PN 1423 Industrial Air Emissions

Assessment of Regulatory Quantification and Reporting
Requirements for Air Emissions from Industrial Facilities
–Final Report–
Submitted to:
Canadian Council of Ministers of the Environment
Submitted by:
Marbek Resource Consultants Ltd.
November 12th, 2008
PN 1423
This report was prepared by Marbek Resource Consultants, under contract to the
Canadian Council of Ministers of the Environment (CCME) and is a working
paper only. It contains information which has been prepared for, but not
approved by, CCME. CCME is not responsible for the accuracy of the
information contained herein and does not warrant, or necessarily share or
affirm, in any way, any opinions expressed therein.
© Canadian Council of Ministers of the Environment 2009

EXECUTIVE SUMMARY
This report has been prepared for the Canadian Council of Ministers of the Environment
(CCME) to characterize and assess the quantification and reporting requirements for air
emissions from industrial facilities in jurisdictions across Canada as well as leading international
jurisdictions.
Background and Objectives
The Federal Government's proposed Regulatory Framework for Industrial Air Emissions is
expected to set fixed emission caps for a variety of air pollutants, including nitrogen oxides
(NOx), sulphur oxides (SOx), volatile organic compounds (VOCs), and particulate matter (PM).
The Federal Government has also indicated its intention to work to reach equivalency
agreements with those provinces that have provincial emissions standards that are at least as
stringent as the federal standards. Quantification and reporting requirements will necessarily be
an important aspect of the development of those equivalency agreements and the overall Federal
approach.
The specific objectives of this study are to:
Compile the approaches to regulatory emission quantification and reporting requirements

across Canada and in leading international jurisdictions
Compare and contrast the approaches in order to identify best practices; and,
Recommend elements that could form the basis for a national approach that would
support the implementation of the Federal Framework for Industrial Air Emissions.
Regulatory Context
Canadian authority over air quality is divided between the federal and provincial governments,
with territories, regional districts and municipalities also exercising delegated authority. Each
jurisdiction employs a variety of laws and regulations to control emissions from industrial
facilities, generally encompassing emission limits, permitting requirements, and quantification
and reporting requirements. Quantification and reporting is important in confirming compliance
and in assessing air quality impacts. Until now, the permitting of air emissions from industrial
facilities has been left to the provinces and municipalities, with limited federal involvement,
other than the establishment of ambient air standards. The Canada-Wide Standard (CWS) on
PM and ozone mandates the provinces to develop implementation plans, including plans to
control emissions from industrial facilities, and report on progress, but there is no formal
oversight.
Internationally, the process for issuing permits and ensuring compliance is generally
implemented at a sub-national level. Often, a national or even a supra-national body (e.g. the
European Union) will establish standards (e.g. ambient air quality standards) or, less frequently,
detailed rules regarding the assignment of emission limits, but the actual permitting is done by
states, provinces, länders, departments, counties, regions, municipalities, etc. Depending on the
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constitutional context (i.e. federation or unitary state), senior jurisdictions may have oversight
authority. Oversight by senior jurisdictions is usually the case when permitting is delegated to
counties or municipalities. In the US and EU countries, there is some level of national oversight.
In Australia, the permitting of air emissions from industrial facilities has been left to the States,
with limited national direction/guidance other than the establishment of ambient air standards.
Overview of Approaches
Industrial sectors and facilities across the country have substantially different quantification and
reporting requirements for air pollutants. The major reason for this variation is that jurisdictions
develop quantification approaches that are suited to the individual characteristics and location of
their facilities. In addition, jurisdictions have also tailored their overall approach to emission
quantification and reporting to match their process for compliance.
Most jurisdictions rely heavily on a case by case analysis to set both emission limits and
quantification and reporting requirements. This reflects the important variations in conditions
that may apply (e.g. different industrial process, different fuels, airshed characteristics, etc.).
Although this allows jurisdictions flexibility to account for varying conditions, it creates
inconsistencies and inefficiencies.
In response some jurisdictions have attempted to develop overall or sectoral standards or

guidelines, specifying, for example the situations that require continuous emissions monitoring
and the requirements associated with manual source performance tests. However, the scope for
variations is greater in some sectors than in others and the opportunity to standardize is similarly
variable. Thus the degree of standardization varies, both by sector and by jurisdiction.
Outside of Canada, national bodies have, in some instances, taken on the standardization
mandate. In many cases, they have established overall standards for quantification and reporting
(e.g. quantification sufficient to establish compliance; quantification sufficient to yield
representative data; use of methods, instruments, etc. consistent with the regulated standard;
reporting every two years). Occasionally, national bodies also specify specific requirements (e.g.
by sector, by substance, by type of emissions source).
Section 4 of the Report describes typical approaches in Canadian jurisdictions, and identifies the
principal variations and exceptions. Section 5 compares these typical approaches with those of
U.S., European and Australian jurisdictions.
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Quantification
Jurisdictions usually prescribe specific approaches in permits and approvals and specific
quantification methods in guidelines. However, jurisdictions often allow for deviations that
allow quantification approaches that are comparable or provide improved accuracy. Where
standard quantification approaches are defined, it is usually on the basis of the specific emission
source (i.e. unit process or operation) and by pollutant. In a few instances, the
requirements/guidelines are specified or organized by industry sector but in most jurisdictions
this is not the case.
Some requirements are fairly common even in the absence of standards. This extends across
facilities within sectors, across sectors and even across jurisdictions. Some jurisdictions have
taken advantage of this consistency to develop explicit requirements or guidelines but many
(including Canadian jurisdictions) have not. Exhibit E.1 summarizes the most common
quantification methodologies that have been identified for pollutants of concern for each of the
industrial sectors based on the Canadian and international jurisdictional review. The
quantification methodologies are broadly organized into five categories including, Continuous
Emissions Monitoring Systems (CEMS'), manual stack testing, Parametric Emissions Monitoring
System (PEMS'), Mass Balance or Emission Factors.
Exhibit E.1: Summary of Quantification Methodologies for Major Sources of Industrial

Pollutants of Concern by Sector
Sector NOx SOx PM VOC Other Pollutants

Aluminum Manual Stack Manual Stack Fluorides: (Manual
Testing Testing and Stack Testing, CEMS
COMS for dry scrubber
stacks)
Base Metal CEMS CEMS Mercury (Manual
Smelting Stack Testing)
Cement CEMS CEMS Manual Stack
Testing and
COMS
CEMS
Chemicals Manual Stack Manual Stack Manual Stack Emission Factors NH3: (Manual Stack
Manufacturing Testing Testing Testing Testing)
Manual Stack
CEMS for Testing Fluoride: (Manual
sulphuric acid Stack Testing)
plants
Electricity CEMS Manual Stack Manual Stack Mercury:
Testing Testing and (Manual Stack Testing,
COMS CEMS)
Mass Balance
for Natural CEMS
Gas
CEMS for
coal fired
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Iron, Steel & Manual Stack Manual Stack Manual Stack Emission Factors
Ilmenite Testing Testing Testing
Smelting
CEMS CEMS CEMS
Iron Ore Pellets Manual Stack Manual Stack Manual Stack
Testing Testing Testing
Lime Manual Stack Manual Stack Manual Stack

Natural Gas Emission Emission Emission Factors

Transmission, Factors Factors (LDAR)
Distribution &
Storage PEMS
Oil Sands CEMS CEMS Manual Stack Emission Factors H2S: (Mass Balance)
Test with (LDAR) TRS: (CEMS)
COMS
Petroleum Emission Factors
Product (LDAR)
Terminals
Manual Source
Testing
Petroleum CEMS CEMS Manual Stack Emission Factors Benzene: (Emission
Refining Test with (LDAR) Factors)
COMS H2S: (Mass Balance)
Manual Source
Testing
Potash Manual Stack
Test
Pulp & Paper Manual Stack Manual Stack Manual Stack TRS: (CEMS)
Testing Testing Testing with
COMS
CEMS for CEMS for
Kraft Mills Kraft Mills
Upstream Oil & Manual Stack Emission Factors H2S: (Mass Balance)
Gas Testing (LDAR) Benzene: (Emission
Factors)
PEMS
CEMS for
sulphur
recovery
plants
Wood Products Manual Stack Manual Stack Manual Stack
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Reporting
Variation in reporting requirements generally mirrors that of quantification requirements. Most

provinces require an annual summary report, including an analysis that demonstrates that both
source emission limits and ambient limits are being met and describes the quantification
methodologies used for individual sources. If emission or ambient limits are not being met, then
the facility must report on the remedial measures that would bring the facility within the
allowable limits. Additional detail in these reports typically includes information on process
changes that have been made and abnormal operating conditions and how these conditions may
have impacted total releases of air pollutants.
Given the differences in reporting approaches, the information that would likely be required for
the proposed Federal Framework for Industrial Air Emissions may not be currently available. As
noted above, some jurisdictions are not currently collecting consistent and comparable data on
total facility wide emissions of air pollutants for regulatory compliance. Information on facility
wide emissions will be crucial for the proposed Federal Framework and the development of a
potential cap and trade system. The format of annual summary reports and emission monitoring
reports also varies considerably; some jurisdictions have standardized reporting formats
available, while other jurisdictions receive reports that have not been standardized and vary for
almost every individual facility. In addition many jurisdictions such as Nova Scotia and British
Columbia still rely on the submission of paper reports only and do not require electronic copies
that can be easily disseminated.
In almost all cases, information concerning permits is public. This usually includes information
on quantification and reporting requirements as well as the actual performance standards. In
some cases, however, the information is not easily accessible. This may be because it can only
be obtained through access to information requests, or because the requirements are contained in
a variety of source-permits issued over time, rather than facility-wide permits that are renewed
regularly. Facility reports are not as easily obtained in Canada and it may be that there are
concerns related to the confidentiality of the data provided by facilities.
In both the U.S. and the E.U., permits and reports are meant to be public; however in many cases
access (particularly to reports) remains difficult.
Potential Best Practices
The information collected from Canadian and international jurisdictions reveals some common
approaches and practices, as well as some interesting differences and contrasts. However, no
objective evidence was found to indicate that any jurisdiction's practices are better at reducing
emissions and/or ensuring compliance, or more efficient in doing so. In particular, the research
did not reveal any program evaluations that would have allowed conclusions about effectiveness,
efficiency or lessons learned, nor did jurisdictions highlight any significant findings or lessons
learned about effectiveness.
Nevertheless, the Project Team has identified a list of candidate "best practices". These were
selected on the basis of our observation of an apparent consensus of jurisdictions and our
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judgment of what would be most likely to contribute to effectiveness, cost-effectiveness,
consistency, accessibility, transparency and simplicity. The list is presented in Exhibit E.2.
Advantages and disadvantages of these practices are assessed in the Report.
Exhibit E.2: Candidate Best Practices
Category Candidate Best Practices

CEMS of major sources including those that may operate infrequently but
that can lead to major emissions
Use of standardized US EPA quantification methods
Assigning specific quantification methods based on facility production
Quantification of
thresholds
Emissions
Differentiated quantification requirements based on the type of fuels burned
or process
Minimum annual quantification of emissions
Development of quantification Codes of Practice for specific emission
sources
Use of Predictive Emission Monitoring (PEMS)
Coverage of Quantification and reporting for all criteria air contaminants emissions
Pollutants Quantification and reporting of other significant toxic air pollutants
Auditing and Third party verification of emissions monitoring and reporting
Verification Annual certification of compliance issued by facility
Requirement of Annual Emission Summary Reports
Reporting of performance of air pollution control equipment
Reporting
Reporting of CEMS monitoring results in real time
Requirement to maintain Quantification and Reporting Records
Publication of environmental permits, monitoring data and emission summary
Public Access
reports on-line
Conclusions and Recommendations
Our main conclusions and recommendations are as follows:
Regulatory Framework
Conclusions
Canadian provinces, territories and relevant regional districts and municipalities have
well-established programs for specifying regulatory quantification and reporting
requirements.
A separate Federal program for quantification and reporting would be duplicative and
therefore not cost-effective.
In all the international jurisdictions examined, the implementation of quantification and

reporting is left to sub-national entities.
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Recommendation
The Federal Government should avoid establishing a parallel system for regulatory
quantification and reporting of air emissions and should rely on the provinces,
territories, regional districts, and municipalities (except in the Northwest Territories).
Overall Approach to Quantification and Reporting
Conclusions
There are a wide range of different approaches to regulatory quantification and reporting
of air emissions from industrial facilities in Canada. Specific requirements vary
between substances, sources, sectors and jurisdictions. They also may vary between
facilities in the same jurisdiction.
Many jurisdictions have adopted a risk based approach to managing air emissions. This
means that quantification and reporting requirements may vary based on factors such as
the ambient level of air pollution in the area surrounding the facility, distance to
sensitive receptors and dispersion characteristics of the facility emission sources.
Attempts, to create a one-size fits all approach to quantification and reporting for any
given sector may not be appropriate or cost effective since requirements would no
longer hinge upon potential risks to the environment.
The variety is a reflection of the different circumstances/risks associated with each

permit but it also reflects a lack of standardization and a lack of easily accessible
guidance on best practices.
In most of the international jurisdictions examined, attempts have been made to provide
standards and guidance to assist competent authorities in setting the quantification and
reporting requirements for permits.
In the U.S., standard rules attempt to cover all scenarios and leave little discretion. The
result appears to be overly complex and inflexible. In European countries, some
standards are established but there is still significant scope to adjust requirements based
on circumstances.
Many of the most common and relevant practices used in Canadian and International
jurisdictions to quantify and report industrial emissions are potential best practices – see
Exhibit E.2. Their advantages and disadvantages are reviewed the Report.
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Recommendation
The Federal Government and the provinces should work together to develop a national
framework for quantification and reporting. This framework would include:
A generic standard establishing consistent objectives, philosophy, approach, process,

and hierarchy of methods for quantification and reporting. This standard should
establish the principle that, at a minimum, facility-wide emissions data should be
collected and reported annually.
A series of specific quantification and reporting standards for selected air

contaminants and/or industrial sectors, where these are feasible. For example, it
may be possible to standardize the requirement for continuous NOX emissions
monitoring using thresholds, geographical location, etc. Similarly, it may be
possible to standardize the approach to quantification and reporting of a range of
contaminants in the electricity generation sector, using thresholds, fuel type, etc.
(this could be patterned on the EU Large Combustion Facility Directive).
A series of guidelines for sectors where standardization is not feasible due to the
variety of circumstances but where the most likely appropriate quantification
approaches can be described. For example, in the chemical sector, where the range
of facilities, processes and sources is too broad for standardization to be feasible, it
may be possible to identify options and typical practices applicable to common unit
processes and operations. In contrast with the U.S. approach, guidelines would not
be prescriptive and would not attempt to cover all scenarios in detail. Instead they
would identify the most common approaches along with appropriate selection
considerations. It is worth noting that the Canadian Chemical Producers Association
(CCPA) has developed an emissions quantification guideline for its members, which
is similar to that of the Canadian Petroleum Products Institute. The CCPA document
provides guidance for specific chemical subsectors (based on the chemical product
produced), as well as emission sources that are common to the entire industry, such
as combustion sources and fugitive leaks.
Adoption of the practices listed in Exhibit E.2 where analysis indicates that the
advantages outweigh the disadvantages.
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Emissions Coverage
Conclusions
Overall, there is relative consistency between jurisdictions in the emissions to be

quantified and reported within each sector.
Within sectors, there is variability in emissions coverage due to differences in processes

or fuels.
Recommendation
The Federal Government and the provinces should work together to capture a standard
list of emissions requiring quantification for each sector. In many sectors this should be
straightforward. In other sectors, this will be more difficult but it should be possible to
develop a list of potential contaminants and a checklist of standard considerations in
choosing which to include.
Quantification
Conclusions
Although quantification approaches are not consistent in many sectors, there are
examples of de-facto standards that are emerging. These are highlighted in Exhibit E.1.
Regarding methods and instrumentation approaches, there are well established standards
and guidelines.
Recommendation
In developing the national framework, governments should make maximum use of

emerging de-facto standards and existing well-established methods and instrumentation
approaches.
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Reporting
Conclusions
Reporting requirements, formats and frequencies vary significantly between sectors and
jurisdictions.
Some form of annual summary report is common but not universal.
Recommendation
The national framework should seek to standardize emission quantification approaches

for large industrial emission sources.
The national framework should seek to standardize the form of reporting and the need
for an annual summary report. However, efforts to standardize reporting should
recognize the unique information demands and regulatory challenges and requirements
of each jurisdiction.
Auditing and Verification
Conclusions
The approach to auditing and verification varies considerably between jurisdictions. As

a result, the reliability of the data reported is also variable.
A promising approach used in Europe is to rely on independent third-party assessment

organizations to prepare/certify the annual emissions summary report.
Recommendation
The national framework should seek to harmonize the approach to auditing and
verification.
Governments should consider the possibility of using independent assessment

organizations to certify the annual emissions report.
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Data Sharing and Availability
Conclusions
With a few exceptions, permit requirements for quantification and reporting are publicly
available but often difficult to obtain. Emission summaries and monitoring reports are
even more difficult to obtain.
There is currently no systematic sharing of facility level compliance information

between jurisdictions. Ad hoc attempts to gather and share information have been time
consuming and not entirely successful
Recommendation
The national framework should work to establish common standards for public access
that account for confidentiality provisions.
The national framework should establish a process for sharing annual reports collected
by provincial, territorial, regional, and municipal authorities with the federal
government.
Where documents and information are public, governments should facilitate public
disclosure by posting the information on the web.
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Table of Contents
EXECUTIVE SUMMARY ........................................................................................................... I

1. INTRODUCTION..............................................................................................................1
1.1 Background ............................................................................................................. 1
1.2 Project Objectives and Scope.................................................................................. 1
1.3 Information Gathering Approach and restrictions on dissemination...................... 2
1.4 Organization of the Report...................................................................................... 7
2. CONTEXT AND OVERVIEW OF QUANTIFICATION AND REPORTING
APPROACHES IN CANADIAN JURISDICTIONS .....................................................8
2.1 Industrial Sectors .................................................................................................... 8
2.2 Regulatory context in Canada................................................................................. 9
2.3 Statutory Basis for Quantification and Reporting................................................. 16
2.4 Characteristics of Permits, Approvals or Licenses ............................................... 18
2.5 Accessibility of Permits and Monitoring Reports................................................. 19
2.6 Quantification and Reporting Requirements ........................................................ 20
3. CONTEXT AND OVERVIEW OF QUANTIFICATION AND REPORTING
APPROACHES – INTERNATIONAL JURISDICTIONS .........................................21
3.1 Regulatory context ................................................................................................ 21
3.2 Quantification and Reporting Requirements ........................................................ 27
4. COMPARISON OF CANADIAN APPROACHES TO QUANTIFICATION AND
REPORTING ...................................................................................................................29
5. COMPARISON OF INTERNATIONAL APPROACHES TO QUANTIFICATION
AND REPORTING..........................................................................................................68
6. ANALYSIS .......................................................................................................................92
6.1 Regulatory Frameworks........................................................................................ 92
6.2 Overall Approaches to Quantification and Reporting .......................................... 93
6.3 Emission Coverage ............................................................................................... 96
6.4 Quantification Methods ........................................................................................ 97
6.5 Reporting Requirements ..................................................................................... 102
6.6 Auditing and Verification ................................................................................... 102
6.7 Data Sharing and Availability............................................................................. 103
6.8 Review of Quantification and Reporting Practices............................................. 103
7. CONCLUSIONS AND RECOMMENDATIONS.......................................................110
7.1 Regulatory Framework for Quantification and Reporting.................................. 110
7.2 Approaches to Quantification and Reporting ..................................................... 110
7.3 Emissions Coverage............................................................................................ 112
7.4 Quantification Methods ...................................................................................... 112
7.5 Reporting Requirements ..................................................................................... 113
7.6 Auditing and Verification ................................................................................... 113
7.7 Data Sharing and Availability............................................................................. 113
APPENDICES
Appendix A: Detailed Profiles of Requirements by Sector – Canadian Jurisdictions

Appendix B: Detailed Profiles of Requirements by Sector – International Jurisdictions
Quantification and Reporting Requirements for Air Emissions from Industrial Facilities –Final Report–
1. INTRODUCTION
This report has been prepared for the Canadian Council of Ministers of the Environment
(CCME) to characterize and assess the quantification and reporting requirements for air
emissions from industrial facilities in jurisdictions across Canada as well as leading international
jurisdictions. In Canada, this includes provinces and territories, as well as a few municipalities
and regional districts that employ regulations and/or other instruments that require industries to
quantify and report the release of air contaminants. Internationally, this includes countries and
sub-national jurisdictions, as well as one supra-national jurisdiction that is active in this area (the
European Union).
1.1 BACKGROUND
Canadian authority over air quality is divided between the federal and provincial governments,
with territories, regional districts and municipalities also exercising delegated authority. Each
jurisdiction employs a variety of laws and regulations to control emissions from industrial
facilities, generally encompassing emission limits, permitting requirements, and quantification
and reporting requirements. Quantification and reporting is important in confirming compliance
and in assessing air quality impacts.
The Federal Government's proposed Regulatory Framework for Industrial Air Emissions is
expected to set fixed emission caps for a variety of air pollutants, including nitrogen oxides
(NOx), sulphur oxides (SOx), volatile organic compounds (VOCs), and particulate matter (PM).
Fixed emission caps for certain other air pollutants from specific sectors, such as benzene from
natural gas production and processing, refineries, and iron and steel, and mercury from electricity
generation and base metal smelting, will also be considered. The emission targets are to be at
least as rigorous of those of leading jurisdictions.
The Federal Government has also indicated its intention to work to reach equivalency
agreements with those provinces that have provincial emissions standards that are at least as
stringent as the federal standards. Quantification and reporting requirements will necessarily be
an important aspect of the development of those equivalency agreements and the overall Federal
approach.
1.2 PROJECT OBJECTIVES AND SCOPE
The specific objectives of this study are to:
Compile the approaches to regulatory emission quantification and reporting requirements

across Canada and in leading international jurisdictions
Compare and contrast the approaches in order to identify best practices; and,
Recommend elements that could form the basis for a national approach that would
support the implementation of the Federal Framework for Industrial Air Emissions.
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The major industrial sectors considered in this study reflect the sectors that are identified in the
Section 71 Regulatory Framework 1 . These sectors, plus one additional sector – Wood Products
– are outlined in Exhibit 1.1 below. Definitions of these sectors, pollutants of concern and the
associated North American Identification Classification System (NAICS) code that classifies the
industry based on its primary activity are also provided in the exhibit.
The study focuses on the quantification and reporting requirements of major industrial facilities
that are used to fulfill a regulatory aspect within the specific jurisdiction such as planning,
permitting of facilities, controlling emissions, evaluating compliance and enforcement.
Quantification and reporting requirements that fulfill other goals such as public right to know
requirements or one-time reporting related to the approval of new facilities are not specifically
addressed by this study. For example federal reporting requirements for the National Pollutant
Release Inventory (NPRI) are not included as this serves primarily a public right to know role
rather than a regulatory role. It is important to note that emission reporting under public right to
know programs like NPRI typically lead to different results than regulatory compliance
monitoring and reporting partly due to thresholds but also due to differences in rigour when
responding to the two kinds of reporting.
Quantification of industrial air emissions can be undertaken using a wide range methods and may
be based on actual measurements or on engineering estimates or other data. The following
quantification methods are considered in this study:
Continuous emission monitoring systems (CEMS)

Manual source testing (i.e. stack testing)
Mass balance
Site-specific emission factors
Emission factors published in scientific, engineering or technical documents
Predictive emission monitoring systems (PEMS) that uses characteristics of the exhaust
to determine pollutant concentrations (e.g., fuel type, % O2, exhaust temperature,
concentration of other pollutants).
1.3 INFORMATION GATHERING APPROACH AND RESTRICTIONS ON

DISSEMINATION
The information gathered for this report was obtained from publicly-available documents, reports
and websites (including specific permits issued to facilities). In the case of Canadian
jurisdictions, this was augmented by interviews with key officials and the review of additional
documents (e.g. permits, reports) that are not publicly available.
Notwithstanding the public unavailability of some of the information, all jurisdictions that
supplied additional information have indicated that there are no restrictions on the dissemination
of the information used in the compilation of this report.
1
Environment Canada. December, 2007. Supplement Canada Gazette, Part I. Notice with respect to reporting of information on
air pollutants, greenhouse gases and other substances for the 2006 calendar year.

Exhibit 1.1: Major Industrial Activities
Industrial
Applicable Pollutants of
Sector Definition of Sector
NAICS Code(s) Primary
Concern
Alumina Facility that produces alumina from bauxite ore using the Bayer Process NAICS 331313 SOx, PM
Aluminum Facility that: NAICS 331313 SOx, PM,
(i) Smelts aluminum from alumna using the Hall-Héroult process, which includes the vertical Fluorides, PAHs
stud Söderberg process, the horizontal stud Söderberg process, the side-worked, prebaked
anode process and the centre-worked, pre-baked anode process;
(ii) produces pre-baked anodes for use in aluminum smelting
(iii) calcines petroleum coke for use in aluminum smelting
Base Metal Facility that: NAICS 33141 SOx, PM,
Smelting (i) engages in the production of copper, nickel, lead, zinc, cobalt or a co-product metal from a Mercury
concentrate or recyclable material, by smelting or refining or both;
(ii) includes a secondary lead smelter and provided that the secondary lead smelter is Teck
Cominco Metals Ltd. Trail Operation or Xstrata Zinc Canada Brunswick Smelter; and
(iii) includes pre-treatment when carried out at the same facility as the activities listed in
subparagraphs (i) and (ii).
Cement Facility that engages in the production of cement. NAICS 32731 NOx, SOx, PM
Chemicals Facilities primarily engaged in manufacturing chemicals and chemical preparations, from organic and NAICS 325 NOx, SOx, VOC,
Manufacturing inorganic raw materials such as the manufacturing of: NH3, PM,
(i) basic chemicals Fluoride
(ii) pesticides, fertilizers
(iii) resin, synthetic rubber and artificial and synthetic fibres
(iv) pharmaceuticals and medicine
(v) paint, coatings and adhesives
(vi) Cleaning compounds
(vii) Biofuels
Electricity Facility that: NAICS 22111 NOx, SOx, PM,
(i) comprises one or more electricity-generating units; Mercury
(ii) produces electricity; and
(iii) is not part of another industrial activity.

Industrial
Concern
Iron, Steel & An “ilmenite smelting facility” is a facility that produces steel or that reheats steel for the purpose of NAICS 33111 NOx, SOx, VOC,
Ilmenite preparing it or for rolling into a steel shape, in order for the steel to be used to manufacture other PM, Benzene
Smelting products and includes at least one of the following activities:
(i) the smelting of ilmenite ore into titanium slag and iron;
(ii) the production of titanium slag upgraded using the UGS process;
(iii) the production of steel from iron obtained from the smelting of ilmenite ore; and
(iv) the production of thermal energy for use in smelting ilmenite ore into titanium slag and iron,
in upgrading titanium slag, or in the production of steel.
An “iron facility” is a facility that engages in any combination of the following activities:
(i) the production of metallurgical coke;
(ii) the sintering of iron-bearing materials to yield material for blast furnace to produce iron;
(iii) the production of iron by direct reduction;
(iv) the production of pig iron in a blast furnace; or,
(v) the production of thermal energy for use in making metallurgical coke or iron.
Iron Ore facility that processes iron ore concentrate into iron ore pellets, but does not include the mining and NAICS 21221 NOx, SOx, PM
Pellets crushing of iron ore, the preparation of iron ore concentrate, or the storage and shipping of feedstocks
and iron ore pellets from the facility to another location.
Lime Facility engaged in manufacturing quicklime, hydrated lime and dead-burned dolomite by crushing, NAICS 32741 NOx, SOx, PM
screening and roasting limestone, dolomite shells or other sources of calcium carbonate.
Natural Gas A “natural gas distribution facility” is a facility that: NAICS 2212 PM, NOx, VOC
Transmission, (i) distributes marketable natural gas downstream of a natural gas transmission facility at the NAICS 4862
Distribution & point where the operator of the natural gas distribution facility lowers the pressure of the
Storage marketable natural gas, in order to distribute that gas to the end user; or
(ii) distributes marketable natural gas to the end user, at a pressure of less than 200 pounds per
square inch.
A “natural gas storage facility” is a facility that stores,

(i) marketable natural gas underground in a depleted natural gas reservoir, an aquifer or a salt
cavern; or
(ii) marketable natural gas in a liquefied form.
A “natural gas transmission facility” is a facility that transports marketable natural gas from a receipt
point, such as a sweet natural gas gathering system, another natural gas transmission facility, a natural
gas straddle plant, or a sour natural gas processing plant, to a natural gas distribution facility, a custody
transfer point, or a sales point but excludes a natural gas storage facility.

Industrial
Concern
Oil Sands Facility that engages in: NAICS 211114 NOx, SOx, VOC,
(i) the extraction of bitumen through surface mining and includes the processing of bitumen to PM, H2S, TRS
remove sand and water;
(ii) the extraction of bitumen through in-situ methods and includes the processing of bitumen to
remove sand and water; or
(iii) upgrading.
Petroleum Facility where crude oil, synthetic crude oil, bitumen diluted with a hydrocarbon liquid, liquefied NAICS 412 VOC
Product petroleum gas, heating oil and other refined petroleum products are received by pipeline, railcar, marine
Terminals transfer or directly from a petroleum refining facility and are stored in bulk for subsequent transportation
or distribution.
Petroleum Facility that engages in the refining of crude oil or bitumen diluted with a hydrocarbon, into petroleum NAICS 32411 NOx, SOx, VOC,
Refining products, and includes storage and processes such as cogeneration, hydrogen generation and sulphur Benzene, PM,
recovery, but excludes the production of synthetic crude oil. H2S
Potash Facility that mines, separates and refines potash from potash-bearing ore. NAICS 212396 PM, NOx, SOx,
VOC
Pulp & Paper Facility that produces any of the following products: NAICS 322 SOx, PM, NOx,
(i) pulp through a process that includes chemical pulping; TRS
(ii) pulp through a process that includes mechanical pulping;
(iii) pulp through the processing of recycled material;
(iv) paperboard through a process that includes chemical pulping;
(v) paperboard through a process that includes mechanical pulping;
(vi) paperboard through a process that includes recycled material;
(vii) uncoated mechanical paper through a process that includes mechanical pulping;
(viii) uncoated mechanical paper through a process that includes recycled material;
(ix) other paper products not included above.
Upstream Oil Facility that is comprised in part or in whole of one or more of the following types of sub-facilities: NAICS 2111 NOx, SOx, VOC,
& Gas (i) crude oil battery; Benzene, H2S
(ii) natural gas battery;
(iii) natural gas gathering system;
(iv) sweet natural gas processing plant;
(v) sour natural gas processing plant (sulphur recovery);
(vi) sour natural gas processing plant (flaring);
(vii) sour natural gas processing plant (injection);
(viii) natural gas straddle plant; or
(ix) offshore oil or gas installation.

Industrial
Concern
Wood Facility primarily engaged in manufacturing products from wood particularly: NAICS 321 VOC, PM
Products (i) sawing logs into lumber and similar products, or preserving these products;
(ii) making products that improve the natural characteristics of wood, by making veneers,
plywood, reconstituted wood panel products or engineered wood assemblies; and,
(iii) making a diverse range of wood products, such as millwork.

1.4 ORGANIZATION OF THE REPORT
This report is organized into seven major sections. Contextual information and a summary of the
quantification and reporting approach of each Canadian jurisdiction are provided in Section 2.
Section 3 provides a summary of the approach of selected international jurisdictions. Section 4
presents a table of the results of the comparative analysis by sector for Canadian jurisdictions,
drawing on the detailed profiles included in Appendix A. Section 5 presents a table of the results
of the comparative analysis by sector for International jurisdictions, drawing on the detailed
profiles included in Appendix B. Section 6 provides an analysis and discussion of the sectoral
comparisons along with a broader discussion of the differences and similarities between the
approaches of the various jurisdictions. Section 7 draws the main conclusions from the analysis
and recommends elements that could form the basis for a national approach that would support
the implementation of the Federal Framework for Industrial Air Emissions.

2. CONTEXT AND OVERVIEW OF QUANTIFICATION AND

REPORTING APPROACHES IN CANADIAN JURISDICTIONS
This section identifies the key sectors present in each jurisdiction involved in regulating
industrial air emissions. It also summarizes the regulatory context, and provides an overview of
the approach to quantification and reporting in each of the jurisdictions. The jurisdictions that
have a role include the 10 provinces, 3 territories, 1 regional district, and 1 municipality.
2.1 INDUSTRIAL SECTORS
Representatives of the different jurisdictions were asked to identify the major industrial sectors
relevant to their jurisdiction. Exhibit 2.1 identifies the major industrial sectors that may be
covered under the framework within each jurisdiction.
Exhibit 2.1: Major Industrial Sectors Identified by Jurisdiction
Metro Van
Montréal
MB
QC
ON
NU
NL
NB
AB
BC
YT
NT
SK
PE
NS
Alumina
Aluminum
Base Metal
Smelting
Cement
Chemicals
Manufacturing
Electricity
Iron, Steel &
Illmenite
Smelting
Iron Ore Pellets
Lime
Natural Gas
Transmission,
Distribution &
Storage
Oil Sands
Petroleum
Product
Terminals
Petroleum
Refining
Potash
Pulp & Paper
Upstream Oil & 2
Gas
Wood Products
See legend on page 9
2
Several facilities that are currently considered in the upstream oil and gas sector may be re-designated as oil sands facilities by
the federal clean air regulatory plan, based on the product that is being upgraded.
Legend:
= Identified by jurisdiction and reviewed in report.
= Identified by jurisdiction but not reviewed in report.
= Included in jurisdiction, but located within sub-jurisdiction (i.e. regional district or municipality)
2.2 REGULATORY CONTEXT IN CANADA
With the exception of the Northwest Territories and Nunavut, all Canadian jurisdictions
reviewed have adopted some form of environmental regulation that governs air emissions and
identifies industrial sectors that are required to have permits, approvals or licenses to operate.
The regulatory context of this legislation for each jurisdiction is reviewed in the following sub-
sections.
2.2.1 Newfoundland and Labrador
Newfoundland and Labrador has an Environmental Protection Act, which states that a
“person shall not release or permit the release of a substance into the environment in an
amount, concentration or level or at a rate of release that in the opinion of the Minister
causes or may cause an adverse effect, unless authorized under this Act or an Approval
issued under this Act.” Activities that require a Certificate of Approval are listed within
the regulations and the Minister may also require that an Approval be issued for an
activity that is not listed in the regulations. Approvals are generally valid for a period of
5 years.
The Air Pollution Control Regulations under the Environmental Protection Act set out
emission standards and limits, as well as requirements for performance testing facilities.
Specific monitoring and reporting requirements for each facility for each pollutant are
summarized in the Approvals. The quantification and reporting information collected
under these Certificates of Approval is used to determine compliance.
2.2.2 Prince Edward Island
The Air Quality Regulations, under the Environmental Protection Act, state that “no
person shall discharge a contaminant into the air from any industrial source, incinerator
or fuel-burning equipment without a Permit” and that any contaminant discharged into
the air shall not exceed the maximum concentration as specified in the permit. Permits
are valid for a maximum of 1 year. Emission limits (maximum concentration) for each
facility are specified within the permit along with the specific testing and reporting
requirements for each pollutant. The quantification and reporting information (including
stack emissions) collected is used to determine compliance as well as the following
year’s Permit fee (which in fact provides an incentive to reduce emissions).
2.2.3 Nova Scotia
Nova Scotia has an Environment Act, which includes the Air Quality Regulation. The
Environment Act states that “no person shall knowingly commence or continue any
activity designated by the regulations as requiring an approval unless that person holds

the appropriate approval.” The Activities Designation Regulation indicates which sectors
require an Approval to Construct and/or an Approval to Operate.
The Approvals to Operate are valid up to 10 years. The Province has also developed
Guidelines and Standards with respect to industrial air emissions, though these are not
binding unless they are included in the Approval. Quantification methodologies are
prescribed in the Approvals, as are reporting requirements. The Air Quality Regulations
also indicate reporting requirements for specific scenarios and emission thresholds.
The quantification and reporting information collected is used to determine compliance

with Approvals.
2.2.4 New Brunswick
New Brunswick has a Clean Air Act, which includes the Air Quality Regulation. The
main regulatory instrument for air emissions is the Industrial Approval, which is
authorized under the Clean Air Act. The Air Quality Regulation states that “no person
shall construct, modify or operate or permit the construction, modification or operation of
a source without applying for and obtaining an approval.” Furthermore, the Air Quality
Regulation states that “the construction, modification, or operation of a source” must be
“in accordance with the terms and conditions imposed on the approval issued for that
source.”
There are four classes of Approvals depending on the amount of emissions produced as
well as the type and complexity of the operation or facility. Class 1 facilities are the
largest individual sources of pollution and Class 4 are the smallest. The Approval can be
in effect for up to 5 years and outlines the responsibilities, regulations, and emission
limits for each source. The role of the Approval is to itemize every requirement in a
legally binding format, including any applicable federal reporting. The main objective
then is to define emission limits (in tonnes/year), including in-stack emission limits, and
contributions to ambient air quality. Monthly site specific reporting is required for
compliance.
The emissions reports required by the Approvals go to the Approval Engineer for
compliance assessment and also are sent to the Air Emissions specialist for inclusion in
provincial and federal emissions inventory programs, which are periodically referenced
to assist in policy and program development.
2.2.5 Quebec
The Loi sur la qualité de l'environnement (LQE) is the basis for all regulations and for
the Certificate of Authorization process, which can contain monitoring, reporting, or
record keeping requirements for air emissions. The Règlement sur la qualité de
l'atmosphère (RQA) includes a few number (8) of ambient air quality standards for
conventional air contaminants (eg SO2, NOx, suspended particulates) as well as several
air emission standards.

The pulp and paper sector has its own regulation, Règlement sur les fabriques de pâtes et
papiers (RFPP), which has specific requirements for the pulp and paper industry,
including emission standards, monitoring and reporting requirements.
The Programme de réduction des rejets industriels et l’attestation d’assainissement

(PRRI) is a sector by sector initiative, which is currently being developed. When in place,
the PRRI will establish an "attestation d'assainissement" or operating permit, which will
be valid for 5 years and replace the current Certificates of Authorization. The PRRI will
also contain the requirements for monitoring, quantification and reporting.
In the meantime, the Certificates of Authorization process is used to establish emission

requirements, as well as quantification and reporting requirements. These are contained
not in the Certificate of Authorization itself but in the facility proposal (usually
confidential) which the Certificate of Authorization references. Certificates of
Authorization are valid indefinitely or until the facility undergoes a major process
change.
The Projet de règlement sur l'assainissement de l'atmosphère (PRAA) is a proposed

regulation that would replace the RQA and establish air emission standards for all
industrial sectors, as it is the case for the RQA. It will also establish a much greater
number of ambient air quality standards (more than one hundred) and establish
standardized monitoring and reporting requirements. Key proposed requirements of the
PRAA are as follows:
Records. Including records regarding VOC leak detection and repair and certain
other specific requirements.
Continuous Monitoring:
o COMS and/or PM, O2, and NOX for combustion units
o O2, NOX, CO, NH3 (if required) for combustion turbines
o Measurement or sampling from roof vents
o COMS and/or PM from ovens and chillers
o COMS and/or PM from copper extraction
o SO2 from stack for copper and zinc extraction
Stack Sampling:
o PM at least every 5 years
o Organic solvents at least every 3 years or calculation based on mass balance
o Stationary internal combustion engines at least every 3 years
o Combustion units at least every 3 years for PM and NOX
o Combustion turbines at least every 3 years for NOX, CO and NH3 (if required)
o Electrolysis tanks at least every 3 years or annual sulphur budget
o Anode ovens at least annually for total fluoride
o Ovens and chillers at least annually for PM
o Ovens PM annually and every 3 years for buildings housing ovens
o Catalyst regeneration for petroleum refineries cracking units at least annually for
CO
o Hardening units at least annually for PM
o Copper and Zinc extraction at least annually for PM and mercury

Reporting. Continuous monitoring is not used for compliance purposes. However,

all stack sampling must be reported. In addition:
o Annual report on VOC leak detection and repair
o Electrolysis tanks - records and annual budget for sulphur
o Copper and zinc extraction – notice if limits are exceeded
2.2.6 Montreal
The Province delegates authority over air emissions to the City for the entire island of
Montréal. This delegation covers most aspects of permitting and regulation of air
emissions. The applicable provincial laws are the Loi sur la qualité de l'environnement
(LQE) and the law that created the Communauté Urbaine de Montréal (even though the
Communauté Urbaine de Montréal no longer exists, the air regulation provisions
survive).
The key Montréal bylaw is the Règlement relatif à l’assainissement de l‘air. This bylaw
contains a variety of emission standards as well as requirements for percentage reductions
or maximum concentration limits covering various contaminants (as applicable) in 25
different industrial sectors. The bylaw also establishes the requirement for a permit,
which is cross-referenced to the regulatory requirements, and may also establish other
requirements. There are some reporting requirements in the bylaw itself, but most
requirements are specified in the permits. The permits therefore are the main instruments
for specifying quantification and reporting requirements.
The main purpose of the permits is to verify compliance and to assist in identifying any
source of problems with respect to air quality.
2.2.7 Ontario
Under the Environmental Protection Act, Ontario Regulation 419/05: Air Pollution –
Local Air Quality has been developed to address the impacts of air pollution. The
Regulation sets out emission standards and limits, as well as requirements for
performance testing facilities and general reporting. Specific monitoring and reporting
requirements for each facility for each pollutant are summarized in Certificates of
Approval (CofAs).
There are two other key Regulations with respect to industrial emissions. Ontario
Regulation 194/05: Industry Emissions – Nitrogen Oxides and Sulphur Dioxide
establishes an emissions trading system for industrial facilities. Ontario Regulation
397/01 does the same for electricity generation facilities. Both regulations also specify
monitoring and reporting requirements to be used in balancing emissions with allowances
and credits. Reporting is on an annual basis, by March 31 in the year following the year
in which the emissions occurred.
The primary mechanism however, for regulating quantification and reporting across the
sectors is the Certificate of Approval. The Approvals may set emission standards and
specify monitoring and further reporting requirements for each facility. The
quantification and reporting information collected is used for compliance with the

Certificates of Approval, which are valid indefinitely or until the facility undergoes a
major process change.
2.2.8 Manitoba
Manitoba has the Environment Act, which empowers the Environment Act Licence. The
Environment Act states that “no person shall construct, alter, operate or set into operation
any Class 1, 2, or 3 development unless the person first files a proposal in writing with
the department and obtains a valid and subsisting licence from the director for the
development.” Licenses are valid indefinitely or until the facility undergoes a major
process change.
The Classes of Development Regulation lists which activities require licences. There are
several industrial sector exceptions to the Licence system. Base Metal Smelting falls
under a specific Environment Act Regulation, Inco Limited and Hudson Bay Mining and
Smelting Co., Limited Smelter Complex Regulation 165/88. The Upstream Oil and Gas
sector is regulated under the Oil and Gas Act. Finally, facilities and operations in the
Petroleum Product Terminals and Natural Gas Transmission, Distribution, and Storage
sectors are not licensed.
New facilities applying for a Licence will have to face more stringent emissions
management. Existing facilities generally do not have to meet the same stringent
emissions management because the Province recognizes that retrofit is both expensive
and difficult for the facilities. There are only approximately 6 facilities that require
regular reporting and stack sampling, for the rest, it is at the discretion of the director. In
addition, only a small number of facilities report regularly because most facilities are
small and this would be a costly (and timely) process for them. The quantification and
reporting information collected under the Environment Act is used to determine
compliance with air emission limits.
In addition to regulatory instruments, some facilities have a Memorandum Of

Understanding with the Province to implement Canada-Wide standards. The voluntary
MOU is used to manage releases, but also includes reporting requirements.
2.2.9 Saskatchewan
Saskatchewan regulates air contaminant emissions under the authority of The Clean Air
Act and The Clean Air Regulations. The Clean Air Act/Regulations govern air emissions
and identify emission sources that are required to have permits to operate. The Clean Air
Act states that “no person shall operate an industrial source, an incinerator or fuel-
burning equipment in a manner that affects the emission of air contaminants unless he
holds a valid subsisting permit authorizing him to do so.” A Clean Air Permit is
generally valid for a period of 5 years unless otherwise stated on the operating permit.
The permits identify monitoring, reporting and general requirements, including the type
of ambient monitoring and stack testing required, as well as emission limits for each
pollutant.

An exception to the Clean Air Permit is for the Saskatchewan potash sector, which is not
governed using a Clean Air Permit, but instead by the Potash Refining Air Emissions
Regulations that identify specific quantification and reporting requirements.
The specific air monitoring and reporting information collected under both the permits
and Potash Regulations are to ensure compliance.
Saskatchewan has produced the Air Monitoring Directive, which is intended to ensure
that air monitoring and reporting requirements for each specific industry (outlined in
permits or regulations) are carried out in a consistent manner.
Saskatchewan has approximately 110 permits. Saskatchewan Environment uses Codes of

Practice for smaller facilities and issues permits for the larger, more significant industrial
sources with respect to air contaminant emissions.
2.2.10 Alberta
The Environmental Protection and Enhancement Act states that “no person shall
knowingly commence or continue any activity that is designated by the regulations as
requiring an approval ... unless that person holds the required approval or registration.”
The Activities Designation Regulations, enabled under the Environmental Protection and
Enhancement Act, provides a list of activities that are regulated through formal means,
such as an Approval or a Code of Practice. Generally, Approvals are used for larger
facilities and smaller facilities are registered under a Code of Practice.
Approvals are issued for 10 years and are the primary mechanism for regulating
monitoring and reporting requirements for each facility. Monitoring information must
also be available upon request for a period of 10 years. When approvals are renewed, the
facility must be able to speak to their performance using the 10 years of summary data as
well as 3 years of raw data. In addition to the Approvals, the Province has developed
guidelines and codes, such as the Alberta Stack Sampling Code, Continuous Emission
Monitoring System (CEMS) Code, Methods Manual for Chemical Analysis of
Atmospheric Pollutants, and the Air Monitoring Directive in order to ensure consistency
in approach and methodology throughout the various industrial sectors and facilities.
Individual Approvals then reference these documents. The quantification and reporting
information collected under the Approvals is used to determine compliance.
2.2.11 British Columbia
The BC Environmental Management Act enables the authorization of permits and

regulations for the regulation of industrial air emissions. The Province is trying to move
away from permits to regulations (especially for smaller operations); however most
authorizations are still in the form of a permit.
Permits, which have no expiry date, describe the requirement to quantify and report
emissions, including authorized sources, required works, specific stack/pollutant limits
and testing and reporting requirements. The permits also specify facility emission caps.

The quantification and reporting information collected under the Permits is used to
determine permit compliance.
New regulations may include reporting requirements and/or refer to Codes of Practice
and Guidelines, which may contain testing and reporting requirements or
recommendations.
2.2.12 Metro Vancouver
Metro Vancouver is the largest regional district in British Columbia and contains about
half the population of the province. Under the BC Environmental Management Act, the
Province delegates authority over air emissions to Metro Vancouver, which allows the
regional district to develop bylaws that prohibit, control, and manage air emissions. The
Air Quality Management Bylaw No. 1082 states that “the District Director may issue a
Permit to allow the discharge of an Air Contaminant subject to requirements for the
protection of the Environment that on reasonable grounds the District Director considers
advisable.” The Bylaw also states that “the Board may, from time to time, establish
Emission Regulations setting out different prohibitions, regulations, conditions,
requirements, exemptions and rates or levels of fees ... for the purpose of prohibiting,
regulating, controlling, or preventing the discharge of Air Contaminants.”
These are the two main instruments: site specific Permits and Emissions Regulations.
Site specific Permits are used for major industrial facilities while the Regulations are
more broad-based and are generally applied to light industrial facilities, such as the
‘Emission Regulation for Gasoline Distribution Terminals’ for the petroleum product
terminals sector.
The Permits indicate sampling and reporting requirements. This information must be
submitted to the District Director by certain dates specified in the Permit. Permit holders
have been using OWNERS 3 for the past few years as a convenient way to report
environmental information to multiple levels of government through a “one-window”
system. However, due to changing needs at both the Metro Vancouver and Environment
Canada levels, continued use of OWNERS to report information required by Metro
Vancouver Permits is under review.
The information reported to Metro Vancouver is used to determine compliance with

permit requirements, to support the emissions inventory, and for the calculation of
emission fees.
2.2.13 Yukon
The Air Emissions Regulations were developed under the Environment Act. The Air
Emissions Regulations state that “no person shall undertake an activity listed in Schedule
1 (Schedule of Activities that Require a Permit) except as authorized by a permit issued
under these regulations.”
3
One Window to National Environmental Reporting System (OWNERS) is an online reporting mechanism to streamline and
simplify environmental reporting requirements. It is used by Environment Canada, provincial, regional, and municipal
governments and the private sector to collect environmental data from industry decreasing the burden of reporting while
improving compliance with regulations.
The Air Emissions Regulations do not have specific monitoring and reporting
requirements, these are specified in the Air Emissions Permits for each facility. The
Permits may also refer to the Canada-wide standards where the facility must address an
overarching air pollutant. The quantification and reporting information collected under
the Air Emissions Permit is to ensure compliance with the terms of the permit.
2.2.14 Northwest Territories
Virtually all major industry in the NWT is located on federal land and regulated by the
federal government, however, air emissions are not currently regulated. This will remain
a federal responsibility until the management of land and water is devolved from the
Government of Canada to the Government of the Northwest Territories.
2.2.15 Nunavut
The only industrial sector identified in Nunavut is electricity. The territorial government
authorizes the operation of electrical generation, which consists of closed system (off-
grid) diesel generators. There are currently no industrial air emission quantification or
reporting requirements, as air emissions are not regulated and air quality is not addressed.
2.3 STATUTORY BASIS FOR QUANTIFICATION AND REPORTING
Exhibit 2.2 identifies the key mechanisms in each jurisdiction.

Exhibit 2.2: Permitting and Regulatory Mechanisms in Canada
Jurisdiction Primary Additional Mechanisms

Mechanisms
NL Certificate of Provision for air quality management zones in Air Pollution Control
Approval Regulation
PE Permit to
Operate
NS Approval to Emission Caps defined in Regulations for Electricity Sector and large
Operate SO2 emitters
NB Approval to
Operate
QC Certificate of Regulation respecting the quality of the atmosphere (Règlement sur la
Authorization qualité de l’atmosphère)
Programme de réduction des rejets industriels et l’attestation
d’assainissement (PRRI)
Regulation Respecting Pulp and Paper Mills (Règlement sur les
fabriques de pâtes et papiers)
Guideline for criteria for air quality
Montreal Permit Municipal bylaw - Règlement relatif à l’assainissement de l‘air
ON Certificate of Guidelines (e.g. Guideline for the Implementation of Canada-wide
Approval Standards for Emissions of Mercury and of Dioxins and Furans and
Monitoring and Reporting Requirements for Municipal Waste
Incinerators, Biomedical Waste Incinerators, Sewage Sludge
Incinerators, Hazardous Waste Incinerators, Steel Manufacturing
Electric Arc Furnaces, Iron Sintering Plants)
Emission Trading Regulation 397/01 (Electricity Generation)
Emission Trading Regulation 194/05 (Industrial Facilities)
MB Environmental Oil and Gas Act
Licence Incinerators Regulation
Limited Smelter Complex Regulation 165/88
MOU for Canada-wide standards
SK Clean Air Code of Practice for Electricity Generation
Permit The Potash Refining Air Emissions Regulations
Airshed Management
AB Approval Air emissions guidelines and standards
Code of Substance release regulations
Practice Alberta Stack Sampling Code
Alberta CEMs Code (takes precedence over Federal PG7)
Air Monitoring Directive
Airshed Management Zones
BC Permit Codes of Practice and Guidelines
Regulations
Metro Permit
Vancouver Emission
Regulations
YT Air Emissions Municipal bylaws
Permit
Exhibit 2.2 indicates that the main mechanism in Canada for control of industrial air emissions is
some form of facility or emission source permit, approval or license to operate that is issued by
the provincial, territorial, regional or municipal government. In general, the permits, approvals
or licenses specifically identify the types of pollutants that must be reported and the frequency of
reporting for the corresponding facility or emission source. Acceptable methods for
quantification are also often outlined directly within the permit or alternatively outlined in
guidance documents published by the jurisdiction.
The primary mechanisms (i.e., permits, approvals and licenses) are typically used to govern all
the different industrial sectors; however, certain sectors or emission sources may be governed by
separate legislation or by codes of practice that have been developed by the jurisdiction. For
example, the Potash Sector in Saskatchewan is not governed using a Clean Air Permit, instead a
Potash Refining Air Emissions Regulations has been developed that identifies specific
quantification and reporting requirements. Facilities associated with the natural gas transmission
and distribution sector and that may have inter-jurisdictional concern since they cross
jurisdictional boundaries are regulated by the National Energy Board. In a few provinces codes
of practice that regulate specific emission sources pertinent to major industrial facilities are also
in common use and may require specific quantification and reporting requirements. For
example, Alberta has adopted a code of practice for compressor/pumping stations and sweet gas
processing plants associated with the Upstream Oil and Gas sector.
Alberta, British Columbia, Saskatchewan and Newfoundland and Labrador have also been
working to develop an airshed approach to manage air emissions for some regions. Airsheds
refer to a specific region where local groups of stakeholders, including citizens and government,
work together to address air quality concerns. While airshed management does not replace the
traditional permitting of industrial facilities, the approach has already been used extensively to
develop requirements for air emission monitoring and to develop regionally specific air quality
control strategies. In this capacity, airsheds may also establish quantification and reporting
requirements.
2.4 CHARACTERISTICS OF PERMITS, APPROVALS OR LICENSES
In most jurisdictions, permits, approvals and licenses are developed based on site specific
conditions. As a result, an industrial facility in one location may not have the same requirements
as a similar facility in a different location. Site specific conditions that were identified that could
lead to different requirements (including different requirements for quantification and reporting)
included:
Production of different products or use of different industrial processes that could lead to
different levels of air emissions.
Use of different fuel types and quality (e.g. use of coal versus natural gas).
Capacity and size of the facility.
Proximity to sensitive receptors where air pollution is of concern.
The vintage of the facility and also the associated permit.
Different airshed characteristics (e.g. macro and micro weather and mixing patterns) and
existing levels of ambient air pollution around the facility.
Differing air pollution management strategies between regional offices or designated
airshed zones.

2.5 ACCESSIBILITY OF PERMITS AND MONITORING REPORTS
Access to permits and to monitoring reports varies by jurisdiction. In the case of a number of
jurisdictions, the permits, approvals or licenses could only be provided upon formal request and
subject to the Access to Information and Privacy Acts (ATIP). Exhibit 2.3 identifies the
availability of permits.
Exhibit 2.3: Characteristics of Permits, Approvals or Licenses
Availability
Jurisdiction Permit
Permits Air Emission Reports
Conditions
Available upon request (electronic copy) Within permit Possibly available upon request
NL
(through ATIP)
Selected permits available upon request Within permit Not available
PE
(confidentiality issues have been noted)
Available upon request (hard copy only) Within permit Possibly available upon request
NS
(through ATIP)
NB Easily available (online) Within permit Available upon request
Not available (permits do not contain Not available – Available upon request.
quantification and reporting information, Within Inventaire québécois des
rather they simply accept the conditions proposal émissions atmosphériques
of the confidential proposal submitted by (IQÉA).
QC the facility following negotiation with the Regulation respecting
Ministère) mandatory reporting of certain
emissions of contaminants into
the atmosphere (at this moment,
reports not available).
Selected permits available upon request Within permit Unknown
Montreal (traditionally cover individual sources
rather than facilities)
Not available by facility (traditionally Available Unknown
only by source, such that a single large upon request
industrial facility can have hundreds of
ON
individual permits - new facilities may
have a comprehensive permit that
includes all emission sources)
MB Easily available (online) Within permit Available upon request
Available upon request. Provided most of Within permit Unknown
the time by the facility, otherwise by
SK
Ministry of Environment (who in turn
notify the company).
Easily available (online) Within permit Available upon request
(disclosure of information
agreement) directly to the
AB company (must provide any
information generated by
monitoring requirements free of
charge).
BC Available upon request (electronic copy) Within permit Available upon request
Metro Available upon request (electronic copy) Within permit Unknown
Vancouver
YT Available upon request (electronic copy) Within permit Available upon request
NT N/A N/A N/A
NU N/A N/A N/A

2.6 QUANTIFICATION AND REPORTING REQUIREMENTS
Appendix A summarizes the specific quantification and reporting requirements identified in

permits, approvals or licenses in Canada. However, given that these requirements may be site
specific and that some sectors have dozens and possibly hundreds of individual facilities, only a
few permits could be reviewed for each jurisdiction and sector.
All of the combinations of sectors and jurisdictions identified in Exhibit 2.1 are included with the
exception of the following:
Quebec – aluminum; base metal smelting; chemicals manufacturing; electricity; iron,

steel and illmenite smelting; iron ore pellets; lime; petroleum refining; wood products.
As noted in Exhibit 2.3, permit information is not easily available in Québec. Although
the Ministère du Développement durable, de l'Environnement et des Parcs agreed to
summarize the requirements in a few sectors, some had to be omitted in the report, as the
information was not available.
Ontario – natural gas; petroleum product terminals; upstream oil and gas. As noted in
Exhibit 2.3, permit information is not easily available in Ontario. Although the Ministry
of Environment agreed to summarize the requirements in a few sectors, some had to be
omitted in the report, as the information was not supplied.
British Columbia – cement. No permits were available in this sector for BC, however,
two permits were reviewed for cement plants in Metro Vancouver.
Montréal. Appropriate permits could not be provided.

3. CONTEXT AND OVERVIEW OF QUANTIFICATION AND

REPORTING APPROACHES – INTERNATIONAL JURISDICTIONS
For the purposes of this report, we examined regulatory quantification and reporting
requirements in the following jurisdictions:
United States, including Federal requirements and those of New York, Michigan, Texas
and California
Europe, including European Union requirements and those of France, Germany and
Sweden
Australia: the State of New South Wales.
3.1 REGULATORY CONTEXT
All of the jurisdictions reviewed have adopted some form of environmental regulation that
governs air emissions and identifies industrial sectors that are required to have permits, approvals
or licenses to operate. The regulatory context of this legislation for each jurisdiction is reviewed
in the following sub-sections.
3.1.1 United States
The Clean Air Act is the key statute governing industrial air approvals in the U.S.
Minimum requirements are set federally and are generally implemented by the States.
Title I covers, among other things, the review of proposed new industrial sources of air
emissions. Title V covers the issuance of permits, which are issued by states and tribes.
However, if those governments do not carry out the Clean Air Act requirements to the
satisfaction of the US EPA, the EPA can take over issuing the permits. The permit
includes all air pollution requirements that apply to the source, including emissions limits
and monitoring, record keeping, and reporting requirements. It also requires that the
source report its compliance status with respect to permit conditions to the permitting
authority. Title V permits must be renewed every five years.
Title V gives the Environmental Protection Agency (EPA) the authority to prescribe
procedures and methods for determining compliance and for monitoring and analysis of
pollutants. Continuous emissions monitoring need not be required if alternative methods
are available that provide sufficiently reliable and timely information for
determining compliance. Title V also specifies that permits must set forth inspection,
entry, monitoring, compliance certification, and reporting requirements to assure
compliance with the permit terms and conditions.
EPA Regional Offices have oversight responsibilities over State programs, including:
Review of State program submittals and revisions to State programs,

Periodic review of State programs,
Review and comment on draft State permits, and
Review of monitoring or other reports required by the permit.

Standard permit conditions include:
Monitoring. In addition to all regulated monitoring requirements (see below),

periodic monitoring sufficient to yield reliable and representative data. Such
monitoring requirements shall assure use of terms, test methods, units, averaging
periods, and other statistical conventions consistent with the applicable requirement.
Recordkeeping provisions may be sufficient to meet the requirements of this
paragraph. As necessary, requirements concerning the use, maintenance, and, where
appropriate, installation of monitoring equipment or methods.
Record Keeping. Where applicable, permits shall require records of required

monitoring information that include the following: date, place and time of sampling
or measurement; date the analyses were performed; company that performed the
analyses; analytical techniques or methods used; results of analyses; and operating
conditions at the time of sampling or measurement. Records of all required
monitoring data and support information must be retained for at least 5 years.
Reporting. Reports of all required monitoring must be submitted at least every 6

months. Reports shall identify all instances of deviations from permit requirements
and must be certified by a responsible official.
New sources are required to conduct performance tests within 60-180 days after initial
startup of such facility and at such other times as may be required by the EPA. The EPA
has established standard procedures for these tests.
Regulated ongoing monitoring requirements include requirements of specific rules such

as National Emission Standards for Hazardous Air Pollutants (NESHAP) rules, Acid
Rain Program, Clean Air Interstate Rule (CAIR), Clean Air Mercury Rule (CAMR), etc.
A specific rule, termed the Compliance Assurance Monitoring (CAM) Rule focuses on
pollution control equipment. It establishes criteria that must be met to ensure the
monitoring, reporting, and record keeping can provide a reasonable assurance of
compliance with emission limitations and standards and to ensure operators pay the same
level of attention to pollution control measures as to production activities. This includes
the applicable monitoring approach, obligation to complete corrective actions as
indicated by the monitoring results, and how such data are used in the annual compliance
certification. The applicable monitoring approach for any operation or facility depends on
the control technology used to meet the applicable emission limit and includes
monitoring of operational and control device parameters indicative of pollution control
performance and record keeping of work practice and inspection procedures necessary to
assure compliance operation.
Performance standards for testing and monitoring are contained in the Code of Federal
Regulations (CFR). These are organized by source (e.g. boiler, glycol dehydration unit,
compressors, flares, incinerators, gas turbines, storage vessels, etc.).
The Clean Air Act provides that all permits and monitoring reports must be public.
Requests for confidentiality may be made on the grounds of trade secrets but this
possibility does not apply to emissions data.

3.1.2 New York
New York State Department of Environmental Conservation (DEC) Regulations, Chapter

III – Air Resources, Subchapter A: Prevention and Control of Air Contamination and Air
Pollution sets out emission limits and performance standards, which are more stringent
than those of the US EPA, as general requirements as well as for several specific
industrial sectors. They also indicate monitoring and reporting requirements for air
emissions. In addition, each permit identifies the applicable requirements, as well as the
specific monitoring (type, method, frequency) and reporting requirements for specific air
contaminants.
Performance tests may be required and the DEC may also conduct separate or additional
emission tests on behalf of the State. Monitoring, reporting and record keeping
requirements conform to the EPA standards. Emission statements of actual annual
emissions generated from the facility during the previous calendar year are also required.
Emission estimates may be based on a variety of methods, which may be specified in

rules. The methods are generally listed in order of most preferred to least preferred.
These include:
(1) Continuous Emissions Monitoring Systems (CEMS);

(2) Material balance calculations or fuel analysis;
(3) Stack test of emissions, including date of test;
(4) Stack test of emissions from identical or similar emission sources;
(5) Published emission factors;
(6) Modeling, emission estimation software;
(7) Best engineering judgment; and
(8) Manufacturer's guarantee.
Standard EPA test methods are used, except where the DEC has issued a specific method
to be used instead of a Reference Method contained in Federal regulations or where the
DEC determines that one or more alternate methods are also acceptable.
All stationary combustion facilities (excluding gas turbines) with a total maximum heat
input capacity exceeding 250 million Btu per hour are subject to the requirement for
COMS and CEMS for SO2. Large boilers must also have CEMS for NOX. If CEMS is
not required, alternative testing and monitoring means must be provided.
3.1.3 Michigan
Title V Permits are referred to as Renewable Operating Permits. These contain all of the
applicable federal and state rules, as well as monitoring, reporting and record keeping
requirements. Applicants for permits are generally required to conduct performance
tests; those in non-attainment areas must do so annually; and others every three years.
Performance tests consist of a minimum of 3 separate samples of a specific air

contaminant conducted within a 36-hour period. All performance tests are conducted
while the source of air contaminant is operating at maximum routine operating
conditions.
Monitoring, reporting and record keeping requirements conform to the EPA standards.
Periodic monitoring, which is used to determine compliance with emission limits, can
consist of: direct measurement of emitted pollutants; parametric monitoring in
conjunction with a Preventative-maintenance and Malfunction-abatement Plan (PMP); or
another method that is approved by the department. Michigan has developed a periodic
monitoring guide that provides examples of periodic monitoring protocols which may be
used to ensure compliance for criteria pollutant emission limitations.
3.1.4 Texas
The Texas Commission on Environmental Quality (TCEQ) – General Air Quality Rules
provide the authority to require sampling to determine the opacity, rate, composition,
and/or concentration of air emissions. A Title V permit is referred to as a Federal
Operating Permit (FOP).
The TCEQ, Air Permits Division has designed three (3) types of FOPs:
Temporary Operating Permit (TOP). A temporary source is defined as a source
which changes location to another site at least once during any five year period.
General Operating Permit (GOP). A General Operating Permit (GOP) provides a

streamlined application and permitting process for sites that are similar in terms of
operations, emission units, and applicable requirements. Examples include a variety
of oil and gas GOPs whose provisions depend on attainment/non-attainment status.
These contain periodic monitoring requirements and compliance monitoring
requirements in compliance with federal requirements.
Site Operating Permit (SOP). A Site Operating Permit (SOP) is required for any
site that does not qualify for GOP or TOP.
3.1.5 California
Primary responsibility for permitting rests with the local and regional air pollution control
authorities known as Air Pollution Control Districts (APCD) or Air Quality Management
Districts (AQMD).
California air districts, which are authorized to issue permits to stationary sources by the
California Health and Safety Code, were required to develop and submit to the U.S. EPA
operating permit programs by November 15, 1993. Consulting with the California Air
Pollution Control Officers Association (CAPCOA) Title V Task Force, the Air Resources
Board (ARB) developed a model Title V operating permit program and rule. This model
program and rule form the basis for many California district Title V operating permit
programs. Title V operating permits contain the monitoring and related recordkeeping
and reporting requirements.

3.1.6 European Union
In the European Union (EU), the Integrated Pollution Prevention and Control (IPPC)
Directive sets out the main principles for the permitting and control of installations based
on an integrated approach and the application of best available techniques (BAT). The
Directive covers air emissions, as well as liquid effluents, waste, etc.
The IPPC Directive contains elements of flexibility by allowing the licensing authorities,
in determining permit conditions, to take into account the technical characteristics of the
installation; its geographical location; and the local environmental conditions.
The Directive imposes a requirement for industrial activities with a high pollution
potential to have a permit which can only be issued if certain environmental conditions
are met. In particular, it must use all appropriate pollution-prevention measures, namely
the best available techniques (which produce the least waste, use less hazardous
substances, enable the recovery and recycling of substances generated, etc.); prevent all
large-scale pollution; prevent, recycle or dispose of waste in the least polluting way
possible; use energy efficiently; ensure accident prevention and damage limitation; and
return sites to their original state when the activity is over. The permit must contain a
number of specific requirements, in particular including: emission limit values for
polluting substances.
The permit must also contain suitable release monitoring requirements, specifying
measurement methodology and frequency, evaluation procedures and an obligation to
supply the competent authority with data required for checking compliance with the
permit.
Permit applications must be sent to the competent authority of the Member State
concerned, which will then decide whether or not to authorize the activity. It is the
responsibility of Member States to take the necessary measures to ensure that the
operator complies with the conditions of the permit when operating the installation; and
that the operator regularly informs the competent authority of the results of the
monitoring of releases and without delay of any incident or accident significantly
affecting the environment.
A companion Directive, the Large Combustion Plant (LCP) Directive, aims to reduce
emissions of acidifying pollutants, particles, and ozone precursors from large combustion
plants - those whose rated thermal input is equal to or greater than 50 MW.
The Member States have chosen various approaches to implement the IPPC, such as
case-by-case permitting or use of General Binding Rules for industry sectors. Several
Member States (at least 8) have used the possibility laid down in the Directive to set up
general binding rules, generally in the form of legislation, instead of setting certain
requirements in individual permit conditions. In many cases, these rules were in force
prior to the IPPC Directive.
Most Member States have established procedures to check compliance with permit
conditions, generally through on-site inspections. The frequency for such inspections, as
well as the use of “self-monitoring” carried out by the operators or by non-administrative
bodies (e.g. accredited laboratories), vary among Member States. The requirement for
operators to regularly inform the competent authorities of the results of the monitoring of
releases has been introduced in most Member States. Procedures for regular inspections
are still being developed in certain Member States. Countries who make most extensive
use of general binding rules are: Germany, Denmark, France, the Flemish region of
Belgium, and Sweden.
The Directive provides for public access to permits and the results of monitoring of
releases. Exceptions may be made on grounds of trade secrets.
3.1.7 France
The Directive is implemented by means of the "classified installations" legislation.

Sectoral ministerial orders define the general rules and technical conditions to impose on
installations. Responsibility for permitting rests with Departmental (i.e. Regional)
Préfets. The Regional Department of Industry, Research and Environment coordinates
the permitting process. Permits are renewed every ten years.
Monitoring requirements are set out in the relevant sectoral orders, of which there are
many (organized into 17 main sectors, and approximately 160 sub-sectors).
Requirements for monitoring of emissions, including frequency and method, are set out
in the permit. At a minimum, monitoring results are reported monthly.
3.1.8 Germany
The Directive is implemented through the Federal Immission Control Act, which
provides for the issuance of permits for industrial facilities. The central licensing
authorities for each Land (i.e. State) act as the regulatory authorities for pollution control.
Permits are valid indefinitely.
A series of technical laws and guidelines contain detailed requirements for emissions
monitoring. Key guidance is found in the Uniform Federal practice in the monitoring of
emissions and the Manual on Emission Monitoring; however neither of these references
contain sector-specific guidance. The main point source emissions must be continuously
monitored for defined parameters or substances and the monitoring results must be
reported (either in real-time or periodically). Annual reports are to be submitted and
every two years a public report is required. In addition, every three years, facilities must
submit a detailed emissions inventory, detailing all point and fugitive emissions, and
complete mass balances. Smaller emission sources are also subject to measurement
every three years and this must be done by an accredited independent assessment body
for submission to the regulatory authority.
3.1.9 Sweden
The key statute is the Environmental Code. The regulatory authority depends on the type
of activity and may be the Environmental Court, County Administration, or Municipal
Board. For larger facilities, permits are granted by the Court and are administered by
Counties or municipalities.

Facilities must submit annual environmental reports, monitoring reports and other reports
that demonstrate compliance. The regulator conducts on-site inspections and examines
the reports. Facilities are usually inspected once every two years but visits and themed
audits may occur more frequently.
3.1.10 Australia – New South Wales
At a national level, there are ambient air standards but emissions from industrial facilities
are subject to state regulatory programs.
In New South Wales, regulations specify air emission standards that provide a minimum
performance level for all industrial activities. Licensing is used to manage site-specific
environmental issues and is additional to, and independent of, the regulation
requirements. Licence conditions may specify emission limits that are more stringent
than the regulation standards or include emission limits for pollutants not covered by the
regulation.
All relevant standards in the regulation must be complied with, but the regulation itself
does not specify monitoring or sampling frequency. Requirements to monitor or sample
emissions of air impurities, including frequency (such as annual, monthly, continuous,
etc.), may instead be specified in individual licences. A licensee may choose to monitor
and/or sample air impurities beyond what is required by their licence in order to
demonstrate that the regulation standards are being met.
A load-based licensing (LBL) scheme sets limits on the pollutant loads emitted by
holders of environment protection licences, and links licence fees to pollutant emissions.
Licensees are required to submit an annual return form. The annual return is a statement
of compliance with the licence conditions and reports the pollutant loads generated by the
premises.
3.2 QUANTIFICATION AND REPORTING REQUIREMENTS
Appendix B summarizes the specific quantification and reporting requirements identified in

international permits, approvals or licenses. Given the variation of approaches within sectors
(sometimes in the same jurisdictions), it was not possible to provide a systematic listing for all
sectors. Instead, the approach was adapted to provide a relatively broad comparison of the
approaches of many jurisdictions to some common sectors, i.e. electricity generation and cement,
and a small selection of other jurisdictions (one or two) that were thought to be reasonably
representative of a few specific sectors of interest.
The coverage of international jurisdictions and sectors is illustrated in Exhibit 3.1.

Exhibit 3.1: Sectoral Coverage in Review of International Jurisdictions
US Federal
Australia -
California
New York
European
Germany
Michigan
Sweden
France
Union
Texas
NSW
Alumina
Aluminum
Base Metal
Smelting
Cement
Chemicals
Manufacturing
Electricity
Iron, Steel &
Illmenite Smelting
Iron Ore Pellets
Lime
Natural Gas
Transmission,
Distribution &
Storage
Oil Sands
Petroleum Product
Terminals
Petroleum
Refining
Potash
Pulp & Paper
Upstream Oil &
Gas
Wood Products

4. COMPARISON OF CANADIAN APPROACHES TO

QUANTIFICATION AND REPORTING
Summary tables of requirements for the sectors included in the Federal Framework for Industrial
Air Emissions were prepared using information provided by provincial, territorial, regional, and
municipal jurisdictions. The information provided by these jurisdictions typically included
samples of facility specific permits or approvals, stack sampling guidelines, sector specific
regulations and relevant codes of practice.
The air emission reporting requirements summarized are those specifically required by regulators
within each jurisdiction for the purposes of compliance with approvals (e.g. permits, CofAs,
licenses, etc.). Federal reporting requirements such as NPRI, emission inventory requirements
and industry led initiatives are not included.
Each sector table below summarizes the typical requirements that are common to most
jurisdictions (second column) and notable exceptions and variations in specific jurisdictions
(third and fourth columns). Specific quantification and reporting elements for individual air
contaminants are provided where they are applicable. Potential gaps in the quantification and
reporting requirements may occur where only a limited number of permits or approvals could be
reviewed. The only relevant Federal Framework sector that is not presented is the Alumina
sector. Information from Alumina facilities in Quebec was not available for review and there
were no ongoing monitoring or reporting requirements indicated for Alumina facilities located in
Ontario.
The requirements associated with Ontario’s emissions trading regime for electricity generation
facilities (O. Reg. 397/01) are included along with permitting requirements in Exhibit 4.5.
Exhibit 4.17 summarizes quantification and reporting requirements associated with Ontario’s
emissions trading regime for industrial facilities (O. Reg. 194/05).

Exhibit 4.1: Aluminum Summary
The following jurisdictions were reviewed for this sector: Quebec, Ontario, Alberta, and British
Columbia.
EXCEPTIONS AND VARIATIONS

ASPECT TYPICAL REQUIREMENTS APPLICABLE
DESCRIPTION
JURISDICTIONS
Process emissions (e.g., scrubber
Types of stacks, coke calciner kiln)
Emissions
Covered Venting emissions (roof vents of
reduction potrooms)
The approach to quantification of Total fluoride emissions must British Columbia
emissions varies considerably be assessed from the
between different facilities because measurement of particulate
of the different processes involved. and gaseous fluoride
A third party consultant typically emissions. Continuous
conducts the stack testing and sampling of gaseous fluoride is
collected samples are analysed in conducted for dry scrubber
accredited laboratories. stacks and vents from the
potline and manual source
As a minimum source testing of sampling is conducted for
particulate matter (PM) and SO2 is particulate fluoride from the
required from the scrubber stack. potline vents.
Overall Approach
However, in general sampling of Alberta Stack Sampling Code Alberta
to Quantification
gaseous fluoride from roof vents or (which is similar to the US
purifiers are also required (if EPA methods) must be
present). Source testing must be referenced for Alberta
completed in accordance with requirements.
specific requirements that include
US EPA Methods as well as The contaminants quantified Quebec
Environment Canada Methods. include CO, SO2, NOx, VOC,
total particulates, PM10, PM2.5,
PAH’s and total fluorides
based on both measurement
and production based emission
factors.
SOx Manual Stack Testing
(US EPA Method 6C)
NOx Monitoring for NOX is Manual stack test or emissions Quebec
conducted in Quebec but estimated based on production
Specific
not in British Columbia emission factors
Quantification
PM Manual Stack Testing
and Reporting
(US EPA Method 5 or
Elements
EPS 1/RM/8)
VOC Monitoring for VOC is Manual stack test or emissions Quebec
conducted in Quebec but estimated based on production
not in British Columbia emission factors

EXCEPTIONS AND VARIATIONS

ASPECT TYPICAL REQUIREMENTS APPLICABLE
DESCRIPTION
JURISDICTIONS
Other CEMS of gaseous fluoride British Columbia
from dry scrubber and potline
vents.
Manual source sampling of

particulate fluoride from
potline vents for one week
twice per year.
CEMS for Benzene soluble Quebec

materials
CEMS or estimate of PAH’s

from production based
emission factors from stack
and purifier
An emission summary report must The information must include Quebec
be submitted to the governing data pertaining to production,
regulator once per year. The fuels used and raw materials
report must include a summary of relevant to the calculation or
air contaminant emissions and a assessment of the quantities of
summary of any manual or contaminants emitted on an
Overall Approach continuous emission testing that annual basis, and the emission
to Reporting (e.g. was conducted. factors used for the calculation
format, frequency, or assessment.
method) Monthly reports of source testing Assessment includes Alberta
results are also typically required in information related to the plant
the month following the sampling. operation and performance of
air pollution control
equipment.
Annual assessment of total British Columbia
Particulate, fluoride and SO2
SOx Concentration of SO2 Monthly and annual British Columbia
(mg/m3) – from stack assessment of all plant SO2
testing - minimum emissions (kg / tonne of
Specific Reporting
annually aluminum produced)
Elements
PM Concentration (mg/m3) Annual assessment of all British Columbia
– from stack testing - particulate emissions (kg /
minimum annually tonne of aluminum produced)
Other Fluoride emissions (kg/t) from British Columbia
combined gaseous and
particulate fluoride sampling
reported monthly.
Chlorine (kg/day) consumed in
fluxing
The results from CEMS and
Auditing / manual stack surveys are used to
Verification establish compliance with the
Approach emission limits stated in the facility
approval.

Exhibit 4.2: Base Metal Smelting Summary
The following jurisdictions were reviewed for this sector: New Brunswick, Quebec, Ontario,
Manitoba, and British Columbia.
Exceptions And Variations

Aspect Typical Requirements Applicable
Description
Jurisdictions
Process emissions (e.g., main smelter
stack, proportioning plant, sinter plant,
Types of Emissions lead refinery, bulk storage domes)
Covered Combustion emissions (e.g., furnaces)
Fugitive emissions (e.g., fugitive dust
from ore handling operations)
The approach to quantification of No continuous emission Ontario
emissions varies considerably between monitoring requirement for
different facilities. A third party the main smelter stack. Stack
consultant typically conducts the stack testing conducted once every
testing and collected samples are year for Metals, CO2, CO,
analysed in accredited laboratories. Sulphate and SO2 and once
every three years for PM,
As a minimum continuous emission Hydrogen Bromide, NO,
monitoring of particulate and SO2 is NOx, Oxygen,
Overall Approach to
normally conducted for the main smelter Polychlorinated dibenzo
Quantification
stack and detailed stack sampling for an dioxins and furans,
assortment of metals related to the type of Polychlorinated
ore and production is conducted at least dibenzofurans total and
every three years. Polychlorinated dibenzo-p-
dioxins total.
Source testing must be completed in
accordance with specific requirements
that include US EPA Methods as well as
Environment Canada Methods.
SOx CEMS Manual Stack Test (US EPA Ontario, New
Method 8 and 6C) Brunswick
NOx Typically there are no Manual Stack Test (US EPA Ontario
requirements for monitoring of Method 7E)
NOX
PM COMS (laser backscatter COMS Manual stack test (EPS New Brunswick
and opacity meters) 1/RM/8)
VOC Typically there are no Manual stack test (US EPA New Brunswick
requirements for monitoring of Method 0030)
VOC
Specific Other Manual Stack test for Metals Manual Stack Test for metals Ontario
Quantification and (e.g., CD, Zn, Hg, Cu) (US (EPA Method 29)
Reporting Elements EPA Method 29 and 101) Manual Stack Test for
particulate (OSTC Method 5)
Manual Stack test for

hydrogen Bromide (EPA New Brunswick
Method 26) and Ontario
Manual stack test for

Chlorinated dioxins and
furans, chlorobenzenes (EPS
Method 1/RM/2)


Description
Jurisdictions
An emission summary report is generally No specific requirements Manitoba,
submitted to the governing regulator once indicated for an annual Ontario
per year. The report must include a assessment report
summary of air contaminant emissions Reports must include the full Ontario
and a summary of any manual or processed test data and the
continuous emission testing that was raw test data used for
conducted. validation purposes. If test
results indicate a significant
Monthly reports of source testing results change in the overall
are also typically required in the month emissions from a facility;
following the sampling. then, the facility is required
to update its Emissions
Summary and Dispersion
Modelling report.
Annual report includes New Brunswick
Overall Approach to description of process
Reporting (e.g. changes; summary of
format, frequency, abnormal operating
method) conditions; and a summary of
the in-plant and ambient
results provided in the
monthly reports, including
the total release to the
atmosphere of SO2, PM, Pb,
Cd, As, Tl, Cu, Zn, and the
consumption and sulphur
content of fuels utilized in the
preceding calendar year.
Annual report includes a British
discussion of remedial Columbia
measures proposed for those
emissions shown to be at
variance with the allowable
limits.
SOx Hourly average emission rate Annual emissions (tonnes) Ontario
(g/s) and concentration (mg/m3)
NOx There are no typical Annual emissions (tonnes) Ontario
requirements for the reporting of
Specific Reporting NOX
Elements PM Hourly average Emission rate Annual emissions (tonnes) Ontario
(g/s) and concentration (mg/m3)
Other Emission rate (g/s) and Annual emissions of metals New Brunswick
concentration (mg/m3) of metals Pb, Cd, Cu, Zn (tonnes)
released
The results from CEMS and manual stack The facility must conduct a New Brunswick
surveys are used to establish compliance yearly audit of the continuous
Auditing /
with the emission limits stated in the emission monitors to verify
Verification
facility approval. the accuracy of the
Approach
concentrations and mass
discharges.

Exhibit 4.3: Cement Summary
The following jurisdictions were reviewed for this sector: Nova Scotia, Quebec, Ontario,
Alberta, British Columbia, and Metro Vancouver.

Description
Jurisdictions
Process emissions (e.g., clinker
Types of
cooler, grinder, mill stack)
Emissions
Combustion emissions (e.g., kiln,
Covered
calciner)
Quantification and reporting Manual stack testing for NOX, SO2, PM Alberta
requirements vary depending on the and CO is conducted every six months
types of fuels burned. Facilities when the clinker production rate exceeds
burning waste derived fuels (e.g., 100 tonnes per hour. The sampling must
municipal solid waste, waste oils, be conducted to represent the fuels that
tyres) generally conduct stack were predominantly used in the kiln and
sampling of kiln exhaust for precalciner.
polychlorinated dibenzo-p-dioxins
and polychlorinated dibenzofurans Manual stack testing for heavy metals,
,polycyclic aromatic hydrocarbons, PM2.5 and PM10 is conducted once per
and HCl. year. When coal is burned, an analysis
of heavy metals in the coal must also be
For all facilities continuous emission conducted.
monitoring of the kiln exhaust is Besides opacity no additional source Nova Scotia
conducted for opacity and in most testing or CEMS monitoring is required
cases also for NOX and SO2. by approval.
Overall CEMS monitoring of SO2 and NOx not Quebec
Approach to A third party consultant typically required by approval.
Quantification conducts the stack testing and For tire derived fuels in excess of 8% of Metro
collected samples are analysed in total net fuel demand stack testing must Vancouver
accredited laboratories. Source be conducted to determine trace metals.
testing must be completed in Continuous emission monitoring also is
accordance with provincial stack required for CO and opacity.
sampling guides that include US EPA Entire facility must report emissions of Quebec
Methods as well as Environment CO, SO2, NOx, VOC, total particulates,
Canada Methods. PM10, PM2.5), mercury, ammonia, lead
and cadmium. Where stack testing or
CEMs is not used these emissions can be
estimate using any of the following
techniques: emission estimation model;
a calculation that may include the use of
an emission factor published in the
scientific literature or documentation
specific to the facility; mass balance; or
predictive emission monitoring.


Description
Jurisdictions
SOx CEMS (Alberta CEMS Code
and EPS 1/PG/7)
NOx CEMS (Alberta CEMS Code
and EPS 1/PG/7)
PM Typically there are no Manual stack test for PM (US EPA Alberta, Ontario
requirements for monitoring Method 5)
of PM Manual stack test for PM10 (US EPA
Method 201A)
Other Manual stack test for Manual stack test for heavy metals (US Alberta
polychlorinated dibenzo-p- EPA Method 29)
dioxins and polychlorinated
dibenzofurans ,polycyclic Manual stack test for PAHs, Acid Gases, Ontario
Specific aromatic hydrocarbons (EPS Ammonia, Anthracene, Metals,
Quantification Method 1/RM/2) Chlorobenzenes, HCl, Total PM,
and Reporting Chlorophenols, Polychlorinated
Elements biphenyls (PCBs), Polychlorinated
dibenzo dioxins and furans,
Polychlorinated dibenzofurans total,
Polychlorinated dibenzo-p-dioxins total.
Manual stack test for Class I Trace

Metals (Pb, Sb, Cu, Mn, V, Zn), Class II
Trace Metals (As, Cr, Co, Ni, Se, Te)
and Class III Trace Metals (Tl, Cd, Hg).
Quebec
COMS – Opacity (Environment Canada
Standard 1-AP-75-2 or US EPA
40CFR60)


Description
Jurisdictions
In most provinces an emission Stack testing reports must include the Ontario
summary report is submitted to the full processed test data and the raw test
governing regulator once per year. data used for validation purposes. If test
The report must include a summary of results indicate a significant change in
air contaminant emissions, a summary the overall emissions from a facility;
of any manual or continuous emission then, the facility is required to update its
testing that was conducted type and Emissions Summary and Dispersion
amount of fuels burned and amount Modelling report.
and the amount of clinker produced in
the preceding year. Annual reporting of SO2 and NOX
emissions is required by Regulation
Monthly reports of source testing 194/05 (Industry Emissions)
results are also typically required in Annual report includes an overview of Alberta
the month following the sampling. the operation and performance of the air
emissions control and monitoring
equipment; a summary of any readings
from source emission monitoring
Overall (manual stack surveys and continuous
Approach to emission monitoring) that exceeded
Reporting (e.g. approval limits and a discussion of the
format, causes and remedial actions taken and a
frequency, summary of the approval holder’s efforts
method) to minimize and reduce site fugitive
emissions and an update on the schedule
for completing outstanding items.
A monthly report must also be submitted
for facilities with CEMs and electronic
data transfer. Hour by hour data is used
to calculate monthly mass emissions.
A summary reports on CEMS Metro
monitoring submitted every 3 months Vancouver
(SOx, NOx, Opacity, CO, Oxygen,
THC, and flow) tht includes minimum
and maximum values obtained; total
hours operated; number of hourly
averages exceeding applicable permit
limits, hourly data (submitted as an
electronic file), monthly weighted
average; and percentage system and
analyser availability.
The results from CEMS and manual
Auditing /
stack surveys are used to establish
Verification
compliance with the emission limits
Approach
stated in the facility approval.

Exhibit 4.4: Chemical Manufacturing Summary
The following jurisdictions were reviewed for this sector: New Brunswick, Quebec, Ontario,
Manitoba, Saskatchewan, Alberta, British Columbia, Prince Edward Island and Metro
Vancouver.
Exceptions and Variations

Description
Jurisdictions
Process emissions (e.g., material
handling, extruders, dryers, reactors,
process vents)
Combustion emissions (e.g., boilers,

Types of
heaters, turbines, flares)
Emissions
Covered
Venting emissions (e.g., storage tanks,
equipment leaks)
Fugitive emissions (e.g., dust from roads

and piles, silos)
The chemical manufacturing sector covers Requirements vary by Ontario
a broad range of petrochemicals, facility type, most require
inorganic chemicals, polymers, and other only one time testing
Overall Approach
organic and specialty chemicals. As such mandated in the
to Quantification
the approach to quantification will vary Certificate of Approval or
greatly by the type, size and potential otherwise requested by the
impact of the facility. Some specific regulating body.
facilities reviewed have almost no Requirements for a British Columbia
quantification and reporting requirements methanol and ammonia
where as some facilities require production facility include
continuous monitoring as well as annual quarterly stack sampling
stack testing of standard criteria air of NOX, SO2, CO2 and CO
contaminants such as PM, SOx, NOx and from major combustion
CO, as well as air pollutants such as HCl, sources and ammonia
Cl2, vinyl chloride, dioxins and furans and from the purge plant and
ethylene. absorption tower.
Requirements for fertilizer Saskatchewan
A third party consultant typically production include annual
conducts the stack testing and collected stack sampling for NOX,
samples are analysed in accredited CO and PM for ammonia
laboratories. Source testing must be plants, NH3 and
completed in accordance with provincial particulates for urea plants
stack sampling guides that include US and NOX and methane for
EPA Methods as well as Environment nitric acid plants.
Canada Methods. There are no reporting Prince Edward
requirements for chemical Island
manufacturing since there
are no facilities in PEI that
require a Permit to
Operate under the Air
Quality Regulations.


Description
Jurisdictions
Requirements for Alberta
petrochemical plants in
Alberta include manual
stack surveys for HCl and
Cl2 from scrubber stacks
and burner exhausts, NOX
from scrubbers, power
boiler and burner exhausts
and vinyl chloride and
dioxins and furans from
incinerator stacks.
Ethylene glycol plants

must monitor
continuously for ethylene
oxide.
SOx Manual stack test (US EPA CEMs for Sulfuric Acid Alberta
Method 6) Plant - Alberta CEMs
code
Specific
NOx Manual stack test (US EPA CEMs for Nitric Acid Alberta
Quantification
Method 7) Plant - Alberta CEMs
and Reporting
code
Elements
PM Manual stack test (US EPA
Method 5 or EPS Method
1/RM/8)
Other Manual stack test for dioxins and Alberta CEMs code - Alberta
furans (EPS 1/RM/2) CEMS for Vinyl chloride
(US EPA Method 106)
CEMS and manual for
ethylene oxide and NH3
CEMS for Chlorine
In most provinces an emission summary Annual report detailing Metro Vancouver
Overall Approach report is submitted to the governing the types and amounts of
to Reporting (e.g. regulator once per year. The report must principal products
format, frequency, include a summary of air contaminant produced and principal
method) emissions, calculations of emission rates, raw materials used in the
a summary of any manual or continuous preceding calendar year.
emission testing that was conducted type Monthly reports including Alberta
and amount of fuels burned in the results of continuous
preceding year. monitoring; results of any
stack surveys and
Monthly reports of source testing results summary of
are also typically required in the month communications with
following the sampling. enforcement and
monitoring.
Annual report including

fugitive emissions
monitoring plan and
performance of air
pollution control
equipment.


Description
Jurisdictions
Annual report including Saskatchewan
estimates of facility
emissions in tonnes per
year, a current list of
emissions sources and
volume of gas flared and
associated SO2 emissions
released.
The results from CEMS and manual stack
Auditing /
surveys are used to establish compliance
Verification
with the emission limits stated in the
Approach
facility approval.

Exhibit 4.5: Electricity Generation Summary
The following jurisdictions were reviewed for this sector: Newfoundland and Labrador, Prince
Edward Island, Nova Scotia, New Brunswick, Quebec, Ontario, Manitoba, Saskatchewan,
Alberta, British Columbia, Yukon, Northwest Territories, and Metro Vancouver. The
requirements associated with Ontario’s emissions trading regime for electricity generation
facilities (O. Reg. 397/01) are also included.

Description
Jurisdictions
Combustion emissions (e.g., turbines,
combined cycle plants, boilers)
Types of Emissions
Process emissions
Covered
Fugitive emissions (e.g., roads and coal
stock piles)
Quantification and reporting requirements Requires stack sampling Saskatchewan
can vary depending on the types of fuels of SO2, NOX and PM only
Overall Approach
burned. Coal powered plants typically have once every 5 years.
to Quantification
the most stringent requirements.
For coal powered generating units, No on-going stack testing Prince Edward
continuous emission monitoring of exhaust requirements, although the Island
stacks is conducted for SO2 and NOX. government may require
Estimates of the average Hg content based source emission testing of
on a sample analysis of the coal burned NOX, SO2, CO, PM and
must also be reported. Hg upon request.
Plants burning light grade Nova Scotia
For natural gas or fuel oil generating units, oil typically have no stack
continuous emission monitoring is required testing requirements
for NOX. beyond CEM of opacity;
however, they are required
Continuous monitoring for opacity is also to report SO2 emissions
standard for most generating units. Manual based on mass balance.
stack suveys are typically required at least Coal thermal plants
annually for PM, NOX and SO2 for all typically have annual or
generating units. biannual stack testing
requirements, although a
A third party consultant typically conducts few facilities are required
the stack testing and collected samples are to have CEM for SO2 and
analysed in accredited laboratories. Source NOX.
testing must be completed in accordance Requires stack sampling Newfoundland
with provincial stack sampling guides that emission testing only once and Labrador
include US EPA Methods as well as every 4 years for facilities
Environment Canada Methods. that are in compliance


Description
Jurisdictions
Total daily and total Manitoba
monthly mass emissions
of NOx, CO, GHGs (CO2,
N2O and methane), SO2,
total VOCs, and PM.
Emission rate factors (for
parameters not being
continuously monitored)
may be sourced from the
US EPA Document AP-42
or determined as per
Environment Canada's
EPS 1/PG/7, unless
otherwise more
specifically determined
through on-site exhaust
duct sampling data.
An analysis of coal for Alberta
sulphur content and
heating value should be
conducted concurrently
with manual stack
surveying.
Temperature, O2, and flow
rate are required to
calculate mass emissions.
Instack opacity must be
measured.
Alberta is considering a
requirement to install Hg
CEMs (for coal).
Emissions Trading (O. Ontario
Reg. 397/01) req.’s:
CEMS in accordance with
MOE publication
“Guideline for the
Installation and Operation
of Continuous Emission
Monitoring Systems
(CEMs) and their Use for
Reporting under the
Provisions of Regulation
O. Reg. 127/01” (April
2001). OR A method
(approved by the Director)
that will provide estimates
of NOx and SO2
emissions at least as
accurate as the estimates
that would be provided by
CEMS.


Description
Jurisdictions
SOx CEMS (EPS 1/PG/7) Permitting requirements: Ontario
Alternate methods
approved by regulator
NOx CEMS (EPS 1/PG/7) Permitting requirements: Ontario
Specific
Alternate methods
Quantification
approved by regulator
and Reporting
Elements PM There are no typical requirements Manual stack test or Manitoba
for the monitoring of PM estimate based on fuel
type emission factors (US
EPA Method 5 or EPS
1/RM/8)
Other COMS for opacity (Environment Manual stack testing for New
Canada Standard 1-AP-75-2 or US metals for coal fired units Brunswick,
EPA 40CFR60) (US EPA Method 29) Ontario
Estimate of Hg emissions (US EPA

Method 29 or mass balance
analysis from coal samples)
In most provinces an emission summary Annual air emissions Alberta

report is submitted to the governing summary report with
regulator once per year. The report must information on
include a summary of air contaminant performance of air
emissions, calculations of emission rates, a pollution abatement
summary of any manual or continuous equipment; thermal
emission testing that was conducted type efficiency of each unit in
and amount of fuels burned in the preceding the plant; and comparison
year. of total annual emissions
per MWh output for the
Overall Approach
Monthly reports of source testing results are corresponding year
to Reporting (e.g.
also typically required in the month between stacks for SO2
format, frequency,
following the sampling. and NOx.
method)
Annual reporting of SO2 Ontario
Monthly CEMS data reports should contain and NOX required by
both processed data and raw data (i.e., one- Regulation 194/05
hour arithmetic average of emission rates). (Industrial Emissions) for
large generators greater
than 25 MW.
Must provide real time Metro
computer access to CEMS Vancouver
data to the District
Director and staff.


Description
Jurisdictions
SOx Emission rate in nanograms/Joule Emission rate in Alberta
or grams/ GJ, kg per hour or t/yr tonnes/MWh
and mg/m3 CEMS performance (EPS New Brunswick
1/PG/7)
reg. 397/01) annual report
includes: amount of SO2
emitted from the facility
in the year; and amount of
SO2 emitted from the
facility in the year because
of reliability must run
contracts (as defined in
the market rules directions
given by the IESO under
the authority of the market
rules).
NOx Emission rate in nanograms/Joule Emission rate in Alberta
Specific Reporting or grams/ GJ, kg per hour or t/yr tonnes/MWh
Elements and mg/m3 CEMS performance (EPS New Brunswick
1/PG/7)
reg. 397/01) annual report
includes: amount of NOx
emitted from the facility
in smog season; amount of
NOx emitted from the
facility in the year, other
than during the smog
season; and amount of
NOx emitted from the
facility in the year because
of reliability must run
contracts (as defined in
the market rules directions
given by the IESO under
the authority of the market
rules).

Exhibit 4.6: Iron and Steel Smelting Summary
The following jurisdictions were reviewed for this sector: Quebec, Ontario, Manitoba,
Saskatchewan, and Alberta.

Description
Jurisdictions
Process emissions (e.g., electric arc furnace,
Types of Emissions material handling, sinter plant)
Covered
Combustion emissions (e.,g., boilers)
The approach to quantification of emissions Requirements for sampling Manitoba
varies considerably between different are not indicated in the
facilities. A third party consultant typically licence to operate but are
conducts the stack testing and collected established through a
samples are analysed in accredited memorandum of
laboratories. understanding with the
province.
As a minimum manual stack sampling of Manual stack testing is Saskatchewan
particulate is conducted annually. required for NOX, Hg,
Approaches to monitoring of other SO2, CO2, H2S and dioxins
Overall Approach pollutants varies extensively between and furans. Plant wide
to Quantification facilities and there are no typical emission estimates based
requirements for the monitoring of SO2, on emission factors is also
NOX or other air contaminants. required for VOCs.
Manual stack testing Alberta
Source testing must be completed in required every two years
accordance with specific requirements that for fluoride, and metals
include US EPA Methods as well as (Cd, Cr, Pb, Hg, Ni, Zn).
Environment Canada Methods. Manual stack testing Ontario
required annually for
Polychlorinated dibenzo
dioxins and furans.
SOx Typically there are no Manual stack testing (US Saskatchewan
requirements for monitoring of EPA Method 6)
SOX
NOx Typically there are no Manual stack testing (US Saskatchewan
requirements for monitoring of EPA Method 7)
NOX
PM Manual stack testing (US EPA Manual stack testing Ontario
Method 5) (OSTC Method 5)
VOC Typically there are no Emission estimate Saskatchewan
Specific requirements for monitoring of (appropriate emission
Quantification VOC factors)
and Reporting Other Manual stack testing for Alberta
Elements metals (US EPA Method
29)
Manual stack testing for Ontario

dioxins and furans (EPS
1/RM/2)
Manual stack testing for

CO2 (US EPA Method
3A)


Description
Jurisdictions
In most provinces an emission summary Annual summary reports Ontario
report is submitted to the governing are not required and stack
regulator once per year. The report must sampling reports are
include a summary of air contaminant submitted normally within
emissions, calculations of emission rates, a 2 months of completing
summary of any manual or continuous source testing. The reports
emission testing that was conducted type must contain raw data and
Overall Approach and amount of fuels burned in the preceding processed data including
to Reporting (e.g. year. an analysis of emission
format, frequency, dispersion. If the manual
method) Monthly reports of source testing results are stack surveys indicate that
also typically required in the month there is a significant
following the sampling. impact on overall
emissions, the facility is
Monthly CEMS data reports should contain required to update its
both processed data and raw data (i.e., one- Emission Summary and
hour arithmetic average of emission rates). Dispersion Modelling
Report.
SOx There are no typical requirements Total emissions in tonnes Saskatchewan,
for reporting of SOX Ontario
(Regulation
194/05)
NOx There are no typical requirements Total emissions in tonnes Saskatchewan,
for reporting of NOX Ontario
(Regulation
194/05)
PM Concentration (micrograms per
Specific Reporting cubic metre), emission flow rate
Elements (cubic metre per second), mass
emission rate (kg/hr pr t/yr)
VOC There are no typical requirements Total emissions in tonnes Saskatchewan
for reporting of VOC
Other Emission rate of dioxins Ontario,
and furans, (micrograms Saskatchewan
per cubic metre), emission
flow rate (cubic metre per
second), mass emission
rate (kg/hr pr t/yr)

Exhibit 4.7: Iron Ore Pellets Summary
The following jurisdictions were reviewed for this sector: Newfoundland and Labrador and
Quebec.
Aspect Typical Requirements
Types of Combustion (e.g., rotary kilns)

Emissions Process (e.g., dryers, material handling)
Covered
Quantification and reporting requirements include:
Manual stack testing for most criteria air contaminants and CO2 and continuous monitoring of
opacity. During manual stack tests sampling of the feed fuel is required % sulphur and some
Overall Approach metals (nickel and vanadium)
to Quantification
A third party consultant typically conducts the stack testing and collected samples are
analysed in accredited laboratories. Source testing must be completed in accordance with
provincial stack sampling guides that include US EPA Methods as well as Environment
Canada Methods.
SOx Manual stack test (US EPA Method 6C)
NOx Manual stack test (US EPA Method 7E)
Specific PM Manual stack test (US EPA Method 5 or 201A or EPS 1/RM/8)
Quantification Other COMS – Opacity (Environment Canada Standard 1-AP-75-2 or US EPA 40CFR60)
and Reporting
Elements Manual stack test for CO2 (US EPA Method 3A)
Sampling of feed fuels for nickel and vanadium

Overall Approach Monthly reports submitted within two months of completion should contain summaries of the
to Reporting (e.g. monitoring and sampling including: record of total fuel consumption of all sources, all field
format, data recorded during testing, instrument calibration information, detailed statistics for each
frequency, sample run, fuel consumption and composition data for each sample run and data confirming
method) the required facility operating conditions
Auditing / All analysis performed must be done by a contracted or in-house accredited laboratory that
Verification submits to an annual inspection by the government regulator.
Approach

Exhibit 4.8: Lime Production Summary
The following jurisdictions were reviewed for this sector: Quebec, Ontario, Manitoba, Alberta,
and Metro Vancouver.

Description
Jurisdictions
Combustion emissions (e.g., rotary or
vertical shaft kilns)
Types of Emissions
Covered
Process emissions (e.g., material handling,
crushing and screening, hydrators)
Quantification and reporting requirements No on-going quantification Ontario
typically include manual stack testing of and reporting requirements
the kiln stack for PM and NOX. If coal is for facilities producing
used as the fuel for the kiln manual stack lime in Ontario are
testing for SOX and inorganic chemicals is specified; however, if there
required, as well as, an analysis of the is a significant change in
sulphur content of the coal. emissions the facility is
Overall Approach
required to update its
to Quantification
A third party consultant typically conducts Emission Summary and
the stack testing and collected samples are Dispersion Modelling
analysed in accredited laboratories. Source Report.
testing must be completed in accordance
with provincial stack sampling guides that
include US EPA Methods as well as
SOx Manual stack test (US EPA
Specific Method 6)
Quantification and NOx Manual stack test (US EPA
Reporting Method 7)
Elements PM Manual stack test (US EPA
Method 5 or EPS Method 1/RM/8)
An annual report of air emission source The annual report must Metro
monitoring results must be prepared and include the types and Vancouver
include: an inventory of emissions on amounts of principal
Overall Approach NOx, SOx, and PM; the number of days products produced and raw
to Reporting (e.g. coal was used as fuel during the year, the materials used.
format, frequency, amount of coal burned, and the fraction of
method) the total kiln heat duty provided by coal;
and a summary of air pollution control
equipment performance and unusual plant
operating conditions.

Exhibit 4.9: Natural Gas Transmission Distribution and Storage Summary
The following jurisdictions were reviewed for this sector: Nova Scotia, New Brunswick, Ontario,
Manitoba, Alberta, British Columbia, and Metro Vancouver.

Description
Jurisdictions
Combustion emissions (e.g.,
compressor engines and turbines)
Process emissions (e.g., dehydrators)

Types of
Emissions Venting emissions (e.g., station
Covered venting, pneumatic devices, storage
tanks)
Fugitive emissions (e.g., equipment

leaks from pumps, valves, flanges)
Emissions from the natural gas Continuous predicted concentration of Metro Vancouver
transmission and distribution sector NOx in the emissions using a
arise primarily from compressor Predictive Emissions Monitoring
stations and equipment leaks. System (PEMS).
Quantification and reporting
requirements vary; however, emissions No on-going quantification and Nova Scotia
Overall
are not normally monitored directly for reporting requirements for a liquid
Approach to
most facilities such as compressor natural gas handling and shipping
Quantification
stations and storage facilities. facility.
Reported emissions for NOX and CO Code of practice for compressor Alberta
are typically estimated using stations and sweet gas processing
manufacturer’s emission factors or plants requires only that
emission factors published in the contraventions of the code of practice
literature. be recorded and reported (see below).
NOx Estimated emissions
(Manufacturer emission
factors)
Other Estimated emissions of CO
(Manufacturer emission
factors)


Description
Jurisdictions
Typically there are no ongoing Annual report summarizing the PEMS Metro Vancouver
reporting requirements. results for NOX in accordance with
approved QA/QC protocol and
conducted by a qualified independent
consultant and amounts of fuel burned
in the preceding calendar year.
Quarterly report summarizing

operations in preceding calendar
quarter, including: hours of operation;
calculated total rate of discharge;
Overall PEMS predicted NOx concentration
Approach to values (hourly average and 720 hour
Reporting (e.g. rolling average maximums,
format, minimums, and means) expressed at
frequency, standard conditions corrected to flue
method) gas oxygen content of 15% dry basis
for each day of operation; any NOx
limit exceedences with explanation;
and daily mass emission rate of NOx
(in kg for each operating day).
Emissions are not reported for Alberta

regulatory compliance and are only
reported to NPRI. The Code of
practice for compressor stations and
sweet gas processing plants requires
only that contraventions of the code of
practice be reported.
NOx There are no typical Measured rate and concentration of Metro Vancouver
requirements for reporting of NOx (g/s and mg/m3).
NOX
Other measured rate and concentration of Metro Vancouver
CO (g/s and mg/m3).

Exhibit 4.10: Oil Sands Summary
The following jurisdictions were reviewed for this sector: Alberta.
Aspect Requirements in Alberta
Combustion Emissions (e.g., coke fired boilers, gas fired boilers, Heaters, steam
generators, gas turbines)
Flaring Emissions (e.g., acid gas flare stack, hydrocarbon flare stacks, hydrogen plant
Types of Emissions
flare stacks)
Covered
Storage Tank Venting Emissions
Process Hydrogen Manufacturing Unit

Quantification and reporting requirements for air emissions from oil sands facilities in
Alberta are conducted in accordance with:
(A) the Alberta Stack Sampling Code, Alberta Environment, 1995,
as amended;
(B) the Methods Manual for Chemical Analysis of Atmospheric Pollutants, Alberta
Environment, 1993, as amended;
(C) the Air Monitoring Directive, Alberta Environment, 1989, as amended; and
(D) the Alberta CEMS Code as amended.
Typical requirements include CEMS of SOX from boilers and heater larger than 264
GJ/hr, sulphur recovery unit incinerator stack (sometimes called thermal oxidation units)
Overall Approach to
and base plant manufacturing units. CEMS of NOX is conducted for gas combustion
Quantification
turbines larger than 25 MW, coker charger heater stacks and hydrogen reformer furnace
stacks.
For boilers using fuels other than natural gas (coke, coal etc) COMS of in-stack opacity is
generally required, as well as manual stack testing of PM emissions.
Fugitive VOC emissions at the plant are monitored in accordance with the Environmental
Code of Practice for the Measurement and Control of Fugitive VOC Emissions from
Equipment Leaks published by the CCME. This guideline requires an estimate of
emissions that employs leak detection monitoring data and/or the use of emission factors
from the Synthetic Organic Chemical Manufacturing Industry specified in the guideline.
SOx CEMS (Alberta CEMS Code – largely based on US EPA and Environment
Canada Methods)
NOx CEMS (Alberta CEMS Code – largely based on US EPA and Environment
Specific
Canada Methods)
Quantification and
PM Manual stack test (US EPA Method 5)
Reporting Elements
VOC Leak detection program (US EPA Method 21)
Other COMS of opacity (Environment Canada Standard 1-AP-75-2 or US EPA
40CFR60 Appendix B)

Aspect Requirements in Alberta

Monthly air emission reports must be compiled on or before the end of the month from
all of the monitoring data that is collected. The following information is provided in the
report:
1. An assessment of the emissions of air contaminants from the plant relative to emission
limits specified in the approval.
2. A summary of the quality control checks and the percent operational time for CEMS.
3. The frequency distribution of all in-stack opacity readings
4. the start time, volume flared, duration and source of all flaring events.
Air emission summary and evaluation reports must be submitted annually and include:
1. an inventory of sulphur dioxide emission from all significant release points
2. an inventory of oxides of nitrogen emission from all significant release points
including a description of the calculations or measurement methods.
Overall Approach to 3. an inventory of THC/VOC emissions including the results of fugitive VOC emissions
Reporting (e.g. monitoring
format, frequency, 4. a summary any readings from source emission monitoring (manual stack surveys and
method) continuous emission monitoring) that exceeded approval limits and a discussion of the
causes and remedial actions taken
5. Report on exceedances of the true vapour pressure in the run-down line of storage
tanks including the date, time duration and source.
In the event that the combined emission rate of oxides of nitrogen or sulphur dioxide
from all sources (including stationary sources and mine mobile equipment) at the plant
exceeds a specific threshold for any calendar year, the approval holder shall submit a
report which shall include an inventory of from all sources at the plant, including a
description of the calculation or measurement methods that were used to quantify the
emissions.
In the event that sulphur dioxide emitted to the atmosphere from flare stacks exceeds a
specific threshold a listing of all flaring events, including the start time, duration, source
(origin plant), the stack that was used, and the tonnes of sulphur dioxide emitted;
SOx Monthly concentration and effluent flow rate (tonnes/day)
NOx Monthly concentration and effluent flow rate (tonnes/day)

Four times per year for main boilers and once per year for gas turbines, coker
Specific Reporting charger heater stack, hydrogen reformer furnace stack, steam generators. Once
Elements per year for boilers and heaters with capacities greater than 105 GJ/hr and less
than 264 GJ/hr
PM Annual emissions (kg/yr)
VOC Annual emissions (kg/yr) from each major equipment type (e.g., valves, pump
seals, compressor seals, flanges and open-ended lines)
Auditing / Verification The results from CEMS and manual stack surveys are used to establish compliance with
Approach the emission limits stated in the facility approval.

Exhibit 4.11: Petroleum Product Terminals Summary
The following jurisdictions were reviewed for this sector: Newfoundland and Labrador, Prince
Edward Island, Nova Scotia, New Brunswick, Ontario, Manitoba, Alberta, British Columbia,
Yukon, Northwest Territories, and Metro Vancouver.

Description
Jurisdictions
Venting emissions (e.g., storage tanks)
Types of
Emissions
Fugitive emissions (e.g., equipment leaks,
Covered
truck loading racks)
Quantification and reporting requirements Test vapour control systems Metro
for petroleum product terminals vary for leaks at least once every Vancouver
significantly between provinces. Most 12 month. In addition,
provinces have no ongoing quantification conduct emission tests on
and reporting requirements for these types of the terminal vapour
facilities. recovery unit (test method
specified in CGSB
In some cases facilities are required to test Standard).
for leaks from equipment and vapour control In some cases where British
Overall
systems but they do not submit reports to the ambient levels of VOCs are Columbia
Approach to
regulatory body. In other cases reporting is a concern, monitoring of
Quantification
required in regards to VOC emissions from discharges from storage
storage tanks in accordance with CCME tanks and truck loading
guidelines. racks may be required.
No specific quantification Yukon,
and reporting requirements Manitoba, New
for petroleum product Brunswick,
terminals Prince Edward
Island and Nova
Scotia
VOC There are no typical requirements Leak detection test (CGSB Metro
for monitoring of VOC Standard or US EPA Vancouver,
Method 21). British
Specific Emission test results on Columbia
Reporting terminal vapour recovery
Elements unit reported to Metro
Vancouver (and in
compliance with a specified
performance standard).
Typically there are no ongoing reporting Annual submission of an Alberta
requirements. annual Air Summary and
Overall
Evaluation report that
Approach to
includes: information
Reporting (e.g.
regarding the performance
format,
of air control equipment
frequency,
and fugitive emissions and
method)
summary of contraventions
reported.

Exhibit 4.12: Petroleum Refining Summary
The following jurisdictions were reviewed for this sector: Newfoundland and Labrador, Nova
Scotia, New Brunswick, Quebec, Ontario, Saskatchewan, Alberta, British Columbia, and Metro
Vancouver.

Description
Jurisdictions
Process emissions (e.g., catalytic cracking
units, sulphur plants, tail gas and acid
regeneration units, hydrocracker, hydrogen
plant, rheniformers, hydrodesulphurizer,
hydrotreaters)
Types of
Emissions Combustion emissions (e.g., heat recovery
Covered steam generators, boilers, heaters)
Flaring emissions
Fugitive emissions (e.g., storage tanks,

equipment leaks)
The Monitoring and reporting strategy Measure or estimate annual Alberta
developed under the National Framework facility emissions of SOx, NOx,
for Petroleum Refinery Emission VOCs, CO, PM10, PM2.5,
Reductions is used extensively by refineries Benzene in accordance with the
to quantify and report emissions. However, recommendations outlined in the
actual requirements vary from province to draft document entitled "National
province. Framework for Petroleum
Refinery Emission, Final, 3 June
Quantification and reporting requirements 2004", as amended.
typically include CEMS for SOX from major Manual stack testing twice per
process emissions sources such as catalytic year for SO2, CO, PM for boiler
cracking units, sulphur plants, tail gas unit, stacks and annually for NOx from
sulphuric acid regeneration units, thermal boiler stacks, cruder heater stack,
incinerators, as well as large boilers or heat and distillate fractionator feed
recovery steam generators. CEMS is also heater stack.
sometimes used for major NOX sources such Instack opacity COMs for main
Overall as from the catalytic cracking unit, tail gas boiler stacks.
Approach to unit and large boilers or heat recovery steam Estimates of daily averages SO2 Nova Scotia
Quantification generators. emissions based on source testing
or approved estimation
Fugitive VOC emissions are measured in techniques. Annual stack testing
accordance with the CCME Code of of PM from Fluid Catalytic
Practice for the Measurement and Control of Cracking Unit.
Fugitive Emissions from Equipment leaks. Manual stack test for particulate New Brunswick
matter metal concentrations from
Flare emissions are typically estimated from the fluid catalytic crack unit and
the rate of discharge (cubic meters per flue gas scrubber.
minute) based on mass balance.
A third party consultant typically conducts

the stack testing and collected samples are
analysed in accredited laboratories. Source
testing must be completed in accordance
with provincial stack sampling guides that
include US EPA Methods.


Description
Jurisdictions
Manual stack measurement of Metro Vancouver
PM from the fluidized catalytic
cracking unit regenerator and the
waste heat boiler every 3 months.
Estimates of hydrocarbon losses

from storage tanks, tank truck and
marine vessel loading,
wastewater treatment and fugitive
emissions from equipment leaks
based emission factors from the
most recent version of the US
EPA Storage Tank Emissions
Calculations.
No CEMS testing is conducted, Newfoundland and
rather manual stack testing of Labrador
SO2, NOX and CO is conducted
for the refinery heaters and
sulphur incinerator stacks and a
representative sample of heaters
and boilers once every two years.
SOx CEMS (US EPA Method 6C) CEMS (Alberta CEMS Code) Alberta
Manual stack test (US EPA
Method 6)
NOx CEMS (US EPA Method 7E)
Specific Method 7)
Quantification PM There are no typical requirements Manual stack test (US EPA Metro Vancouver
and Reporting for the monitoring of PM Method 5)
Elements VOC Leak detection and repair program
(US EPA Method 21 and CCME
Code of Practice)
Other Manual stack test of particulate New Brunswick
metal concentrations (US EPA
Method 29)
Emission summary reports are prepared and Annual summary of emissions of New Brunswick
submitted to the governing regulator once VOC in metric tonnes and
per year. The reports include: a summary benzene in kg from fugitive
of air contaminant emissions; summary of sources, tank farm, fuel
fuel use and sulphur content typically distribution, stacks, spills and
presenting a sulphur mass balance for the wastewater treatment.
facility; information on the total crude
Overall processed and production summary; results Quarterly report the operating Nova Scotia
Approach to of fugitive emissions leak detection and efficiency (% removal) of the
Reporting repair programs; summary of flaring activity sulphur recovery plant.
(e.g. format, and emissions and a summary of any manual Quarterly report detailing the Metro Vancouver
frequency, or continuous emission testing that was average rate of discharge (cubic
method) conducted. metre per min) resulting from
flare pilot operation and from
Monthly or quarterly reports of source flare base load operation.
testing results are also typically required in Detailed record shall be
the month following the sampling. submitted of start-stop dates and
times of any planned flaring
activities, flaring events resulting
in visible smoke (for more than 3


Description
Jurisdictions
minutes) and flaring events which
result in hourly average flare flow
of 50 cubic metres per min or
greater.
Quarterly summary of each of the

measured parameters (SOx, NOx,
opacity) as monitored by the
CEMS for the preceding calendar
quarter. Summary shall include:
total hours of valid data collected;
minimum and maximum hourly
concentrations in mg/cubic metre;
number of hourly average
concentrations exceeding
applicable permit restrictions;
calculated daily emission rates in
kg/day and total tonnes per
quarter (based on stack flow data
from an approved discharge flow
meter or the most recent stack test
flow data where a discharge flow
meter is no available); and
number of days exceeding
applicable kg/day permit
restriction.
Quarterly report detailing the

average percent sulphur recovery
efficiency; estimated tonnes of
SOx discharged for each
shutdown (SRU incinerator
bypass); and total tonnes of
sulphur emitted in the tail gas.
Quarterly report containing:

crude processed (m3, tonnes,
average bbl/operating day); crude
sulphur content (% maximum, %
average, tonnes); product sulphur
content (tonnes); sulphur
recovered (tonnes); and
calculated discharge of sulphur
(tonnes).
SOx Concentration (mg/m3), emission Average daily and 30 day rolling New Brunswick
rates (kg/hr and kg/day) and total average concentrations and
emissions (tonnes) emission rates
Specific NOx Concentration (mg/m3), emission
Reporting rates (kg/hr and kg/day) and total
Elements emissions (tonnes)
PM Concentration (mg/m3), emission
rates (kg/hr and kg/day) and total
emissions (tonnes)


Description
Jurisdictions
The results from CEMS and manual stack
Auditing /
surveys are used to establish compliance
Verification
with the emission limits stated in the facility
Approach
approval.

Exhibit 4.13: Potash Summary
The following jurisdictions were reviewed for this sector: New Brunswick and Saskatchewan.

Description
Jurisdictions
Types of Emissions from the Dryer Stack
Emissions
Covered
Source testing of particulate matter (PM)
from the dryers stack is conducted an annual
Overall
basis. Source testing must be completed in
Approach to
accordance with specific requirements that
Quantification
Specific PM Source Stack Testing (Environment
Quantification Canada Method EPS 1/RM/8 or US
Elements (e.g. EPA Method 201)
continuous
monitoring, stack
surveys,
modelling, etc.)
A report must be submitted to the governing Annual report must New Brunswick
regulator once per year. The report must include fuel
include the unit or process tested, the flow consumption of all
rate of gas emitted from the product drying fuel burning
process and the emission data for PM equipment including
normalized to appropriate standard conditions the fuel type,
and reported in SI units. Emission data must consumption in litres
be reported in both milligrams per cubic and average sulphur
metre (mg/m3) for concentration, and content of each fuel.
kilograms per hour (kg/hr) in mass emission Report appendices
rate. should include raw
data all the raw data
Overall
The annual report should also include a from the source
Approach to
summary of the tests results including type of testing equipment and
Reporting (e.g.
fuel and operating conditions during all tests. sample calculations.
format,
frequency,
If applicable, an
method)
interpretation of the
results should be
provided including a
comparison with
emission data
normally generated
for compliance
purposes and/or a
comparison with
emission limits from
the source’s Air
Quality Approval.


Description
Jurisdictions
An additional report is Saskatchewan
required if the PM
emission limit is
exceeded within 60
days of the
completion of the
emission test. The
report must include
the steps and
procedures planned to
reduce the emissions
and a summary of the
immediate and long-
term environmental
effects of exceeding
the limit.
PM Concentration and emission rate
Specific
(mg / m3 and kg/hr) - Annually
Reporting
Other There are no typical requirements Fuel Use – (litres / yr New Brunswick
Elements
for reporting of fuel use and Sulphur content)
Auditing / Submitted data is reviewed and checked by
Verification government regulators. Generally there is no
Approach formal verification process.

Exhibit 4.14: Pulp and Paper Summary
Scotia, New Brunswick, Quebec, Ontario, Manitoba, Saskatchewan, Alberta, British Columbia,

Description
Jurisdictions
Process emissions (e.g., evaporation and
condensate systems, pulp washing
Types of systems)
Emissions
Covered Combustion emissions (e.g., recovery
furnace / boiler, power boiler, lime kiln)
Emission testing must comply with Annual source testing for Polycyclic Quebec
provincial stack sampling codes that Aromatic Hydrocarbons (PAHs)
typically refer to both US EPA and emitted by the lime kiln and recovery
Overall Environment Canada test methods. furnace and VOCs emitted by the
Approach to recovery furnace are conducted for
Quantification Kraft mills typically use continuous sulphate pulp mills.
monitoring to measure Total Reduced
Sulphur and if applicable chlorine CEMS for SO2, NOX and ClO2 from
dioxide (ClO2) emissions. kraft pulp mills.
For bleached kraft mills, Nova Scotia Nova Scotia
Major combustion emission sources requires twice yearly stack testing of
such as recovery boilers, power boilers PM from recovery boiler, lime kiln,
and lime kilns are typically tested at a smelt dissolving tank and power
minimum every two years for SO2, PM boiler, as well as, TRS from the lime
and NOX. kiln and high level roof vent.
Source stack testing required every Ontario
two years for TRS (US EPA Method
16B)
CEMS of CO for wood fire

combustors
Continuous Emissions monitoring Alberta,
(CEMS) for opacity for main boilers. Newfoundland and
Labrador, New
Brunswick and
Nova Scotia
Kraft Mills - CEMs for TRS, SO2, Alberta
NOx, instack opacity; ClO2 manually.
CTMP Mills – only require stack
monitoring for PM.
If the facility is in compliance with Newfoundland and
the Air Pollution Control Labrador
Regulations, stack emissions testing
of criteria air contaimants (SO2,
NOX, PM and CO) as well as CO2
must be done once every four years.
If the facility is not in compliance
with the regulations then stack
testing must be done every two years.


Description
Jurisdictions
Testing for polychlorinated dibenzo- British Columbia
p-dioxins (PCDD) and
polychlorinated dibenzofurans
(PCDF) is conducted in accordance
with the Canada Wide Standard
where salt laden wood is burned in
boilers.
SOx Source Stack Test - (US CEMS (US EPA Method 6C) Quebec
EPA Method 6C)
NOx Source Stack Test - (US CEMS (US EPA Method 7E) Quebec
EPA Method 7E)
PM Source Stack Test - (US Source Stack Test - (OSTC Method Ontario
EPA Method 5 or 201A) 5)
Specific Environment Canada EPS 1/RM/8 Nova Scotia

Quantification VOC Typically there is no Source Stack Test - (US EPA Quebec
Elements (e.g. requirement for the Method 25)
continuous monitoring of VOC
monitoring, emissions.
stack surveys, Other CEMS for TRS (US EPA Source Stack Test - PCDD / PCDF British Columbia
modelling, etc.) Method 16 or Environment (EPA Method 23 or Environment
Canada EPS 1/RM/6) Canada EPS 1/RM/3)
Ontario
COMS for Opacity (US EPA CEMS of CO for wood fire
Method 203, laser opacity combustors as required by Guideline
meter) A-1: Interim Design and Review
Guidelines for Wood Fired
CEMS for ClO2 Combustors
Monthly reports due within a month of
the monitoring period are typically
required where CEMS is conducted.
These reports must include the
Overall environmental monitoring results and
Approach to the methods used. 1 hr and 24 rolling
Reporting (e.g. averages are typically reported for TRS.
format,
frequency, Annual reports are required that detail
method) the stack emission testing results
conducted as well as estimates of
facility emissions in tonnes per year and
summaries of the calculations and data
used to obtain the emission figures.
Specific SOx Concentration (mg/m3) – List of all fuel-fired sources, New Brunswick
Reporting minimum every two years including the amount burned and %
Elements sulphur of each type.
NOx Concentration (mg/m3) –
minimum every two years
PM concentration and mass
emissions (mg/m3 g/s) –
minimum every two years


Description
Jurisdictions
Other TRS concentration (ppm) – annual inventory data for
continuous measurement or acetaldehyde, acetone, ammonia,
minimum every two years for antimony, arsenic, barium, benzene,
source testing beryllium, cadmium, CO, ClO2,
chlorine, chromium, cobalt, Cu,
cresols, dimethyl disulphide,
dimethyl sulphide, ethylbenzene,
fluorides, formaldehyde, hydrogen
sulphide, Pb, methanol, methyl ethyl
ketone, methyl mercaptan, Hg,
molybdenum, napthalene, Ni,
nitrogen dioxide, phenol, selenium,
sulphuric acid, toluene, vandium, and
zinc (tonnes / yr)
Auditing / Submitted data is reviewed and checked
Verification by government regulators. Generally
Approach there is no formal verification process.

Exhibit 4.15: Upstream Oil and Gas Summary
The following jurisdictions were reviewed for this sector: Ontario, Manitoba, Saskatchewan,
Alberta, Yukon, and Northwest Territories.

Description
Jurisdictions
Combustion emissions (e.g., compressor
engines, pump engines, oil treaters,
heaters, turbines, boilers)
Process emissions (e.g., glycol

Types of dehydrator, sulfur recovery plants)
Emissions Covered
Flaring emissions (e.g., acid gas flare,
emergency flare)

Fugitive emissions (e.g., equipment leaks)
Quantification and reporting requirements Manual Stack tests once Saskatchewan
are identified for emissions from natural every 5 years of sulphur
gas processing plants. Sulphur plant plant incinerator stacks
incinerator stacks are typically monitored for flue gas velocity,
continuously for the flow rate of gas and temperature and mass
SO2 emissions are measured or estimated SO2 concentration.
daily. Manual stack tests for SO2 of the CEMS for SO2 from gas British Columbia
sulphur plant incinerator stack are also processing plants
conducted. Manual Stack tests for Alberta
SO2 twice per year of
Emissions from flaring sources such as sulphur plant incinerator
SO2 and H2S are reported for flaring stacks.
episodes and are typically based on the Most intensive
estimated sulphur content of the gas and monitoring is done at
measurement of the volume of gas flared. sour gas plants. There is
Overall Approach
to Quantification also a hierarchy within
Annual emissions of benzene from glycol the sour gas plants for
dehydrators must also be reported and a monitoring: 1. Sulphur
best management practice produced by the recovery gas plant; 2.
Canadian Association of Petroleum Flaring sour gas plant; 3.
Producers (CAPP) indicates a number of Acid gas incineration
acceptable estimation methods. plant.
1. SO2, flow rate,
A third party consultant typically conducts temperature – report
the stack testing and collected samples are hourly limit and daily
analysed in accredited laboratories. limit, temperature
Source testing must be completed in minimum; 2 manual stack
accordance with provincial stack sampling per year
guides that include US EPA Methods as 2. quantify emissions
well as Environment Canada Methods. 3. CEMs of temperature.


Description
Jurisdictions
SOx CEMS monitoring flow rate of
inlet gas
Method 6)
VOC Through the Energy Alberta
Resources and
Conservation Board
(ERCB) Directive 60 –
Specific
must quantify and control
Quantification
VOCs –methods
and Reporting
suggested in CAPP
Elements
guideline (CH4 and VOC
Emissions from the
Canadian Upstream Oil
and Gas Industry –
Volume 4).
Other Benzene (Engineering
calculations and estimation
methods)
Annual emission summary reports are Monthly reports Saskatchewan
required for natural gas processing plants containing: identification
that include; stack emission testing of the environmental
results, estimates of the facility criteria air monitoring methods used;
contaminant emissions in tonnes per year environmental monitoring
and performance of the air emission results (including units of
control and monitoring equipment. measurement and any
QA/QC failures or invalid
Overall Approach
Summary reports are also required for data identified);
to Reporting (e.g.
flaring activities that include the volume identification of the basis
format, frequency,
of gas flared and tonnes of sulphur (dry or wet weight) on
method)
dioxide released. which the data are
calculated; the data value;
Monthly reports of the hourly and daily the data presented
mass emission rates of SO2 from sulphur numerically in tables and
plant incinerator stacks. graphical format and a
statement of compliance
and/or non-compliance
with requirements.


Description
Jurisdictions
Summary reports of well Yukon
flaring that include:
a) dates, times, and
duration of each flaring
episode; b) measurements
of the volume of gas
flared during each
episode; c) the maximum
flow rate during each
flaring episode; d)
composition of gas
emitted, including the
fraction of H2S; e)
specific exceedences of
the standards identified
(for H2S and SO2) in the
permit; f) summary of all
opacity monitoring
results; and g) copies of
all field notes related to
flaring activities.
SOx Tonnes per year

Specific Reporting
Other Annual inventory of benzene
Elements
emissions tonnes per year

Exhibit 4.16: Wood Products Summary
Scotia, New Brunswick, Quebec, Ontario, Manitoba, Saskatchewan, Alberta, British Columbia,

Description
Jurisdictions
Process emissions (e.g., dryers, baghouses,
Types of
regenerative thermal oxidizer,)
Emissions
Covered
Combustion emissions (e.g., power boilers)
Main exhaust stacks are typically monitored Source testing of Press New Brunswick
using manual stack tests for PM, CO, NOX, Vents for CO, formaldehyde
VOC and formaldehyde. Manual stack tests and VOCs conducted in the
Overall are also commonly conducted for dryer and final year that the Approval
Approach to press hood exhausts are also often monitored is valid for (i.e. year 5).
Quantification using stack tests. Source testing of dryer
exhaust stacks for PM, SO2,
Measurement of other air contaminants of NOX, CO and formaldehyde
concern such as phenol, benzene, every two years.
acetaldehyde, acrolein and methanol are Source testing for oriented Saskatchewan
conducted less frequently. strand board facilities
includes the exhaust stack
from the electrified filter bed
shall be tested once per
calendar year to determine
the following: concentration
(mg/m3) and flow rates
(kg/hr, kg/tonne of solid fuel
fired, kg/ft2 OSB) for
particulates, CO, NOx, total
VOCs, and formaldehyde
Visual monitoring of the British
discharges from baghouse Columbia
system, planer mill chip
cyclone, planer mill grinding
operation, sawdust cyclone,
sawmill filing room,
grinding operations, natural
gas fired heater, lumber dry
kilns, and other
miscellaneous sources to be
carried out by
Environmental Protection
staff. Based on the
monitoring results, source
monitoring and/or ambient
air monitoring may be
required.


Description
Jurisdictions
Manual stack testing for Alberta
main stack of oriented strand
board facilities for PM,
formaldehyde, total VOCs,
CO, NOx and benzene once
per year or every 3 years.
Press hood exhaust stacks
and strand dryer exhaust
stacks once every three years
or every year.
NOx Manual stack test (US EPA Method

7C, 7D or 7E)
PM Manual stack test (US EPA Method
5, 202, 201 or 201A)
VOC Manual stack test (US EPA Method
25A)
Other Manual stack test formaldehyde
(EPA Method 0011)
Annual emission summary reports are Reports over three Metro
required that include as a minimum; the consecutive years (e.g. 2006, Vancouver
amount and type of fuel burned; calculations 2007, 2008) of the measured
and estimates of the annual emission rates of discharge rate and
PM, formaldehyde, NOX, VOC and CO; concentration of
production data. acetaldehyde, acrolein,
formaldehyde, methane,
methanol, and total VOCs in
the emission.
Monthly report containing: Saskatchewan

Overall identification of the
Approach to environmental monitoring
Reporting (e.g. methods used;
format, environmental monitoring
frequency, results (including units of
method) measurement and any
QA/QC failures or invalid
data identified);
identification of the basis
(dry or wet weight) on
which the data are
calculated; the data value;
the data presented
numerically in tables and
graphical format and a
statement of compliance
and/or non-compliance with
requirements.

Exhibit 4.17: Ontario Emissions Trading for Industrial Facilities
Ontario’s emissions trading regime for industrial facilities (O. Reg. 194/05) applies to the
following industrial sectors: Base Metal Smelting; Carbon Black; Cement; Flat Glass; Iron and
Steel; Petroleum; and Pulp and Paper.
Aspect Requirements
The owner must decide on and report to the Director a method (along with the
information used in the application of the method) to monitor or calculate the amount of
NOx and SO2 emitted from the facility in accordance with the methodologies listed in O.
Overall Approach to
Reg. 127/01 (Airborne Contaminant Discharge Monitoring and Reporting), which
Quantification
include: CEMs, PEMs, Source Testing, Mass Balance, Emission Factors, Emission
Estimation Model, and Engineering Calculation. Otherwise, the owner may monitor or
calculate emissions using another method, as determined by the Director.
Any facility in the Cement sector as well as Inco and Falconbridge (Base Metal
Smelting - Sudbury) must ensure that emissions of SO2 from kilns and specific stacks
(as stated in the Regulation – Table 10) are monitored during the year with: a CEMs
SOx installed and operated in accordance with EPS 1/PG/7 (including the design
Specific specifications and performance standards); or by a method (approved by the Director)
Quantification that will provide estimates of SO2 emissions that are at least as accurate as the estimates
Elements that would be provided by a CEMs.
Cement sector - emissions of NOx from any kiln are monitored during the year with: a
CEMs installed and operated in accordance with EPS 1/PG/7; or by a method (approved
NOx
by the Director) that will provide estimates of NOx emissions that are at least as accurate
as the estimates that would be provided by a CEMs.
Submit an Emissions Monitoring Report to the Director by March 31 of each year
summarizing the monitoring data of the previous year, including total amount of NOx or
SO2 emitted during the smog season; and total amount of NOx or SO2 emitted during the
non-smog season.
For the cement sector, Inco and Falconbridge, submit an Emissions Monitoring Report
Overall Approach to to the Director by March 1 of each year summarizing the monitoring data of the previous
Reporting (e.g. format, year, including: name of (or identifier for) each source (set out in the Regulation – Table
frequency, method) 10) from which NOx or SO2 are emitted; amount of NOx or SO2 emitted each month
from each source; total amount of NOx or SO2 emitted during the smog season from
each source; total amount of NOx or SO2 emitted during the non-smog season from each
source; and the total amount of NOx or SO2 emitted during the year from each source.
Information and supporting documentation on which the report is based must be kept for
5 years after the report is submitted.
SOx Annual report includes: amount of SO2 emitted from the facility.
Annual report includes: amount of NOx emitted from the facility in the smog season;
and the amount of NOx emitted from the facility in the non-smog season.
Specific
Reporting If a generation unit produces a useful product (other than electricity), amount of NOx
Elements NOx
reported includes amount determined in accordance with: (A/B)*C where: A = amount
of energy used by the generation unit to produce the useful product; B = total amount of
energy used by the generation unit to produce electricity and other useful products; and
C = total amount of NOx or SO2 emitted from the generation unit.

5. COMPARISON OF INTERNATIONAL APPROACHES TO

QUANTIFICATION AND REPORTING
Summary tables of international requirements for Industrial Air Emissions were prepared using
information gathered for national, state and super-national jurisdictions. The information
available for these jurisdictions typically included third party reports, facility specific permits or
approvals, stack sampling guidelines and sector specific regulations.
The air emission reporting requirements summarized are those specifically required by regulators
within each jurisdiction for the purposes of compliance with approvals (e.g. permits, CofAs,
licenses, etc.). Emission inventory requirements and industry led initiatives are not included.
Each sector table below contrasts the Canadian typical requirements that are common to most
jurisdictions (second column) to the typical requirements in international jurisdictions including
the US, European nations and Australia (third, fourth and fifth columns). Specific quantification
and reporting elements for individual air contaminants are provided where they are applicable.
Gaps in the quantification and reporting requirements occur since only nine of the seventeen
sectors were reviewed in detail and only a limited number of resources and specific facility level
permits or approvals were reviewed. The eight sectors that are covered below are Base Metal
Smelting, Iron and Steel Smelting, Cement, Petroleum Refining, Petroleum Product Terminals,
Chemical Manufacturing, Electricity Generation and Upstream Oil and Gas.
In addition, a comparison of the quantification and reporting requirements of Ontario’s emissions

trading regime for electricity generating facilities (O. Reg. 397/01) with those of the US EPA
(Acid Rain Program, NOx SIP Call) are included along with permitting requirements in Exhibit
5.4. Similarly, a comparison of the quantification and reporting requirements of Ontario's
emissions trading regime for industrial facilities (O. Reg. 194/05) with those of the US EPA are
provided in Exhibit 5.9.

Exhibit 5.1: Base Metal Smelting Summary
The following jurisdictions were reviewed for this sector: France.
Aspect Typical Canadian Requirements European Jurisdictions

Process emissions (e.g., main smelter stack, proportioning plant, sinter plant, lead
refinery, bulk storage domes)
Types of Emissions
Covered Combustion emissions (e.g., furnaces)
Fugitive emissions (e.g., fugitive dust from ore handling operations)

The approach to quantification of emissions varies FRANCE
considerably between different facilities. A third party
consultant typically conducts the stack testing and Quantification requirements
collected samples are analysed in accredited for a lead smelting facility
laboratories. include CEMS and quarterly
manual stack testing of PM.
As a minimum continuous emission monitoring of
Overall Approach to
particulate and SO2 is normally conducted for the main Manual stack testing of the
Quantification
smelter stack and detailed stack sampling for an furnaces is also conducted at
assortment of metals related to the type of ore and least annually for metals (SB,
production is conducted at least every three years. AS, PB, Cr, Co, Cu, MN, Ni,
V), SO2, VOC, dioxins and
Source testing must be completed in accordance with furans, HCl and HF.
specific requirements that include US EPA Methods as
well as Environment Canada Methods.
SOx CEMS Manual stack testing of SO2
PM COMS (laser backscatter COMS and CEMS and manual stack
opacity meters) testing
Specific Quantification VOC Typically there are no requirements for Manual stack testing of global
and Reporting monitoring of VOC and specific VOC
Elements Other Manual Stack test for Metals (e.g., CD, Manual stack testing of metals
Zn, Hg, Cu) (US EPA Method 29 and (SB, AS, PB, Cr, Co, Cu, MN,
101) Ni, V), dioxins and furans,
HCl and HF
An emission summary report is generally submitted to An emission summary report
the governing regulator once per year. The report and a separate public report
must include a summary of air contaminant emissions must be prepared and
and a summary of any manual or continuous emission submitted annually to the
testing that was conducted. regulator.
Monthly reports of source testing results are also Monthly reports of lead
Overall Approach to
typically required in the month following the sampling. emissions, quarterly reporting
Reporting (e.g. format,
of SO2 and VOC emissions
frequency, method)
and annual reporting of
dioxins and furans is required
by the regulator.
Results of CEMS of PM must

be submitted on a quarterly
basis.

Exhibit 5.2: Cement Summary
The following jurisdictions were reviewed for this sector: New York, Michigan, France and
Germany.
European
Aspect Typical Canadian Requirements US Jurisdictions
Jurisdictions
Types of Process emissions (e.g., clinker cooler, grinder, mill stack)
Emissions
Covered Combustion emissions (e.g., kiln, calciner)
Quantification and reporting NEW YORK and MICHIGAN FRANCE and
requirements vary depending on the GERMANY
types of fuels burned. Facilities Quantification and reporting
burning waste derived fuels (e.g., requirements may be limited to Quantification
municipal solid waste, waste oils, CEMS of opacity for kiln or approaches include the
tyres) generally conduct stack clinker cooler stacks. While use of CEMS for
sampling of kiln exhaust for performance testing of air NOX,SO2 and PM from
polychlorinated dibenzo-p-dioxins and contaminants is conducted at the the kiln.
polychlorinated dibenzofurans start-up of the facility periodic
,polycyclic aromatic hydrocarbons, monitoring can consist of either In France a sulphur
and HCl. direct measurement of emitted mass balance may also
Overall pollutants, parametric monitoring be used as long as
Approach to For all facilities continuous emission in conjunction with a preventive periodic stack testing
Quantification monitoring of the kiln exhaust is maintenance plan or another surveys are conducted
conducted for opacity and in most method approved by the regulator. to validate the
cases also for NOX and SO2. calculation and in the
case of NOX stack
A third party consultant typically surveys may also
conducts the stack testing and replace CEMS.
collected samples are analysed in
accredited laboratories. Source testing
must be completed in accordance with
provincial stack sampling guides that
SOx CEMS (Alberta CEMS None Identified CEMS or mass balance
Code) with periodic stack
testing surveys
NOx CEMS (Alberta CEMS None Identified CEMS or stack testing
Code) surveys
PM Typically there are no Monitoring of baghouses is CEMS
requirements for required, although this may consist
monitoring of PM of daily non-certified visible
Specific emissions readings and record of
Quantification pressure drop.
and Reporting Other Manual stack test for None Identified
Elements polychlorinated
dibenzo-p-dioxins and
polychlorinated
dibenzofurans
,polycyclic aromatic
hydrocarbons (EPS
Method 1/RM/2)

Aspect Typical Canadian Requirements US Jurisdictions European Jurisdictions

In most provinces an emission Monthly reports that include Germany requires that
summary report is submitted to the production data and feed rates CEMS data be
governing regulator once per year. must be submitted. submitted
The report must include a summary of electronically and that
air contaminant emissions, a summary Semiannual reports of periodic an annual emissions
of any manual or continuous emission monitoring must be submitted and summary report be
testing that was conducted type and include any emission deviations. prepared. A specific
Overall
amount of fuels burned and amount emissions declaration
Approach to
and the amount of clinker produced in An annual certification of that includes a detailed
Reporting
the preceding year. compliance must also be emission inventory
(e.g. format,
completed using forms provided with all point and
frequency,
Monthly reports of source testing by the regulator. fugitive emissions
method)
results are also typically required in identified is required
the month following the sampling. every three years.
France requires
monthly reports of
manual or continuous
emission testing.

Exhibit 5.3: Chemical Manufacturing Summary
The following jurisdictions were reviewed for this sector: New York and France.
European
Jurisdictions
Process emissions (e.g., material handling, extruders, dryers, reactors, process vents)
Types of Combustion emissions (e.g., boilers, heaters, turbines, flares)

Emissions
Covered Venting emissions (e.g., storage tanks, equipment leaks)
Fugitive emissions (e.g., dust from roads and piles, silos)

The chemical manufacturing sector NEW YORK FRANCE
covers a broad range of petrochemicals,
inorganic chemicals, polymers, and other Quarterly monitoring of Quantification
organic and specialty chemicals. As such pumps, compressors and requirements for an
the approach to quantification will vary pressure relieve valves for organic chemicals
greatly by the type, size and potential leaks is required. plant includes
impact of the facility. Some specific manual stack
facilities reviewed have almost no CEMS for NOX from testing of
quantification and reporting requirements nitric acid production emissions of
where as some facilities require sources and CEMS for hydrocarbons, total
continuous monitoring as well as annual SO2 from sulphuric acid metals, zinc and
stack testing of standard criteria air production sources must VOCs.
Overall Approach
contaminants such as PM, SOx, NOx and be installed on new plants
to Quantification
CO, as well as air pollutants such as HCl, or existing plants greater
Cl2, vinyl chloride, dioxins and furans than 300 tons per day.
and ethylene.
A third party consultant typically

conducts the stack testing and collected
samples are analysed in accredited
laboratories. Source testing must be
completed in accordance with provincial
stack sampling guides that include US
EPA Methods as well as Environment
Canada Methods.
SOx Manual stack test (US EPA Sulphur content of fuel None identified
Method 6)
Specific
NOx Manual stack test (US EPA CEMS None identified
Quantification
Method 7)
and Reporting
PM Manual stack test (US EPA EPA Method 5 None identified
Elements
Method 5 or EPS Method
1/RM/8)
Other Manual stack test for dioxins and Ammonia, Sodium Manual stack
furans (EPS 1/RM/2) hydroxide, hydrogen testing surveys of
peroxide, acetic acid, metals and VOCs
hydrogen chloride,
vanadium oxide,
phosphoric acid, chlorine,
butane, sodium
hypochlorite,
methanesulfenyl chloride,
methyl alcohol as
required.

Typical Canadian Requirements US Jurisdictions European

Aspect
Jurisdictions
In most provinces an emission summary Quarterly reports that Monthly reports of
report is submitted to the governing include emission averages manual emission
regulator once per year. The report must for periods of excess testing of
include a summary of air contaminant emissions of applicable hydrocarbons, total
emissions, calculations of emission rates, emission standards as well metals and zinc
Overall Approach a summary of any manual or continuous as daily product rates and
to Reporting (e.g. emission testing that was conducted type appropriate CEMS data. Annual emission
format, frequency, and amount of fuels burned in the summary report
method) preceding year. that includes total
VOCs.
Monthly reports of source testing results
are also typically required in the month
following the sampling.

Exhibit 5.4: Electricity Generation Summary
The following jurisdictions were reviewed for this sector: New York, Michigan and California, European Union and New South
Wales. A comparison of the quantification and reporting requirements of Ontario’s emissions trading regime (O. Reg. 397/01) with
those of US EPA requirements (Acid Rain Program, NOx SIP Call) is included along with the comparison of permitting requirements.
European Australian
Jurisdictions Jurisdictions
Types of Combustion emissions (e.g., turbines, combined cycle plants, boilers)
Emissions Process emissions
Covered Fugitive emissions (e.g., roads and coal stock piles)
Quantification and reporting NEW YORK, MICHIGAN and EUROPEAN NEW SOUTH
requirements can vary depending on the CALIFORNIA UNION WALES
types of fuels burned. Coal powered
plants typically have the most stringent Performance stack tests for specific CEMS for NOX and CEMS for NOX, SO2
requirements of all types of generating air contaminants annually in non- PM for combustion and PM for coal fired
units. attainment areas and every three years plants with a rated plants.
in attainment areas. thermal input greater
For coal powered generating units, than 100 MW. Manual stack testing
continuous emission monitoring of Compliance source testing of CEMS for SO2 is for chlorine, copper,
exhaust stacks is conducted for SO2 and generating units for PM and SO2. required except for fluorides, several
NOX. Estimates of the average Hg plants burning HAPs, hydrogen
content based on a sample analysis of the CEMS of NOX and CO for each natural gas or chloride and
coal burned must also be reported. turbine or reciprocating engine. biomass, or firing oil sulphuric acid.
Overall
with a known sulphur
Approach to
For natural gas or fuel oil generating content and no
Quantification
units, continuous emission monitoring is desulphurization
required for NOX.
In all other cases,
Continuous monitoring for opacity is manual stack surveys
also standard for most generating units. are required at least
Manual stack suveys are typically every six months..
required at least annually for PM, NOX
and SO2 for all generating units.
A third party consultant typically

conducts the stack testing and collected
samples are analysed in accredited
laboratories. Source testing must be

European Australian
completed in accordance with provincial
stack sampling guides that include US
EPA Methods as well as Environment
Canada Methods.
Ontario Emissions Trading (O. Reg. US EPA – Acid Rain Program

397) 40 CFR 75 requires continuous
CEMS in accordance with the MOE monitoring systems for opacity, SO2,
publication “Guideline for the NOx, flow, CO2, and heat input.
Installation and Operation of Continuous
Emission Monitoring Systems (CEMs) Low-emitting oil-fired and gas fired
and their Use for Reporting under the units may use default emission rates
Provisions of Regulation O. Reg. and records of fuel usage to estimate
127/01” (April 2001). OR A method SO2, NOx, and CO2 emissions.
(approved by the Director) that will
provide estimates of NOx and SO2
emissions at least as accurate as the
estimates that would be provided by
CEMS.
SOx CEMS (EPS 1/PG/7) Sulfur content on monthly basis using CEMS or manual CEMS
ASTM D3246 and stack testing stack surveys
US EPA – Acid Rain Program

CEMS required for SO2. Exceptions
to this include the following:
- Units burning natural gas may

Specific
determine SO2 mass emissions by one
Quantification
of the following methods: measure
Elements
heat input with a gas flow meter and
use a default emission rate; sample
and analyse gas daily for sulfur and
use the volume of gas combusted; or
use a CEMs.
- Units burning oil may monitor SO2

mass emissions by one of the

European Australian
following methods: daily manual oil
sampling and analysis plus oil flow
meter; sampling and analysis of diesel
fuel oil as-delivered plus oil flow
meter; automatic continuous oil
sampling plus oil flow meter; or SO2
and flow CEMs.
- Oil-fired and gas-fired units may use

fuel flow metering and fuel sampling
data to estimate heat input rate and
hourly SO2 emissions.
NOx CEMS (EPS 1/PG/7) CEMS for NOX in accordance with 40 CEMS or manual CEMS
CFR 75 stack surveys
US EPA – Acid Rain Program

Exceptions to CEMS requirement
include gas-fired and oil-fired peaking
units, which may estimate hourly NOx
emissions using site-specific emission
correlations and periodic stack testing
(to verify correlations).
US EPA – NOx SIP Call

Monitor NOx emission rate
(lb/mmBtu) and heat input
(mmBtu/hr) OR NOx concentration
(ppm) and stack flow rate (scfh) to
calculate NOx mass emissions in
accordance with 40 CFR 96 and
Subpart H of 40 CFR 75.
Exceptions include low-emitting oil-

fired and gas fired nonpeaking units,
which may use default emission rates
and records of fuel usage to estimate
NOx emissions.

European Australian
May also use fuel flow monitoring,
NOx and O2 concentration to
determine NOx emission rate for gas
and oil fired peaking units.
PM There are no typical Stack testing (US EPA Methods 1 CEMS or manual CEMS and manual
requirements for the through 5 and 202) stack surveys stack testing (Method
monitoring of PM TM-15)
Other COMS for opacity Mass balance calculation of NH3 Manual stack testing
(Environment Canada emissions. for Chlorine (TM-7 &
Standard 1-AP-75-2 or US TM-8), Copper (TM-
EPA 40CFR60) Stack test for formaldehyde (US EPA 12, TM-13 & TM-
Method 316) 14),
Estimate of Hg emissions (US Fluorides (TM-9),
EPA Method 29 or mass Opacity visible emissions evaluation Hazardous substances
balance analysis from coal (US EPA Method 9) (TM-12, TM-13 &
samples) TM-14), Hydrogen
chloride (TM-7 &
TM-8) and
Sulfuric acid (TM-3)
In most provinces an emission summary Twice yearly reporting of monitoring. Annual emission An annual report
report is submitted to the governing summary report must must be submitted to
regulator once per year. The report Stack testing results submitted to be submitted to the the regulator that
must include a summary of air regulator within 60 days following the regulator. The report includes a statement
contaminant emissions, calculations of last date of the test. must include a of compliance with
emission rates, a summary of any manual summary of SO2, license requirements
or continuous emission testing that was An annual certification of compliance NOX, and PM and a summary of the
Overall
conducted type and amount of fuels and emissions statement must also be emissions and the monitoring conducted
Approach to
burned in the preceding year. completed using forms provided by total amount of and complaints
Reporting (e.g.
the regulator. energy input by fuel issued.
format,
Monthly reports of source testing results type.
frequency,
method)
following the sampling. Reporting of CEMS
and manual stack
Monthly CEMS data reports should survey results must
contain both processed data and raw data be conducted on an
(i.e., one-hour arithmetic average of on-going basis and
emission rates). include information
on measures

European Australian
conducted to verify
data.
Ontario Emissions Trading (O. Reg. US EPA – Acid Rain Program

397) Part 75 requires emissions data to be
Annual report includes: amount of SO2 reported for every hour that a unit is
emitted from the facility in the year; operating. Requirements include:
amount of NOx emitted from the facility Recording and maintaining hourly
in smog season; amount of NOx emitted emissions data, operating data, flow
from the facility in the year, other than data, results of QA tests; Electronic
during the smog season; and amount of Quarterly Reports (emissions, flow,
SO2 and NOx emitted from the facility unit operation, and monitoring
in the year because of reliability must run performance data); and Semiannual or
contracts (as defined in the market rules annual RATA reports (if required).
directions given by the IESO under the
authority of the market rules). In addition to SOx and NOx reporting
requirements, quarterly electronic
report must include: Tons of CO2
emitted during quarter and cumulative
CO2 emissions for calendar year;
Total heat input (mmBtu) for quarter
and cumulative heat input for
calendar year; For units using the fuel
flow to load methodology, report fuel
flow-to-load baseline data and results
of the fuel flow-to-load test each
quarter.
EPA provides a standard electronic

data reporting format that must be
used.
US EPA – NOx SIP Call

Requirements for reporting, include:
Monitoring Plans; Quarterly reports;
and Quality assurance RATA reports
(if requested by permitting authority).
Each Quarterly report must be

European Australian
submitted to the Administrator within
30 days of the end of each calendar
quarter.
Quarterly report includes: Avg. NOx

emission rate during the quarter and
cumulative for the calendar year;
Tons of NOx emitted during quarter,
cumulative tons for the second, third
quarter and year, and cumulative tons
for the ozone season; second and third
quarter cumulative heat input for the
ozone season; and operating hours
during quarter, calendar year, and
ozone season.

Exhibit 5.5: Iron and Steel Smelting Summary
The following jurisdictions were reviewed for this sector: New York, Germany and Sweden.

Process emissions (e.g., electric arc furnace, material handling, sinter plant)
Types of Emissions
Covered
Combustion emissions (e.,g., boilers)
The approach to quantification of NEW YORK GERMANY AND
emissions varies considerably between SWEDEN
different facilities. A third party Manual stack testing
consultant typically conducts the stack of PM emissions CEMS of PM for major
testing and collected samples are must be conducted sources of particulate
analysed in accredited laboratories. using EPA emissions including coke
monitoring methods oven, coke crushing and
As a minimum manual stack sampling and in a manner screening and coke
of particulate is conducted annually. acceptable to the pusher de-dusting unit.
Overall Approach
Approaches to monitoring of other regulator. Sampling
to Quantification
pollutants varies extensively between of the blast furnace In Germany CEMS for
facilities and there are no typical must be conducted NOX, SO2 and CO is
requirements for the monitoring of SO2, during the blast also conducted for the
NOX or other air contaminants. furnace tapping coke oven.
period.
Source testing must be completed in
accordance with specific requirements
that include US EPA Methods as well as
SOx Typically there are no None Identified CEMS
requirements for monitoring of
SOX
NOx Typically there are no None Identified CEMS
Specific requirements for monitoring of
Quantification NOX
and Reporting PM Manual stack testing (US EPA Manual stack testing CEMS
Elements Method 5) (US EPA Method 5)
Other Minimum of 24
consecutive
observations of
opacity emissions.
Marbek Resource Consultants Page 80


In most provinces an emission summary All records and In Germany continuous
report is submitted to the governing summaries required emission monitoring
regulator once per year. The report in connection with data is transmitted daily
must include a summary of air the installation, in electronic format and
contaminant emissions, calculations of maintenance and a specific emissions
emission rates, a summary of any operation methods declaration that includes
manual or continuous emission testing must be retained for a detailed emission
that was conducted type and amount of at least three years. inventory of all point
fuels burned in the preceding year. and fugitive sources is
Overall Approach
required every three
to Reporting (e.g.
Monthly reports of source testing results years.
format, frequency,
method)
following the sampling. In Sweden monthly
monitoring data reports
Monthly CEMS data reports should and an annual emission
contain both processed data and raw summary report is
data (i.e., one-hour arithmetic average submitted to the
of emission rates). regulator. The annual
report includes a
statement of emissions
compliance.

Exhibit 5.6: Petroleum Product Terminals Summary
The following jurisdictions were reviewed for this sector: New York.

Types of Emissions
Covered
Fugitive emissions (e.g., equipment leaks, truck loading racks)
Quantification and reporting requirements for NEW YORK
petroleum product terminals vary significantly
between provinces. Most provinces have no Standard EPA methods acceptable to
ongoing quantification and reporting the regulator for measurement of VOC
requirements for these types of facilities. emissions if the facility is above the
annual potential threshold of 10 tons
Overall Approach to
In some cases facilities are required to test for per year.
Quantification
leaks from equipment and vapour control
systems but they do not submit reports to the
regulatory body. In other cases reporting is
required in regards to VOC emissions from
storage tanks in accordance with CCME
guidelines.
VOC There are no typical requirements for Determination of VOC concentrations
monitoring of VOC of a gas stream at the inlet and outlet
of a control device using either (1)
Method 18, Measurement of Gaseous
Organic Compound Emissions by Gas
Chromatography; (2) Method 25,
Specific Reporting
Determination of Total Gaseous
Elements
Organic Emissions as Carbon; (3)
Method 25A, Determination of Total
Gaseous Organic Concentration Using
a Flame Ionization Analyzer; or (4)
Methods approved in advance by the
regulator
Typically there are no ongoing reporting Maintenance of records for a period of
requirements. five years including: (a) capacities of
Overall Approach to
petroleum liquid storage tanks; (b)
Reporting (e.g.
daily gasoline throughput for gasoline
format, frequency,
bulk plants or loading terminals; and
method)
(d) capacities of volatile organic liquid
storage tanks.

Exhibit 5.7: Petroleum Refining Summary
The following jurisdictions were reviewed for this sector: California and New York.

Process emissions (e.g., catalytic cracking units, sulphur plants, tail gas and acid regeneration
units, hydrocracker, hydrogen plant, rheniformers, hydrodesulphurizer, hydrotreaters)
Types of
Combustion emissions (e.g., heat recovery steam generators, boilers, heaters)
Emissions
Covered
Flaring emissions
Fugitive emissions (e.g., storage tanks, equipment leaks)

The Monitoring and reporting strategy developed Source testing semi-annually for NOX,
under the National Framework for Petroleum CO, hydrogen sulphide, ammonia and
Refinery Emission Reductions is used extensively by VOC emissions or twice every five
refineries to quantify and report emissions. years if four consecutive semi-annual
However, actual requirements vary from province to source tests document that emissions
province. are less than 50% of the standard.
Quantification and reporting requirements typically CEMS of SO2 for Tailgas incinerator
include CEMS for SOX from major process and CEMS for NOX and SO2 on large
emissions sources such as catalytic cracking units, boilers.
sulphur plants, tail gas unit, sulphuric acid
regeneration units, thermal incinerators, as well as Every combustion source installed,
large boilers or heat recovery steam generators. modified or replaced shall be equipped
CEMS is also sometimes used for major NOX with a continuous fuel flow monitor.
sources such as from the catalytic cracking unit, tail
Overall
gas unit and large boilers or heat recovery steam Fugitive VOC emissions are measured
Approach to
generators. in accordance with US EPA guideline
Quantification
“Control of VOC Leaks from
Fugitive VOC emissions are measured in accordance Petroleum Refinery Equipment EPA-
with the CCME Code of Practice for the 450/2-78-036.
Measurement and Control of Fugitive Emissions
from Equipment leaks. Compliance with daily emission caps
shall be based on records of daily fuel
Flare emissions are typically estimated from the rate consumption, data from the NOX, O2
of discharge (cubic meters per minute) based on and SO2 CEMS, and emission factors
mass balance. established from original source tests.
A third party consultant typically conducts the stack

testing and collected samples are analysed in
accredited laboratories. Source testing must be
completed in accordance with provincial stack
sampling guides that include US EPA Methods.


SOx CEMS (US EPA Method 6C) CEMS (US EPA Method 6C)
Manual stack test (US EPA Method 6)
NOx CEMS (US EPA Method 7E) Manual stack test, emission factors and
Manual stack test (US EPA Method 7) CEMS
VOC Leak detection and repair program (US Manual stack test, emission factors and
Specific EPA Method 21 and CCME Code of CEMS
Quantification Practice)
and Reporting Other Manual stack test, emission factors and
Elements CEMS for ammonia
Compliance with H2S and TRS limits

from boilers is inferred from
measurements of refinery fuel gas
supply.
Emission summary reports are prepared and Source test results must be made
submitted to the governing regulator once per year. available to the regulator within 60
The reports include: a summary of air contaminant days.
emissions; summary of fuel use and sulphur content
typically presenting a sulphur mass balance for the At a minimum semi-annual reporting
facility; information on the total crude processed and of monitoring. Instances of non-
production summary; results of fugitive emissions compliance with the permit shall be
Overall
leak detection and repair programs; summary of reported in writing to the regulator
Approach to
flaring activity and emissions and a summary of any within 10 calendar days and followed
Reporting (e.g.
manual or continuous emission testing that was with a report on the probable cause of
format,
conducted. non-compliance and corrective or
frequency,
preventative actions.
method)
Monthly or quarterly reports of source testing results
are also typically required in the month following the Annual compliance certifications must
sampling. be submitted to the regulator and
include daily compliance/non-
compliance for each pollutant and
daily total emissions for each pollutant.

Exhibit 5.8: Upstream Oil and Gas Summary
The following jurisdictions were reviewed for this sector: Texas.

Combustion emissions (e.g., compressor engines, pump engines, oil treaters, heaters,
turbines, boilers)
Process emissions (e.g., glycol dehydrator, sulfur recovery plants)

Types of Emissions
Covered Flaring emissions (e.g., acid gas flare, emergency flare)
Fugitive emissions (e.g., equipment leaks)

Quantification and reporting requirements are TEXAS
identified for emissions from natural gas processing
plants. Sulphur plant incinerator stacks are Specific quantification
typically monitored continuously for the flow rate of requirements apply to each
gas and SO2 emissions are measured or estimated source: vessels, ancillary
daily. Manual stack tests for SO2 of the sulphur equipment, glycol dehydration
plant incinerator stack are also conducted. unit, flares, incinerators, VOC
loading/unloading facilities, etc.
Emissions from flaring sources such as SO2 and H2S
are reported for flaring episodes and are typically Requirements are detailed and
based on the estimated sulphur content of the gas contained in performance
and measurement of the volume of gas flared. specifications from Code of
Federal Regulation 40 CFR 60,
Overall Approach to
Annual emissions of benzene from glycol 40 CFR 63, and Texas
Quantification
dehydrators must also be reported and a best Administrative Code Title 30.
management practice produced by the Canadian
Association of Petroleum Producers (CAPP)
indicates a number of acceptable estimation
methods.
A third party consultant typically conducts the stack

testing and collected samples are analysed in
accredited laboratories. Source testing must be
completed in accordance with provincial stack
sampling guides that include US EPA Methods as
well as Environment Canada Methods.


SOx CEMS monitoring flow rate of inlet gas Suphur Recovery Plant:
Manual stack test (US EPA Method 6) performance testing according
to methods 6, 6A or 6C; CEMS
for exhaust stream of control
devices
Other Benzene (Engineering calculations and Leak detection of VOC

Specific Quantification estimation methods) emissions for ancillary
and Reporting equipment. Performance testing
Elements of flares and vapour combustors
for VOC. CEMS of VOC in the
exhaust stream of control
devices.
Benzene (glycol dehydration)-

measured or modelled
Annual emission summary reports are required for Semi-annual compliance report
natural gas processing plants that include; stack and periodic monitoring report
emission testing results, estimates of the facility including results of any CEMS
criteria air contaminant emissions in tonnes per year evaluations.
and performance of the air emission control and
monitoring equipment. In addition reporting of all start-
Overall Approach to
up, shutdown and malfunction
Summary reports are also required for flaring operations.
frequency, method)
activities that include the volume of gas flared and
tonnes of sulphur dioxide released.
Monthly reports of the hourly and daily mass

emission rates of SO2 from sulphur plant incinerator
stacks.
SOx Tonnes per year
Specific Reporting Other Annual inventory of benzene emissions Estimate of % reduction of HAP
Elements tonnes per year emissions from control devices
once per hour

Exhibit 5.9: Emissions Trading for Industrial Facilities
This table compares the quantification and reporting requirements of Ontario’s emissions trading
regime for industrial facilities (O. Reg. 194/05) with US EPA requirements under the Acid Rain
Program and the NOx SIP Call.
US EPA – NOx SIP Call /

Ontario Regulations
Aspect US EPA – Acid Rain Program NOx Budget Trading
194/05
Program
Base Metal Smelting; All electric generating units over Mainly large electric generating
Carbon Black; Cement; 25 MW that burn fossil fuels and units and industrial boilers.
Regulated
Flat Glass; Iron and Steel; new units under 25 MW that use
Sectors
Petroleum; Pulp and fuel with a sulfur content greater
Paper than .05 percent by weight.
The owner must decide on 40 CFR 75 requires continuous 40 CFR 75 Subpart H and 40
and report to the Director monitoring systems for: opacity, CFR 96
a method (along with the flow, SO2, CO2, NOx, and heat
information used in the input. Part 75 requires an Subpart H of 40 CFR 75 has
application of the method) hourly accounting of the been adopted as the required
to monitor or calculate the emissions from each unit. monitoring methodology for
amount of NOx and SO2 NOx mass emissions and heat
emitted from the facility Part 75 requires the EPA to input under the NOx Budget
in accordance with the certify the monitoring Trading Program.
methodologies listed in O. methodology and monitoring
Reg. 127/01 (Airborne systems for each unit. Ongoing Monitor NOx emission rate
Contaminant Discharge QA/QC procedures are also (lb/mmBtu) and heat input
Monitoring and required to ensure accurate data (mmBtu/hr) OR NOx
Reporting), which collection. concentration (ppm) and stack
Overall include: CEMs, PEMs, flow rate (scfh) to calculate
Approach to Source Testing, Mass All new coal-fired units and NOx mass emissions.
Quantification Balance, Emission existing coal units that serve a
Factors, Emission generator over 25 MW must use Calculate hourly NOx mass
Estimation Model, and CEMs for SO2 and NOx. emissions (lbs) by multiplying
Engineering Calculation. hourly NOx emission rate by
Otherwise, the owner may There are exceptions to the hourly heat input and the hourly
monitor or calculate CEMs requirement, mainly operating time (hr).
emissions using another applying to oil-fired and gas- Calculate quarterly and
method, as determined by fired units. Low-emitting oil- cumulative year-to-date NOx
the Director. fired and gas fired units may use mass emissions and cumulative
default emission rates and NOx mass emissions for the
records of fuel usage to estimate ozone season (tons) by
SO2, NOx, and CO2 emissions. summing the hourly NOx mass
emissions according to the
procedures in Appendix F
(section 8).
Any facility in the CEMS and a flow monitoring N/A
Cement sector as well as system to measure and record
Inco and Falconbridge SO2 concentration (ppm),
Specific
(Base Metal Smelting - volumetric gas flow (scfh), and
Quantif-
Sudbury) must ensure that SO2 mass emissions (lb/hr).
ication SOx
emissions of SO2 from
Elements
kilns and specific stacks Exceptions:
(as stated in the Units burning natural gas may
Regulation – Table 10) determine SO2 mass emissions


Ontario Regulations
194/05
Program
are monitored during the by one of the following methods:
year with: a CEMs measure heat input with a gas
installed and operated in flow meter and use a default
accordance with EPS emission rate; sample and
1/PG/7 (including the analyse gas daily for sulfur and
design specifications and use the volume of gas
performance standards); combusted; or use a CEMs.
OR a method (approved
by the Director) that will Units burning oil may monitor
provide estimates of SO2 SO2 mass emissions by one of
emissions that are at least the following methods: daily
as accurate as the manual oil sampling and analysis
estimates that would be plus oil flow meter; sampling
provided by a CEMs. and analysis of diesel fuel oil as-
delivered plus oil flow meter;
automatic continuous oil
sampling plus oil flow meter; or
SO2 and flow CEMs.
Oil-fired and gas-fired units may

use fuel flow metering and fuel
sampling data to estimate heat
input rate and hourly SO2
emissions.
Cement sector - emissions CEMS (including a NOx Coal fired units – NOx diluent
of NOx from any kiln pollutant concentration monitor CEMS (including a NOx
located are monitored and O2 or CO2 diluent gas pollutant concentration monitor
during the year with: a monitor) to measure and record and O2 or CO2 diluent gas
CEMs installed and NOx concentration (ppm), O2 or monitor) to measure and record
operated in accordance CO2 concentration (%) and NOx NOx emission rate; flow
with EPS 1/PG/7; OR a emission rate (lb/mmBtu). monitoring system and an O2 or
method (approved by the CO2 diluent gas monitor to
Director) that will provide Must account for total NOx measure heat input. OR NOx
estimates of NOx emissions (NO and NO2) by concentration monitoring
emissions that are at least monitoring for both or by system (consisting of a NOx
as accurate as the monitoring for NO only and pollutant concentration
estimates that would be adjusting the emissions data to monitor) to measure NOx
provided by a CEMs. account for NO2. concentration; and a flow
NOx
monitoring system. If heat
Exceptions: input is required, a flow
Gas-fired peaking units and oil- monitoring system and an O2 or
fired peaking units may estimate CO2 diluent gas monitor to
hourly NOx emissions using site- measure heat input.
specific emission correlations
and periodic stack testing (to Gas-fired or oil-fired
verify correlations) or use NOx nonpeaking units – NOx diluent
CEMS. CEMS and equations provided
in Appendix D to determine
hourly heat input. OR NOx
concentration monitoring
system. OR If meet the
requirements of the low mass


Ontario Regulations
194/05
Program
emissions - Low-emitting oil
fired and gas fired units may
use default emission rates and
records of fuel usage to
estimate NOx emissions.
Gas-fired or oil-fired peaking

units – NOx diluent CEMS.
OR NOx concentration
monitoring system. OR Meet
the requirements of nonpeaking
unit monitoring. OR Use
procedures in Appendix D (fuel
flow monitoring) to determine
hourly heat input and procedure
in Appendix E 4 to measure
NOX and O2 concentration to
determine NOX emission rate.
Other units (wood, waste, etc.)

– NOx diluent CEMS. OR
NOx concentration monitoring
system.
Submit an Emissions Part 75 requires emissions data Emissions measurements
Monitoring Report to the to be reported for every hour that recorded and reported are used
Director by March 31 of a unit is operating (including to determine compliance (by
each year summarizing during start-up, shutdown, and unit) with the NOx Budget
the monitoring data of the malfunction) and information to emissions limitation.
previous year, including be kept (electronically or in
total amount of SO2, total some instances hard copy) for a Requirements for record
NOx emitted during the minimum of 3 years. keeping and reporting, include:
smog season; and total Initial certification and
amount of NOx emitted Requirements for record keeping recertification applications;
Overall during the non-smog and reporting, include: Monitoring Plans; Quarterly
Approach to season. Certifications; Monitoring Plans; reports; Other petitions and
Reporting (e.g. Recording and maintaining communications; Quality
format, For cement facilities as hourly emissions data, operating assurance RATA reports (if
frequency, well as Inco and data, flow data, results of QA requested by permitting
method) Falconbridge: By March 1 tests, and other information; authority); and Notifications.
of each year, submit an Electronic Quarterly Reports
annual report to the (emissions, flow, unit operation, All documents, monitoring
Director from an and monitoring performance data, and associated
independent third party data); Semiannual or annual information must be kept on
that sets out the results of RATA reports (if required). site for at least 5 years.
the evaluation conducted
in accordance with EPS In addition to the SOx and NOx Each Quarterly report must be
1/PG/7 (section 6.4). reporting requirements, the submitted to the Administrator
Submit an Emissions quarterly electronic report must within 30 days of the end of
Monitoring Report to the include: Tons of CO2 emitted each calendar quarter.
4
The average NOx emission rate (lb/mmBtu) is determined from: Periodic fuel specific NOx emission rate testing for Boilers
(Method 7E for NOx ; Method 3A for the diluent) and Stationary gas turbines (Method 7E for NOx ; Method 3A for the diluent).


Ontario Regulations
194/05
Program
Director by March 1 of during quarter and cumulative
each year summarizing CO2 emissions for calendar year;
the monitoring data of the Total heat input (mmBtu) for
previous year, including: quarter and cumulative heat
name of (or identifier for) input for calendar year; For units
each source (set out in the using the fuel flow to load
Regulation – Table 10) methodology, report fuel flow-
from which NOx or SO2 to-load baseline data and results
are emitted; amount of of the fuel flow-to-load test each
NOx or SO2 emitted each quarter.
month from each source;
total amount of NOx or EPA uses the reported
SO2 emitted during the information to determine
smog season from each compliance with the emissions
source; total amount of reductions mandated by the
NOx or SO2 emitted Clean Air Act.
during the non-smog
season from each source; EPA provides a standard
and the total amount of electronic data reporting format
NOx or SO2 emitted that must be used and provides
during the year from each monitoring data checking
source. software that can be used to
perform quality control checks
Information and on the data prior to data
supporting documentation submittal.
on which the reports are
based must be kept for 5 Note: The electronic reporting
years after the report is system is changing to an XML
submitted. based format with the first
quarter of 2009. The new
system, Emissions Collection
and Monitoring Plan System
(ECMPS), is designed to be
more streamlined and will be
used for facilities to submit
monitoring plans,
QA/certification tests, and
emissions data for the Acid Rain
and CAIR programs.


Ontario Regulations
194/05
Program
Annual report includes: Quarterly report must include: N/A
amount of SO2 emitted Tons of SO2 emitted during the
SOx
from the facility. quarter and cumulative SO2
emissions for the calendar year.
Annual report includes: This program does not have an Quarterly report includes:
amount of NOx emitted emissions trading component for Average NOx emission rate
from the facility in the NOx, and therefore does not during the quarter and
smog season; and the require NOx mass emissions to cumulative for the calendar
amount of NOx emitted be reported. year; Tons of NOx emitted
from the facility in the during the quarter, cumulative
non-smog season. Average NOx emission rate tons for the second, theird
(lb/mmBtu) during the quarter quarter and year, and
If a generation unit and cumulative NOx emission cumulative tons for the ozone
Specific produces a useful product rate for the calendar year. season; second and third quarter
Reporting (other than electricity), cumulative heat input for the
Elements amount of NOx reported NOx emissions must be reported ozone season; and operating
includes amount for low mass emissions units, hours during quarter, calendar
NOx
determined in accordance where NOx mass emissions and year, and ozone season.
with: (A/B)*C where: A = emission rate are reported to
amount of energy used by demonstrate that the unit
the generation unit to continues to qualify for low
produce the useful mass emissions status on an
product; B = total amount annual basis.
of energy used by the
generation unit to produce
electricity and other
useful products; and C =
total amount of NOx or
SO2 emitted from the
generation unit.

6. ANALYSIS
The information collected from Canadian and international jurisdictions reveals some common
approaches and practices, as well as some interesting differences and contrasts. However, no
objective evidence was found to indicate that any jurisdiction's practices are better at reducing
emissions and/or ensuring compliance, or more efficient in doing so. In particular, the research
did not reveal any program evaluations that would have allowed conclusions about effectiveness,
efficiency or lessons learned, nor did jurisdictions highlight any significant findings or lessons
learned about effectiveness.
Having said that, the contrasts and the similarities are instructive and, in some cases, they point
to an apparent consensus that certain approaches and practices are more suitable. Furthermore,
there are some observations that can be made about the nature of the approaches and practices
that have a bearing on their suitability to the Canadian context.
The following sub-sections highlight some of the more important observations. These include
observations emerging from the sectoral comparisons as well as broader comparisons of
approaches.
6.1 REGULATORY FRAMEWORKS
In all cases that were examined the key vehicle for regulating air emissions from industrial
facilities is some form of permit, license or certificate of authorization. In many cases, these are
combined with some form of emission regulations, but the permitting process and the
compliance monitoring and enforcement process associated with permits are the primary
mechanisms for limiting emissions and for verifying performance. In a few cases, emission
regulations are market-based rather than being prescriptive. These involve some form of
emissions trading and associated requirements for balancing emissions with allowances and
credits. While Alberta has been moving towards developing Codes of Practice for a number of
smaller industrial emission sources, so far, only a few of these codes impact the 17 industrial
sectors considered in this study and none currently offer a replacement to permitting. It is
important to note as well that the Codes of Practice will cover only smaller facilities with a lower
environmental impact and Alberta will continue to use Approvals for the major industrial sectors.
In all cases, the process for issuing permits and ensuring compliance is implemented at a sub-
national level. Often, a national or even a supra-national body (e.g. the European Union) will
establish standards (e.g. ambient air quality standards) or, less frequently, detailed rules
regarding the assignment of emission limits, but the actual permitting is done by states,
provinces, länders, departments, counties, regions, municipalities, etc. Depending on the
constitutional context (i.e. federation or unitary state), senior jurisdictions may have oversight
authority. Oversight by senior jurisdictions is usually the case when permitting is delegated to
counties or municipalities. In the US and EU countries, there is some level of national oversight.
In Australia and Canada (until now), the permitting of air emissions from industrial facilities has
been left to the States/Provinces, with limited national direction/guidance other than the
establishment of ambient air standards. In Canada, the Canada-Wide Standard (CWS) on PM

and ozone mandates the provinces to develop implementation plans, including plans to control
emissions from industrial facilities, and report on progress.
6.2 OVERALL APPROACHES TO QUANTIFICATION AND REPORTING
Industrial sectors and facilities across the country have substantially different quantification and
reporting requirements for air pollutants. The major reason for this variation is that jurisdictions
develop quantification approaches that are suited to the individual characteristics and location of
their facilities. In addition, jurisdictions have also tailored their overall approach to emission
quantification and reporting to match their process for compliance. While we did not
specifically investigate the compliance process of each jurisdiction and each industrial sector, it
is clear from Section 6.1 that this process is not the same for all jurisdictions.
Not all jurisdictions currently require industrial facilities to submit data for compliance purposes
that would allow them to independently verify total facility wide emissions for all of the criteria
air contaminants and air toxics that may be of concern. The review of applicable permits,
approvals and regulations conducted for this study identified Manitoba, Yukon, Nova Scotia,
British Columbia (some sectors), Newfoundland and Labrador (some sectors), Québec and
Ontario as provinces that do not typically collect facility wide emission data for compliance.
Instead, these jurisdictions typically require monitoring from specified sources only. However,
planned changes in reporting requirements in Québec and Ontario are expected to require on-
going facility wide emission reporting.
Most jurisdictions rely heavily on a case by case analysis to set both emission limits and
quantification and reporting requirements. This reflects the important variations in conditions
that may apply (e.g. different industrial process, different fuels, airshed characteristics, etc. – see
Section 2.4). Although this allows jurisdictions flexibility to account for varying conditions, it
creates inconsistencies and inefficiencies. Without centralized guidance, much more reliance is
put on individual permit assessors who, if they have not previously dealt with similar facilities,
may be forced to "reinvent the wheel". Lack of consistency makes it more difficult to
demonstrate fairness and it may mean that monitoring and reporting is not sufficient to
demonstrate compliance. In response some jurisdictions have attempted to develop overall or
sectoral standards or guidelines, specifying, for example the situations that require continuous
emissions monitoring and the requirements associated with manual source performance tests.
However, the scope for variations is greater in some sectors than in others and the opportunity to
standardize is similarly variable. Thus the degree of standardization varies, both by sector and
by jurisdiction. A good example of the variation in the approach to quantification and reporting
is the petroleum refinery sector as highlighted in the three bullets below:
In Alberta there are specific requirements related to measuring or estimating total facility
wide emissions of SOX, NOX, VOC, CO, PM and benzene. In fact, recommendations and
guidance from the CCME National Framework for Petroleum Refinery Emissions have
been adopted, which promotes a one-window approach to harmonizing regulatory
compliance reporting with the NPRI and other reporting programs. As a result, reporting
focuses on the ability to establish compliance with annual facility-wide emission caps and
to provide sufficient information to demonstrate that appropriate and consistent

quantification methods have been used. Alberta’s overall goal is to maintain consistency
within a sector between regions and if possible to be consistent between sectors, at the
very least by unit. They acknowledge that the best approach would be to write the
requirements into a regulation and therefore unilaterally be able to change monitoring
requirements. The provinces of New Brunswick, Newfoundland and Labrador and
Saskatchewan also have similar quantification and reporting requirements that allow
them to determine total annual facility wide emissions. While there may be some minor
differences in the quantification methods used between these provinces the reporting
elements are reasonably consistent.
Metro Vancouver typically has more stringent quantification and reporting requirements
then many jurisdictions because they require consistent and accurate data not just for
regulatory compliance but to calculate direct emission fees. Pollution emissions fees per
tonne of pollutant released are established for PM, NOX, VOC, SO2, TRS and several
hazardous air pollutants from major emission sources that exceed specific thresholds.
For example, Metro Vancouver is the only jurisdiction that requires ongoing
quantification and reporting of NOX for compressor stations in the Natural Gas
Transmission, Distribution and Storage sector.
This can be contrasted to jurisdictions where detailed annual facility-wide emission

summary reports are not required for compliance. In Nova Scotia, reporting requirements
for compliance are limited to providing manual stack test information and background
information such as on the efficiency of removal of the sulphur recovery plant, fuel usage
and flaring activity and there is no requirement to provide an annual emission summary
report. Similarly in British Columbia detailed reporting and quantification is only
required for some pollutants (SO2 and TRS), but annual emission estimates for other air
pollutants are not required. In Metro Vancouver, a highly prescriptive approach is
adopted, where detailed source by source quantification and reporting requirements are
provided for over 40 individual emission sources such that there is no ambiguity or
decision to be made on the quantification methods to employ, the data to present or the
data analysis that must be conducted to demonstrate compliance.
In Ontario a risk-based approach to quantification and reporting of air pollutants has been
adopted. While the Standards Development Branch collects and audits source testing
stack surveys from relevant sectors, regulators currently do not typically receive annual
emission summary reports that quantify facility wide emissions for compliance purposes.
Rather compliance is demonstrated through facilities updating their Emission Summary
and Dispersion Modelling (ESDM) reports if there has been a significant process change
at the facility that impacts overall emissions. However, by 2010 or 2013, specific
industry sectors that include all of the relevant sectors considered in this study with the
exception of the cement, wood products and petroleum product terminal sectors will be
required to complete and update their ESDM annually.
In terms of the variability of approaches to quantification and reporting in the different

jurisdictions of Canada, the same conclusions apply to almost all of the industrial sectors with
the exception of the Petroleum Products Terminals sector where typically there are no on-going

quantification and reporting requirements for regulatory compliance. A comparison of

quantification and reporting requirements between Canadian jurisdictions could not be made for
the oil sands sector where activity is limited to only one jurisdiction and the Aluminum and Iron
Ore Pellets sectors where an insufficient number of jurisdictions were reviewed to compare
requirements.
Outside of Canada, national bodies have, in some instances, taken on the standardization
mandate. In many cases, they have established overall standards for quantification and reporting
(e.g. quantification sufficient to establish compliance; quantification sufficient to yield
representative data; use of methods, instruments, etc. consistent with the regulated standard;
reporting every two years). Occasionally, national bodies also specify specific requirements (e.g.
by sector, by substance, by type of emissions source).
In the case of the U.S., this direction comes in the form of detailed rules that cover almost
all scenarios. This includes specific rules for typical regulatory monitoring, additional
rules for compliance monitoring for air pollution control equipment, and other
requirements for periodic monitoring. The rules cover each individual source of air
emissions (e.g. combustion units, vessels, glycol dehydrators, etc.); they cover a variety
of scenarios; and they are lengthy and detailed. States have very little discretion and are
bound to meet EPA rules. In particular, U.S. jurisdictions are unique in that they have set
out very specific quantification and requirements for localized sub-state areas where
ambient emission levels exceed national standards. For example in the electricity
generation sector manual stack testing is required annually in areas of non-attainment of
the standard, but only every three years in attainment areas. U.S. jurisdictions also have
regulations that require facilities to measure certain air pollutants if they exceed a certain
total annual facility emission level. For example, the emission monitoring of VOCs from
petroleum product terminals is required if the annual potential threshold exceeds 10 tons
per year. In some cases U.S. jurisdictions also have daily quantification requirements for
industrial facilities to determine compliance with daily emission caps. This means that
facilities must be able to report daily compliance for each pollutant of concern based on
records of fuel consumption, data from CEMS or emission factors based on original
manual stack testing surveys (whichever is applicable). For example, in the petroleum
refining sector, annual compliance certifications must be prepared and include daily total
emissions for each pollutant of concern.
The E.U. has general standards for quantification and reporting and has specific
requirements for large combustion plants, which are common enough and comparable
enough to be suited to a standardized approach. Germany has detailed standards for
quantification and reporting but these are not sector-specific. France has some sector-
specific rules but these are not comprehensive and much discretion is left to the local
authorities.
In comparison with Canadian jurisdictions, both E.U. and U.S. jurisdictions make greater
use of overall facility production capacity to determine specific reporting and
quantification requirements. For example, the US identifies additional quantification
requirements for SO2 from sulphuric acid chemical manufacturing plants that exceed 300

tons of production per day. In all European Union jurisdictions electricity generation
units greater than 100 MW requires continuous emission monitoring of NOX and PM.
US jurisdictions in some cases have daily quantification requirements to determine

compliance with daily emission caps. This means that facilities must be able to report
daily compliance for each pollutant of concern based on records of fuel consumption,
data from CEMS and emission factors based on original manual stack testing surveys.
For example, in the petroleum refining sector, annual compliance certifications must be
prepared and include daily total emissions for each pollutant of concern.
Federal governments in Australia and Canada provide some quantification method

guidelines but to date have not imposed requirements for regulatory quantification and
reporting (as opposed to requirements for pollution release and transfer reporting).
6.3 EMISSION COVERAGE
Different types of emissions are of concern in different sectors. The need for and opportunity to
accurately measure emissions depends both on the nature of the emissions and the relative
importance of those emissions within and across sectors. Typical coverage in each sector is
described in Section 4 (Canada) and Section 5 (international). Variability in emission coverage
within Canada and between international jurisdictions is highlighted for different sectors in the
bullets below:
In the Aluminum sector minimum requirements for quantification of fluoride emissions

vary between published emissions factors based on production, source testing stack
surveys and the use of continuous emission monitors (CEMS). Where some provinces
require NOX and VOC monitoring of emission sources others do not. British Columbia is
the only jurisdiction that requires quantification and reporting of chlorine emissions
consumed in fluxing.
The chemical sector includes such a broad range of different facilities, processes and
emission sources that it is difficult to evaluate the consistency of quantification and
reporting requirements based on a limited subset of permits. Where some facilities have
almost no quantification and reporting requirements this is related more to the type and
size of the plant and as well as judgement by regulators regarding the risk the facility
poses to public health.
The iron and steel smelting sector in Alberta requires monitoring of fluoride and some
metals (e.g., Cd, Cr, Pb, Ni, Zn) that are not monitored in other Canadian jurisdictions.
Ontario and Saskatchewan also require quantification and reporting of emission rates of
dioxins and furans which are not reported in the jurisdictions of Alberta and Manitoba.
Base metal smelting in European jurisdictions includes the measurement and annual
reporting of dioxins and furans that is not typically reported in Canadian jurisdictions
with the exception of Ontario.

The Oil Sands sector is one of the most emission intensive sectors but is currently active
only in Alberta and therefore there was no basis for a sectoral comparison between
jurisdictions. However, the emission quantification and reporting guidelines can be
compared to similar emissions sources in other sectors. Major emissions sources in the
Oil Sands that include gas turbines, large steam boilers and flaring emissions typically
have the same requirements as those employed in the electricity, refinery and oil and gas
sectors.
The petroleum refining sector in New Brunswick requires the monitoring of particulate
matter metal concentrations which is not covered in other Canadian jurisdictions. Alberta
does require PM monitoring, however PM monitoring is not speciated for metals.
In the petroleum product terminal sector, only Alberta has reporting and quantification
requirements of air pollutants released.
The pulp and paper sector in British Columbia monitors emissions of dioxins and furans
that are not typically monitored in other Canadian jurisdictions.
The wood products sector in Alberta monitors emissions of benzene that are not typically
monitored in other Canadian jurisdictions.
US jurisdictions have a greater emphasis on the emission monitoring of air toxics than is
typically required in Canadian jurisdictions. In particular the chemical manufacturing
sector monitors air pollutants that are not typically monitored in Canada.
6.4 QUANTIFICATION METHODS
A review of permits and approvals across Canada indicates a clear hierarchy of quantification
approaches at least in terms of accuracy and preference (see Exhibit 6.1). Not all quantification
approaches are suitable to all emission sources; however, jurisdictions usually prescribe specific
approaches in permits and approvals and specific quantification methods in guidelines.
However, jurisdictions often allow for deviations that allow quantification approaches that are
comparable or provide improved accuracy.

Exhibit 6.1: Hierarchy of Emission Quantification Approaches
CEMS
Parametric Source Tests
Single Source Tests
Material Balance
Increasing
Cost
Source Category Emission Model
Industry Specific Emission Factors
AP-42 Emission Factors

E D C B A
Engineering Judgement
Increasing Reliability of Estimate
Source:U.S. Environmental Protection Agency. January 1995. Introduction to AP 42, Volume I, Fifth Edition.
Website: http://www.epa.gov/ttn/chief/ap42/
Where standard quantification approaches are defined, it is usually on the basis of the specific
emission source and by pollutant. In a few instances, the requirements/guidelines are specified
or organized by industry sector but in most jurisdictions this is not the case.
Some requirements are fairly common even in the absence of standards. This extends across
facilities within sectors, across sectors and even across jurisdictions. This consistency may be
the result of a number of factors, including: a consensus of professional opinion on the merits of
different approaches; a desire to learn from others and avoid "reinventing the wheel"; a common
recognition of the sources and pollutants that have the greatest impact; industry's own
standardization brought about by globalization; and the increasing affordability of continuous
monitoring instrumentation.
Some jurisdictions have taken advantage of this consistency to develop explicit requirements or
guidelines but, as noted earlier, many (including Canadian jurisdictions) have not. France has
attempted to standardize requirements over time but does not appear to have developed a

comprehensive compilation of those requirements. As noted earlier, the E.U. has standardized
both the performance requirements and the quantification and reporting requirements for large
combustion plants.
Exhibit 6.2 summarizes the most common quantification methodologies that have been identified
for pollutants of concern for each of the industrial sectors based on the Canadian and
international jurisdictional review. The quantification methodologies are broadly organized into
five categories including, CEMS, manual stack testing, PEMS, Mass Balance or Emission
Factors.
Using the hierarchy depicted in Exhibit 6.1, the methodologies that are most reliable are
highlighted in the table using bold italicized font.
Exhibit 6.2: Summary of Quantification Methodologies for Major Sources of Industrial

Pollutants of Concern by Sector

Aluminum Manual Stack Manual Stack Fluorides: (Manual
Testing Testing and Stack Testing, CEMS
COMS for dry scrubber
stacks)
Base Metal CEMS CEMS Mercury (Manual
Smelting Stack Testing)
Cement CEMS CEMS Manual Stack
Testing and
COMS
CEMS
Chemicals Manual Stack Manual Stack Manual Stack Emission Factors NH3: (Manual Stack
Manufacturing Testing Testing Testing Testing)
Manual Stack
CEMS for Testing Fluoride: (Manual
sulphuric acid Stack Testing)
plants
Electricity CEMS Manual Stack Manual Stack Mercury:
Testing Testing and (Manual Stack Testing,
COMS CEMS)
Mass Balance
for Natural CEMS
Gas
CEMS for
coal fired
Iron, Steel & Manual Stack Manual Stack Manual Stack Emission Factors
Ilmenite Testing Testing Testing
Smelting
CEMS CEMS CEMS
Iron Ore Pellets Manual Stack Manual Stack Manual Stack


Lime Manual Stack Manual Stack Manual Stack
Natural Gas Emission Emission Emission Factors

Transmission, Factors Factors (LDAR)
Distribution &
Storage PEMS
Oil Sands CEMS CEMS Manual Stack Emission Factors H2S: (Mass Balance)
Test with (LDAR) TRS: (CEMS)
COMS
Petroleum Emission Factors
Product (LDAR)
Terminals
Manual Source
Testing
Petroleum CEMS CEMS Manual Stack Emission Factors Benzene: (Emission
Refining Test with (LDAR) Factors)
COMS H2S: (Mass Balance)
Manual Source
Testing
Potash Manual Stack
Test
Pulp & Paper Manual Stack Manual Stack Manual Stack TRS: (CEMS)
Testing Testing Testing with
COMS
CEMS for CEMS for
Kraft Mills Kraft Mills
Upstream Oil & Manual Stack Emission Factors H2S: (Mass Balance)
Gas Testing (LDAR) Benzene: (Emission
Factors)
PEMS
CEMS for
sulphur
recovery
plants
Wood Products Manual Stack Manual Stack Manual Stack
Regarding methods and instrumentation standards, almost all provinces provide sampling code
guidelines for conducting source testing stack surveys. A few jurisdictions also provide
guidelines for conducting Continuous Emission Monitoring (CEMs). While the quantification
methods prescribed in these guidelines typically default to either US EPA or Environment
Canada test methods, several provinces have developed detailed quantification methods of their
own including Alberta’s Continuous Emission Monitoring System Code and the Ontario Source
Testing Code (OSTC). Both the U.S. and the E.U. have developed detailed guidance on the use
of instrumentation; procedures for the standardization of test procedures; standard emission
factors and approaches to the conduct of mass balances and predictive monitoring. These are
well-documented, easily accessible and frequently quoted even by jurisdictions outside of the
U.S. and E.U.

Nevertheless, in many cases approaches to quantification for specific sources and air pollutants
are not consistent across Canada. Below are a number of examples of how quantification
approaches and methods are not consistent.
Reporting frequencies range from real-time (for some parameters in some jurisdictions)
to every 2-5 years, with most intervals in-between. When source performance tests are
conducted, reporting is usually required within one or two months following the tests.
In the base metal smelting sector some provinces require CEMS for SO2 monitoring and
some require source testing stack surveys.
In the cement sector CEMS for NOX and SO2 is required by many jurisdictions such as
Ontario, British Columbia and Metro Vancouver but other jurisdictions such as Quebec
rely on source testing stack surveys.
In Ontario source testing stack surveys are required in the aluminum, iron and steel
smelting and base metal smelting for a number of hazardous air pollutants (e.g., metals,
chlorinated dioxins and furans, chlorobenzenes) that are not routinely tested in other
jurisdictions.
In the electricity generation sector, coal fired generation has quantification and reporting
requirements that are more consistent across the country than for other fuel types. All
coal powered plants of significant size across the country require CEMS of SO2 and
NOX. While generation from other fuels such as natural gas and bunker fuel generally
require source testing stack surveys, there are a number of provinces that do not have end
of stack monitoring requirements, and that rely on estimates of mass emissions based on
mass balance or emission rate factors published by US EPA AP-42 or Environment
Canada.
For kraft mills in the pulp and paper sector typical requirements are for CEMS of TRS
(BC, Newfoundland and Labrador, Alberta, New Brunswick, Quebec); however, a few
jurisdictions prescribe the use of source testing stack surveys. In Nova Scotia, source
testing stack surveys for TRS are conducted twice yearly for significant sources. In
Ontario, source testing stack surveys are only required every two years.
The cement sector in US jurisdictions have not moved towards CEMS of NOX and SO2
that is typical in Canadian and European jurisdictions.
The continuous emission monitoring of SO2 and NOX from the iron and steel smelting
sector is common in European jurisdictions where there are typically no requirements for
monitoring in Canadian jurisdictions.

6.5 REPORTING REQUIREMENTS
Variation in reporting requirements generally mirrors that of quantification requirements.
Most provinces require an annual summary report, including an analysis that demonstrates that
both source emission limits and ambient limits are being met and describes the quantification
methodologies used for individual sources. If emission or ambient limits are not being met, then
the facility must report on the remedial measures that would bring the facility within the
allowable limits. Additional detail in these reports typically includes information on process
changes that have been made and abnormal operating conditions and how these conditions may
have impacted total releases of air pollutants.
Given the differences in reporting approaches, the information that would likely be required for
the proposed Federal Framework for Industrial Air Emissions may not be currently available. As
noted above, some jurisdictions are not currently collecting consistent and comparable data on
total facility wide emissions of air pollutants for regulatory compliance. Information on facility
wide emissions will be crucial for the proposed Federal Framework and the development of a
potential cap and trade system. The format of annual summary reports and emission monitoring
reports also varies considerably; some jurisdictions have standardized reporting formats
available, while other jurisdictions receive reports that have not been standardized and vary for
almost every individual facility. In addition many jurisdictions such as Nova Scotia and British
Columbia still rely on the submission of paper reports only and do not require electronic copies
that can be easily disseminated.
6.6 AUDITING AND VERIFICATION
Interviews with jurisdictional representatives in Canada indicated different approaches to both

auditing and verification for regulatory compliance of air emissions from industrial facilities. In
most jurisdictions, the same regulatory body responsible for issuing permits is also responsible
for auditing and verification. An exception to this is Ontario where the Standards Development
Branch is responsible for auditing and verification programs for certificate of approvals and the
emissions trading regulation.
In a few jurisdictions such as Nova Scotia, Prince Edward Island, Newfoundland and Labrador
and the Yukon representatives indicated that the role of auditing and verification of emissions
was reduced or limited and that they focused primarily on conducting reviews of the emission
monitoring data they received from facilities. Other jurisdictions such as Saskatchewan and New
Brunswick reported that they had minimal auditing and verification procedures and generally
relied on independent parties to conduct on-site verification of emissions monitoring. Both
Metro Vancouver and Montréal reported that they take a much more active role in on-site
verification and frequently conduct emission monitoring at facilities for verification purposes.
Germany employs an interesting reporting mechanism to collect information on facility wide

emissions. As part of their permit requirements, facilities must have an accredited independent
assessment body prepare a detailed emissions inventory every three years that describes all point

and fugitive emission sources, conducts complete mass balances of air pollutants and identifies
methodologies used to estimate emissions.
6.7 DATA SHARING AND AVAILABILITY
As indicated in Exhibit 2.3, in almost all cases, information concerning permits is public. This
usually includes information on quantification and reporting requirements as well as the actual
performance standards. In some cases, however, the information is not easily accessible. This
may be because it can only be obtained through access to information requests, or because the
requirements are contained in a variety of source-permits issued over time, rather than facility-
wide permits that are renewed regularly. Facility reports are not as easily obtained in Canada
and it may be that there are concerns related to the confidentiality of the data provided by
facilities.
In both the U.S. and the E.U., permits and reports are meant to be public; however in many cases
access (particularly to reports) remains difficult and would appear to require a specific request.
6.8 REVIEW OF QUANTIFICATION AND REPORTING PRACTICES
In this section, different jurisdictional approaches to quantification and reporting on both a

sectoral and cross-sectoral basis were reviewed in order to summarize the most relevant
quantification and reporting practices.
As noted previously, it was not possible to identify “best” practices as no objective evidence was
found to indicate that any jurisdiction's practices are better at reducing emissions and/or ensuring
compliance, or more efficient in doing so. Furthermore, regional and facility specific variations
such as fuel type, local dispersion of air pollutants and ambient air quality, types of emission
sources and processes and jurisdiction specific regulatory compliance rules would often dictate
what is the best practice to implement.
Nevertheless, the following five tables present a list of practices that are candidates for "best
practices". These were selected on the basis of our observation of an apparent consensus of
jurisdictions and our own judgment of what would be most likely to contribute to effectiveness,
cost-effectiveness, consistency, accessibility, transparency and simplicity. The tables identify
and describe specific practices and the advantages and disadvantages of employing these
practices in the context of the federal framework and regulatory compliance. The tables review
practices related to each of the following categories: 1) Quantification of Emissions, 2) Coverage
of Pollutants, 3) Reporting Requirements, 4) Auditing and Verification of Emissions and 5)
Public Disclosure.
It is clear that every practice in every jurisdiction and every sector cannot be included in this
review. Instead, the review focuses on identifying the most prominent practices and where
possible considers them from a cross-sectoral, multi-pollutant and multi-source perspective.
There will of course be a number of reasons why certain practices are not suitable in all cases;
however, this review should provide a starting point for identifying appropriate quantification
and reporting requirements for the federal framework.

Exhibit 6.3: Practices Related to the Quantification of Emissions
Practice Advantages Disadvantages

CEMS of major sources including those
that may operate infrequently but that
can lead to major emissions.
Continuous Emission Monitoring (CEM)

is used in many jurisdictions to monitor
NOX, SO2 and PM from major emissions
sources where these contaminants are of For many large sources that
concern, and also in specific cases where Considered to be the most have predictable emissions,
emission trading of these pollutants is accurate quantification CEM may not be justified for
regulated. Typical sources where CEM method that reliably the cost based on limited data
for NOX and SO2 are required include quantifies emissions over improvement from other
electricity generating units, power boilers, any time period and quantification methods such
and cement kilns. The Ontario emission addresses concerns in as mass balance or predictive
trading program requires CEM for the regards to variability in emission monitoring
electricity, cement and base metal emission source operation CEM may not be reasonable
smelting sectors. The US SO2 allowance Identifies operation for more than a few criteria
program and the OTC NOX Budget anomalies and provides real air contaminants, since the
Trading Program require CEMS for large time feedback for process cost of monitoring of more
emission sources. Certain jurisdictions control than a few pollutants may
may also require CEMS for specific outweigh the benefits.
sources within sector such as sulphur
recovery unit incinerator stacks that could
have a wide range of mass emission rates.
Given the uniqueness of the process, even
brief emission upsets can release large
amounts of sulphur dioxide and lead to
substantial impacts.
Use of standardized US EPA
quantification methods
Companies that conduct
The US Environmental Protection Agency source testing, test Specific goals or programs in
has developed standardized stack testing laboratories and third party Canada such as for the
and CEMS quantification methodologies accreditation and proposed Federal Framework
for a wide range of industrial pollutants verification consultants are may require modification of
that are extensively used and referenced most familiar with and are US EPA quantification
world wide. In Canada, most set up to use US EPA methods.
quantification methodologies follow US quantification
EPA quantification methodologies or were methodologies
originally based on these methodologies.


Assigning specific quantification
methods based on facility production
thresholds
Reduces monitoring burden
on smaller facilities that In terms of the federal
The EU requires that CEMS for NOX and
pose a correspondingly framework this practice can
particulate matter be used for coal or
smaller risk to the result in the use of different
heavy fuel oil fired power plants with a
environment than larger quantification methodologies
rated thermal input greater than 100 MW.
facilities. and as a result different levels
Can allow consistency of data confidence for the
Alberta has established that when clinker
between sources and same emission sources within
production rates exceed 100 tonnes per
facilities of a similar size a specific sector.
hour for cement facilities, manual stack
that have comparable risks.
testing for NOX, SO2, PM and CO must be
conducted every six months.
Differentiated quantification
requirements based on the type of fuels
burned or process
The type of fuel that is combusted and the

type of processes employed within an
industrial sector can significantly impact Quantification
No facility within a specific
the overall level of emissions generated. methodologies can be
sector is identical to another
For example, coal used in power and assigned so that the burden
and the differentiation of
steam generation generally has of monitoring and reporting
facilities by process or fuel
substantially higher emissions of SOX, PM of emissions is based on the
type could lead to the creation
and mercury than equivalent generation environmental risk posed by
of so many different
using natural gas as a fuel. the facility
quantification requirements
Can improve consistency of
that the burden of compliance,
Similar facilities may use different quantification
auditing, verification and
quantification methodologies depending methodologies across sectors
benchmarking is greater than
on the processes adopted at the facility. (for example all coal burning
the benefit.
For example, in Alberta there is a equipment have the same
monitoring methodology hierarchy for quantification requirements)
sour gas plants, where sulphur recovery
gas plants have the most stringent
requirements and flaring sour gas plants
and acid gas incineration plants have less
stringent requirements.
Minimum annual quantification of

emissions
In many jurisdictions industrial facilities Increasing the frequency of Burden of monitoring may
are required to quantify and report manual source testing to at increase substantially
emissions on an annual basis. This least once per year improves especially if there are a large
condition requires that quantification the ability to compare and number of pollutants that
methodologies for some pollutants that benchmark emissions require manual source testing.
rely on manual source testing alone must between facilities over time.
be conducted at a minimum frequency of
once per year.


Establishing quantification
requirements by source type
Establishing quantification
Development of quantification Codes of independent of location of the
requirements by source type
Practice for specific emission sources source is often not compatible
independent of the industrial
with a risk based approach
sector or the location of the
In the United States quantification (i.e., establishing burden of
source improves the ability
requirements by source (e.g. boiler, glycol monitoring based on the
to compare and benchmark
dehydration unit, compressors, flares, environmental risk posed by
emissions.
incinerators, gas turbines, storage vessels) the facility).
Harmonization of
are contained in the Code of Federal Establishing quantification
quantification requirements
Regulations (CFR). All industrial sectors requirements by source type
by source type independent
that operate the listed sources are required introduces complexity since
of industrial sector is
to meet the same quantification and facilities in some sectors will
inherently fairer than
monitoring conditions. have a wide range of sources.
allowing a wide disparity of
Ultimately it is the emissions
quantification requirements.
of the facility as a whole that
matter.
Use of Predictive Emission Monitoring
(PEMS)
Some industrial pollutants can be reliably

quantified by continuously measuring Only a small number of
Can accurately quantify
related parameters such a fuel flow, % industrial pollutants can be
emissions over time similar
oxygen, opacity or exhaust temperature. accurately quantified using
to CEMS at reduced cost.
Metro Vancouver uses PEMS to predict PEMS.
concentration of NOX from natural gas
compressor stations.
Exhibit 6.4: Practices Related to the Coverage of Pollutants

Most of the criteria air
Quantification and reporting for all
contaminants are also the
criteria air contaminants emissions
primary pollutants of
concern from the 17
Several jurisdictions in Canada including Burden of quantification and
industrial sectors and for
Alberta and Metro Vancouver consistently reporting would increase and
benchmarking and
require that industrial facilities quantify may be unwarranted in cases
consistency quantification
and report all criteria air contaminants as where certain CACs pose a
and reporting of CACs is
part of regulatory compliance (as opposed low environmental risk.
desirable
to reporting to NPRI). The seven criteria
Above specific thresholds
air contaminants in Canada are TPM,
these emissions are already
PM10, PM2.5, SOX, NOX, VOC and CO.
reported to NPRI


Quantification and reporting of other
significant toxic air pollutants
Besides CACs, the federal framework also

aims to control other significant toxic air
pollutants that are of specific concern to Consistent coverage of toxic
each of the 17 major industrial sectors (see air pollutants of concern for Burden of quantification and
Exhibit 1.1). Currently jurisdictions each industrial sector across reporting would increase and
across Canada inconsistently quantify and all jurisdictions would may be unwarranted in cases
report these toxic air pollutants (e.g., provide the federal where certain toxic air
metals, dioxins and furans, PAHs). For framework the ability to pollutants pose a low
example, some provinces such as Ontario, consistently regulate and environmental risk.
New Brunswick and Alberta require benchmark these emissions.
manual stack sampling for mercury for
coal powered electricity generation and
others do not.
Exhibit 6.5: Auditing and Verification

Third party verification of emissions Third party verifiers can
monitoring and reporting certify that industrial
facilities are meeting
Some jurisdictions require that a third reporting and quantification
party verify emission monitoring and/or requirements reducing the
Third party verification may
reporting. For example, Germany requires burden and costs of auditing
result in regulators being less
that every industrial facility have an and verification for
familiar with facility level
accredited independent assessment body regulators
emission sources and
prepare a detailed emissions inventory Approach may lead to higher
quantification methodologies.
every three years that describes all point standardization of reporting
and fugitive emission sources, conducts than existing facility level
complete mass balances of air pollutants reporting as there would
and identifies methodologies used to likely be a reduced number
estimate emissions. of third party verifiers.
Annual certification of compliance

issued by facility Requiring annual
certification of compliance
In international jurisdictions, such as the of industrial facilities with
Increased costs borne by
United States, Australia and Sweden, air emission regulations
facilities to produce annual
many operating industrial facilities or would raise the profile of
certification.
large emission sources are required to this activity and potentially
annually certify that they are in lead to improved reliability
compliance with legislation that governs and quality of reporting.
air emissions.

Exhibit 6.6: Practices Related to Reporting Requirements

Requirement of Annual Emission
Summary Reports
Annual emission summary
In many Canadian jurisdictions such as
reports could be designed to
New Brunswick, British Columbia,
provide detailed information
Alberta and Saskatchewan industrial
on emissions and
facilities are required to quantify and
benchmarking of emissions
report emissions on an annual basis (in a Preparation of annual
to meet requirements of the
summary report). Typical requirements of summary reports poses an
federal framework.
annual summary reports include an increased burden on facilities
A single comprehensive
inventory of criteria air contaminants and that already report emission
annual emission summary
other toxic pollutants of concern; information to regulators and
report from each facility
summary and interpretation of stack to NPRI
could theoretically fulfill
testing data conducted during the year;
reporting and quantification
identification of quantification
reporting requirements for
methodologies used and supporting
both regulatory compliance
calculations; and other information used to
and the federal framework
quantify emissions such as fuel use and
facility production levels.
Reporting of performance of air

pollution control equipment
Information on the
Many emission sources are required to performance of air pollution
operate and maintain air pollution controls can be helpful in
controls. Different jurisdictions, such as determining if larger Increase in burden of
Alberta and the U.S., require that the emission reductions are monitoring and reporting for
performance of air pollution control possible through facilities.
equipment be reported (e.g., percent improvements to existing
reduction of pollutant from exhaust controls or by replacement
stream, number of operating hours) so that or addition of new controls
the effectiveness of these controls can be with better performance.
evaluated.
Reporting of CEMS monitoring results

in real time
Real time data allows
While it is common for CEMS data to be
regulators to monitor
transferred periodically in electronic files
emissions to determine
to regulators, data can also be transmitted
regulatory compliance Increase in burden of
in real time.
continuously and more monitoring and reporting for
Metro Vancouver requires that CEMS
accurately relate ambient air facilities.
data results for the Burrard power plant be
quality to emissions.
transmitted in real time. Germany also
Real time data provides the
requires continuous electronic transfer of
highest degree of emissions
CEMS data for certain sectors including
disclosure.
the cement and electricity generation
sector.


Requirement to maintain
Quantification and Reporting Records
Complete records allow for
US jurisdictions and some Canadian
long term monitoring of Increase in burden of
jurisdictions require that all records for
trends and benchmarking of monitoring and reporting for
federally enforceable requirements be
data that could be useful to facilities.
maintained for at least five years. These
the federal framework.
records must be provided to regulators if
requested.
Exhibit 6.7: Practices Related to Public Reporting

Publication of environmental permits,
monitoring data and emission summary
reports on-line
Public reporting of Potential issues related to
emissions data supports the confidential information and
In Canada, several jurisdictions including
concept of transparency to confidentiality provisions of
Alberta and Manitoba post environmental
the public and also provides the Canadian Environmental
permits that include quantification and
a motivating force for Protection Act.
reporting requirements on public access
reducing emissions. Increase in burden of
websites. All US federally enforceable
Imposes minimal burden on reporting for facilities.
permits are available on public access
regulators.
websites. Some jurisdictions are also
planning to post monitoring data online.

7. CONCLUSIONS AND RECOMMENDATIONS
7.1 REGULATORY FRAMEWORK FOR QUANTIFICATION AND REPORTING
Conclusions
Canadian provinces, territories and relevant regional districts and municipalities have
well-established programs for specifying regulatory quantification and reporting
requirements for emissions of air pollutants, for receiving and reviewing the ensuing
reports, and for auditing and verifying the information (except in the Northwest
Territories).
A separate Federal program for quantification and reporting would be duplicative and
therefore not cost-effective.
In all the international jurisdictions examined, the implementation of quantification and

reporting is left to sub-national entities.
Recommendation
The Federal Government should avoid establishing a parallel system for regulatory
quantification and reporting of air emissions and should rely on the provinces, territories,
regional districts, and municipalities (except in the Northwest Territories).
7.2 APPROACHES TO QUANTIFICATION AND REPORTING
Conclusions
There are a wide range of different approaches to regulatory quantification and reporting
of air emissions from industrial facilities in Canada. Specific requirements vary between
substances, sources, sectors and jurisdictions. They also may vary between facilities in
the same jurisdiction.
Many jurisdictions have adopted a risk based approach to managing air emissions. This
means that quantification and reporting requirements may vary based on factors such as
the ambient level of air pollution in the area surrounding the facility, distance to sensitive
receptors and dispersion characteristics of the facility emission sources. Attempts, to
create a one-size fits all approach to quantification and reporting for any given sector may
not be appropriate or cost effective since requirements would no longer hinge upon
potential risks to the environment.
The variety is a reflection of the different circumstances/risks associated with each permit
but it also reflects a lack of standardization and a lack of easily accessible guidance on
best practices.

An important example of the inconsistency is the varying requirement for industrial

facilities to collect and submit facility-wide emissions data for regulatory compliance
purposes, as opposed to data for specified sources.
In most of the international jurisdictions examined, attempts have been made to provide
standards and guidance to assist competent authorities in setting the quantification and
reporting requirements for permits.
In the U.S., standard rules attempt to cover all scenarios and leave little discretion. The
result appears to be overly complex and inflexible. In European countries, some
standards are established but there is still significant scope to adjust requirements based
on circumstances.
Many of the most common and relevant practices used in Canadian and International
jurisdictions to quantify and report industrial emissions are potential best practices. Their
advantages and disadvantages are reviewed in Section 6.7.
Recommendation
The Federal Government and the provinces should work together to develop a national
framework for quantification and reporting. This framework would include:
A generic standard establishing consistent objectives, philosophy, approach, process,

and hierarchy of methods for quantification and reporting. This standard should
establish the principle that, at a minimum, facility-wide emissions data should be
collected and reported annually.
A series of specific quantification and reporting standards for selected air

contaminants and/or industrial sectors, where these are feasible. For example, it may
be possible to standardize the requirement for continuous NOX emissions monitoring
using thresholds, geographical location, etc. Similarly, it may be possible to
standardize the approach to quantification and reporting of a range of contaminants in
the electricity generation sector, using thresholds, fuel type, etc. (this could be
patterned on the EU Large Combustion Facility Directive).
A series of guidelines for sectors where standardization is not feasible due to the
variety of circumstances but where the most likely appropriate quantification
approaches can be described. For example, in the chemical sector, where the range of
facilities, processes and sources is too broad for standardization to be feasible, it may
be possible to identify options and typical practices applicable to common unit
processes and operations. In contrast with the U.S. approach, guidelines would not be
prescriptive and would not attempt to cover all scenarios in detail. Instead they
would identify the most common approaches along with appropriate selection
considerations. It is worth noting that the Canadian Chemical Producers Association
(CCPA) has developed an emissions quantification guideline for its members, which
is similar to that of the Canadian Petroleum Products Institute. The CCPA document

provides guidance for specific chemical subsectors (based on the chemical product
produced), as well as emission sources that are common to the entire industry, such as
combustion sources and fugitive leaks.
Adoption of the practices listed in Section 6.7 where analysis indicates that the
advantages outweigh the disadvantages.
7.3 EMISSIONS COVERAGE
Conclusion
Overall, there is relative consistency between jurisdictions in the emissions to be

quantified and reported within each sector.
Within sectors, there is variability in emissions coverage due to differences in processes

or fuels.
Recommendation
The Federal Government and the provinces should work together to capture a standard
list of emissions requiring quantification for each sector. In many sectors this should be
straightforward. In other sectors, this will be more difficult but it should be possible to
develop a list of potential contaminants and a checklist of standard considerations in
choosing which to include.
7.4 QUANTIFICATION METHODS
Conclusions
Although quantification approaches are not consistent in many sectors, there are
examples of de-facto standards that are emerging. These are highlighted in Exhibit 6.2.
Regarding methods and instrumentation approaches, there are well established standards
and guidelines.
Recommendation
In developing the national framework, governments should make maximum use of

emerging de-facto standards and existing well-established methods and instrumentation
approaches.

7.5 REPORTING REQUIREMENTS
Conclusions
Reporting requirements, formats and frequencies vary significantly between sectors and
jurisdictions.
Some form of annual summary report is common but not universal.
Recommendation
The national framework should seek to standardize emission quantification approaches

for large industrial emission sources.
The national framework should seek to standardize the form of reporting and the need for
an annual summary report. However, efforts to standardize reporting should recognize
the unique information demands and regulatory challenges and requirements of each
jurisdiction.
7.6 AUDITING AND VERIFICATION
Conclusion
The approach to auditing and verification varies considerably between jurisdictions. As a

result, the reliability of the data reported is also variable.
A promising approach used in Europe is to rely on independent third-party assessment

organizations to prepare/certify the annual emissions summary report.
Recommendations
The national framework should seek to harmonize the approach to auditing and
verification.
Governments should consider the possibility of using independent assessment

organizations to certify the annual emissions report.
7.7 DATA SHARING AND AVAILABILITY
Conclusions
With a few exceptions, permit requirements for quantification and reporting are publicly
available but often difficult to obtain. Emission summaries and monitoring reports are
even more difficult to obtain.

There is currently no systematic sharing of facility level compliance information between

jurisdictions. Ad hoc attempts to gather and share information have been time consuming
and not entirely successful
Recommendation
The national framework should work to establish common standards for public access
that account for confidentiality provisions.
The national framework should establish a process for sharing annual reports collected by
provincial, territorial, regional, and municipal authorities with the federal government.
Where documents and information are public, governments should facilitate public
disclosure by posting the information on the web.

APPENDIX A
Detailed Profile of Requirements by Sector

Canadian Jurisdictions
Appendix A Index – Detailed Profiles
A.1 Newfoundland and Labrador
A.2 Prince Edward Island
A.3 Nova Scotia
A.4 New Brunswick
A.5 Quebec
A.6 Ontario
A.7 Manitoba
A.8 Saskatchewan
A.9 Alberta
A.10 British Columbia
A.11 Metro Vancouver
A.12 Yukon
A.13 Northwest Territories
A.14 Nunavut
Note: Due to the large amount of text and the limits of excel, the text in some cells will appear to
be truncated. In order to view the entire text in each cell, please select the cell and read the text
from the formula bar.
Marbek Resource Consultants Ltd. Page A-1

APPENDIX B
Detailed Profile of Requirements by Sector

International Jurisdictions
Base Metal Smelting
Jurisdiction France
Sector Base Metal Smelting - Lead
Process
Types of Emissions Covered
Combustion
Quarterly monitoring (by a third party) for temperature, flow and total
dust.
Periodic monitoring of Cd and Tl, Hg, total metals (Sb, As, Pb, Cr, Co,
Cu, Mn, Ni, V), SO2, global and specific VOC from furnaces, dioxins
Overall Approach to and furans, TOC, HCl and HF.
Quantification Continuous dust monitoring in each chimney.
Continuous dust monitoring in the vicinity of the works.
Lead and dust are regularly measured by a third party.
Methods of sampling, measurement and analysis are contained in a
separate annex.
Monthly reporting of lead emissions.
Quarterly reporting of third party monitoring (SO2, VOC)
Overall Approach to
Annual reporting of dioxins and furans.
Dust monitoring results to be submitted on a quarterly basis.
frequency, method)
Annual report on emissions and separate annual public report to be
submitted to the Préfet and the mayor.
Case Study documented by Entec UK Ltd. for EU Directorate General
Sources
Environment.
Marbek Resource Consultants Ltd. Page B-1

Cement
Jurisdiction New York

Sector Cement
Process
Combustion
Portland cement kiln or clinker cooler must maintain a file of daily
production rates, kiln feed rates, and any particulate emission
measurements
The owner or operator of any portland cement kiln at a dry process plant
Overall Approach to or clinker cooler at either a dry or wet process plant, must install,
Quantification maintain, calibrate daily and operate a device, approved by the
commissioner, for continuously measuring and recording the opacity of
emissions from such kiln or clinker cooler. If two or more kilns are
vented through a single stack, an opacity monitor in the common stack
would satisfy the requirements of this subdivision.
The production and feed rates must be summarized monthly. The records
and summary must be retained for at least three years following the date
Overall Approach to
of such records and summaries and must be made available for
inspection by the commissioner during normal business hours
frequency, method)
Records of opacity must be retained for at least three years following the
date on which they are made
New York State, Department of Environmental Conservation,
Regulations, Chapter III – Air Resources, Subchapter A: Prevention and
Sources
Control of Air Contamination and Air Pollution, Part 220: Portland
Cement Plants

Jurisdiction US - Michigan
Sector Cement
Process
Combustion
In accordance with the requirements of the Clean Air Act, quantification
requirements include testing, rule-based monitoring, compliance
assurance monitoring and periodic monitoring.
Applicants for permits are generally required to conduct performance
tests; those in non-attainment areas must do so annually; and others
every three years.
Performance tests consist of a minimum of 3 separate samples of a
specific air contaminant conducted within a 36-hour period. All
performance tests are conducted while the source of air contaminant is
Overall Approach to operating at maximum routine operating conditions.
Quantification Monitoring, reporting and record keeping requirements conform to the
EPA standards.
Periodic monitoring, which is used to determine compliance with
emission limits, can consist of: direct measurement of emitted pollutants;
parametric monitoring in conjunction with a Preventative-maintenance
and Malfunction-abatement Plan (PMP); or another method that is
approved by the department. Michigan has developed a periodic
monitoring guide that provides examples of periodic monitoring
protocols which may be used to ensure compliance for criteria pollutant
emission limitations.
Specific PM PM monitoring/testing required on all baghouses.
Quantification Daily non-certified visible emissions readings of each process dust
Elements (e.g. collector and record the results in the shift process sheet.
continuous Monitor and record pressure drop across each dust collector and
monitoring, stack maintain the data weekly in the shift process sheet.
surveys, modelling,
etc.)
Results of performance tests shall be submitted to the department in the
format prescribed by the applicable reference test method within 60 days
after the last date of the test.
Records shall be maintained on file for a period of 5 years.
Semiannual reporting of monitoring and deviations. Report shall be
postmarked or received by appropriate AQD district office by March 15
for reporting period July 1 to December 31 and September 15 for
Overall Approach to
reporting period January 1 to June 30.
Annual certification of compliance. Report shall be postmarked or
frequency, method)
received by appropriate AQD district office by March 15 for the
previous calendar year.
Use the MDEQ Report Certification form (EQP 5736) and MDEQ
Deviation Report form (EQP 5737) for the annual, semiannual and
deviation certification reporting. Alternative formats must meet the
provisions of Rule 213(4)(c) and Rule 213(3)(c)(i), respectively, and be
approved by the AQD District Supervisor.
Essroc Cement Corporation – Renewable Operating Permit – Permit
Sources Number: MI-ROP-A0224-2007 – Effective May 15, 2007 (Expires May
15, 2012)

Jurisdiction France
Sector Cement
Process
Combustion
Continuous monitoring of dust through a network of three dust monitors.
Independent monitoring at operator's expense may be required by
regulator.
Monitoring approach includes continuous monitoring (e.g. one hour
interval) of principal pollutants augmented by more precise periodic
monitoring
A sulphur mass balance can be used instead of continuous monitoring of
SO2, however periodic measurements are still needed to validate this
calculation.
Overall Approach to
If NOX monitoring is to be used instead of stack testing, a comparative
Quantification
study must be completed to determine correlation factors between stack
and oven.
Crushing and storage operations require monitoring, however, if
crushing operations are monitored, storage areas may be exempt
provided the operation of dust control systems is checked by a qualified
expert.
Additional requirements may be specified by the regulator.
Methods of sampling, measurement and analysis are contained in a
separate annex.
Monthly submission of self-monitoring data.
Overall Approach to Submission of data from third parties as they are received.
Reporting (e.g. format, Results of continuous dust monitoring must be reported on a quarterly
frequency, method) basis.
Other reporting is specified in the permit.
Environment.
Sources
Circulaire DPPR/SEI du 3 mai 1993 relative à l'application de l'arrêté du
3 mai 1993 sur les cimenteries.

Jurisdiction Germany
Sector Cement
Process
Combustion
Continuous monitoring of dust from rotary kiln
Continuous monitoring of NOX from rotary kiln
Overall Approach to
Continuous monitoring of SO2
Quantification
Noise monitoring
Calibration of all equipment every three years
Continuous electronic reporting
Overall Approach to Annual emissions summary
Reporting (e.g. format, Noise monitoring results
frequency, method) Annual environmental report
Emissions declaration every three years
Sources
Environment.

Chemicals Manufacturing

Sector Chemicals Manufacturing
Process
Types of Emissions Covered Combustion
Fugitive
Any owner or operator of a synthetic organic chemical manufacturing
facility must monitor each of the following process unit components for
leaks, on a quarterly schedule: each pump in light liquid service; each
compressor in gas/vapor service; each pressure relief valve in gas/vapor
service; each valve in light liquid service; and each valve in gas/vapor
service.
CEMS - The owner or operator of any nitric acid plant with a production
capacity greater than 300 tons per day (expressed as 100 percent nitric
acid), located in an area of the State where any applicable ambient air
quality standard for nitrogen dioxide is not being attained, must install,
calibrate, maintain and operate a continuous stack monitoring system for
Overall Approach to the measurement of nitrogen oxides (expressed as nitrogen dioxide) from
Quantification each nitric acid producing emission source
The owner or operator of any sulfuric acid plant with a production
capacity of greater than 300 tons per day (expressed as 100 percent
sulfuric acid) must install, calibrate, maintain and operate a continuous
stack monitoring system for the measurement of sulfur dioxide from
each sulfuric acid producing emission source
For new facilities, there is no capacity limit - A continuous monitoring
system for the measurement of nitrogen oxides (expressed as nitrogen
dioxide) from each nitric acid production source, or sulfur dioxide from
each sulfuric acid production source, must be installed, calibrated,
maintained and operated by the owner or operator of any new emission
source or modification subject to this Part
SOx Sulphur content of fuel
Specific NOx Weekly; continuous
Quantification
PM EPA Method 5
Elements (e.g.
continuous VOC EPA Method 21
monitoring, stack NH3 Ammonia, as required
surveys, modelling, Other Sodium hydroxide, hydrogen peroxide, acetic acid, hydrogen chloride,
etc.) vanadium oxide, phosphoric acid, chlorine, butane, sodium hypochlorite,
methanesulfenyl chloride, methyl alcohol,
Submit a written report to the commissioner for each calendar quarter.
This report must include: (i) emission averages for periods of excess
emissions (a "period of excess emissions" is any three-hour period
during which the arithmetic average of emissions for three consecutive
one-hour periods exceeds any applicable emission standard); (ii) the time
and date of each period during which the continuous monitoring system
Overall Approach to was inoperative except for zero and span checks, and the nature of
Reporting (e.g. format, system repairs or adjustments; or (iii) information that no excess
frequency, method) emissions have occurred and the continuous monitoring system has not
been inoperative, repaired or adjusted, if such is the case.
maintain records of quarterly summaries, including daily production
rates, hours of operation and all other data collected either by the
continuous stack monitoring system or as necessary to convert stack
monitoring data to the units of the applicable emission standards, for a
period of three years from the date of collection of such data

make records available for inspection during normal business hours by
the commissioner or his representative and furnish copies of such
records to the commissioner or his representative upon request
Control of Air Contamination and Air Pollution, Part 236: Synthetic
Sources Organic Chemical Manufacturing Facility Component Leaks and Part
224: Sulfuric and Nitric Acid Plants
Air Title V Facility Permit – Arch Chemicals Inc. – Permit ID 8-2614-
00344/00307 – October 26, 2001 (Expires October 26, 2006)

Jurisdiction France
Sector Chemicals Manufacturing – organic chemicals plant
Types of Emissions Covered Process
Overall Approach to Monitoring requirements include daily measurements of emissions of
Quantification hydrocarbons, total metals, zinc and VOCs
Overall Approach to Monthly submission of self-monitoring data for regulated parameters
Reporting (e.g. format, except VOCs (annual).
frequency, method) Annual report on performance.
Sources
Environment.

Electricity

Sector Electricity (NG, fuel oil)
Overall Approach to Standard EPA methods apply
Quantification
SOx Comply with the monitoring and reporting requirements as provided for
in EPA methods.
Specific NOx CEM – Reference test method - 40 CFR 75
Quantification PM Stack - 40CFR60 Method 5 – once during the term of the permit
Elements (e.g.
continuous VOC
monitoring, stack NH3 CEM – Reference test method - Method 027
surveys, modelling, Other For fuel oil – sulphur content of fuel – reference test method - ASTM D-
etc.) 4294
Opacity - 40CFR 60 Appendix A Method 9 – minimum once per year;
Continuous; 40 CFR 60 APP B
Submit reports of any required monitoring at a minimum frequency of
every 6 months, based on a calendar year reporting schedule. These
reports shall be submitted to the Department within 30 days after the end
of a reporting period.
Overall Approach to
All semi-annual reports shall be submitted to the Administrator (or his or
her representative) as well as two copies to the Department (one copy to
frequency, method)
the regional air pollution control engineer (RAPCE) in the regional
office and one copy to the Bureau of Quality Assurance (BQA) in the
DEC central office).
Annual Emissions Statements required by April 15th of each year
SOx Annually
NOx Quarterly
PM Semi- annually (not sure how this is possible when only requires testing
Specific Reporting
once over the term of the permit)
Elements
VOC
NH3 Quarterly
Other Opacity – semi annually; Annually; Quarterly
Air Title V Facility Permit – Edgewood Energy – Permit ID 1-4728-
03244/00005 – January 1, 2008 (Expires December 31, 2012)
Sources
Air Title V Facility Permit – EF Barrett Power Station – Permit ID 1-
2820-00553/00025 – February 9, 2006 (Expires February 8, 2011)

Sector • Electricity (NG)
In accordance with the requirements of the Clean Air Act, quantification
requirements include testing, rule-based monitoring, compliance
assurance monitoring and periodic monitoring.
Applicants for permits are generally required to conduct performance
tests; those in non-attainment areas must do so annually; and others
every three years.
Performance tests consist of a minimum of 3 separate samples of a
specific air contaminant conducted within a 36-hour period. All
performance tests are conducted while the source of air contaminant is
Overall Approach to operating at maximum routine operating conditions.
Quantification Monitoring, reporting and record keeping requirements conform to the
EPA standards.
Periodic monitoring, which is used to determine compliance with
emission limits, can consist of: direct measurement of emitted pollutants;
parametric monitoring in conjunction with a Preventative-maintenance
and Malfunction-abatement Plan (PMP); or another method that is
approved by the department. Michigan has developed a periodic
monitoring guide that provides examples of periodic monitoring
protocols which may be used to ensure compliance for criteria pollutant
emission limitations.
SOx Monitor the sulfur content of natural gas combusted in accordance with
40 CFR 60.334(h) or as described in the “Custom Fuel Monitoring
Program”
Analysis for fuel sulfur content of the natural gas conducted using one of
the approved ASTM reference methods or an approved alternate method.
Reference methods are {as referenced in 40 CFR 60.334(b)(2)}: i.
ASTM D3031-81 Total Sulfur in Natural Gas by Hydrogenation; ii.
ASTM D3246 Sulfur in Petroleum Gas by Oxidative Microcoulometry;
iii. ASTM D4084-82 Analysis of Hydrogen Sulfide in Gaseous Fuels
(Lead Acetate Reaction Rate Method); iv. Testing for Hydrogen Sulfide
in Natural Gas Using Length of Stain Tubes
Sulfur monitoring shall be conducted as follows: i. Twice monthly for 6
Specific months (if monitoring shows little variability and represents compliance
Quantification with the SO2 emission limits, then follow ii.); ii. Once per calendar
Elements (e.g. quarter for 6 calendar quarters (if monitoring shows little variability and
continuous represents compliance with the SO2 emission limits, then follow iii.); iii.
monitoring, stack Semiannually, during the first and third calendar quarters of the calendar
surveys, modelling, year; iv. Should any sulfur analysis indicate non-compliance with 40
etc.) CFR 60.333, sulfur monitoring shall be conducted weekly
NOx Install, calibrate, maintain and operate CEMS for NOx emissions from
each turbine and according to the procedures outlined in the permit and
40 CFR 75
PM Stack tests in combination with records of heat input – PM10 – US EPA
Methods 1 through 5 and Method 202
VOC Stack test in combination with records of heat input – US EPA Method
25A
NH3 Mass balance calculation
Other Monitor and record the heat input, in mmBtu, for each turbine on a
continuous basis
Install, calibrate, maintain and operate CEMS for CO emissions from

each turbine on a continuous basis and according to the procedures
outlined in the permit
Formaldehyde – Stack test in combination with records of heat input –
US EPA Method 316
Opacity - Visible emissions evaluations per US EPA Method 9
Records shall be maintained on file for a period of 5 years.
Compliance with the visible emissions (opacity) limit shall be
determined at least once per 1,624 hours of operation for each turbine
using Federal Reference Method 9 (40 CFR 60, Appendix A) during
maximum routine operating conditions
Overall Approach to
Submit a complete test report of stack test results to the AQD within 60
days following the last date of the test
frequency, method)
Use the MDEQ Report Certification form (EQP 5736) and MDEQ
Deviation Report form (EQP 5737) for the annual, semiannual and
deviation certification reporting. Alternative formats must meet the
provisions of Rule 213(4)(c) and Rule 213(3)(c)(i), respectively, and be
approved by the AQD District Supervisor.
SOx
NOx Maintain (in a satisfactory manner) daily average, monthly, and previous
12-month rolling time period NOx emission calculation records for each
turbine
PM Maintain daily average, monthly and previous 12-month rolling time

period PM10 emission calculation records for each turbine
Specific Reporting VOC Maintain daily average, monthly and previous 12-month rolling time
Elements period VOC emission calculation records for each turbine
NH3 Maintain daily average ammonia slip records for each turbine/duct
burner
Other Maintain daily average, monthly and previous 12-month rolling time
period CO emission calculation records for each turbine
Maintain monthly and previous 12-month rolling time period
formaldehyde emission calculation records for each turbine
Maintain records of the visible emission readings for each turbine
Zeeland Generating Station – Renewable Operating Permit – Permit

Sources Number: MI-ROP-N6521-2004b – Effective December 29, 2004 (Last
Revised February 29, 2008) (Expires May 31, 2009)

Jurisdiction US - California
Sector Electricity (NG)
Pre-construction will involve a source test. Operation will involve
ongoing monitoring, including compliance assurance monitoring and
periodic monitoring.
Source test will demonstrate compliance with all the emission limits
during the Commissioning Period of each of the reciprocating using the
following methods.
• a. Particulate Matter – CARB Method 5 (front and back half) or
EPA Methods 201a and 202
• b. Diesel Particulate Matter – CARB Method 5 (front half)
• c. Visible Emissions
• i. Permittee shall perform a “Visible Emission Evaluation” (VEE)
concurrent with particulate matter testing. A CARB certified
contractor shall perform such an evaluation.
• d. Ammonia – Bay Area Air Quality Management NCUAQMD
Method ST-1B
• e. Reactive Organic Gases – CARB Method 100
• f. Nitrogen Oxides – CARB Method 100
• g. Carbon Monoxide – CARB Method 100 & ASTM D6522-00
[NESHAP ZZZZ]
• h. Oxygen – CARB Method 100 & ASTM D6522-00 [NESHAP
Overall Approach to
ZZZZ]
Quantification
i. Oxygen shall be measured at the inlet and outlet of the oxidation
catalyst
ii. Oxygen measurements shall be made at the same time as the CO
measurements
iii. Pressure drop measurements across the catalyst shall be made at
the same time as the CO measurements
• i. Natural Gas Fuel Sulfur Content – ASTM D3246
• j. Liquid Fuel Sulfur Content – ASTM D5453-93
Demonstrate compliance with all the emission limits once per calendar
year in natural gas mode and once every three years in diesel mode.
Comply with the applicable requirements for quality assurance testing
and maintenance of the continuous emission monitor equipment in
accordance with the procedures and guidance specified in 40 CFR Part
60, Appendix F.
Relative accuracy test audits (RATAs) shall be performed on each
CEMS at least once every twelve months, in accordance with the
requirements of 40 CFR 60, Appendix B. Calibration Gas Audits of
continuous emission monitors shall be conducted quarterly, except
during quarters in which relative accuracy and total accuracy testing is
performed, in accordance with EPA guidelines.
Specific SOx Demonstrate compliance with the hourly, daily, and annual SOx
Quantification emission limits through the use of valid fuel use records, natural gas
Elements (e.g. sulfur content, diesel fuel sulfur content, mass balance calculations; and
continuous APCO approved emission factors and methodology. The natural gas
monitoring, stack sulfur content shall be determined on a monthly basis using ASTM
surveys, modelling, D3246.
etc.) NOx Each reciprocating engine will be equipped with a continuous emission
monitor (CEM) for NOx, CO, and O2. Continuous emissions monitor(s)
must meet the requirements of 40 CFR part 60. The monitors must be
designed and operated so as to be capable of monitoring emissions

Jurisdiction US - California
during normal operating conditions and during Startup and Shutdowns
Periods.
PM Demonstrate compliance with the hourly, daily, and annual PM emission
limits, and the diesel particulate matter emission limits, through the use
of valid fuel use records, source tests, and APCO approved emission
factors and methodology.
VOC Demonstrate compliance with the hourly, daily, and annual Reactive
Organic Carbon (ROC) emission limits through the use of valid CO
CEM data and the ROC/CO relationship determined by annual CO and
ROC source tests; and APCO approved emission factors and
methodology.
NH3 Continuous recording of the ratio of the ammonia injection rate to the
NOx inlet rate into the SCR control system (molar ratio). Alternatively, a
continuous in-stack emissions monitor for emissions of ammonia.
Source test results shall be submitted no later than 60 days after the
testing is completed.
Submit at least once every six months reports of all required monitoring.
All required reports must be certified by the responsible official and
shall state that, based on information and belief formed after reasonable
inquiry, the statements and information in the document are true,
accurate and complete.
The Permittee shall submit on an annual basis a certification of
compliance. The compliance certification shall include the following: i.
The identification of each term or condition of the Title V permit that is
the basis of the certification. ii. The method(s) used for determining the
compliance status of the source, currently and over the reporting period,
Overall Approach to and whether such method(s) provides continuous or intermittent data. iii.
Reporting (e.g. format, The status of compliance with the terms and conditions of the Title V
frequency, method) permit for the period covered by the certification, based on the method
designated in Section D (ii) of this condition. iv. Such other facts as the
Air Pollution Control Officer may require in order to determine the
compliance status of the source. v. A method for monitoring the
compliance of the stationary source with its emissions limitations,
standards and work practices.
All monitoring data and support information required by a federally
enforceable applicable requirement must be kept by the stationary source
for a period of 5 years from the date of the monitoring sample,
measurement, report or application. Support information includes all
calibration and maintenance records and all original strip-chart
recordings for continuous monitoring instrumentation, and copies of all
reports
TITLE V FEDERAL OPERATING PERMIT NCUAQMD PERMIT TO
OPERATE AND FINAL DETERMINATION OF COMPLIANCE ATC
Sources PERMIT NO: 443-1 ISSUED TO: PLANT SITE LOCATION: Pacific Gas
& Electric Humboldt Bay Power Plant 1000 King Salmon Avenue 1000 King
Salmon Avenue Eureka, CA 95503 Eureka, CA

Jurisdiction European Union
Sector Electricity – Large Combustion Plants
Continuous measurements of concentrations of SO2, NOx, and dust
from waste gases from each combustion plant with a rated thermal input
of 100 MW or more.
By way of derogation from the first subparagraph, continuous
measurements may not be required in the following cases:
for combustion plants with a life span of less than 10 000 operational
hours;
for SO2 and dust from natural gas burning boilers or from gas turbines
firing natural gas;
for SO2 from gas turbines or boilers firing oil with known sulphur
content in cases where there is no desulphurisation equipment;
for SO2 from biomass firing boilers if the operator can prove that the
SO2 emissions can under no circumstances be higher than the prescribed
emission limit values.
Where continuous measurements are not required, discontinuous
measurements shall be required at least every six months. As an
alternative, appropriate determination procedures, which must be
verified and approved by the competent authorities, may be used to
evaluate the quantity of the above mentioned pollutants present in the
emissions.
Such procedures shall use relevant CEN standards as soon as they are
available. If CEN standards are not available ISO standards, national or
international standards which will ensure the provision of data of an
equivalent scientific quality shall apply.
In the case of plants which must comply with fixed desulphurisation
Overall Approach to
rates, the above requirements concerning SO2 emission measurements
Quantification
shall apply. Moreover, the sulphur content of the fuel which is
introduced into the combustion plant facilities must be regularly
monitored.
The competent authorities shall be informed of substantial changes in the
type of fuel used or in the mode of operation of the plant. They shall
decide whether the monitoring requirements established above are still
adequate or require adaptation.
The continuous measurements shall include the relevant process
operation parameters of oxygen content, temperature, pressure and water
vapour content. The continuous measurement of the water vapour
content of the exhaust gases shall not be necessary, provided that the
sampled exhaust gas is dried before the emissions are analysed.
Representative measurements, i.e. sampling and analysis, of relevant
pollutants and process parameters as well as reference measurement
methods to calibrate automated measurement systems shall be carried
out in accordance with CEN standards as soon as they are available. If
CEN standards are not available ISO standards, national or international
standards which will ensure the provision of data of an equivalent
scientific quality shall apply.
Continuous measuring systems shall be subject to control by means of
parallel measurements with the reference methods at least every year.
The values of the 95 % confidence intervals of a single measured result
shall not exceed the following percentages of the emission limit values:
Sulphur dioxide 20 % Nitrogen oxides 20 % Dust 30 %.
The validated hourly and daily average values shall be determined from

Jurisdiction European Union
the measured valid hourly average values after having subtracted the
value of the confidence interval specified above.
Any day in which more than three hourly average values are invalid due
to malfunction or maintenance of the continuous measurement system
shall be invalidated. If more than ten days over a year are invalidated for
such situations the competent authority shall require the operator to take
adequate measures to improve the reliability of the continuous
monitoring system.
Specific SOx Continuous or discontinuous

Quantification NOx Continuous
Elements (e.g. PM Continuous or discontinuous
continuous
monitoring, stack
surveys, modelling,
etc.)
Operator must report the results of the continuous measurements, the
checking of the measuring equipment, the individual measurements and
all other measurements carried out in order to assess compliance with
Overall Approach to this Directive.
Reporting (e.g. format, Plants must report: — the total annual emissions of SO2, NOx and dust
frequency, method) (as total suspended particles). — the total annual amount of energy
input, related to the net calorific value, broken down in terms of the five
categories of fuel: biomass, other solid fuels, liquid fuels, natural gas,
other gases.
Sources EU Large Combustion Plant Directive

Jurisdiction Australia – New South Wales
Sector Electricity – Coal
Combination of continuous and annual
Overall Approach to
For annual monitoring, a series of approved methods are referenced
Quantification
The mass of all pollutant discharges must also be monitored
SOx Continuous
NOx Continuous
PM Undifferentiated - Continuous
Solid Particles - Annual (Method TM-15)
VOC Annual (Method OM-2)
Specific Other Chlorine mg/m3 Yearly TM-7 & TM-8
Quantification Copper mg/m3 Yearly TM-12, TM-13 & TM-14
Elements (e.g. Dry gas density kg/m3 Yearly TM-23
continuous Fluorides mg/m3 Yearly TM-9
monitoring, stack Hazardous substances mg/m3 Yearly TM-12, TM-13 & TM-14
surveys, modelling, Hydrogen chloride mg/m3 Yearly TM-7 & TM-8
etc.) Moisture content % Yearly TM-23
Molecular weight of stack gases g/g-mole Yearly TM-23
Sulfuric acid mist and sulphur trioxide (as SO3) mg/m3 Yearly TM-3
Temperature oC Yearly TM-2
Velocity m/s Yearly TM-2
Volumetric flowrate m3/s Yearly TM-2
The results of any monitoring required to be conducted by this licence or
a load calculation protocol must be recorded and retained as set out in
this condition.
All records required to be kept by this licence must be: in a legible form,
or in a form that can readily be reduced to a legible form; kept for at
least 4 years after the monitoring or event to which they relate took
place; and produced in a legible form to any authorised officer of the
EPA who asks to see them.
Overall Approach to
The following records must be kept in respect of any samples required to
be collected for the purposes of this licence:
frequency, method)
• the date(s) on which the sample was taken;
• the time(s) at which the sample was collected;
• the point at which the sample was taken; and
• the name of the person who collected the sample.
The licensee must complete and supply to the EPA an Annual Return in
the approved form comprising:
• a Statement of Compliance; and
• a Monitoring and Complaints Summary.
Sources Environmental Protection License - Munmorah Power Station

Iron, Steel, and Illmenite Smelting
Jurisdiction US - New York

Sector Iron, Steel and Illmenite Smelting
Process
Combustion
Exhaust gas - Compliance with the mass emission standards determined
by stack testing in a manner acceptable to the commissioner (US EPA
Overall Approach to Method 5 is an acceptable method).
Quantification For blast furnace tapping operations, sampling must be conducted during
the blast furnace tapping period.
EPA monitoring methods and standards apply.
Specific Other Opacity - determined by observing visible emissions discharged during
Quantification the operation of the iron and/or steel process. A sufficient number of
Elements (e.g. process cycles must be observed to accumulate the required minimum of
continuous 24 consecutive opacity readings.
monitoring, stack
surveys, modelling,
etc.)
All records and summaries, required in connection with the acceptable
Overall Approach to
installation, maintenance and operation methods specified in the
regulations must be retained by the source owner for at least three years.
frequency, method)
These records must be furnished upon request.
Sources
Control of Air Contamination and Air Pollution, Part 216: Iron and/Or
Steel Processes

Jurisdiction Germany
Sector Iron and Steel Smelting
Process
Combustion
Main point source emission sources are monitored continuously
Continuous dust monitoring from coke oven undergrate firing, coke
Overall Approach to pusher de-dusting, coke crushing, and screening unit de-dusting
Quantification Continuous NOX monitoring
Continuous SO2 monitoring of coke oven gas
Continuous CO monitoring
Daily electronic data transmission
Overall Approach to
Smaller sources are monitored and reported on following commissioning
Detailed emissions inventory must be submitted every three years,
frequency, method)
including full mass balance prepared by an accredited assessment body
Sources
Environment.

Jurisdiction Sweden
Sector Iron and Steel Smelting
Process
Combustion
Overall Approach to Continuous monitoring of particulate matter
Quantification Other requirement in the permit
Submit monitoring data reports
Overall Approach to Submit annual environmental report detailing how compliance has been
Reporting (e.g. format, maintained
frequency, method) A computer based system of files details monitoring resuls against
regulated limits
Sources
Environment.

Petroleum Product Terminals

Sector Petroleum Product Terminals
Types of Emissions Covered Fugitive
Test methods to determine the level of gasoline vapors which are
acceptable to the commissioner must be used to determine compliance
with the standard.
Standard EPA test methods apply.
Overall Approach to Any facility which is not subject to the control requirements of this Part
Quantification because its annual potential to emit volatile organic compounds are
below the applicability levels, must maintain records in a format
acceptable to the commissioner's representative that verify the facility's
annual potential to emit VOC. Upon request, these records must be
submitted to the department
VOC Depending upon conditions at a test site, one of the following test
Specific methods from Appendix A of 40 CFR part 60 must be used to determine
Quantification VOC concentrations of a gas stream at the inlet and outlet of a control
Elements (e.g. device: (1) Method 18, Measurement of Gaseous Organic Compound
continuous Emissions by Gas Chromatography; (2) Method 25, Determination of
monitoring, stack Total Gaseous Organic Emissions as Carbon; (3) Method 25A,
surveys, modelling, Determination of Total Gaseous Organic Concentration Using a Flame
etc.) Ionization Analyzer; (4) Methods not listed above must be approved in
advance by the department's representative and the US EPA
The owner or operator of a gasoline bulk plant, gasoline loading
terminal, petroleum liquid storage tank, marine loading vessel facility, or
volatile organic liquid storage tank subject to this Part must maintain the
Overall Approach to following records at the facility for a period of five years: (a) capacities
Reporting (e.g. format, of petroleum liquid storage tanks in gallons; (b) average daily gasoline
frequency, method) throughput per day for gasoline bulk plants in gallons; (c) average daily
gasoline throughput for gasoline loading terminals in gallons per year;
(d) capacities of volatile organic liquid storage tanks, in gallons; and (e)
daily gasoline throughput for marine vessel loading facilities in gallons.
Sources
Control of Air Contamination and Air Pollution, Part 229: Petroleum
and Volatile Organic Liquid Storage and Transfer

Petroleum Refining
Sector Petroleum Refining
Process
Combustion
The owner or operator of a petroleum refinery shall meet the following
schedule: (1) submit to the commissioner and commence a monitoring
program six months after the effective date of this regulation. This
program shall contain, as a minimum, a list of the refinery units and the
quarter in which they will be monitored, a copy of the log book forma,
and the make and model of the monitoring equipment to be used.
Average coke burn-off rate (thousands of kilograms/hr) and hours of
Overall Approach to
operation for any fluid catalytic cracking unit catalyst regenerator
Quantification
recorded daily.
Record daily the combustion rates of liquid or solid fossil fuels (liters/hr
or kilograms/hr) and the hours of operation during which liquid or solid
fossil fuels are combusted in the incinerator - waste heat boiler for any
fluid catalytic cracking unit catalyst regenerator and which utilizes an
incinerator - waste heat boiler to combust the exhaust gases from the
catalyst regenerator.
SOx Continuous
Specific
Quantification NOx
Elements (e.g. PM
continuous VOC
monitoring, stack NH3
surveys, modelling,
etc.) Other Opacity – Continuous
CO – Continuous
Maintain a file of the required measurements tabulated in a format
acceptable to the commissioner. Such records of measurements shall be
retained for a minimum of three years, and shall be furnished to the
commissioner on his request
Submit a written report, at the request of the commissioner, of excess
emissions of opacity and sulfur dioxide for each calendar quarter, and
the nature and cause of the excessive emissions if known.
Submit leak report upon the completion of each yearly and/or quarterly
monitoring procedure. Testing and calibration procedures to determine
compliance with this part of the regulation must be consistent with
Overall Approach to
Appendix B of the US EPA guideline series document, "Control of
Volatile Organic Compound Leaks from Petroleum Refinery
frequency, method)
Equipment", EPA-450/2-78-036
The owner or operator of a petroleum refinery subject to this Part of the
regulation must: (1) Monitor yearly by the methods referenced above
(US EPA guidelines), all pump seals, pipeline valves in liquid services,
and process drains in gaseous or light petroleum compound service; (2)
Monitor quarterly by the methods referenced above (US EPA
guidelines), all compressor seals, pipeline valves in gaseous service and
pressure relief valves in gas service; (3) Monitor weekly by visual
methods all pump seals in pumps in gaseous or light petroleum
compound service.
Sources
Control of Air Contamination and Air Pollution, Part 223: Petroleum
Refineries

Jurisdiction California
Sector Petroleum Refining
Process
Combustion
Source tests are required semi-annually to determine the nitrogen oxide,
carbon monoxide, hydrogen sulphide, ammonia and VOC emissions
from each applicable source. The frequency of source testing is reduced
from annually to once every five years or from semi-annually to twice
every five years if three consecutive annual or four consecutive semi-
annual source tests document that emissions are less than 50 percent of
the standard.
There are a wide range of requirements for monitoring, measurement
and quantification associated with permit conditions and compliance
monitoring requirements for specific sources. For example:
• Coke corral to be checked for visible emissions quarterly.
• Carbon vessel - Monitor with a photo-ionization detector (PID),
flame-ionization detector (FID), or other method.
• Use emission factors for combustion. Determine average sulfur
content for each gaseous fuel on a daily basis, and for each liquid or
solid fuel on a weekly basis. Use CEM data and calculated stack
flows to estimate NOx emissions from selected sources. Sulfur plant
Overall Approach to emissions will be based on the actual measured sulfur emissions
Quantification • A District-approved SO2 continuous emission monitor and recorder
(CEM) shall be installed, calibrated, maintained, and operated
according to District regulations, on the exhaust of the Tailgas
Incinerator.
• Operate NOx and SO2 continuous emission monitors on the CO
Boilers in accordance with the District's Manual of Procedures.
Install a continuous emission monitor (CEM) and recording system
for NH3 in each CO Boiler stack if there are 3 separate violations of
permit conditions in any consecutive 12 month period.
There are also general requirements. For example:
• Every combustion source (or group of sources with the same
emission factors) installed, modified or replaced as part of the CFP
shall be equipped with a continuous fuel flow monitor in order to
determine fuel consumption.
• Compliance with the daily emission caps shall be based on the
records on daily fuel consumption, data from the NOx CEM, data
from the O2 CEM, data from the SO2 CEM, and the emission
factors established in the source test required in Condition 28b.
SOx CEMS
NOx Source test, emission factors, and CEMS
Specific
PM
Quantification
Elements (e.g. VOC Source test, emission factors, and CEMS
continuous NH3 Source test, emission factors, and CEMS
monitoring, stack Other Compliance with the H2S and TRS limits for the CO Boilers will be
surveys, modelling, inferred by directly measuring the H2S and TRS contents of the refinery
etc.) fuel gas supply
Calculate and record the: (1) 3-hour H2S content; (2) 24-hour rolling
average H2S content; and (3) TRS content of the refinery fuel gas
Overall Approach to The results of the source test must be made available to the District
Reporting (e.g. format, within 60 days of the source test and kept for a minimum of 5 years from
frequency, method) the date of the report. The permit holder must provide any information,

Jurisdiction California
records, and reports requested or specified by the APCO. All records for
federally enforceable requirements must be maintained for at least five
years.
Reports of all required monitoring must be submitted to the District at
least once every six months, except where an applicable requirement
specifies more frequent reporting. All instances of non-compliance must
be clearly identified in these reports. The reports must be certified by the
responsible official as true, accurate, and complete. In addition, all
instances of non-compliance with the permit shall be reported in writing
to the District’s Compliance and Enforcement Division within 10
calendar days of the discovery of the incident. Within 30 calendar days
of the discovery of any incident of non-compliance, the facility must
submit a written report including the probable cause of non-compliance
and any corrective or preventative actions.
Compliance certifications must be submitted annually by the responsible
official. The certification must list each applicable requirement, the
compliance status, whether compliance was continuous or intermittent,
the method used.
For selected sources, the owner/operator must report the following on a
monthly basis:
Daily compliance/non-compliance for each pollutant.
Daily total emissions for each pollutant.
MAJOR FACILITY REVIEW PERMIT
Sources Issued To: Shell Martinez Refinery, Shell Oil Products US
Facility # A0011

Upstream Oil and Gas
Jurisdiction US - Texas
Sector Upstream Oil and Gas
Types of Emissions Covered Fugitive
(e.g. process, combustion, Flaring
fugitive, venting, etc.) Combustion
Overall Approach to Specific requirements apply to each source: vessels, ancillary equipment,
Quantification glycol dehydration unit, flares, incinerators, VOC loading/unloading facilities,
etc.
Requirements are detailed and contained in hundreds of pages of performance

specifications from Code of Federal Regulation 40 CFR 60, 40 CFR 63, and
Texas Administrative Code Title 30.
Specific Quantification SOx Suphur Recovery Plant: performance testing
Elements (e.g. continuous according to methods 6, 6A or 6C; CEMS
monitoring, stack surveys, for exhaust stream of control devices
modelling, etc.)
NOx CEMS or PEMS for exhaust stream of
control devices.
VOC Leak detection monitoring for ancillary
equipment; performance testing of flares and
vapour combustors; CEMS to measure
concentration of organic compounds in the
exhaust stream of control devices.
Other Benzene (glycol dehydration)- measured or
modelled
Flares – control device performance test
Flares – visible emission using method 22
Opacity using method 9 or 22, or COMS
CPMS to estimate HAPs
Overall Approach to Records must be maintained for 5 years.
Reporting (e.g. format, Reports of performance tests, start-up, shutdown and malfunction.
frequency, method)
Semi-annual compliance report and periodic monitoring report.
Specific Reporting Elements Other Results of compliance and performance tests

Estimate of % reduction of HAP emissions
from control devices once per hour
Results of any CEMS evaluations
Sources and / or Contact Code of Federal Regulation 40 CFR 60, 40 CFR 63, Texas Administrative
Information Code, Title 30
Air General Operating Permit No. 514 Oil and Gas

PN 1423 Industrial Air Emissions

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Assessment of Regulatory Quantification and Reporting

Requirements for Air Emissions from Industrial Facilities

Canadian Council of Ministers of the Environment

Marbek Resource Consultants Ltd.

November 12th, 2008

© Canadian Council of Ministers of the Environment 2009

Background and Objectives

The specific objectives of this study are to:

Compile the approaches to regulatory emission quantification and reporting requirements

Marbek Resource Consultants Ltd. Page i

In response some jurisdictions have attempted to develop overall or sectoral standards or

Marbek Resource Consultants Ltd. Page ii

Exhibit E.1: Summary of Quantification Methodologies for Major Sources of Industrial

Sector NOx SOx PM VOC Other Pollutants

Marbek Resource Consultants Ltd. Page iii

Lime Manual Stack Manual Stack Manual Stack

Natural Gas Emission Emission Emission Factors

Marbek Resource Consultants Ltd. Page iv

Variation in reporting requirements generally mirrors that of quantification requirements. Most

Potential Best Practices

Marbek Resource Consultants Ltd. Page v

Exhibit E.2: Candidate Best Practices

Category Candidate Best Practices

Conclusions and Recommendations

Our main conclusions and recommendations are as follows:

In all the international jurisdictions examined, the implementation of quantification and

Marbek Resource Consultants Ltd. Page vi

Overall Approach to Quantification and Reporting

The variety is a reflection of the different circumstances/risks associated with each

Marbek Resource Consultants Ltd. Page vii

A generic standard establishing consistent objectives, philosophy, approach, process,

A series of specific quantification and reporting standards for selected air

Marbek Resource Consultants Ltd. Page viii

Overall, there is relative consistency between jurisdictions in the emissions to be

Within sectors, there is variability in emissions coverage due to differences in processes

In developing the national framework, governments should make maximum use of

Marbek Resource Consultants Ltd. Page ix

Some form of annual summary report is common but not universal.

The national framework should seek to standardize emission quantification approaches

Auditing and Verification

The approach to auditing and verification varies considerably between jurisdictions. As

A promising approach used in Europe is to rely on independent third-party assessment

Governments should consider the possibility of using independent assessment

Marbek Resource Consultants Ltd. Page x

There is currently no systematic sharing of facility level compliance information

Marbek Resource Consultants Ltd. Page xi

EXECUTIVE SUMMARY ........................................................................................................... I

Appendix A: Detailed Profiles of Requirements by Sector – Canadian Jurisdictions

1.2 PROJECT OBJECTIVES AND SCOPE

The specific objectives of this study are to:

Compile the approaches to regulatory emission quantification and reporting requirements

Marbek Resource Consultants Ltd. Page 1

Continuous emission monitoring systems (CEMS)

1.3 INFORMATION GATHERING APPROACH AND RESTRICTIONS ON

Marbek Resource Consultants Ltd. Page 2

Exhibit 1.1: Major Industrial Activities

Marbek Resource Consultants Ltd. Page 3

A “natural gas storage facility” is a facility that stores,

Marbek Resource Consultants Ltd. Page 4

Marbek Resource Consultants Ltd. Page 5

Marbek Resource Consultants Ltd. Page 6

1.4 ORGANIZATION OF THE REPORT

Marbek Resource Consultants Ltd. Page 7