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NPRI landfill waste disposal reporting requirements

A new bulletin to members from the Ontario Waste Management Association (OWMA) explains a January 17, 2004 amendmen...


A new bulletin to members from the Ontario Waste Management Association (OWMA) explains a January 17, 2004 amendment to the Canadian Environmental Protection Act (CEPA) 2003 National Pollutant Release Inventory (NPRI) Notice.

The January 17 NPRI amendment to the NPRI reporting structure (published in the Canada Gazette) changes the definitions under which reporting is required. This amendment introduced a new reporting category of "disposal of a substance to landfill." Previous years reporting requirements did not include this category. The details of the new definitions and the reporting requirements can be found at:

http://www.ec.gc.ca/pdb/npri/npri_gdocs_e.cfm

with particular reference to Schedule 4 of Notice as amended by Article 24, Page 78 of January 17, 2004 Canada Gazette.

Prior to this amendment, as a general rule, most non-hazardous solid waste landfill operators were not required to report to NPRI. As a result of the amendment, landfill operators across Canada "may" now be required to report. Reports of the quantities of listed wastes and chemicals disposed in landfills are now required if certain conditions are satisfied (as described below).

NPRI reporting is required only if ALL of the following three conditions are satisfied:

1. More than 20,000 man-hours of work occurred at the site in the reporting year. This includes managers, regular employees and contract employees. [Schedule 2, Part 1, Article 4(1)]. Contract employees are typically regular employees and do not include construction contractors, consultants, etc. The "hours" calculation must include personnel who normally work at the reporting location, even if they are not employed on work relating to the location.

2. The threshold limit for reporting has been exceeded. The Notice provides a threshold quantity for each parameter or waste listed above which the reporting requirement is triggered. For example, in the case of friable asbestos, the limit is 10 tonnes in the reporting year. [Schedule 1, Part 1, Group 1 Substance # 18; and Schedule 2, Part 1, Table 1]. In most cases, minimum concentration criteria also apply. Some operators have chosen to describe entire loads containing such listed substances as consisting entirely of that substance. This procedure is quite normal for such waste streams as asbestos, for example.

3. The quantity data to be reported is based on the best available information that the "person possesses" and is information which the person may reasonably be expected to have access to. [Schedule 3, General, Article 1] It is NOT a requirement to gather this data SOLELY for the purpose of NPRI reporting if it is not already being gathered for some other purpose. Therefore, you do not need to start collecting quantity data solely to comply with this amendment for NPRI reporting purposes only. Using asbestos as an example, truck load weights of loads containing asbestos are usually recorded separately at the landfill scales specifically identifying the load as containing asbestos. Under NPRI, this is "reasonable access" to this data and as such it is required to be reported. In the case of some other listed parameter, the quantity of which is not currently measured by any means, this parameter would not require reporting as "reasonable access" to this data does not exist.
Reporting Deadline Reports for 2003 data are required to be submitted to NPRI "post-marked" by June 1, 2004. On-line reporting is not yet available. Reports are required on a specific NPRI form generated by NPRI reporting software which can be found at:

http://www.ec.gc.ca/pdb/npri/npri_gdocs_e.cfm

Typical landfill parameters listed which may require reporting:

There are some 300 or so chemicals on the NPRI list on the 2003 Notice. It is unlikely, however, that reporting of more than a few parameters landfilled will be triggered by the new reporting requirement. The parameters below are the more likely candidates, again provided that the quantities of these parameters are measured or estimated for some purpose other than NPRI reporting:

Friable asbestos

Particulates – PM10 (dust)

Particulates – PM2.5 (dust)

Particulates – Total (dust)

CFCs & HCFCs (typically from onsite decommissioning of white goods where CFCs are removed onsite and transferred to an offsite location)

NOX — Nitrous Oxides

Operators should verify that they are not collecting "quantity" data for any parameter for some other purpose. If "quantity" data is being collected, reporting may be required, depending on threshold levels.

Individual site reporting responsibility:

Landfill operators should satisfy themselves as to their individual reporting responsibilities under this Notice.

If you have a question regarding the "Info Bulletin" please contact OWMA. The organization will provide a list of Associate Members who can provide professional assistance.

Contact OWMA at 905-791-9500 or contact@owma.org


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