Coming Changes to Environmental Compliance Approvals (ECAs). Is your facility ready?

Photo by Flo Dnd.

Photo by Flo Dnd.

Schedule 3 standards will apply to all facilities as of February 1st, 2020—is your facility ready?

By: Giulia Celli

As of February 1st, 2020 Schedule 3 standards will apply to all facilities and the Reg346 model will no longer be an “approved dispersion model” under O.Reg.419/05 (the Regulation). However, as of February 1st, 2019, all Environmental Compliance Approval (ECA) applications must already include Emission Summary and Dispersion Modelling (ESDM) reports showing compliance with Schedule 3 standards and using SCREEN3 or AERMOD models.

What is the difference between Schedule 2 and Schedule 3 standards?

Schedule 2 and Schedule 3 of the Regulation both provide a list of contaminants and the respective concentration of each contaminant that is not to be exceeded at a point of impingement. In the Schedule 2 list of contaminants, these limits are based on half hour averaging periods, whereas Schedule 3 limits are based on variable averaging periods. The approved dispersion model when Schedule 2 contaminants are evaluated is the Reg346 model. Schedule 3 contaminants are to be evaluated using the SCREEN3 and AERMOD models. For most facilities, Schedule 2 standards apply from January 31, 2010 to February 1, 2020. Schedule 3 standards will apply as of February 1st, 2020.

Do facilities need to update their ESDM reports now to maintain compliance?

The next time you prepare or update your ESDM report you need to ensure that the Schedule 3 standards, as well as the applicable models are used. This could occur during an annual update of an ESDM report – either as required by regulation (which is to be done each year by March 31st) or as required by a condition of an ECA. An ESDM report update may also be triggered by making any modifications to the facility or by a follow-up action from an inspection or audit.

ORTECH can help you prepare for the 2020 phase-in of Schedule 3 standards. Please contact us for more information.