they are mre than 50 m frm the nearest prperty line f a nise receptr This apprach still prvides an incentive t upgrade standby generatrs t be EASR eligible because getting an ECA fr the generatr means the whle facility is ineligible fr EASR 15
Current Situatin 5 Year ECA t EASR Transitin Activities d nt need t be registered in EASR if they are already cvered by an ECA EASR registratin is triggered if the equipment is changed r replaced which requires an ECA amendment Hwever, current EASR regulatins (except Slar) specify that this exemptin frm registering expires after 5 years Transitin will begin t impact the regulated cmmunity and the Ministry in Oct 2016 (heating, standby pwer and autmtive refinishing) and Nv 2017 (waste transprt, printing) Prpsed Change Prpse t amend EASR regulatins t extend timelines t 10 years frm when they were implemented 16
Existing EASR Registratins must be Updated An additinal amendment is prpsed t ensure existing registratins fr heating systems and standby pwer systems are transitined t reflect regulatry changes Registrants need t return t the EASR system and update their registratins t ensure they still meet eligibility requirements and t identify any ther EASR eligible activities at the site if applicable Prpsed Amendment O. Reg. 245/11 (Registratins under part II.2 f the Act General) is prpsed t be amended t allw the Directr t request that existing registrants prvide an update t their registratin infrmatin The Directr wuld make the request thrugh an electrnic ntificatin t the registrants specifying the date when an update must be cmpleted This will enable Access Envirnment t reflect current infrmatin in accrdance with the prpsed regulatry changes E.g. heating system will nw be HVAC 17
Next Steps Prpsed regulatry amendments psted t the Envirnmental and Regulatry Registries n August 23, 2013 fr 45 day cmment perid clses Octber 7, 2013 (EBR N. 011-9631) Prpsed implementatin f the expanded list f eligible activities, delineatin between EASR/ECA, and IT deplyment tracking fr late fall/early winter 18