5. Facility description

The purpose of the Facility Description in an ESDM report is to provide a summary of the operations and activities at the facility that discharge contaminants.

Paragraph 1 of subsection 26(1) of the Regulation requires that the Facility Description include:

Under Subsection 26(1) of the Regulation – Contents of ESDM report:

“1. A description of the activities that are engaged in on the property from which contaminants are discharged, including, if anything is produced on the property,

  1. a description of what is produced and a statement of the amount of product that is produced on each day that the production process operates in accordance with the operating conditions described in paragraph 6,
  2. a description of the steps involved in the production process, including a drawing of the process,
  3. a description of the materials used in the production process, and
  4. a statement of the number of weeks per year, the number of days per week and the number of hours per day that the production process is in operation.”

The Facility Description is intended as an overview of facility operations and relevant data to support the selection of the appropriate operating conditions that will form the basis of air emission rate estimates and the assessment of maximum POI concentrations.

Information related to the four items required by paragraph 1 of subsection 26(1) of the Regulation must be provided in sufficient detail to support the identification of the operating conditions that correspond to the maximum POI concentrations. Although the above- mentioned items must always be included in an ESDM report, they may be included in a general manner in the Facility Description, if more specific information relevant to the development of estimates of air emissions and maximum POI concentrations is provided in the operating condition portion of the ESDM report. For example, if the description of the operating conditions provides specific information to support the development of estimates of air emissions and maximum POI concentration then, the ESDM report could refer the reader to these portions of the Report and the Facility Description may be expressed in a general manner including:

  • what is produced;
  • a summary of the overall facility production rate (or rates if multiple products are manufactured);
  • an explanation of how the production rate(s) relate to the operating conditions that are used to estimate emissions and predict the maximum POI concentration;
  • a statement within a Facility Description might indicate that “a maximum of ‘x widgets’ per day are produced where the applicable standard has a 24-hour averaging period and operating conditions, air contaminant emission rate estimates and corresponding predictions of POI concentrations contained in this ESDM report are either directly or indirectly related to this production rate”;
  • the basic unit processes (including a simplified process flow diagram), that are relevant to the air contaminants emitted from the facility;
  • the raw materials that are most relevant to estimating air emissions;
  • the overall facility production periods that will assist in defining the appropriate averaging periods for the operating conditions. For example, to assess compliance with a standard that has a 24-hour averaging period, it would be relevant to include the daily production at the facility; and
  • whether or not any contaminants are part of a site-specific standard or registered to a technical standard.

The location with zoning information and identification of sensitive receptors is also helpful to have. Please refer to Chapter 8 Operating Conditions of this Procedure Document for a more detailed discussion of information required to describe the relevant operating conditions.

Providing the NAICS code or codes for the facility

All facility descriptions in an ESDM report must include the NAICS code or codes that are applicable to the facility. The NAICS codes are maintained for Canada by Statistics Canada and may be amended from time to time. A facility should review the NAICS code descriptions to determine which codes best fit its site operations. This information is also provided by facilities when reporting air emissions under provincial regulations such as Ontario Regulation 127/01 – Airborne Contaminant Discharge Monitoring and Reporting, the Toxics Reduction Act and Ontario Regulation 455/09, Ontario Regulation 452/09 – Greenhouse Gas Emissions Reporting Regulation. The NAICS codes identified under these programs should be the same. NAICS codes are also provided when reporting under federal programs such as the National Pollutant Release Inventory (NPRI) requirements. In addition the Industry Canada web-site also includes descriptions for the various NAICS code sectors and sub-sectors.

The NAICS Code of the facility determines whether Section 19 or 20 of the Regulation applies to the facility at the time the ESDM report was prepared or updated, and whether section 19 or 20 of the Regulation is used in the ESDM report to assess compliance with the requirements of the Regulation. The Facility Description must include the NAICS code for the facility and which of s. 19 or 20 applies to the facility or specific contaminant.

Applying for an ECA

Applicants for an ECA must include a description of the facility however applicants are only required to provide a description of the facility that contains sources that emit contaminants in common with the sources that are the subject of the application itself.