by Françoise Robe and Kirk Easto
Have you scheduled testing of all your NOx sources yet? Under the new Multi-Sector Air Pollutants Regulations (MSAPR), many Canadian operations face strict and rather onerous reporting requirements of their nitrogen oxides (NOx) emissions.
If the new requirements have left you scratching your head, you’re not alone. We are working with clients across the country to clarify which sources must be tested and when.
The MSAPR apply to Boilers and Heaters (Part 1), Stationary Spark-Ignition Engines (Part 2), and Cement Kilns (Part 3). Your reporting deadline depends on the type and size of the sources and when they were put into operation.
RWDI has been actively sharing ideas about how you can adapt to this major revision of the Air Quality Management System (AQMS), with various seminars and most recently at CANECT18 where RWDI senior project manager and principal Brad Bergeron co-chaired a session on managing industrial air emissions, featuring speakers from Environment Canada, as well as experts from RWDI and other firms.
Think about a complete shift in practice
As you consider your plan for responding to this regulation, you may find it helpful to adopt a mindset of completely shifting your practice. As we see it, these are the biggest changes you’ll need to make under the new laws:
- Testing is key. You can no longer simply use manufacturers’ data.
- Frequent reporting is required. You must show that equipment continues to meet the standards, so you’ll need to plan for more frequent testing to document compliance.
- Testing methodology is strict. The regulations stipulate strict test requirements, including port specifications and operating conditions. This change means that you’ll need to plan ahead to meet the test conditions within your operating schedule. We have put together checklists to help you prepare and ensure efficient and compliant testing sessions.
Complying with MSAPR is, without question, a significant endeavour. But by making informed choices, you may find opportunities for savings.
A long-term, big-picture strategy is critical
To make effective choices about MSAPR compliance, you need to start from three foundations:
- Correct interpretation of the regulation
- Comprehensive, long-term planning
- Good source data (i.e., accurate, appropriate to the source and sufficiently comprehensive).
Determine what and when to report. You’ll need to understand in detail how the regulation applies to your operation’s unique profile. First and foremost, your portfolio of sources will determine when and how often you need to report. However, the deadlines are not straightforward and vary by source.
Plan strategically for capital expenditures. You may need to reconsider your capital equipment plans with a view to retiring your worst sources sooner than expected.
Rethink testing programs for accuracy and efficiency. Your reporting profile will guide your choice of new systems and procedures for testing and reporting. For the looming near-term deadlines, you may want to share testing visits with nearby operations facing the same time pressures. Shared scheduling may save everyone time and money.
In the longer term, it may help to see opportunity in necessity. Invest now to develop an efficient ongoing testing program, and you’ll save money and headaches in the coming years. For example, you may need to look for easy ways to keep more comprehensive historical records, because the regulation uses the operational date as a criterion. You may also need new kinds of source inventories, methodologies and testing schedules.
Because this regulation requires so much more actual testing, another long-term strategy may be to start or enhance in-house testing capabilities. For example, local staff could be trained to perform routine stack testing.
We can help.
Given our 30 years of experience, we have plenty of ideas about the best ways to adapt to this new compliance landscape! But we’ll help in whatever way meets your needs and circumstances. Here are some things we can do to make the adjustment less overwhelming:
- Conduct on-site testing
- Evaluate your source portfolio to determine new requirements
- Consult with you on long-term strategy
- Train your local staff to do routine testing
- Provide training and support as you develop robust in-house testing capability (e.g., quality assurance and certification).