Test firms favour flexible approach to C of AsSince early this year, two leading auto industry companies in southern Ontario have been testing a new, performance-based approach to manufacturing facility permitting, with positive results.
The Ontario Ministry of Environment's site-wide certificate of approval (C of A) system was undertaken as a pilot project at General Motors' Oshawa vehicle assembly plant and Cooper Standard Automotive's operation in Stratford. Doug Yates, manager of technical services and environment for GM of Canada, told the Canadian Institute's Environmental Law and Regulation in Ontario conference last week that the main driving force for this new permitting approach was the need to update the facility's compliance and keep its myriad air emission permits current while still proceeding with rapid process and operating changes.
The current permitting system, under Ontario's Environmental Protection Act, requires individual C of As for each emission source. For GM's huge auto manufacturing complex, this meant some 200 permits covering a total of 1,000 stack sources, Yates noted. Moreover, the EP Act requires the permit holder to re-apply whenever a modification is made to the facility. For a company seeking to manage change as quickly as possible in order to remain competitive, these requirements pose a challenge.
The pilot project began with a complete emissions inventory of the Oshawa complex, focusing on NOX, VOC, particulate and lead emissions from its three main operations. The air dispersion model set out in Ontario Regulation 346 was used to predict point of impingement concentrations, Yates noted, adding that the first inventory was completed in mid-1998.
These inventories, he explained, are the core of the site-wide permit, and GM has carried out two more since then, the latest of which is just now being completed. In January, GM was granted Ontario's first comprehensive site-wide C of A for air emissions, a single document that replaced all 200 of the old permits.
The 13-page permit, which runs to January 2003, sets out terms and conditions relating to matters such as updates of emission summaries, retention of records, notification of the MOE regarding any process change resulting in a change in emissions (whether lower or higher), operation and maintenance, and local and site-specific issues. It includes definitions and outlines limits on operational flexibility.
The important feature of this type of C of A is that it does provide built-in operational flexibility, allowing changes to be made without having to seek new permits. There are limitations to this flexibility, including requirements to notify the MOE of changes (and any resulting changes in emissions), to maintain records of changes and emissions and, obviously, to meet provincial limits for the contaminants of concern.
Its emphasis on continuing emissions inventory and focus on environmental performance, however, make the site-wide approval a living document, providing for a continuous review of operations and ability to make needed changes quickly.
Such changes range in degree of impact, from merely moving equipment to changing processes or reformulating compounds, but the old permitting system is not flexible enough for the dynamic world of manufacturing, Laura Rourke, manager of health, safety and environment for Cooper Standard Automotive told the conference. The auto parts supplier's medium-sized Stratford facility was also chosen by the MOE as a participant in the permitting pilot project, which is part of the Ministry's Selected Targets for Air Compliance (STAC) program, aimed at improving compliance with Regulation 346.
As with GM, Cooper Standard began with a full emissions inventory of its five operating areas (extrusion, molding, rubber mixing, coating and heating). The company then proposed a flexible site-wide permit in two parts, the first covering the site as a whole and describing the processes and total emissions from each area (an area consisting of groups of similar processes). The second part of the permit application would include details about the exhaust fans and would be updated regularly to show any changes made.
The permit issued to Cooper Standard, requires an annual emissions summary and a Ministry-approved ambient air monitoring program for selected contaminants during the first year of the three-year term. It also sets out record-keeping and notification requirements regarding equipment maintenance and production levels, modifications or other activities resulting in a change in emissions, and any exceedance of point of impingement limits or ambient air quality criteria.
50 changes since permit issued
Since the permit was issued, Rourke said the company has made over 50 changes, almost all minor, although two involved a manufacturing addition and a product reformulation. The permit enables the company to make any needed changes, so long as it stays within permitted emission levels. Benefits of this system go two ways, she noted. It requires the company to have a complete understanding of its total site emissions and impacts, and has given the MOE an understanding of Cooper's processes and impacts. As well, the new permit enables senior management to keep track of changes in a timely manner, which was not always the case in the past.
In Cooper Standard's view, said Rourke, the only drawback is the three-year time limit. Once the process has been proven, she said, we would like to see the time limit removed.
A word or two of advice on this system was offered by Henry Krupa, director of legal services for the MOE. While it stands to benefit companies and facilities trying to manage diverse operations, rapid changes and multiple permits, any prospective applicants will have to ensure that they can demonstrate site-wide compliance. This type of permit requires a very great deal of work by prospective permittees. It is also important to note that the legislation itself remains unchanged; only the implementation is being altered slightly, he added.
More information is available from Doug Yates at GM, 905/644-4367, E-mail email@example.com; Laura Rourke at Cooper Standard, 519/272-8646, E-mail firstname.lastname@example.org; or the MOE Environmental Assessment and Approvals Branch, 416/314-8001.