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Rubidium Environmental
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Attention commercial, and industrial property buyers look out for our upcoming ad in the Business Exchange. Interested in buying or developing a commercial, or industrial property. Find out how we can help!

Environmental Site Assessments (Phase I and Phase II ESAs) are an important part of understanding the environmental risk associated with property transactions. Is the land use designation going to be changed? Find out if you need to conduct a land use compatibility study.
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Phase I Environmental Site Assessments (ESAs): Realtors and Conditional Offers
Phase I ESAs are required during a majority of property transactions, whether it may be a commercial or industrial property of interest, or an agricultural parcel of land, or a vacant undeveloped lot. A Phase I ESA allows the potential purchaser to understand if any environmental liabilities associated with the property exist and if any identified environmental risks need to be further explored by conducting an intrusive soil and/or groundwater investigation. These investigations are meant to be conducted during the due diligence period, once a potential purchaser has retained a Realtor to prepare a conditional offer on a property of interest.
What should a property purchaser be aware of once a property of interest has been identified?
What type of property are you looking for? Each property type can be associated with different environmental risks, including the following examples:
• Vacant, undeveloped lot
o Historical use of the property included a residential dwelling that was formerly heated by fuel oil
• Agricultural parcel of land
o Large-scale applications of pesticides, herbicides, and fungicides
• Residential
o Former or present use of fuel oil for heating purposes
• Commercial
o Types of tenants that previously and presently occupy the building (i.e., on-site dry cleaning and automotive repair operations)
• Industrial
o Historical and current operations occurring on-site (i.e., manufacturing processes and use of hazardous materials)
In addition, the properties in close proximity to your property of interest, can also pose an environmental risk to your potential property. Land uses such as a gasoline service station, automotive repair garage, dry cleaning facility, and manufacturing facility can pose an environmental risk to your property, specifically if these properties are located up-gradient to your Site (at a higher elevation with respect to the direction of groundwater flow) or are located immediately adjacent to a property boundary of the Site of interest. A Phase I ESA considers all properties located within a 250 metre (m) radius from the Site, which may pose an environmental risk to your potential property. Upon the identification of a potential environmental risk located within the 250 m radius, it is the discretion of the Qualified Person (QP) conducting the ESA to determine the extent of risk (on the Site) that is associated with that property based on length of operations, type of operations, distance from the Site, location, historical records associated with the property etc.
What should your Realtor consider when making a conditional offer?
A buyer and Realtor commonly base their conditional offers on one or more of the following:
• Financing – the buyer receiving the necessary financing to finalize the purchase.
• Home Inspection and/or Building Condition Assessment – the buyer conducting a building inspection to verify the structural integrity and condition of the building and/or conducting a life cycle cost analysis for building components.
• Property Appraisal – the buyer verifying the value of the property.
• Environmental Investigations – the buyer conducting an ESA and being satisfied with the results of the environmental report completed by a consultant.
The Realtor is also responsible for delegating a time period to each of the conditions, based on the length of time required to complete any associated tasks that confirm or refute the buyers purchase. In the case of environmental risk, the Realtor and buyer should consider the following:
• Financing
o Verify if the financial institution requires the buyer to conduct an ESA as part of their risk evaluation during the pre-approval process.
o Verify if the financial institution obtains a Pre-Approved Consultant Vendor List.
o Verify that the retained Consultant is on the Pre-Approved Vendor List of the financial institution the buyer is seeking financing with.
• Environmental Investigations
o Phase I ESA
 Typical turnaround times to complete a Canadian Standards Association (CSA) Phase I ESA is three to four weeks.
o Phase II ESA
 Typical turnaround times to complete a CSA Phase II ESA is four to six weeks.
o Contact the Consultant and discuss what timeline is required to complete the necessary investigations (Phase I and/or Phase II ESA), so that the appropriate timelines are included in the conditional offer.
What should an individual and/or business consider when leasing a space?
Leasing a space may be considered an ideal option for financial reasons; however, it is still very important that a future tenant reduce their risk associated with building occupancy and fully understand the existence of any environmental liabilities. Rubidium recommends that a potential leasee conduct the same environmental due diligence as a potential purchaser, so that all risk factors can be explored and mitigated. If a former dry cleaning tenant operated within the unit currently listed for lease, would you want to occupy that space not knowing what environmental liabilities exist due to the former tenant or operations that took place in that space?
Waiving Conditions
Some property transactions are finalized almost immediately when a Relator presents an offer that waives any conditions. Rubidium suggest that you, as a buyer, be diligent and retain a consultant to investigate the potential presence of environmental liabilities associated with the property of interest and/or space for lease. It is important that property owners or occupants fully understand any risks associated with a financial investment that may lead to greater risk in the future when the property is listed for sale or you decide to terminate a lease and vacate the space.


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Dust Management Plans – Are they enough?
Fugitive dust emissions from on-site roadways and storage piles can be excluded from the emission summary and dispersion modeling (ESDM) report of a facilities Environmental Compliance Approval (ECA) when an approved dispersion model is used under special circumstances.  This typically means that AERMOD will be used as the dispersion model for completing the Environmental Compliance Approval application for the air modelling.  The special circumstances that allow these sources to be removed from the ESDM report are:
• The nature of the fugitive dust emissions is such that they are not likely to pose a health risk to humans; and 
• The emissions are relatively small or have been minimized through the effective implementation of a fugitive dust control plan, consistent with best management practices.
For most facilities in the aggregate, mining, steel, and non-ferrous industries this means that a Fugitive Dust Best Management Practices Plan (BMPP) must be prepared in support of the Environmental Compliance Approval application.  For most facilities, an accepted dust management plan from the Ministry of Environment and Climate Change (MOECC) was typically enough.  With the weather we have been having over the past few years, we have seen some uncharacteristically warm winters, and extended dry spells throughout the year.  These factors all lead to more airborne dust.  As storage piles or unpaved roads dry out, the average particle size on the surface decreases, and will more readily drift away.  Precipitation is often the free solution for dust control, but plans need to account for extended dry spells, coupled with high winds.  All these factors lead to increased risk of complaints from neighbours, which may then necessitate additional dust control measures.  
Recently, the operator of an open pit mine near Havelock was fined over $300,000 for adverse impacts resulting from excess fugitive dust causing nuisance issues, despite having an approved Environmental Compliance Approval and dust management plan (BMPP).
As the frequency of adverse weather conditions continues to increases, businesses that have unpaved roads and storage piles are at an increased risk of fugitive dust from their property coating nearby businesses, homes, vehicles, etc.  The cost of penalties for violations of the Environmental Protection Act (EPA) have skyrocketed in recent years, understanding the limitations of dust management plans. 
When preparing ECA applications for facilities located in close proximity to neighbours, modelling of the fugitive dust emissions should be conducted to determine the concentrations of dust at various impacted points of reception.  From this an effective mitigation strategy can be developed.  Using opportunities such as relocating storage piles to other parcels on the property can minimize the potential for dust to cause nuisance concerns to neighbours.  Modeling can be used to careful design barriers to minimize dust erosion of storage piles, and determine the appropriate speed for on-site vehicles during dry periods of the year.
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Annual Written Summary – Environmental Compliance Approvals
Understanding the terms and conditions of your environmental compliance approval (ECA), and what your company’s obligations are, is very important.  Recently a Richmond Hill company was fined over $6,000 for failing to provide an annual report.  (http://news.ontario.ca/ene/en/2015/08/richmond-hill-company-fined-5000-for-failing-to-provide-annual-report.html)
Environmental Compliance Approvals (formerly Certificate of Approvals) are legal instruments granted by the Ministry of Environment and Climate Change (MOECC).  For businesses which discharge to the natural environment (air emissions, odour, noise, water, or waste) an environmental compliance approval is required.  The terms and conditions of the environmental compliance approval spell out the annual reporting requirements. The list below are typical annual reporting requirements that we often see in ECAs:
Air – Annual Written Summary to update Emission Summary & Dispersion Modelling (ESDM) Report, Stack Testing Results, and/or Odour Monitoring Results
Noise – Annual Written Summary to update Acoustic Assessment Report (AAR) for any new or modified sources
Wastewater/Stormwater/Sewage Works – Annual Report to confirm water quality and/or flow parameters
Waste – Annual Report on tonnage, ground water, and/or soil testing
The terms and conditions of an ECA typically specify a date at which these reports must be provided to the Ministry of Environment and Climate Change, commonly they range from March to August.  It is important to note that while the date to provide the annual reports to the MOECC is typically in the spring or summer, most ECAs require that the information be updated by December 31st of the previous year.  In the case of Air and Noise approvals, facilities with ECAs with limited operational flexibility must have onsite an updated ESDM and AAR by December 31st.  Effectively, this means that the true date is December 31st and the extra time is given for the submission to help spread-out the backlog at the MOECC.
The terms and conditions of an ECA can be quite confusing, often long, complex, and seemingly riddled with ‘legalese’. If you have received an approval from the MOECC, we suggest you review it, and if you are still uncertain as to what your obligations are, give us a call.
Rubidium Environmental is an environmental consultant headquartered in Burlington, Ontario, serving clients all across Ontario, and Canada.  If you have any questions, please contact us at: 905-635-4063 or by email at info@rb-enviro.com. Rubidium Environmental are experts at assisting industrial, institutional, and commercial clients apply for Environmental Compliance Approvals.
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Cost Neutral Environmental Compliance Approval Strategy

More often than not, most businesses in Ontario find Environmental Compliance as a cost of doing business.  As consultants, we are often asked for budgets for projected environmental services for the coming year, which includes:
-Annual NPRI / TRA Reports
-TRA Plan updates
- O. Reg 455 Greenhouse Gas (GHG) reporting
-Emission Summary Dispersion Modelling (ESDM), and Acoustic Assessment Report Updates
-Amended Environmental Compliance Approval (ECA) formerly certificate of approval (CofA) applications
-Annual source testing, stormwater monitoring, wastewater testing, drinking water testing
-Environmental Emergencies (E2) Plan update, etc

Depending on the operations at your facility that list can become quite lengthy, and of course, costly.  But with all the environmental reporting, permitting, and testing requirements, there are also great opportunities.

The multitude of environmental regulations in Ontario, and Canada have given consultants a wealth of information.  The Ontario Toxics Reduction Act (TRA) brought significant insight into the costs of manufacturing including waste disposal costs, and recycling rates for various grades of steel and aluminum.

Why is this important?  At Rubidium we can leverage our experience, and knowledge gained to help minimize waste disposal costs from your facility, and optimize the rates paid for scrap.  Through the National Pollutant Release Inventory (NPRI), we are aware of the various material/chemical inputs, and might be able to help source a lower cost material generated from another facility.

Water rates in Ontario are among the lowest of the developed countries. While recently the rates have been going up, the costs associated with treating wastewater have been skyrocketing.  Aging infrastructure, and more stringent water quality levels have more than doubled the wastewater rates in many municipalities over the recent years.  How can Rubidium Environmental hope alleviate some of the burden caused by increased water rates, and water bylaw surcharge rates?  Many municipalities have what is known as wastewater rebates, or water bylaw reductions.  Simply put, many businesses consume water but discharge only a fraction of it.  Water consuming processes, evaporative losses, or simply the water is used in the manufactured product are all common examples of wastewater diversion.  Secondly, technologies to enhance water recovery, and reusability have become remarkably more affordable in recent years with reasonable payback periods.  Rubidium can help identify if your facility fits the criteria for a wastewater rebate, or if opportunities exist for onsite water reuse.  Typically, this begins to become worthwhile for facilities whose water costs are in excess of $25,000/year.

While their are costs associated with environmental compliance in Ontario, there are also great opportunities to reduce operating costs.  Waste reduction, turning waste into an input stream, optimizing scrap rates, reducing wastewater charges, and implementing wastewater optimizing systems are all examples of how Rubidium Environmental can provide your company with complete environmental solutions.  Our mandate is to forge a strong relationship with our clients through identification of cost neutral solutions.  Stop seeing environmental compliance as a cost of doing business, and let Rubidium Environmental's experience start making environmental compliance activities start paying dividends for your facility.

Rubidium Environmental is an environmental  consulting firm.  From our head office in Burlington, we supply environmental and engineering services across Canada.  Experts in Environmental Compliance Approvals (ECAs), industrial pollution control (air, noise, odour), acoustic assessment reports, industrial hygiene, and environmental reporting.

Find us online at: www.Rb-Enviro.com
Contact us: (905) 635-4063
Email us at: info@rb-enviro.com
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Spill Reporting - Environmental Protection Act

As environmental consultants we often get asked,  "at what point does a spill or release need to be reported?"  Well the Ministry of Environment and Climate Change (MOECC) has shown that even the shortest unintended spills need to be reported.  Recently, a Stoney Creek company was fined $10,000 under the Environmental Protection Act (Ontario) for release of a whitish grey particulate from a silo that lasted only a couple of minutes.  The release from the silos had deposited on about 30 vehicles of neighbouring vehicles that required multiple car washes to remove.

The MOECC had no record that the spill had been reported by the company, but rather, the individuals that had dust settle on their cars were the first to report.  This is an important fact.  Obviously, when a spill or unintentional release occurs from your facility, regardless of how mundane or insignificant you think it is, you need to be the first to report if you are aware.  

Under the Environmental Protection Act, the minimum fine for companies failing to report a spill or discharge is $25,000. Interestingly enough, this company was fined less than the minimum.

Spill and discharge reporting are part of the terms and conditions of Environmental Compliance Approvals, and as can be seen failing to comply can result in fines to your company.  The MOECC regularly posts convictions on its Court Bulletins website, definitely not the type of free press you want!
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Metals Finishers - Technical Standard

In May, the Ministry of Environment and Climate Change (MOECC) posted on the Environmental Registry posted draft copies of the proposed Technical Standard for the Metal Finishers Industry.  The technical standard covers hexavalent chromium, and nickel.
The proposed standard would apply only to facilities with NAICS code 332810 (Coating, Engraving, Heat Treating and Allied Activities).

As part of the environmental compliance options under O. Reg 419/05 facilities essentially have three options:

1) If the air quality limits of O. Reg 419/05 can be met, then applicants can then apply for an environmental compliance approval (ECA)
If the air quality limits of O. Reg 419/05 are exceed for one or more substances:
2) Apply for a technical standard (if one is available) to support the environmental compliance approval application (ECA).
3) Apply for a site-specific standard to support the environmental compliance approval (ECA) application

Since 2011, various manufacturers, and industry associations such as the Canadian Association for Surface Finishing (CASF) have approached the MOECC requesting to develop a technical standard under Local Air Quality Regulation O. Reg 419/05 for hexavalent chromium and nickel.

New, and more respective air quality standards for these contaminants come into effect in July 2016.  With these new standards many facilities will be out of compliance, and unable to demonstrate compliance for an ECA.  As part of the technical standard, the following sources have been identified for potential inclusion:
• Decorative chromium electroplating
• Hard chromium electroplating
• Chromium anodizing
• Chromium reverse etching
• Nickel plating
• Electroless nickel plating; and
• General ventilation

How are these substances created

Hexavalent chromium and nickel exists as charged ions inside the plating baths.  Based on factors such as temperature, and surface tension these compounds will be generated as fume from the tanks, and be emitted into the facility fugitive or captured in direct ventilation systems. 

Part of the proposed standard is specification of control technologies for hexavalent chromium generating processes, including the use of:
-air pollution control vehicle (such as a scrubber, or HEPA filter)
-fume suppressants,
-tank covers

For nickel emissions the following technologies have been specified for new or existing operations"
-air pollution control device (such as a scrubber or HEPA filter)
-wetting agent

An important point to note is the requirement to have a vertical and unimpeded discharge.  This manner of discharge will maximize the dispersion from that stack.  Often stacks are outfitted with rain caps to prevent rain from getting into the duct work.  New stacks may now have to be double walled, or offset to meet the requirements.  It's important for facilities that are looking to modify equipment or processes, as this may mean that using existing stack locations simply won't be possible.

Similar to the Operations and Maintenance terms and conditions of an Environmental Compliance Approval (ECA) facilities will also now be required to record operating parameters of the various sources, and pollution control equipment.  For most pollution control equipment the required monitoring frequency is daily, however, for some new equipment like a packed bed scrubber, the requirements are continuous, meaning that instrumentation and computerized control systems will also need to be implemented.  Detailed inspection and maintenance logs will also need to be prepared, and depending on the equipment at play, weekly inspections may be required.

Ventilation Program
The MOECC is also mandating that facilities appoint a ventilation coordinator, whose would have the responsibility of ensuring all the necessary documentation is in place.  This would include:
-a description of all ventilation systems
-process flow diagrams (drawn to scale)

Ontario plating facilities would also be required to conduct a ventilation assessment report.  Ventilation assessment reports are intended to ensure that the system is operating at optimal capture efficiency.
A ventilation assessment report would include:
-measured duct velocities
-static pressure measures in all branches
-volumetric flow rate calculations
-comparison of the total make-up air to exhaust air rates
-face velocity of hoods
-visual assessment of fugitive emissions
-exit velocity for each stack
-drawings showing orientation and configuration of each stack, and
-an assessment as to whether or not any part of the ventilation system is inadequate to capture fugitive dust emissions.

The above contains a couple of big 'asks' from the MOECC.  First ,process flow diagrams drawn to scale..the reality is must facilities evolved over time, and having accurate drawing for all ducts and process equipment might be a challenge.  For instance, some air pollution control equipment might predate electronic CAD packages, and records might either by absent or not easily transferable to include other equipment in the system.  Also, the ventilation system seems to be overly constrained?  Why so many measurements?  Wouldn't it be easier to require a professional engineer to certify whether or not the ventilation system is adequate to capture the identified contaminants?  Making static pressure readings at every branch can surely have no value for most companies, and additionally, the reality is, most of these branches likely occur in areas where no safe access exists, or in the roofs where no sample ports are available.  Additionally, most duct work within the industry was likely installed by contractors, and the availability of a suitable sample location in a laminar flow regime is scarce.

If you could like to know more about how Technical Standards, or how Rubidium can help feel free to give us a call or email: 905-635-4063  info@rb-enviro.com
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Sewer Surcharge Rebate

Does your process consume water that does not get discharged to municipal sanitary sewers?  If your facility has a sewer use agreement, is paying a sewer surcharge you may be entitled to a rebate on your waste water bill.

Common reasons include:
-Evaporative losses (cooling towers, etc)
-Steam losses (boilers)
-Process (contained in product).

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Ontario Industries Can Finally Burn Waste

As part of the Ministry of Environment and Climate Change (MOECC) push to eliminate coal use in the province, O. Reg 79/15 - Alternative Low Carbon Fuels has been passed.  O. Reg 79/15 allows energy intensive industries that currently burn coal, or petcoke to use alternative low carbon fuels.  

While several waste options are appealing, the focus will shift to bio-mass, and other woody feed-stocks.  The cement industry has been toying with this concept for years. Lafarge has recently launched cement2020.org in an attempt to displace coal from one of its cement plants.

One of the challenges for manufacturers will be complying with the air quality regulations, especially Environmental Compliance Approvals.  Dioxin and Furan emissions have long been a problem for biomass combustion.

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Ontario’s Cap & Trade on GHG emissions

Ever since Premier Kathleen Wynne announced that Ontario has signed a letter of intent with Quebec to adopt a cap and trade system that sets limits the greenhouse gas emissions, industry has been set a buzz with trying to understand the implications.

But what are the implications?  And what will Ontario’s cap and trade system look like?  Right now, the MOE, industrial stakeholders, and consultants are still trying to establish exactly that.  Given that policies will been to be established, regulations enacted and amended, it’s not likely that we will see anything formalized until sometime in 2016, perhaps even later.
In 2009, the Ministry of Environment (MOE) published “Moving Forward: A Greenhouse Gas Cap-and-Trade System for Ontario”  which provides background on the framework that the MOE is considering in adopting its system.

Also in 2009, Ontario took its first step in setting up the cap and trade system when it passed O. Reg 452/09: Greenhouse Gas Emissions Reporting.  This regulation requires facilities with stationary fuel combustion equipment, and specific industrial processing that emit CO2, to report to the MOE if their total emissions of GHGs exceed 25,000 tonnes of CO2e (carbon dioxide equivalent).  This regulation has two components, first the reporting of the emissions, and then a third party validation of the emission estimates.  The third party verification must be done by a firm that has been accredited under ISO 14064, and that can confirm that the report meets the international standards of ISO 14064-3.  For a GHG report to be verified, the verifier must conclude that the GHG calculations are accurate within +/- 5%.

These verified GHG reports will serve as the basis for establishing where companies fall within the cap & trade system.  To discussions are still open, and some major considerations are:
• What year to use as baseline?  (potential negative impacts if baseline year was a year with production cut-backs, i.e. average from 2003-2007)
• Phase-In – will everyone be brought in at once, or will it be staggered based on sector?
• Allowance/Allocation - how will the allowance of GHG emissions be determined?  How an 
• Offset Credits – how will they work?  Pricing structure (open market, floor/ceiling pricing, etc)
There is still a lot left to figure out, and multiple rounds of stakeholder meetings still to be had.  But the biggest question still on everyone’s mind is how much will all this cost?

Interesting in finding out more about Greenhouse Gas (GHG) regulations, feel free to give us a call (905) 635-4063 or email us at: info@rb-enviro.com 
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