What to do during an inspection by the Ministère de l’Environnement et de la Lutte contre les changements climatiques

22 April, 2019 | Blog

DAVID GIARD, P.Eng., M.Sc.

Project Leader - Environment

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Government representatives can ask to conduct a plant inspection—a request that may worry facility owners. This article discusses air quality management and will inform you on how inspections are carried out and what you can do to ensure your facilities comply with government air quality standards.

A number of things can prompt the Ministère de l’Environnement et de la Lutte contre les changements climatiques (MELCC) to undertake a plant inspection, including citizen complaints. Close to 70% of complaints from the public have to do with problems about odours or dust.

Checking the certificate of authorization

Here is how the inspection usually unfolds. First, with some exceptions, an MELCC representative notifies the plant owner that there will be an inspection. Next, the representative may ask to see the certificate of authorization (CA) issued by the MELCC in order to compare the information it contains to the plant’s actual operations. Obtaining a CA is mandatory under section 22 of the Environment Quality Act before beginning any activity or using an industrial process.

A CA must also be obtained before an increase in the production of goods or services, if such an activity is likely to result in an emission, deposit, issue or discharge of contaminants into the environment or alter the quality of the environment.

In general, the CA contains information such as the production schedule and peak periods, number of production and administrative employees, the type and quantity of products manufactured, inputs and fuels used as well as storage method, processes and equipment.

If the information in the CA does not reflect the facilities in place (e.g., the plant’s production rate is higher than that shown or processes or production lines have been added), the MELCC will ask the plant owner to update the CA to make it comply with operations. 

During the inspection, the MELCC may observe all points of emission into the atmosphere—chimneys, vents, stockpiles, material chutes, etc.—that are likely to release odours, dust or any other atmospheric contaminant. If there is air purification equipment (e.g., a dust extractor), the MELCC may ask for proof of effectiveness. This usually means confirming that the purification equipment is in good working order and properly maintained.

Plant emissions inventory: three methods

The MELCC could also require an inventory of the plant’s emissions. This inventory provides an overview of all the atmospheric contaminants released by the plant. The inventory may be performed in three different ways: by characterizing emission sources, performing a mass balance or producing an emissions inventory based on emission factors drawn from the scientific literature or from information provided by the equipment manufacturer.

One way of characterizing emission sources is to conduct a sampling campaign. Normally carried out by a specialized firm, a sampling campaign determines the type and quantity of atmospheric contaminants (dust, chemical compounds or odours) released by each of the points of emission into the atmosphere. These points of emission are for the most part stacks releasing gaseous effluents.

An emissions inventory by mass balance may be performed by the plant owner or by process specialists. The mass balance considers that part or all of the difference between production inputs and outputs is released into the atmosphere. Since owners can perform it themselves, this method, while less accurate than an at-source sampling campaign, is faster and less costly.

Lastly, an emissions inventory based on factors drawn from the literature involves using scientific data that pools the results of many source characterizations. Using this data, the emission rates of equipment can be calculated based on values taken from comparable equipment for which emission factors have already been estimated. Often, the manufacturer of equipment releasing contaminants into the atmosphere may propose its own emission factors that are specific to its equipment.

Atmospheric dispersion modelling

Once the results are gathered, it is sometimes necessary to use atmospheric dispersion modelling, which simulates the atmospheric phenomena associated with the transport and dispersion of a contaminant from one or more sources. Atmospheric dispersion modelling also makes it possible to verify the plant’s compliance with current ambient air quality standards. These standards set out a maximum chemical contaminant concentration measured at ground level.

The modelling also determines whether the plant is to blame for neighbours’ complaints. In nearly all cases, modelling that shows compliance with all air quality standards and criteria is required before a CA can be issued for the plant.

Should mitigation measures be required to make the plant compliant, experts must determine the right measures to be implemented based on the circumstances.

Once the mitigation measures have been carried out, the MELCC may ask for validation of equipment effectiveness and an updated modelling. The latter could be used to verify whether or not the mitigation measures render the plant compliant with current air quality standards and criteria.

For more information on atmospheric dispersion models, check out our article “Everything You Need to Know About Atmospheric Modelling.”

In conclusion

As the owner, you must make sure that the activities carried out at the plant comply with what appears on the CA issued by the MELCC. This simple check could save you a lot of hassle.

A good practice is to ensure that your plant’s equipment, including the purification equipment, is regularly inspected and maintained, and that it is in good working order. Another is to save the equipment maintenance reports, plant inventory emissions reports and emission modelling in order to present them during an MELCC inspection. Of course, work methods that respect the environment throughout the production cycle remain your best tool for ensuring the plant’s compliance with air quality standards and criteria and avoiding complaints from neighbours.

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