Carbon Black Industry Standard

ERO number
019-6492
Notice type
Policy
Act
Environmental Protection Act, R.S.O. 1990
Posted by
Ministry of the Environment, Conservation and Parks
Notice stage
Proposal
Proposal posted
Comment period
June 23, 2023 - July 23, 2023 (30 days) Closed
Last updated

This consultation was open from:

June 23, 2023
to July 23, 2023

Proposal summary

We are proposing a technical standard for the carbon black sector that would include requirements to reduce sulphur dioxide air emissions from facilities that register to the technical standard. The proposed technical standard would help align the industry with similar environmental practices in other jurisdictions, such as the United States.

Proposal details

Overview

The Government of Ontario is committed to taking more action to improve Ontario’s air quality and creating strong and effective standards for cleaner air that protects human health and the environment. As part of this commitment, the ministry is working to reduce air contaminants released by certain industrial facilities.

Ontario’s carbon black facilities are a significant source of sulphur dioxide air emissions, particularly in Sarnia and Hamilton where the facilities are located.

To address this issue, the ministry is proposing a new industry standard for the carbon black sector that, once implemented, is expected to significantly reduce emissions of sulphur dioxide (SO2) from registered facilities.

Technical standards ensure the facilities implement the best available technology and practices for their sector to help them reduce the risk to public health, while allowing them to continue to operate responsibly and in a transparent manner.

The proposed requirements would be aligned with environmental controls and practices used by comparable facilities in the United States.

More details on the proposal are provided below in the proposal description, and also in the Plain Language Overview that accompanies this notice.

We invite feedback from the public, Indigenous communities, municipalities, environmental groups and industry on the proposed requirements so that we can continue to protect air quality and create tailored solutions that address the unique challenges in our communities.

Proposal Description

The proposal would apply to Cabot Canada Ltd. located in Sarnia and Birla Carbon in Hamilton, which are the two carbon black facilities located in Ontario.

The proposed technical standard would require these facilities, if registered, to install air pollution control technology and demonstrate compliance with the technical standard in accordance with Option A or B below:

Option A: By July 1, 2028, facilities must install and continuously operate an air pollution control system(s) that is capable of achieving a 95% reduction in the emissions of SO2. Under this option, registered facilities will initially operate under interim in-stack limits and then final in-stack limits by mid-2030 that will correspond to a 95% reduction in SO2 emissions.

Option B: By July 1, 2028, facilities must install and continuously operate an air pollution control system(s) that meets the below interim in-stack limits of:

  • 160 parts per million SO2, dry basis (ppmvd) and 0% oxygen (O2), calculated on a 7-day rolling average; and
  • 130 ppmvd and 0% O2, calculate on an annual rolling average.

and, then by January 1, 2030, meets the following final in-stack limits of:

  • 120 ppmvd and 0% O2, calculated on a 7-day rolling average; and
  • 80 ppmvd and 0% O2, calculated on an annual rolling average.

The ministry is also proposing to specify a short term SO2 in-stack concentration action level for the occurrence of elevated 1-hour in-stack concentrations that may lead to levels exceeding 120 ppb SO2 off-property.

The proposed technical standard would also include the following requirements for registered facilities:

  • Consider and implement interim management practices to reduce SO2 emissions
  • Facilities selecting Option A must complete baseline source testing no later than one year after registration.
  • Option A facilities must also conduct, for a period of 18 months following the installation of the air pollution control system, an “Optimization and Demonstration Study” (Study) in accordance with an approved work plan.
  • The Study will be the basis for determining that the equipment is achieving a 95% reduction in sulphur dioxide emissions and propose in-stack limits that the facility will operate within.
  • Facilities selecting Option B will be required at all times to operate within the applicable in-stack SO2 limits.

All facilities will be required to:

  • Develop plans for the design, installation, commissioning and operation of all required continuous emissions monitoring systems (CEMS)
  • Perform an annual Relative Accuracy Test Audits to assess the accuracy of the CEMS installed on the air pollution control system stack.
  • Conduct root cause analysis and develop/implement corrective and preventive actions for all exceedances of emissions limits and the short term SO2 in-stack concentration action level
  • Operate and maintain at least one ambient air monitor for sulphur dioxide in the vicinity of each facility to assess sulphur dioxide concentrations in the local community
  • Make public the most recent five years of facility SO2 emissions data and ambient monitoring data
  • Provide reporting to the ministry

If implemented, this proposal would significantly reduce emissions of sulphur dioxide from carbon black facilities that register to the technical standard and support improved health outcomes for the Sarnia and Hamilton communities, as well as local First Nations. Complying with the requirements of this proposed technical standard would provide an alternative for registrants to meeting the updated sulphur dioxide air standards taking effect on July 1, 2023.

Other actions

In addition to the proposed industry standard, the ministry is taking actions in the Sarnia and Hamilton areas to address sulphur dioxide. Many of these activities fall under the Sarnia Air Action Plan and Hamilton Air Action Plan, ministry initiatives to achieve better local air quality and improve communication and outreach in these respective communities.

The ministry is also undertaking the Sarnia Area Environmental Health Project to enhance our understanding of the links between environment and health and help address concerns that people have expressed about living close to industrial operations in this area.

Real-time ambient air quality monitoring data is also available to the public on the Clean Air Sarnia and Area website for Sarnia and the Hamilton Air Monitoring Network website for Hamilton.

Health benefits

The proposal is expected to benefit all Ontarians. Levels of sulphur dioxide and fine particulate matter would be expected to improve across the province, particularly in southern Ontario near where the two facilities are located.

Additional benefits are also expected from improved access to reporting about facility emissions and local air quality for local communities.

Costs

The main compliance costs incurred by facilities would consist of the costs of installing and operating pollution control equipment to achieve significant sulphur dioxide emissions reductions. This requirement would align the environmental performance of Ontario’s facilities with similar facilities in the United States which have already installed similar controls and methods to reduce sulphur dioxide.

Background

Our government takes sulphur dioxide emissions very seriously. We know that short-term exposure to sulphur dioxide can cause respiratory distress, especially in sensitive individuals such as those with asthma, and may cause difficulty breathing and increased asthma symptoms. In some cases, sulphur dioxide exposure can cause effects on the heart, which may result in hospital admissions or, in severe cases, premature death. We also know that long-term exposure to sulphur dioxide can damage crops, trees, and other vegetation. It is a precursor to acid rain and can contribute to the acidification of soils, lakes, and streams.

Sulphur dioxide emissions are a source of fine particulate matter, which is either emitted directly as primary particulate matter or forms as secondary particulate matter when sulphur dioxide reacts with other pollutants in the air. Some emission controls reduce both emissions of primary fine particulate matter and sulphur dioxide (e.g., wet gas scrubber). Fine particulate matter is associated with various negative health impacts, particularly on the respiratory and cardiovascular systems. Reduced fine particulate matter would be a co-benefit of addressing sulphur dioxide emissions under the proposed industry standard.

The ministry is also requiring significant actions to address other important local sources of sulphur dioxide emissions like Ontario’s five petroleum facilities (largely based in the Sarnia Area). Similarly, Ontario is supporting the transition to low carbon steel at the ArcelorMittal Dofasco facility in Hamilton, which will result in a significant reduction of sulphur dioxide emissions.

Regulating air contaminants in Ontario

Ontario's Local Air Quality Regulation (O. Reg. 419/05: Air Pollution - Local Air Quality) works within the province's air management framework by regulating air contaminants released into communities by various sources including local industrial and commercial facilities.

Ontario’s regulatory approach to improving local air quality that starts with setting science-based standards to protect human health and the environment. While these standards may not always be achievable due to limitations in technology or economics, the goal is to reduce emissions through continuous improvement and best available technologies and practices over time.

Facilities unable to meet an air standard because of limitations in technology or potential economic considerations may request a site-specific or apply to register to a technical standard. Both compliance options may require companies to invest in the best available technologies and practices to monitor and reduce air emissions and improve air quality over time.

We closely oversee the companies' progress to ensure they are achieving the desired results.

Improvements in addressing air emissions have been achieved as a result of our regulatory approach.

Site-specific and technical standards are developed with full public transparency through public consultation. We consult the public on all applications for site-specific standards and registrations to technical standards and public input plays an integral role in the ministry's review of proposals.

Read more about the rules on air quality and pollution in Ontario

Supporting materials

View materials in person

Some supporting materials may not be available online. If this is the case, you can request to view the materials in person.

Get in touch with the office listed below to find out if materials are available.

Local Air Quality Section
Address

40 St. Clair Avenue West
7th & 9th floor
Toronto, ON
M4V 1M2
Canada

Office phone number

Comment

Commenting is now closed.

The comment period was from June 23, 2023
to July 23, 2023

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