Instructions for Completing the Schedules to the Canada Gazette Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in respect of Specified

Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) – Toluene Diisocyanates

(TDIs)

NOTE

This document is intended to provide guidance only. It does not in any way supersede or modify

the Canadian Environmental Protection Act, 1999 (CEPA 1999) or any Notice issued by the Minister of Environment under Section 56 of the Act requiring the preparation and

implementation of a pollution prevention (P2) plan. In the event of an inconsistency between this document and CEPA 1999 or the P2 Notice issued by the Minister and published in the Canada

Gazette, the Act and the P2 Notice prevail.

Table of Contents

A. General Instructions ................................................................................................................ 2

B. Information on the Person or Class of Persons Subject to the Notice .................................... 4

C. Substance and Activity Information......................................................................................... 5

D. Achievement of Risk Management Objectives and Accounting of Factors to Consider ....... 20

E. Certification ........................................................................................................................... 21

F. Waiver of the Requirement to Consider a Factor or Factors ................................................ 21

G. Time Extension to Prepare or Implement a Pollution Prevention Plan ................................. 22

H. Confidential Business Information......................................................................................... 23

I. Useful links............................................................................................................................ 23

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A. General Instructions These instructions are designed to accompany the “Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene)”, specifically for Toluene Diisocyanates (TDIs), referred to as “the Notice” throughout this document. Certain forms must be submitted to the Minister of the Environment by the deadlines specified in the Notice. These forms are:

Schedule 1: Declaration that a Pollution Prevention Plan Has Been Prepared and Is Being Implemented – Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) – Toluene Diisocyanates (TDIs) [Subsection 58(1) of CEPA 1999]. Schedule 1 is due on December 26, 2012.

Schedule 2: Request for Waiver of the Requirement to Consider a Factor or Factors –

Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) – Toluene Diisocyanates (TDIs) [Subsection 56(5) of CEPA 1999]. In the event that a person subject to the Notice is of the opinion that it is not reasonable or practicable to consider one or more of the factors specified in the Notice, that person may request a waiver of that factor from the Minister of the Environment by submitting a Schedule 2.

Schedule 3: Request for Time Extension – Pollution Prevention Planning Notice in Respect

of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) – Toluene Diisocyanates (TDIs) [Subsection 56(3) of CEPA 1999]. A person subject to the Notice may submit a request for an extension of the time specified in the Notice to prepare or implement a pollution prevention plan. In such cases, the person subject to the Notice must complete and submit a Schedule 3 to the Minister of the Environment.

Schedule 4: Interim Progress Report – Pollution Prevention Planning Notice in Respect of

Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Related to the Polyurethane and Other Foam Sector (except Polystyrene) – Toluene Diisocyanates (TDIs). Interim Progress Report #1 is due on November 26, 2013. Interim Progress Report #2 is due on November 26, 2014.

Schedule 5: Declaration that a Pollution Prevention Plan Has Been Implemented – Pollution

Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the

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Schedule 5 is due on December 26, 2015.

Online Reporting Forms referred to in the Notice (Schedules 1 to 5) are to be filled out electronically using the Pollution Prevention Planning Online Reporting Tool found in the Pollution Prevention (P2) Planning section of Environment Canada’s Web site. Once at the Web site, select “Report Online for Pollution Prevention Planning Notices” from the side menu bar. For guidance on how to complete these forms electronically and submit online using the Pollution Prevention Planning Online Reporting Tool, please refer to the “Information Sheet: Using the P2 Planning Online Reporting Tool to Submit a Schedule” found under the “Pollution Prevention Planning Support Tools” side menu bar option.

Amendments In the event that information submitted in any Declaration or Interim Progress Report becomes false or misleading, an amended Declaration or amended Interim Progress Report must be filed within 30 days from the time that the information has become false or misleading. Amendments to a previously submitted Schedule may be filled out electronically using the Pollution Prevention Planning Online Reporting Tool. Once at the Web site, select “Report Online for Pollution Prevention Planning Notices” from the side menu bar, then select “Report” and choose the Schedule listed at the bottom of the screen that you wish to amend and click “Amend”. Indicate if this is an amendment to a previously filed Declaration or Interim Progress Report. If it is an amendment, you must specify the Part(s) of the Schedule that you are amending and reason(s) for each amendment. Also, you must complete Parts 1.0 and 9.0 and make changes to any other Parts where previously reported information has become false or misleading. The rest of the previously reported information will remain unchanged. Public Disclosure of Information For all Pollution Prevention Planning Notices, the submitted Schedules 1, 4 and 5, and amendments to such Schedules (where applicable) will be posted on the P2 Planning section of Environment Canada’s Web site. Certification, general contact and technical contact information will not be published. As much of the information required in the Schedules is common or similar, these instructions provide part-by-part rather than form-by-form guidance. The beginning of each section of these instructions outlines those Schedules to which the information in that part of the Schedule applies. In addition, the numbering within each section of these instructions is the same as the numbering used in the Schedules to which the information in that part of the Schedule applies.

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B. Information on the Person or Class of Persons Subject to the Notice The information described in this section is collected in Part 1.0 of all Schedules. 1.0 Information on the Person or Class of Persons Subject to the Notice Name of the Person or Class of Persons Subject to the Notice Enter the company name. If you own or operate more than one reporting facility, please ensure that the same name is used consistently for all facilities. Facility1 Name Enter the name of the facility. If the “Name of the Person or Class of Persons Subject to the Notice” alone completely identifies the facility, reenter it. If you own or operate more than one facility that is subject to the Notice, please ensure you specify the unique name for that facility and file a separate Schedule for each individual facility. Street Address of Facility, City, Province/Territory, Postal Code Enter the street name and number, street type, street direction, and other identifiers such as unit number, suite number or building designation (for example, Building A). For rural addresses, where a street address is not available, enter the lot and concession numbers. Enter the name of the city, town, village, district or township, the province or territory, and the postal code where the facility is located. Because this is a location identifier, do not use a post office box or mailing address (if different from the street address). Telephone Number (with area code) Enter a telephone number (with the area code) for the facility. Email If available, enter an email address for the facility. Mailing Address of Facility, City, Province/Territory, Postal Code If the facility’s mailing address is different from the facility’s street address, enter the post office box or mailing address information, as well as the name of the city, town, village, district or township, the province or territory, and the postal code in the appropriate fields. If the mailing address is the same as the street address, leave this field blank. National Pollutant Release Inventory Identification (ID)-optional Facilities that submit a National Pollutant Release Inventory (NPRI) report are assigned a permanent NPRI identification (ID) number. If this facility has an NPRI ID number, enter it here. The NPRI ID is specific to the facility and does not change, even if the ownership of the facility has changed. If you do not have an NPRI ID number, leave this field blank. North American Industry Classification System (NAICS) Code-optional Enter the six-digit NAICS code for this facility. Statistics Canada provides complete details of NAICS Canada on its Web site.

1 A “facility” refers to all buildings, equipment, structures and other stationary items that are located on a single site or on contiguous or adjacent sites that are owned or operated by the same person and function as a single integrated site.

Facility Technical Contact Enter the name and telephone number (with area code) of the facility’s technical contact. If available, enter the email address and facsimile number (with the area code) of the facility’s technical contact. It is recommended that the technical contact be a representative who can be contacted by Environment Canada for clarification of information submitted in the Schedule(s). This person should be familiar with and be able to answer questions about the information provided. The technical contact will receive all information, mailings and inquiries from Environment Canada. The name and contact information for the technical contact will not be posted electronically. General Contact Information Please enter a General Contact name and information for the facility. This General Contact Information for the facility could be used by Environment Canada to correspond with your facility on items related to your facility registration and password required for logging into the P2 Planning Online Reporting Tool and online reporting. Please ensure your General Contact Information for the facility is kept up-to-date. This information will not be posted online. For Schedule 1 only: 2.0 Use of Plans Prepared or Implemented for Another Purpose A pollution prevention plan prepared or implemented for purposes other than to comply with this Notice may be used as long as it fulfills all the requirements of this Notice. If the existing plan does not meet all the requirements, it can either be updated so that it meets the requirements or a new pollution prevention plan that meets the requirements can be prepared and implemented. Indicate if you are satisfying the requirements of this Notice using a pollution prevention plan previously prepared voluntarily or to comply with other legal requirements, such as for another government or another Act of Parliament. If yes, identify the legal requirement(s). Examples of other legal requirements for which a pollution prevention plan may have been prepared are municipal by-laws, provincial regulations, court orders and EPAM (environmental protection alternative measures).

C. Substance and Activity Information The information described in this section is collected in Parts 3.0 through 7.0 of Schedules 1, 4 and 5. 3.0 Substance and Activity Toluene diisocyanates (TDIs) refer to one or more of the following substances: Benzene, 1,3-diisocyanato-2-methyl- or 2,6-TDI [Chemical Abstracts Service Registry

Number (CAS RN) 91-08-7)]; Benzene, 2,4-diisocyanato-1-methyl- or 2,4-TDI (CAS RN 584-84-9); or Benzene, 1,3-diisocyanatomethyl- or mixtures of 2,6-TDI and 2,4-TDI (CAS RN 26471-62-5).

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Indicate the name of the substance and corresponding activity on which you are reporting. You need to choose all the possible combination of substance and activities that apply to your facility. Once you do that, you will be prompted to fill out the required information in the Schedules for each combination of substance and activity you have selected.

TDIs & Manufacturing of flexible slabstock foam (including TDIs storage in tanks and cutting and shaping of foam)

TDIs & Manufacturing of flexible moulded foam (including TDIs storage in tanks and cutting and shaping of foam)

TDIs & Manufacturing of rigid foam (including TDIs storage in tanks and cutting and shaping of foam)

TDIs & Manufacturing of structural foam (including TDIs storage in tanks and cutting and shaping of foam)

TDIs & Rebonding of foam (including cutting and shaping of foam) Note that Parts 3.0 through 7.0 must be completed separately for each applicable combination of substance and activity identified in Part 3.0. In a case where a substance is used in more than one activity, report that substance separately for each activity. 4.0 Baseline Information Prior to Implementation of the Pollution Prevention Plan Note a): National Pollutant Release Inventory (NPRI) The NPRI is used as a basis for developing the requirements for the baseline information collected in Parts 4.1, 4.3 and 4.4 of Schedules 1, 4 and 5. If you already report to the NPRI, you may find that data previously collected for NPRI reporting can be used to complete some or all of these Parts. Note b): “Basis of Estimate Codes” “Basis of Estimate Codes” provide information about how you determined the quantity of a substance that was used, released or transferred. Whenever a quantity is reported in Part 4.0 of a Schedule, a Basis of Estimate Code must be provided. The codes for the methods of estimating uses, releases or transfers are listed below (Note: the same codes are used for NPRI reporting). For more information, see the NPRI Reporting Guide. If none of the codes listed below describe the method for estimating uses, releases or transfers, please select X - Other and specify the method used in the field provided.

M1 - Continuous Emission Monitoring Systems (CEMS) - record emissions over an extended and uninterrupted period. Once the concentration and the flow rate have been determined, emission rates can be calculated by multiplying the concentration by the discharge flow rate or volumetric stack gas flow rate. Annual emissions of the substance can then be estimated by multiplying the concentration by the annual flow rate of the discharged effluent or gases in the stack or duct.

M2 - Predictive Emission Monitoring (PEM) - is based on developing a correlation between substance emission rates and process parameters (e.g., fuel usage, steam production, furnace temperature). PEM may be considered a hybrid of continuous monitoring, emission factors and stack tests. A correlation test must first be performed to determine the relationship between emission rates and process parameters. Emissions can then be calculated or predicted using

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process parameters to predict emission rates based on the results of the initial source test.

M3 - Source Testing - involves collecting a sample of the emission or effluent, then determining the concentration of one or more substances in the sample. The concentration of the substance(s) of interest is then multiplied by the volumetric flow rate to determine the amount of the substance(s) emitted over time. Source testing of air emissions generally involves inserting a sample probe into the stack or duct to collect a volume of exhaust effluent isokinetically. The substances collected in or on various media are subsequently analyzed. For liquid effluents, grab samples or 24-hour composite samples are extracted from the effluent stream.

C - Mass Balance - involves applying the law of conservation of mass to a facility, process or piece of equipment. If there is no accumulation, then all the materials that go into the system must come out. Releases are determined from the difference in the input, output, accumulation and depletion of a substance.

E1 and E2 - Site-specific and Published Emission Factors - Generally, emission factors relate the quantity of substances emitted from a source to some common activity associated with those emissions. Emission factors may be published or developed by facilities using emission-testing data and source-activity information. For a particular piece of equipment, specific emission factors may be available from the manufacturer or sales centre. When completing the report, you must specify whether a site-specific emission factor (E1) or published emission factor (E2) was used.

O - Engineering Estimates - In many cases, sound engineering assessment is the most appropriate approach to determining process factors and base quantity values. Releases can be estimated from engineering principles and judgment by using knowledge of the chemical and physical processes involved, the design features of the source, and an understanding of the applicable physical and chemical laws. The reliability of these estimates depends on the complexity of the process and the level of understanding of its physical and chemical properties.

Note: If more than one Basis of Estimate Code is used to calculate a single quantity, enter the Basis of Estimate Code corresponding to the method that applies to the largest portion of the estimated releases or transfers. Note c): Reporting Period Each Schedule requires reporting of data for a full year (from November 26 to November 25). Reference is made to different reporting years throughout these instructions:

1) The Preparation Year refers to the year the Plan was prepared and the first year of reporting. If you are completing Schedule 1, the data you are reporting corresponds to the Preparation Year.

2) The Reporting Year refers to the year you are reporting data for the Interim Progress Reports (Schedule 4). If you are completing Schedule 4, the data you are reporting corresponds to the Reporting Year for either the Interim Progress Report #1 or the Interim Progress Report #2.

3) The Implementation Year refers to the final year of reporting. If you are completing Schedule 5, the data you are reporting corresponds to the Implementation Year.

If you are subject to the Notice on the date of publication of the Notice, the main milestones for the preparation and implementation of the P2 Plan are listed in the Table 1.

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Table 1 - Milestones for the preparation and implementation of the P2 Plan for facilities subject to the Notice on the date of publication of the Notice

Milestones Period from the Date of Publication

of Final Notice

Deadlines to Prepare and

Implement the Plan

Due Date to Submit Schedules

Date of Publication of Final Notice in the Canada Gazette, Part I — November 26, 2011

Preparation of P2 Plan 12 months November 26, 2012 Schedule 1 due on December 26, 2012 (reporting of data from November 26,

2011 to November 25, 2012)

Interim Progress Report #1 24 months Schedule 4 due on November 26, 2013 (reporting of data from November 26,

2012 to November 25, 2013)

Interim Progress Report #2 36 months Schedule 4 due on November 26, 2014 (reporting of data from November 26,

2013 to November 25, 2014)

Implementation of P2 Plan 48 months November 26, 2015 Schedule 5 due on December 26, 2015 (reporting of data from November 26,

2014 to November 25, 2015)

For new or existing facilities that meet the criteria of person or class of persons subject to the Notice after the date of publication of the Notice, the deadlines to prepare and implement a P2 Plan and due dates to submit Schedules vary depending on the date the facilities become subject to the Notice. An example is given in the Table 2.

Table 2 – Example of milestones for the preparation and implementation of the P2 Plan for facilities subject to the Notice after the date of publication of the Notice

Milestones Period from the Date the Person or Facility becomes

Subject to the Notice

Deadlines to Prepare and

Implement the Plan

Due Date to Submit Schedules

Date of Publication of Final Notice in the Canada Gazette, Part I — November 26, 2011

Example of date of when a facility becomes subject to the Notice (after the Date of publication of the Notice in the Canada Gazette, Part I)

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— July 23, 2015

Preparation of P2 plan 12 months July 23, 2016 Schedule 1 due on August 23, 2016 (reporting of data from July 23, 2015 to

July 22, 2016)

Interim Progress Report #1 24 months Schedule 4 due on July 23, 2017 (reporting of data from July 23, 2016 to

July 22, 2017)

Interim Progress Report #2 36 months Schedule 4 due on July 23, 2018 (reporting of data from July 23, 2017 to

July 22, 2018)

Implementation of P2 plan 48 months July 23, 2019 Schedule 5 due on August 23, 2019 (reporting of data from July 23, 2018 to

July 22, 2019)

If you have applied for and received a response granting a time extension that subsequently affects the year for which you must report, indicate the new year for which you are reporting. If you are reporting data that covers more than one calendar year (For example: reporting of data from July 23, 2015 to July 22, 2016), then assign the “new year” based on the year for which you began reporting (e.g. 2015). Please provide your start and end date representing one full year’s duration (e.g. 2015-07-23 to 2016-07-22). All references to the reporting year in the Schedules correspond to the new year that you have identified. 4.1 Nature of Activity Indicate whether the substance was manufactured, distributed, processed or otherwise used at this facility for the time period for which you are reporting. You may identify more than one activity. Select all the activities that apply to your facility. If required, provide a description to further clarify the identified nature of activities. Descriptions of activities are provided below. Manufacture The term “manufacture” means to produce, prepare or compound the substance. This also includes the incidental production of the substance as a by-product as the result of the manufacture, processing, use or treatment of other substances, products or materials. For example, the substance may result from treatment of wastewater or other treatment processes. If this facility manufactured the substance, select at least one of the following: For on-site use/processing — Substance was manufactured and then further processed or used at

the same facility. For sale/distribution — Substance was manufactured specifically for sale or distribution outside the

facility. As a by-product — Substance was produced incidentally and released to the environment or

transferred off-site for disposal. As an impurity — Substance was produced incidentally and remained in the product destined to be

distributed in commerce. Description — Provide a description to further clarify the identified nature of activities.

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Process The term “process” means the preparation of the substance, after its manufacture, for distribution in commerce, or the use of the substance as part of a chemical, physical or biological process. Processing includes the preparation of the substance with or without change in physical or chemical form. The term also applies to the processing of materials, mixtures or formulations that contain the substance as one component. During processing, the substance is generally not separated from the product. If this facility processed the substance, select at least one of the following: As a reactant — Substance was used in chemical reactions for the manufacture or processing of

another substance or product. This includes, but is not limited to, feedstock, raw materials, intermediates, catalysts and nutrients added to wastewater systems.

As a formulation component — Substance was added to a product (or product mixture) before further distribution of the product. Examples of substances used in this capacity include, but are not limited to, additives, dyes, reaction diluents, initiators, solvents, inhibitors, emulsifiers, surfactants, lubricants, flame retardants and rheological modifiers.

As an article component — Substance became an integral component of an article distributed for industrial, trade or consumer use. An example is ethylene glycol added to vehicle radiators during assembly.

Repackaging only — Substance (or mixture containing the substance) was processed or prepared for distribution in commerce. This also includes transferring the substance to and from bulk containers.

As a by-product — Substance was incidentally processed and was released to the environment or transferred off-site for disposal.

Description — Provide a description to further clarify the identified nature of activities. Distribution The term distribution means to distribute or sell the substance or a product containing the substance. If this facility sold or distributed the substance, select at least one of the following: Sold or distributed on its own — Substance was sold or distributed on its own (not as a component of or ingredient in a product). Sold or distributed as part of a product — Substance was sold or distributed as a component of or

ingredient in a product or product mixture (not on its own). Description — Provide a description to further clarify the identified nature of activities. Other use “Other use” encompasses any activity involving the substance and relevant to the purposes of the facility that does not fall under the definitions of “manufacture,” “process” or “distribution.” As an example, if this facility cleaned equipment with the substance, it would be considered under the category “other”. If this facility used the substance in a manner that falls under the category “other”, select at least one of the following: As a physical or chemical processing aid — Substance was added to a mixture to aid in the

manufacture or synthesis of another substance but was not intended to remain in or become a component of or ingredient in the product or product mixture. Examples include, but are not limited to, process solvents, catalysts, inhibitors, initiators, reaction terminators and buffers.

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As a manufacturing aid — Substance aided the manufacturing process but did not become a component of or ingredient in the resulting product and was not added to the mixture during the manufacture of a product or during synthesis of another substance. Examples include, but are not limited to, process lubricants, metal-working fluids, coolants, refrigerants and hydraulic fluids.

Ancillary or other use — Substance was used at a facility for purposes other than as a chemical processing aid or manufacturing aid. This includes, but is not limited to, equipment cleaners, degreasers, fuels, flocculants and waste treatment. As a by-product — Substance was incidentally present in a material that was otherwise used at the facility and released to the environment or transferred off-site for disposal.

Description — Provide a description to further clarify the identified nature of activities. Note: Throughout the instructions for Parts 4.2 and 4.4, Parts that are modeled on NPRI reporting requirements are marked with “(NPRI)”. 4.2 On-site Uses “On-site” means within the property boundaries of the facility. Indicate if this facility used the substance on-site in the reporting year(s). If yes, report the total quantity of all on-site uses of the substance, in kilograms (kg), for that year, and the Basis of Estimate Code (see Part 4.0, Note b) in the appropriate field in the table. Indicate how the substance was used. If no, proceed to Part 4.3 (On-site Releases). 4.3 On-site Releases: On-site releases data to be reported in Part 4.5 No data is required for Part 4.3. For this Notice, “On-sites Releases” are to be reported in Part 4.5. 4.4 Off-site Transfers 4.4.1 Off-site Transfers for Distribution Indicate if this facility transferred the substance to off-site locations for its distribution as a product or part of a product in the reporting year(s). If no, proceed to Part 4.5 (Additional Information — On-site Industrial TDIs Emissions). All types of transfers for distribution: Report the quantities of each transfer of the substance for distribution, indicating the Basis of Estimate Codes for the methods used to derive those values. Types of transfers for distribution are described in the box below. Calculate the sum of these transfers to obtain the total amount transferred for distribution from this facility. If known, report the expected use of the substance or a product containing the substance by your client and the expected disposal method.

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Types of transfers for distribution: Substance on its own — The substance is distributed on its own. As a component of or ingredient in a product — The substance is distributed as a component of or ingredient in a product. 4.4.2 Off-site Transfers for Disposal — No data required for Part 4.4.2 No data required in this Part for this Notice. 4.4.3 Off-site Transfers for Recycling — No data required for Part 4.4.3 No data required in this Part for this Notice. 4.5 Additional Information — On-site Industrial TDIs Emissions These instructions apply to Part 4.5 of the Schedules 1, 4 and 5. Part 4.5 is used to collect additional information related to On-site Industrial TDIs Emissions for the reporting year(s). Figure 1 below presents a flowchart that summarizes the requirements in paragraph 4(1)(c) of the Notice to be reported in Part 4.5 of the Schedules 1, 4, and 5.

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Figure 1 – Flowchart of requirements in paragraph 4(1)(c) of the Notice to be reported in Part 4.5 of the Schedules 1, 4, and 5

4.5.2 Air Concentration of TDIs at or beyond the Facility Boundaries If you chose the option stated in subparagraph 4(1)(c)(i) of the Notice to predict TDIs concentration in ambient air using AERMOD, report all information required in this part of the schedules. As stated in the Notice, it is recommended that the provincial or territorial guidelines for compliance with the AERMOD dispersion model requirements be taken into account, wherever applicable. 4.5.3 Actual On-site Releases of TDIs to Air If you chose the option stated in subparagraphs 4(1)(c)(ii), 4(1)(c)(iii), and 4(1)(c)(iv) of the Notice to measure or estimate actual on-site releases of TDIs to air, report the quantities of each type of release of the substance to air, indicating which of the measurement methods or estimation

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methods listed in the Notice was used to derive those values. Types of releases to air are described in the box below. Calculate the sum of these releases to obtain the total amount released to air on-site from this facility. Note: Both routine releases, such as fugitive releases to air, and accidental or non-routine releases, such as a relief valve opening due to process upset, should be included in your estimate of the quantity released. Types of releases to air: Stack or point releases — Releases from stack or point sources, including stacks, vents, ducts, pipes or other confined streams. Releases to air from pollution control equipment generally fall into this category. Storage tanks or handling releases — Releases to air from storage or handling of the substance. Fugitive releases — Releases to air that are not released through confined streams. These releases include: fugitive equipment leaks from valves, pump seals, flanges, compressors, sampling

connections, open-ended lines, etc.; releases from building ventilation systems; and any other fugitive or non-point air emissions from land treatment, mine tailings,

storage piles, etc. Spills — Accidental releases of the substance that result in releases of the substance to air that do not qualify as point or non-point air releases. Other releases — Any other releases to air not estimated in one of the above air-related release types. If you select Other releases, please specify. 5.0 Actions and Results These instructions are designed to provide direction for completing Part 5.0 in the Schedules 1, 4, and 5. Titles and headings in this part of the instructions represent those found in all Schedules. Therefore, headings in a particular Schedule may be slightly different from those found in these instructions to reflect the type of data required in that Schedule (e.g., anticipated results, results achieved to date and results achieved).

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In Schedule 1, Part 5.0 requires you to enter the “anticipated” changes to uses, releases or

transfers of the substance that you intend to achieve through implementing a Pollution Prevention Plan.

In Schedule 4, Part 5.0 requires you to enter the changes you have achieved as of the date

that you submit this report, to illustrate the progress you have made in implementing the Plan.

In Schedule 5, Part 5.0 requires you to report the final changes to uses, releases or

transfers of the substance achieved by the Pollution Prevention Plan, after completing the implementation of the Plan.

Parts 5.1.1 through 5.1.6 must be completed separately for each individual action identified in the P2 Plan, i.e. Part 5.1 will be completed as many times as there are actions in the Plan to report on. 5.1 Actions Part 5.1 summarizes the actions that you plan to take or have already taken in implementing the Pollution Prevention Plan in order to work towards achieving the risk management objective as specified in the Notice. The following is a description of the information required in each section. Describe for the activity identified in Part 3.0 of this Schedule, the current status of the action taken to date in implementing the Pollution Prevention Plan. That is, indicate if the action is:

“Planned/to be initiated”; “In progress”; “Completed”; or “Discontinued”.

Please complete for each action that was reported in your last submitted Schedule. If the action is "Discontinued", please provide the reason why you will no longer be carrying out this action for the activity. 5.1.1 Action Describe each action that you plan to implement or have already implemented in the Pollution Prevention Plan (for example, Action 1: “Implemented ‘first-in–first-out’ stock management,” Action 2: “installed overflow alarms and relief valves”, etc.). If you are required to file multiple Interim Progress Reports, you are required to report new actions taken since your last report and any updates to actions previously reported on. For example, when completing the second Interim Progress Report you must report actions taken since you submitted the first Interim Progress Report and not all actions taken to date in implementing your Plan. Similarly, in Schedule 5 you must report those actions taken since your last Interim Progress Report. However, you must report updates, if there are any, on all actions taken to date.

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In Parts 5.1.2 and 5.1.3, identify whether the action taken to date represents a pollution prevention method or other environmental protection method by selecting from the list of options provided. You must select at least one type of pollution prevention or environmental protection method. If you select “Other”, please specify. 5.1.2 Types of Pollution Prevention Methods If the action identified in 5.1.1 utilizes a pollution prevention (P2) method, indicate the type of method used, choosing from the list provided. More than one P2 method can be used. Alternatively, no P2 method may be applicable. P2 methods are described in the box below. Types of Pollution Prevention Methods:

Materials or feedstock substitution — Replacing polluting substances or materials used in a process or a product with non-polluting or less polluting substances, materials and feedstock (for example, using aqueous-based cleaners rather than solvent-based cleaners; using a non-toxic detergent to clean glassware rather than chromic acid). Product design or reformulation — Preventing the pollution associated with the entire life cycle of products through design of new products and redesign or reformulation of old ones (for example, reducing or eliminating the use of toxic substances by changing product specifications, modifying design or composition of products). Equipment or process modifications — Introducing new technologies or approaches to existing operating systems, processes and practices to improve production efficiencies and reduce pollution generated and materials, energy or water wasted (for example, changing to mechanical stripping/cleaning devices from solvents; using more efficient spray-paint systems; instituting re-circulation within a process). Spill and leak prevention — Using measures to prevent accidental and chronic releases such as leaks of a substance (for example, installing splash guards and drip trays around equipment, such as solvent sinks, hot tanks and jet-spray washers, to collect and return drainage and contain leaks and spills). On-site reuse, recycling or recovery — Reusing, recycling and recovering within the property boundaries of where an activity has taken place (for example, using a small distillation unit to reclaim solvents; recovering metals by ion exchange, reverse osmosis). Inventory management or purchasing techniques — Integration of environmental considerations into inventory management systems and into existing and new purchasing practices (for example, avoiding the unnecessary generation of waste by ensuring that materials do not stay in inventory beyond their shelf life; instituting a clearinghouse to exchange materials that would otherwise be discarded). Good operating practices or training — Improving operating efficiencies and training and encouraging staff to recognize pollution prevention opportunities (for example, changing production schedules to minimize equipment and feedstock changeovers; improved maintenance scheduling; implementing good housekeeping practices; training staff to improve materials handling).

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Other (specify) — Other methods that result in preventing or avoiding the creation of pollutants and waste. If you select Other, please specify. 5.1.3 Other Types of Environmental Protection Methods If the action identified in 5.1.1 utilizes an environmental protection method other than a P2 method, indicate the type of method used, choosing from the list provided. More than one environmental protection method can be used. Alternatively, no other environmental protection method may be applicable. Descriptions of the other environmental protection methods are listed in the box below. Types of Environmental Protection Methods: Energy recovery — Using a waste with sufficient energy content as a fuel for energy recovery to offset the need for additional energy (for example, recovery of methane from landfills). Off-site recycling — Recycling of materials at a place outside the property boundaries of where an activity has taken place (for example, transfer of paper products to another facility for recycling into new paper products). Incineration with energy recovery — Thermal treatment of wastes and recovery and use of the resulting energy to offset the need for additional energy (for example, incinerating waste and using the resulting heat to heat building air and/or water). Waste treatment — Processing of waste to render it less harmful or harmless to the environment (for example, bio-oxidation, evaporation, precipitation, neutralization). Pollution control — Addition of equipment to the end of a system to collect pollutants prior to their release into the environment (for example, addition of filters to collect dust prior to release). Disposal — Final disposal in such a way as to cause the least amount of harm to the environment (for example, landfill of biodegradable materials, containment of wastes containing the substance). Other (specify) — Other methods that result in environmental protection. If you select Other, please specify. 5.1.4 Anticipated Changes / Changes Achieved Report the anticipated/achieved annual increase or decrease in the quantity/concentration of substance used, released or transferred from this facility resulting from implementation of the action described in Part 5.1.1, if possible. Note that predicting a quantitative change for some actions, such as training, may not be possible. In such cases, report whether the action anticipated/achieved an increase (“+”) or decrease (“-“) in the substance used, released or transferred, without specifying the quantity.

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5.1.5 Baseline Elements Affected Describe which baseline elements (as reported in Part 4.2, 4.4 and 4.5) are affected by the changes reported in Part 5.1.4. More than one baseline element may be chosen, as many actions will affect more than one baseline element. Baseline elements are listed in the box below. Baseline Elements Total on-site uses Total off-site transfers for distribution On-site Industrial TDIs Emissions

5.1.6 Planned Completion Date Provide the date on which the action is anticipated to be or was fully implemented. 5.2 Total Results Anticipated/Achieved To Date/Achieved Part 5.2 requires reporting results relative to the Preparation Year. Depending on the Schedule you are completing, report the total anticipated/achieved change in uses and transfers of the substance relative to the Preparation Year levels. Schedule 1: In the first column, report the total anticipated change from implementing all the anticipated actions described in Part 5.1. In the second column, report the anticipated change as a percentage of Preparation Year for uses and transfers.

Schedules 4 and 5: In the first column, report the total change from implementing all actions taken since initiating the implementation of the Pollution Prevention Plan. In the second column, report the change as a percentage of Preparation Year for uses and transfers. For example, consider the following annual uses: The change achieved by 2015 relative to the Preparation Year is:

250 kg – 1250 kg = –1000 kg; this would be reported in the first column; and –1000 kg/1250 kg x 100% = –80%; this would be reported in the second column.

Reporting Year Uses Preparation Year, 2012 (from November 26, 2011 to November 25, 2012)

1250 kg

Implementation Year, 2015 (from November 26, 2014 to November 25, 2015)

250 kg

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Total changes must be reported in units specified and as a percentage using a negative sign (“-“) before the reported total to denote a decrease or a positive sign (“+”) to denote an increase. 5.3 Detailed Anticipated/Achieved Results Information Instructions provided in this section apply to Part 5.3 of the Schedules 1, 4 and 5. Part 5.3 is used to collect additional information on anticipated/achieved results necessary to evaluate the achievement of the risk management objective that is not already collected in Part 5. The information pertains to the reporting year to which each of the Schedules corresponds. Complete the following part of the Schedule that is applicable to your facility, based on your responses to Part 4.5.1 of the Schedule. 5.3.1 Detailed Anticipated Results/Results Achieved to Date/Results Achieved for the Air

Concentration of TDIs at or beyond the Facility Boundaries This part must be completed by facilities that chose the option to predict TDIs concentration in ambient air using AERMOD stated in subparagraph 4(1)(c)(i) of the Notice. Otherwise, proceed to Part 5.3.2 of the Schedule. Use the results of TDIs concentration in ambient air identified in Part 4.5.2 of the Schedule to fill out the table and report information relative to the reporting year(s). Report the total changes anticipated to be achieved/changes achieved by implementing ALL the actions anticipated to be taken/taken to date/taken as described in Part 5.1 of the Schedule. Total changes must be reported in units specified and as a percentage using a negative sign (“-“) before the reported total to denote a decrease or a positive sign (“+”) to denote an increase. 5.3.2 Detailed Anticipated Results/Results Achieved to Date/Results Achieved for Actual On-site

Releases of TDIs to Air This part must be completed by facilities that chose the option to measure or estimate actual on-site releases of TDIs to air stated in subparagraphs 4(1)(c)(ii), 4(1)(c)(iii), and 4(1)(c)(iv) of the Notice. Use the results of actual on-site releases of TDIs to air identified in Part 4.5.3 of the Schedule to fill out the table and report information relative to the reporting year(s). Report the total changes anticipated to be achieved/changes achieved by implementing ALL the actions anticipated to be taken/taken to date/taken as described in Part 5.1 of the Schedule. Total changes must be reported in units specified and as a percentage using a negative sign (“-“) before the reported total to denote a decrease or a positive sign (“+”) to denote an increase.

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6.0 Monitoring and Reporting Describe the monitoring and reporting used to track progress in implementing the Pollution Prevention Plan. This may include: activities monitored (for example, stack testing); performance indicators to track progress (for example, percentage of emission reduction per

year); how monitoring will be/has been performed frequency of monitoring (for example, weekly or monthly); and reporting mechanism and frequency (for example, reporting to the facility’s Environmental

Manager at six-month intervals).

D. Achievement of Risk Management Objectives and Accounting of Factors to Consider The information described in this section is collected in Parts 7.0 and 8.0 of Schedules 1, 4 and 5. 7.0 Risk Management Objective The risk management objective is the desired environmental aim, goal or outcome to reduce the risk posed to the environment and human health by the release of a substance. Environment Canada’s risk management objective for TDIs is stated in column 6 of the Table in section 3 of the Notice. In Schedule 1 and Schedule 5, briefly describe how the Pollution Prevention Plan will meet/has met the risk management objective for TDIs. If the Plan does not meet the risk management objective, explain why. 8.0 Factors to Consider The Notice states the factors that you must consider while preparing and deciding which actions to take in your Pollution Prevention Plan. You must report on the “Substance-specific factors to consider in preparing the Plan” in paragraphs 4(1)(b) and 4(1)(c) of the Notice and the “Other factors to consider in preparing the Plan” in subsections 5(1) and 5(2) of the Notice. Briefly describe what has been done in the reporting year to take into account these factors to consider during the preparation/implementation of the Plan. If applicable, describe any additional details or changes in how these factors were taken into account, except those factors for which a waiver has been granted by the Minister of the Environment. Refer to section F of these instructions for information on applying for a waiver of the requirement to consider a factor to consider.

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8.1 Exceedance of Emission or Concentration Thresholds for TDIs Part 8.1 of Schedules 1, 4 and 5 must be completed only by facilities that exceed the emission or concentration thresholds for TDIs. Indicate if your facility, at any time within the period to implement the Plan, released to air more than 100 kg per year of TDIs OR had a 24-hour average concentration of TDIs at or beyond the facility boundaries greater than 0.2 µg/m3, as reported in Part 4.5 of the Schedule. If yes, describe what was done in the reporting year to take into account the “Substance-specific factors to consider in preparing the Plan” in paragraphs 4(1)(d), 4(1)(e), 4(1)(f) and 4(1)(g) of the Notice to reduce industrial TDIs emissions to the environment. E. Certification The information described in this section is collected in all Schedules (either Part 4.0 or 9.0): Part 4.0 or 9.0 Certification All schedules submitted to Environment Canada must be certified by an appropriate authority, since the person who signs the schedules is confirming that the information being reported is true, accurate, and complete. All forms submitted to Environment Canada must be signed and dated by the person subject to the Notice or a Duly Authorized Representative.2 Facilities reporting electronically must send a signed paper copy, either by fax or mail to Environment Canada. Signed paper copies can also be scanned and emailed to: LCPEPlansP2-CEPAP2Plans@ec.gc.ca

F. Waiver of the Requirement to Consider a Factor or Factors The information described in this section is collected in Parts 2.0 and 3.0 of Schedule 2. Information submitted in Schedule 2 will not be available to the public. The Notice states factors that you are to consider while developing and deciding which actions you anticipate taking in your Pollution Prevention Plan. If you do not think it is reasonable or practicable to consider one or more of the factors specified in the Notice, you may apply for a waiver of the requirement to consider factor(s). Such a request will only be considered if it is received on or before the deadline to prepare the Plan as specified in the Notice (or before the expiry of any extended period), not the deadline to submit the Schedule 1. Persons submitting requests for waivers of the requirement to consider a factor will receive a written response informing them of the Minister’s decision to grant or deny the request. Unless you submit Schedule 2 and are granted a written waiver by the Minister of the Environment, you must consider all factors identified in the Notice.

2 For example, this person might be the Chief Executive Officer, environmental coordinator or plant manager.

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2.0 Factor(s) for Which a Waiver Is Being Requested Identify exactly those factors specified in the Notice for which you are requesting a waiver for the requirement to consider. 3.0 Rationale for Request Explain the reason(s) for which you are applying for a waiver (i.e., why you believe the factor(s) specified in the Notice are not reasonable or practicable to consider). Explain how the outcome of your Pollution Prevention Plan will be affected if the factor(s) for which you are requesting a waiver of the requirement to consider is(are) not taken into account when preparing your Pollution Prevention Plan. You may also identify other alternative factors, if any, that were not specified in the Notice that you propose to consider in your Plan. This is optional.

G. Time Extension to Prepare or Implement a Pollution Prevention Plan The information described in this section is collected in Parts 2.0 and 3.0 of Schedule 3. Information submitted in Schedule 3 will not be available to the public. The Notice states the time period within which your Pollution Prevention Plan must be prepared and its implementation begun, and the time period within which your Pollution Prevention Plan must be implemented3. If you do not think it is reasonable or practicable to prepare or implement your Pollution Prevention Plan in the time allotted, you may request an extension of the time period specified in the Notice using Schedule 3. Such a request will only be considered if it is received on or before the deadline to prepare (or implement) the Plan as published in the Notice (or before the expiry of any extended period), not the deadline to submit the Schedule 1 (or Schedule 5). Persons submitting such requests will receive a written response informing them of the Minister’s decision to grant or deny the request. Note that the Minister of the Environment publishes in the Canada Gazette the name of any person for whom an extension is granted, the duration of the period of the extension, and whether the extension is for the preparation or implementation of the Plan. 2.0 Request for Time Extension Indicate which time period you are requesting to be extended (period to prepare a Pollution Prevention Plan, or period to implement a Pollution Prevention Plan). Specify the new date to which you wish the time period to be extended.

3 A Pollution Prevention Plan is implemented once all of its steps have been put into effect and all of its actions have been fully executed.

3.0 Rationale for Request Explain the reasons for which you are applying for an extension (i.e., why you believe the time period specified in the Notice is not reasonable or practicable). The Minister of the Environment will evaluate the request for a time extension based on the reasons or rationale provided in the request. H. Confidential Business Information All persons submitting information to the Minister of the Environment are entitled to submit a request under section 313 of CEPA 1999 that some or all of the information reported in the Schedule(s) be treated as confidential. Please note that the Facility Technical Contact and General Contact Information found in Part 1.0 as well as the Certification information found in Part 9.0 of the Schedules will not be publicly posted. To request that information be treated as confidential, submit a letter clearly indicating each field on the Schedule for which a confidentiality request is being made with the Schedule that you are submitting. You must also indicate the reason or justification for the request. When submitting information under Part 4 of CEPA 1999 for which a request for confidentiality is being made, do not use the online reporting tool. The following are some precautions that are advisable to take when submitting your Schedule: complete your schedule using paper forms. submit confidential material (letter requesting confidentiality and completed Schedule) in double

envelopes, excluding the courier outer envelope. do not identify “confidentiality” on the outside envelope, which should be unmarked except for

mailing and return addresses and postage. write or stamp the word “Confidential” or the phrase “Contains Confidential Information” on both

sides of the inside envelope. All such requests will be reviewed under the provisions of sections 315 to 321 of CEPA 1999 and section 20 of the Access to Information Act. For more information on the type of information that might be considered confidential business information, please refer to section 20 of the Access to Information Act.

I. Useful Links Access to Information Act: http://laws.justice.gc.ca/en/A-1/39.html NAICS Canada classification: http://www.statcan.gc.ca/subjects-sujets/standard-norme/naics-scian/2007/list-liste-eng.htm NPRI Reporting Guide: http://www.ec.gc.ca/Publications/default.asp?lang=en&xml=079E87D6-8D0E-4B1C-8476-7608AE27EA92

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Pollution Prevention Planning Online Reporting Tool: http://www.ec.gc.ca/planp2-p2plan P2 Planning section of Environment Canada’s Web site: www.ec.gc.ca/planp2-p2plan