Control of Air Contaminants: Waste Management Act

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Control of Air Contaminants Waste Management Act
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Waste Management Act (WMA)Overview

• The Waste Management Act
• Administered by the Ministry of Water, Land and
  Air Protection, Environmental Protection
  Division.
• Primary legislative tool in B.C. to achieve our
  mandate of clean air, clean water and clean soil.
  
• Supported by 35 Regulations and hundreds of
  permits.

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Waste Management ActHow does it Work?

• Prohibits the discharge of ANY waste into the
  environment from a business activity.
• Prohibits the discharge of waste from any source
  that causes pollution.
• Some exemptions
• Unless authorised by a Permit, Approval or
  Regulation

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Types of authorizations for waste discharges

• General

Waste Management Act
Pulp and Paper Mill Liquid Effluent Control
Regulation
Regulations
Special Waste Regulation
Contaminated Sites Regulation
Wood Residue Burner and Incinerator Regulation
Site-Specific Authorizations
Permit
Approval
Specific
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What is a Waste?

• Air contaminants
• Litter
• Effluent
• Refuse
• Biomedical waste
• Special (hazardous) waste

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What is an air contaminant?

• A substance emitted into the air that
• Injures or is capable of injuring the health and
  safety of a person,
• Injures or is capable of injuring property or any
  life form,
• Interferes or is capable of interfering with
  visibility or the normal conduct of business,
• Causes or is capable of causing physical
  discomfort to a person,
• Damages or is capable of damaging the environment.

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Regulations

• Applies across the province to specified
  operations or wastes.
• Provides little flexibility for regional managers
  to consider site-specific factors.
• Most suitable for a fairly simple operations or
  wastes.

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Wood Residue Burner and Incinerator Regulation
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Wood Residue Burner and Incinerator Regulation

• Came into effect in 1995.
• Requires the phase-out of Tier 1 beehive burners
  by Dec. 31, 2004.
• Beehive burners no longer operate in Prince
  George, previously 15.
• Any replacement incinerators must meet a
  particulate level of at least 120 mg/m3.
• Remaining burners operating more cleanly.

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Yes, it is operating
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Solid Fuel Burning Domestic Appliance Regulation

• Applies to wood stoves, pellet stoves, fireplace
  inserts.
• Prohibits a business from selling an appliance
  unless it meets specified standards.
• Doesnt apply to recent outdoor wood burning
  systems.

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Cleaner Gasoline Regulation

• Sets standards for gasoline distributed in B.C.
• Vapour pressure
• Benzene
• Sulphur

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Permits/Approvals

• Authorizations issued regionally for discharges
  at individual operations at individual locations.
• Approval a short term authorization (15 months
  max.). Permit has no expiry date.
• In setting requirements, provides flexibility to
  consider the unique circumstances at a facility
  and local ambient conditions.
• Prior to issuing a permit for air discharges,
  require air dispersion modeling.

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Permits/Approvals

• Specify
• Discharge quality quantity
• Monitoring reporting procedures
• Type maintenance of pollution control works
• Suitable for unique, complex operations e.g. pulp
  mills, gas plants, chemical plants, etc.

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MINISTRY OF ENVIRONMENT, LANDS AND
PARKS PERMIT PA-04530 Under the Provisions of
the Waste Management Act Northwood Inc. doing
business under the firm name and style of North
Central Plywoods P.O. Box 9000 Prince George
, British Columbia V2L 4W2 is authorised to
discharge air contaminants to the air from a
veneer/plywood/chipper mill located in Prince
George, British Columbia, subject to the
conditions listed below. Contravention of any of
these conditions is a violation of the Waste
Management Act and may result in prosecution.
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• AUTHORIZED DISCHARGES
• This subsection applies to the discharge of air
  contaminants from THREE VENEER DRYERS. The site
  reference number for this discharge is E211421.
• The maximum authorised rate of discharge is 20
  m3/Second.
• The authorised discharge period is 24 hours/day,
  7 days/week.
• The characteristics of the discharge resulting
  from the veneer drying process shall not exceed
• Total particulate matter and condensible organics
  - 116 mg/m3
• The characteristics of the discharge resulting
  from the combustion of natural gas include
  particulate matter, sulphur oxides, nitrogen
  oxides, volatile organic compounds and carbon
  monoxide.
• The authorised works are three natural gas fired
  veneer dryers, one wet electrostatic precipitator
  associated with the three dryers, one stack, and
  related appurtenances approximately located as
  shown on attached Site Plan A.
• The location of the facilities from which the
  discharge originates and the location of the
  point of discharge is Lot A, District Lot 747,
  Plan 18882, Cariboo Land District, British
  Columbia.

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• GENERAL REQUIREMENTS
• Standard Temperature and Pressure
• All air and gaseous volumes specified in this
  permit are at standard conditions. These
  are Standard Temperature 293.15 K Standard
  Pressure 101.325 kPa Water Vapour zero
• Maintenance of Works and Emergency Procedures
• The permittee shall inspect the authorized works
  regularly and maintain them in good working
  order. In the event of an emergency or condition
  beyond the control of the permittee which
  prevents continuing operation of the approved
  method of pollution control, the permittee shall
  take appropriate remedial action immediately and
  notify the Regional Waste Manager . Written
  documentation of the malfunction shall be
  submitted to the Pollution Prevention office
  within 30 days of the event. This shall include
  an explanation for the need to bypass, the
  duration of bypass, and remedial action taken.

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• MONITORING AND REPORTING REQUIREMENTS
• The Regional Waste Manager may alter the
  monitoring program based on the results submitted
  as well as any other relevant information
  obtained by Pollution Prevention.
• Discharge Monitoring - Dryers
• The permittee shall monitor the dryer emissions
  in the stack downstream of the electrostatic
  precipitator at a frequency of twice per year,
  preferably during periods when pine wood species
  are dried, and analyze for the following
  contaminants
• Total particulate matter and condensable organics
• Sampling is to be carried out in accordance with
  procedures described in the latest version of
  "British Columbia Field Sampling Manual for
  Continuous Monitoring plus the Collection of Air,
  Air-Emission, Water,

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Appeals

• Permits and Approvals can be appealed to the
  Environmental Appeal Board.
• Appellants can be
• The company receiving the permit,
• A member of the public who feels s/he is
  adversely affected by issuance of the permit.
• Rulings by the Environmental Appeal Board are
  open to judicial review.

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Compliance Activity for Air Contaminant Discharges

• Review monitoring information supplied by the
  company
• Carry out inspections/visual observations, e.g.
  opacity
• Expect air quality to meet objectives e.g. fine
  particulate (PM10)
• Use ambient monitoring to identify contaminant
  sources

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Enforcement

• MELP has a policy of 'Progressive Enforcement'
• Administrative Enforcement
• Notification letters
• Meetings
• Amendments of permits
• Orders - Pollution Abatement Order
• - Pollution Prevention Order

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Enforcement

• Prosecutorial Enforcement
• Administrative enforcement has failed or
  violation is more serious
• Includes
• Warnings - Warning Letter
• - Warning Ticket
• Charges - Violation Ticket
• - Form 2 Information

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Offences and Penalties - Examples
Penalties may be assessed for each day that the
offence continues.
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Case Study

• Complaints About Air Quality
• near a Forest Products Mill

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Case Study

• Things we know
• Results of stack testing provided by the company
  show compliance with permit conditions.
• An air quality monitor (discontinuous PM10)
  indicates that particulate matter levels are
  below acceptable criteria.
• Nearby residents report that mills stacks often
  emit smoke.
• Company representatives say smoke is very rare.
• An inspection confirms visual emissions from
  stack and compromised air quality.

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Case Study

• What action do you take?

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Case Study

• Review other sources of emissions
• Review monitoring programs
• Is ambient monitor located in area most likely to
  be impacted by emissions?
• Is stack testing occurring under representative
  mill operating conditions?
• Are proper monitoring procedures being followed?
• Meet with complainants
• Review mill operation and pollution control
  equipment

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Case Study

• Possible next steps
• Change stack testing program
• Relocate ambient monitors
• Assess relative contribution of all sources
• Amend permit to
• lower emission limits
• require upgrading of pollution control works
• Issue order to abate pollution
• Take enforcement action