Updates to Guideline A-5 regarding the control of air emissions from stationary combustion turbines

ERO number
019-2061
Notice type
Policy
Act
Environmental Protection Act, R.S.O. 1990
Posted by
Ministry of the Environment, Conservation and Parks
Notice stage
Decision
Decision posted
Comment period
October 13, 2020 - November 27, 2020 (45 days) Closed
Last updated

This consultation was open from:
October 13, 2020
to November 27, 2020

Decision summary

Ontario is updating its Guideline A-5 to align with recent federal guidance regarding the control of air emissions from stationary combustion turbines. These changes will enhance environmental protection by aligning with requirements for stationary combustion turbines eligible for the Air Emissions Environmental Activity and Sector Registry.

Decision details

As outlined in the Made-in-Ontario Environment Plan, Ontario is committed to protecting our air, ensuring we have strong environmental standards that are protective of human health and the environment, and taking action to enforce local air quality standards.

Ontario is updating its Guideline A-5 regarding the control of air emissions from stationary combustion turbines to align with the federal government’s guidelines. By adopting the latest federal guidelines and incorporating industry best practices, the updated guideline will reduce overall air emissions that contribute to air pollution, such as nitrogen oxides, from individual combustion turbine systems. Facilities will also benefit from streamlined expectations and reduced compliance costs.

The change will also help ensure that Ontario has consistent air emission limits with other provinces and territories across Canada that have adopted or will also be adopting the 2017 federal guidelines.

Updates to Guideline A-5

Updates to Guideline A-5 will apply to new and, under certain circumstances, modified stationary combustion turbines applying for permissions on or after July 1, 2021. Updates include:

  • changing the applicability categories of new combustion turbines by power rating and type to determine the new in-stack emission limit for nitrogen oxides
  • changing the energy quantification to a “higher heating value” basis from a “lower heating value” basis
  • lowering the in-stack emission limit of carbon monoxide from 60 parts per million by volume (ppmv) to 50 ppmv
  • streamlining the requirements for natural gas combustion turbines with power ratings of up to 25 megawatts, including:
    • subdividing the concentration-based limits for nitrogen oxides into two categories by thermal efficiency (i.e. less than 60 per cent versus 60 per cent or greater)
    • enabling the use of a portable gas analyzer for measuring the air emissions according to ASTM D6522-20
    • allowing thermal efficiency to be monitored using modern sensor devices to reduce the need for on-site testing
  • including sulphur limits in fuels and removing sulphur dioxide in-stack emission limits
  • removing provisions for the gasification of solid fuels as they are intended to be addressed in separate guidance

The technical information in the updated Guideline A-5 is consistent with operational requirements for natural gas combustion turbines that meet specified criteria in the amendments to Ontario Regulation 1/17 (Registrations Under Part II.2 of the Act – Activities Requiring Assessment of Air Emissions).

The regulatory amendments reduce burden for those operating combustion turbines that meet specified criteria by requiring registration in the EASR as opposed to obtaining an ECA and make it easier for eligible facilities to use more efficient technologies.

Background

The ministry regulates the discharge of contaminants into the air through the Environmental Protection Act (EPA) and its regulations. Guideline A-5 provides the ministry’s expectations regarding new, modified and existing stationary combustion turbines. The ministry uses the technical information in Guideline A-5 to approve stationary combustion turbines and draft terms and conditions in Environmental Compliance Approvals.

The EPA prohibits a person from operating equipment that may discharge contaminants into the air without first obtaining an Environmental Compliance Approval (ECA), and from engaging in a related prescribed activity unless the person has registered the activities in the Environmental Activity and Sector Registry (EASR). The prohibitions apply except where there are specific regulatory exemptions.

Guideline A-5 describes the technical requirements that the ministry uses as a basis to control and monitor discharge of contaminants to the air (such as nitrogen oxides and carbon monoxide), including:

  • in-stack emission limits
  • fuel specifications
  • source testing
  • continuous monitoring

By updating Guideline A-5 as described above, Ontario is aligned with:

  • Canada’s guidelines for the reduction of nitrogen oxide emissions from natural gas-fuelled stationary combustion turbines, published in 2017
  • modern technology designs and industry best practices

Comments received

Through the registry

2

By email

3

By mail

0
View comments submitted through the registry

Effects of consultation

The ministry considered all comments received during and after the posting, five comments in total.

The following is an overview of the themes in the comments received during the consultation period and the ministry’s responses:

  1. Recommendation that a mechanism to take into account cumulative impacts arising from the combined total of systems in a particular geographical area.
     

    Response: The Cumulative Effects Assessment in Air Approvals Policy decision was posted to the Environmental Registry in April, 2018 and came into effect on October 1, 2018. More information on this decision can be found in ERO notice 013-1680 (Cumulative effects assessment in air approvals). This policy strengthens and clarifies the consideration of cumulative effects when making decisions related to environmental compliance approvals and indicates when additional measures may be needed beyond current regulatory requirements.

  2. Recommendation that the ministry’s assessment of combustion turbines prior to issuing an Environmental Compliance Approval include assessment of the site-specific context of the proposal.
     

    Response: Ontario regulates contaminants released to air from various sources, including on a site-specific basis for industrial and commercial facilities, to limit exposure to substances that can affect human health and the environment. All applications for Environmental Compliance Approvals undergo a site-specific assessment by the ministry prior to issuance of an Environmental Compliance Approval.

  3. Recommendation that where appropriate the ministry include a condition in Environmental Compliance Approvals for combustion turbines that the proponent post a phone number on the facility for complaints by the public regarding the facility.
     

    Response: To register complaints, the public can call their local ministry district office or the ministry’s reporting hotline at 1-866-MOE-TIPS (663-8477).

  4. Recommendation to clarify the averaging times for portable testing.
     

    Response: The section related to monitoring averaging times was clarified in the final updated Guideline A-5.

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Original proposal

ERO number
019-2061
Notice type
Policy
Act
Environmental Protection Act, R.S.O. 1990
Posted by
Ministry of the Environment, Conservation and Parks
Proposal posted

Comment period

October 13, 2020 - November 27, 2020 (45 days)

Proposal details

As outlined in the Made-in-Ontario Environment Plan, the ministry is committed to protecting our air, ensuring we have strong environmental standards that are protective of human health and the environment, and taking action to enforce local air quality standards.

The ministry regulates the discharge of contaminants into the air through the Environmental Protection Act (EPA) and its regulations. Guideline A-5 provides the ministry’s expectations regarding new, modified and existing stationary combustion turbines. The ministry uses the technical information in Guideline A-5 to approve stationary combustion turbines and draft terms and conditions in Environmental Compliance Approvals.

The EPA prohibits a person from operating equipment that may discharge contaminants into the air without first obtaining an Environmental Compliance Approval (ECA), and from engaging in a related prescribed activity unless the person has registered the activities in the Environmental Activity and Sector Registry (EASR). The prohibitions apply except where there are specific regulatory exemptions.

Guideline A-5 describes the technical requirements that the ministry is proposing to use as a basis to control and monitor discharge of contaminants to the air (such as nitrogen oxides and carbon monoxide), including:

  • in-stack emission limits
  • fuel specifications
  • source testing
  • continuous monitoring

By updating Guideline A-5, Ontario would be aligned with:

  • Canada’s guidelines for the reduction of nitrogen oxide emissions from natural gas-fuelled stationary combustion turbines, published in 2017
  • modern technology designs and industry best practices

Proposed updates to Guideline A-5

The key updates that we’re proposing to Guideline A-5 will help ensure that Ontario has consistent air emission limits with other provinces and territories across Canada that will also be adopting the 2017 federal guidelines.

Updates would apply to new and, under certain circumstances, modified stationary combustion turbines. These changes would include:

  • changing the applicability categories of new combustion turbines by power rating and type to determine the new in-stack emission limit for nitrogen oxides
  • changing the energy quantification to a “higher heating value” basis from a “lower heating value” basis
  • lowering the in-stack emission limit of carbon monoxide from 60 parts per million by volume (ppmv) to 50 ppmv
  • Including sulphur limits in fuels and removing sulphur dioxide in-stack emission limits
  • removing provisions for the gasification of solid fuels as they are intended to be addressed in separate guidance
  • streamlining the requirements for natural gas combustion turbines with power ratings of up to 25 megawatts, including:
    • subdividing the concentration-based limits for nitrogen oxides into two categories by thermal efficiency (i.e., less than 60 per cent versus 60 per cent or greater)
    • enabling the use of a portable gas analyzer for measuring the air emissions according to ASTM D6522-20
    • allowing thermal efficiency to be monitored using modern sensor devices to reduce the need for on-site testing

The new technical information proposed in the updated Guideline A-5 is also being considered to define operational requirements for natural gas combustion turbines that meet specified criteria in the proposed amendments to Ontario Regulation 1/17 (Registrations Under Part II.2 of the Act – Activities Requiring Assessment of Air Emissions). The regulation proposal aims to reduce burden for those operating combustion turbines that meet specified criteria by requiring registration in the EASR as opposed to obtaining an ECA and make it easier for eligible facilities to use more efficient technologies.

Supporting materials

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Comment

Commenting is now closed.

This consultation was open from October 13, 2020
to November 27, 2020

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