HomeMy WebLinkAboutPSD-064-16Planning Services
Report
If this information is required in an alternate accessible format, please contact the Accessibility
Coordinator at 905-623-3379 ext. 2131.
Report To: Planning and Development Committee
Date of Meeting: November 14, 2016
Report Number: PSD-064-16 Resolution:
File Number: PLN 33.3.10 By-law Number:
Report Subject: Durham York Energy Centre Air Quality Monitoring Results –
Options for Retaining an Air Quality Expert
Recommendations:
1.That Report PSD-064-16 be received; and
2.Council provide direction to staff on any further actions that it deems necessary.
Municipality of Clarington
Report PSD-064-16 Page 2
Report Overview
Staff were requested to report back to Committee in November 2016 on options for retaining
an air quality expert, with expertise recognized in North America, to assist Council with
interpreting the ambient air (off-site) and stack test reports for the Durham York Energy Centre
energy from waste facility. The report outlines options and recommends that explanation of
the ambient air and/or stack test results be requested from the Region of Durham and Ministry
of the Environment and Climate Change staff.
1. Background
Ambient Air Monitoring Program in the Area of the Durham York Energy Centre
The Durham York Energy Centre (DYEC) Ambient Air Quality Monitoring Plan has been
prepared to satisfy Condition 11 of the Environmental Assessment (EA) Notice of
Approval and Condition 7(4) of the Environmental Compliance Approval (ECA). The
monitoring network includes upwind and downwind stations that have been measuring air
contaminants since May 2013, prior to facility start-up. Some parameters are measured
continuously, while others are non-continuously monitored. A fence line station, which
measures non-continuous parameters, was installed prior to full operation of the DYEC.
In October 2014 the Region added an additional monitoring station at Clarington’s
request, which is located off of Crago Road on the Ontario Power Generation (OPG) site.
The ambient air quality monitoring station locations are shown on Figure 1. A list of air
emissions monitoring parameters is provided in Attachment 1.
Figure 1: Ambient Air Monitoring Stations for the DYEC
Municipality of Clarington
Report PSD-064-16 Page 3
Quarterly Ambient Air Quality Monitoring Reports are submitted by the Region’s
consultant, Stantec, to the Ministry of the Environment and Climate Change (MOECC) for
review. The results for the Crago Road station are not part of the MOECC monitoring
program requirement, and are reported separately on a quarterly basis.
The ambient air monitoring program for the DYEC is scheduled to run for three years
after commencement of operations. At the July 5, 2016 meeting of Council, it was
resolved that the Municipality of Clarington would write to the MOECC and request the
Minister order that the ambient air monitoring program be extended by two years. The
response received from the MOECC is included as Attachment 2 and indicates that
MOECC staff will complete an assessment and determine whether additional ambient air
monitoring is required in February 2018.
The ambient air monitoring stations monitor air quality in the area of the DYEC, not
exclusively DYEC emissions. The equipment is calibrated on at least a quarterly basis,
with periodic equipment audits by the MOECC at their discretion. In 2015, calibrations
were completed monthly. The CALPUFF computer model is an MOECC standard; as is
the averaging over 36 months and using the 98th percentile for PM2.5. Anomalies
(spikes/lows) happen when averaged they are not considered exceedances.
There are other ambient air monitoring stations in the general area (see Attachment 3).
St. Mary’s Cement maintains an upwind and downwind station for its operations and
monitoring program. Temporary ambient air monitoring stations have also been installed
to monitor conditions as part of the 407/418 construction. In addition, the MOECC has a
long-term ambient air monitoring station at the Durham College Oshawa Campus.
In 2014 and 2015, the Environmental Monitoring and Reporting Branch of the MOECC
conducted an air monitoring survey (TAGA – trace atmospheric gas analyzer survey) in
the vicinity of the DYEC at the request of the Ministry’s York-Durham District Office.
Clarington had been instrumental in making this a priority for the District Office. It was
announced at the September 21, 2016 meeting of the EFW -WMAC that the MOECC
would be carrying out the same testing in October 2016.
The objectives of the TAGA air monitoring were to:
a) Measure background ambient concentrations of volatile organic compounds (VOCs)
in the vicinity of the DYEC prior to its operation; and
b) Identify and measure concentrations of VOC’s in ambient air downwind of DYEC
during operation.
The results where typical of urban areas in Ontario before and after DYEC operation with
no marked change (see Attachment 4).
Municipality of Clarington
Report PSD-064-16 Page 4
DYEC Facility Air Emissions Monitoring Program
Separate from the DYEC Ambient Air Quality Monitoring Plan, the Air Emissions
Monitoring Plan has been prepared to satisfy Conditions 12 and 13 of the EA Notice of
Approval and Conditions 7(1), 7(2) and 7(3) of the ECA. Air emissions monitoring started
when the first discharges were emitted from the facility. The monitoring program includes:
a) Continuous emissions monitoring systems (CEMS);
Continuous emissions monitoring (CEM) began with the commencement of boiler
operations (each boiler has its own monitoring equipment). A list of CEMS
monitoring parameters is provided as part of Attachment 1. Live CEM data is
posted to the DYEC website and the external facility display board.
b) Stack testing (also known as source testing);
In addition to CEM, air emissions from the facility are tested twice per year by a
stack (source) test. The parameter categories tested during the stack (source) test
are also listed in Attachment 1. The stack tests are carried out by a qualified air
specialist team under the scrutiny of an independent (third party) consultant. The
labs that analyze the samples collected are selected by Durham Region and results
are submitted to the MOECC.
c) Long term sampling for dioxins and furans;
Long-term sampling for dioxins and furans is performed by the AMESA sampler.
Through continuous monitoring, the sampling is intended to determine long-term
variations of dioxin and furan emissions levels over time. The system is evaluated
as part of the stack testing program. When Boiler #2 failed the stack test in May
2016, the Region retained experts to ensure that the AMESA sampler was
performing as anticipated.
DYEC Facility Air Pollution Control Equipment
Each boiler has its own dedicated Air Pollution Control system consisting of:
Selective non-catalytic reduction system for control of nitrogen oxides (NOx);
Patented Very Low NOx™ system for additional NOx control;
Evaporative cooling tower with dry lime reactor for acid gas control;
Activated carbon injection system for mercury and dioxin control;
Minimum temperature of 1,000°C for VOC and dioxin and furan control; and
Fabric filter baghouse system for particulate matter control.
CEM devices monitor stack emissions on a continuous basis to ensure compliance. The
DYEC is required to meet the air emissions standards set out in Ontario Regulation
419/05 Air Pollution – Local Air Quality (O.Reg. 419/05) and the MOECC Guideline A-7
Combustion and Air Pollution Control Requirements for New Municipal Waste
Incinerators (A7 Guideline). One exception to this is the stack emission limit for dioxins
Municipality of Clarington
Report PSD-064-16 Page 5
and furans at the DYEC, which is more stringent than the A7 Guideline limit (60 pg/Rm3
for the DYEC compared to the A7 Guideline value of 80 pg/Rm3).
2. Options for Retaining an Air Quality Consultant
2.1 Retaining a Consultant
Depending on what role is required of the consultant and the assignment, there are
options within the Municipality’s Purchasing By-law to retain a consultant:
Expression of Interest (EOI) - A multi-staged process that can be used to shortlist
potential bidders before seeking detailed bids from the shortlisted bidders. An EOI is
generally used when the information required from bidders is specific, but the
Municipality is unsure of the capability of bidders to provide the required goods or
services. An EOI can also be used if the buyer is just looking to find out if there are
potential bidders who may have an interest in a particular project for goods or
services, or is seeking industry input into scoping requirements that will then go
back out to market later on as a Request for Proposal.
Request for Proposal (RFP) – The Municipality issues a detailed terms for reference
that outlines the tasks, timeframe, background material to be reviewed to orient the
consultant to the project, number of meetings, presentations to Council and public
meetings they are expected to attend, and reporting requirements. The length of
the assignment must be clearly stated, and whether there will be additional work
beyond what can be detailed in the terms of reference and how any additional work
will be paid (e.g. by task, hourly, expenses).
Sole Source – The selection of a consultant based on their expertise. If the contract
amount is $30,000 or less, direct hiring of a consultant is allowed under the
Municipality’s Purchasing By-Law. If it is anticipated that a contract could exceed
$30,000, the Municipal Purchasing By-law would have to be waived by Council.
2.2 Consultant Qualifications
Council resolution #C-192-16 outlines that the consultant has to be an air quality expert
with expertise recognized in North America. Such a consultant has previously been
retained by the Municipality during the initial permitting stages for the DYEC. As part of
the peer review for the DYEC Environmental Assessment, Clarington hired SENES
Consultants for the air quality and human health and ecological risk assessment aspects;
since that time SENES has been purchased by another company (Arcadis) and none of
the individuals involved with our contract remain with the new company.
It may be difficult to find an air quality expert that does not have a conflict of interest given
the number of consultants that are already engaged with respect to DYEC air emissions
or have affiliations with previous phases of the project. In addition, recent consolidations
in the consulting sector may limit the number of companies. Further, while having a
consultant with expertise recognized in North America is important, it is also imperative to
have a consultant who is fully cognizant of the O.Reg. 419/05 and the A7 Guideline
requirements.
Municipality of Clarington
Report PSD-064-16 Page 6
2.3 Consulting Assignment
A terms of reference for the consulting assignment will have to be determined for what
Council would like the consultant to interpret. There is a significant difference between
being able to review reports and explain them, as opposed to digging into the numbers
and being able to verify the readings, check the computer model, or question the lab
results. Regardless of what process is used to retain a consultant, a clear understanding
of the assignment will be required in order to obtain an accurate project budget estimate
in advance of hiring the consultant.
2.4 Consulting Tasks and Costs
To obtain a task outline and preliminary estimate of effort required, staff looked to similar
assignments. Essentially there are three options that Council could consider to retain an
air quality expert.
2.4.1 Option 1, Monitor – The consultants’ role would be explanatory. The consultant would
provide costing for a five year term of service. The scope of work would be limited to
reviewing the annual DYEC air quality reports and explaining findings to Council. This
would include:
a) Background familiarization with the EA conditions, background reports, monitoring
reports to date and other information for a consultant already familiar with the A7
Guidelines for Ontario, MOECC CALPUFF computer model and regulatory
requirements - 115 to 150 hours; and
b) Annual Presentation and Meeting with Council for 5 years, including all preparation
time for presentation and report writing – 300 to 350 hours (60-70 hours annually).
Typically the charge-out rate for an experienced consultant with good standing and
recognition in the field would start at $200/hour. The cost range would be from $83,000
to $100,000.
Ambient Air Quality Monitoring Reports for the DYEC are issued on a quarterly basis; so
if Council is seeking more frequent input this should be set out in the terms of reference,
and would increase the cost range. Additional scope of work items to be considered
include whether the consultant is to be on call to respond to questions or concerns from
the public or individual Council members, and whether the consultant is to provide
comments and/or recommendations to the MOECC. All of these interactions will need to
be tracked and authorized to ensure the consultant does not exceed the budget.
Additional work beyond what can be detailed in the terms of reference could be
performed on an hourly basis. The hourly basis rate should be determined at the time of
retaining the consultant with an annual cost of living escalation provision, as well as an
annual upset limit.
2.4.2 Option 2, Peer Review – The consultants’ role would be both explanatory as noted
above, and the consultant would be requested to provide their expert opinion on the
process being followed and interpretations provided. If the process or interpretation are
not acceptable the consultant would then be asked for a course of corrective action which
Municipality of Clarington
Report PSD-064-16 Page 7
would be submitted to the Region and MOECC for their consideration. For the consultant
to Peer Review the stack tests, access during the testing as part of the team will be
required and at the discretion of the Region and Ministry who are responsible under the
terms of the Environmental Compliance Approval. The cost range would be starting from
$100,000 to $250,000 over the five year term, and possibly more depending on how in
depth and/or the number of reports requiring peer review.
2.4.3 Option 3, As Needed Basis – The consultants’ role of this assignment would be
background familiarization of the project (Option 1, item a) and to provide clarification and
explanation on an as needed (“on-call”) basis at Council’s discretion. In this case there
would be a minimum amount of effort initially for limited background familiarization of less
than $30,000. When called upon, which may be on an annual basis, quarterly basis, or
more frequently, an hourly rate would apply. For this option, costs could be contained by
establishing an overall upset budget on an annual basis.
2.4.4 Option 4, Responsible Agencies – Council should be cognizant that the Region is
paying in the range of $450K annually on ambient air monitoring for the DYEC. In
addition, each stack test is monitored by both the Region and Covanta and a third party
consultant at a total of $380K per test (currently 2 per year are required). The air
pollution control equipment consultant brought in to review the AMESA sampler data was
an additional $35K. All of this information is submitted to the MOECC who review the
results to ensure they meet the Air Emissions Monitoring Plan, Ambient Air Quality
Monitoring Plan, the requirements of the EA Notice of Approval and ECA, and the O.Reg.
419/05 and A7 Guideline requirements.
As outlined above, more than $1.2 million of public funds are spent annually in air
monitoring at the DYEC. Council has sought and may continue to seek clarification and
explanation, first from the Region of Durham and second from the MOECC. Regional
staff have provided Council with presentations and explanation when requested.
Clarington staff can call upon MOECC staff at any time. As the responsible agencies, the
Region and MOECC are obligated to communicate the impacts on the air shed of the air
emissions in an understandable and comprehensive manner.
3. Concurrence
This report has been reviewed by the Purchasing Manager.
4. Conclusion
The Region and MOECC have responsibility for the air quality monitoring program at the
DYEC. The Region has retained consultants with expertise in air monitoring and the
MOECC’s technical staff review all the data. In addition, MOECC staff conduct quarterly
audits of the air monitoring equipment to ensure they are operating properly. In the past,
Council has requested the Region provide an explanation of the air monitoring results
which has been complied with expeditiously. Given the willingness of Regional staff to
provide explanations of the air monitoring results Clarington staff are recommending that
Option 4, Responsible Agencies, the Region is the first response for air emission queries.
Municipality of Clarington
Report PSD-064-16 Page 8
As a second line of response Ministry staff have indicated that they would be available to
respond to inquiries.
Lastly, we note that annual air quality reports have been prepared by the Province since
1970 based on the ambient air monitoring stations that the Province has across Ontario.
The general trend across the Province is a decrease in air emissions. However, given the
number of ambient air monitoring stations in the Courtice/Bowmanville area for different
projects and facilities and since all of this data is submitted to the MOECC; a request to
the MOECC for a summary of the cumulative findings and any potential implications for
Clarington residents could be made.
If Council wishes to pursue the retention of their own expert air quality consultant, then
direction should be given to staff regarding the preferred work assignment, Options 1, 2
or 3 and the estimated cost be listed as an optional item for the 2017 budget
deliberations.
5. Strategic Plan Application
Not applicable.
Submitted by: Reviewed by:
David J. Crome, MCIP, RPP Curry Clifford, MPA, CMO
Director of Planning Services Interim CAO
Staff Contact: Faye Langmaid, Manager of Special Projects 905-623-3379 ext. 2407 or
flangmaid@clarington.net
Attachments:
Glossary of Terms
Attachment 1 - DYEC Summary of Air Emissions Monitoring Parameters
Attachment 2 - MOECC response dated Aug 8, 2016
Attachment 3 - Ambient Air Monitoring Stations by St. Mary’s Cement and for Highway
407/418 construction.
Attachment 4 - Mobile TAGA Ambient Air Monitoring by MOECC
There are no interested parties to be notified of Council’s decision.
DJC/FL/tg/df
I:\^Department\LDO NEW FILING SYSTEM\PLN Planning Files\PLN 33 Waste Management\PLN 33.3.10 EFW - DURHAM YORK RESIDUAL WASTE STUDY\Air Quality Monitoring
Expert\Staff Reports\PSD-064-16 _DYEC Air Quality Report.docx
Glossery of Terms to
Municipality of Clarington Report PSD-064-16
Glossary of Terms
A7 Guideline MOECC Guideline A-7 Combustion and Air Pollution Control Requirements for
New Municipal Waste Incinerators
CEM Continuous Emissions Monitoring
CEMS Continuous Emissions Monitoring System
DYEC Durham York Energy Centre
EA Environmental Assessment
ECA Environmental Compliance Approval
EFW -WMAC Energy from Waste – Waste Management Advisory Committee
EOI Expression of Interest
MOECC Ministry of the Environment and Climate Change
NOx Nitrogen Oxides
OPG Ontario Power Generation
O.Reg. 419/05 Ontario Regulation 419/05 Air Pollution – Local Air Quality (O.Reg. 419/05)
PM2.5 Particular Matter measuring 2.5 microns (2.5 um) in diameter or less
RFP Request for Proposal
TAGA Trace Atmospheric Gas Analyzer Survey
VOCs Volatile Organic Compounds
Attachment 1 to
Municipality of Clarington Report PSD-064-16
Durham York Energy Centre Summary of Air Emissions Monitoring Parameters
Ambient Air Monitoring – Upwind/Downwind Stations and Crago Station
Continuous emissions monitoring (CEM):
Nitrogen oxides (NOx), Sulphur dioxide (SO2), Particulate matter less than 2.5 microns in
diameter (PM2.5)
Non-continuous monitoring:
Total Suspended Particulate Matter (TSP), Metals (in TSP), Polycyclic Aromatic
Hydrocarbons (PAHs), Dioxins and Furans
Ambient Air Monitoring - Fence Line Station
Non-continuous monitoring:
Metals (in TSP)
Stack (Source) Testing
Metals, Chlorobenzenes and Chlorophenols, Polychlorinated Biphenyls (PCBs), Volatile
Organic Matter (volatile organic compounds VOCs), Polycyclic Organic Matter (polycyclic
aromatic hydrocarbons PAHs), Dioxins and Furans, CEM System parameters, Total
Suspended Particulate Matter, Total PM-10, including condensables, Total PM-2.5, including
condensables
Schedule D in the Environmental Compliance Approval (ECA) lists the full suite of parameters
to be tested.
CEM System
nitrogen oxides (NOx), sulphur dioxide (SO2), carbon monoxide (CO), hydrochloric acid (HCl),
hydrogen fluoride (HF), ammonia (NH3), organic matter, oxygen (O2), opacity, moisture,
temperature
·Ministry
of the Environment
and Climate Change
Central Region Office
5775 Yonge Street
81h Floor
North York ON M2M 4J 1
Tel.: 416 326-6700
Fax: 416-326-6345
August 8, 2016
June Gallagher
Deputy Clerk
Minist8re
de !'Environnement et de l'Action
en matiere de changement climatique
RE!gion du Centre
5775, rue Yonge
a e etage
North York (Ontario) M2M 4J1
Tel: (416) 326-6700
Telec: (416) 326-6345
The Corporation of the Municipality of Clarington
40 Temperance Street
Bowmanville, ON LlC 3A6
Ms. Gallagher,
l')h t >i,,r Ontario
ENV1283MC-2016-2024
Thank you for providing the Clarington Council Resolution to the Honourable Glen Murray, Minister of
the Environment and Climate Change regarding the Durham York Energy Center located in the
Municipality of Clarington. I have been asked to respond on behalf of the minister.
On May 16, 2012, the ministry approved the Ambient Air Monitoring Plan (Plan), prepared by the
Regional Municipalities of Durham and York in accordance with Condition 11 of the Notice to Proceed
with the Undertaking. The Plan specifies that the operational monitoring ( at the upwind and downwind
ambient air monitoring stations) is to be conducted for a minimum of 3 years.
The ambient air monitoring results for PM2.5 are compared to the Canadian Ambient Air Quality
Standards (CAAQS). Though there was a slight increase in the 98th percentile of PM2.5 24 hour
concentrations at Courtice and Rundle stations in 2014 compared to 2015, only Rundle station was
slightly above the CAAQS target value of28 µg/m3 in 2015. However, this comparison is based on only
one year of data, and three years of data is required to assess against the PM2.5 CAAQS. Since
operational monitoring commenced on February 13th, 2015, insufficient data has been collected to
determine with any certainty if elevated concentrations have resulted in an exceedance of the CAAQS.
The following table provides a summary of the number of days, both before and after operations began
at the facility, where PM2.5 24 hour concentrations were above 28 µg/m3 at the Courtice Station,
Rundle Station and where elevated concentrations were experienced at both stations on the same day. In
total, 10 events of elevated concentrations occurred before operation, and 16 occurred after.
No. of davs with 24 hr PM2.5 concentrations 11reater than 28 1111/m3
Station Before Operation After Operation
Courtice 4 5
Rundle 6 11
No. of days where both stations
experienced elevated 4 4
concentrations
... 2
A
Attachment 3 to
Municipality of Clarington Report PSD-064-16
St. Mary’s Cement Ambient Air Emissions Monitoring Stations
St. Marys Cement air emissions are monitored using a series of sampling locations as set out
in the following table.
The location of the sampling stations is shown on the aerial, below.
Sample Station Location Monitor
SMC1 OPG PM 10 BAM, Dust fall jar
A North East of Quarry PM 10 Hi Vol, Dust fall jar
B Cedar Crest PM 10 Hi Vol, Dust fall jar
C Cedar Crest (MOE location) Dust fall jar
SMC 2 Cove Road PM 10 BAM, Dust fall jar
Highway 407 and 418 Construction Monitoring Stations
The location of the sampling stations is shown on the aerial, below.
Pre-construction monitoring of Phase 2 of the Highway 407 East extension construction at
1939 Highway 2, Courtice, ON (“the Hwy 2 location”, took place from July 1 to September 30,
2015. This program involved continuous monitoring of Inhalable Particulate Matter (PM10),
Fine Particulate Matter (PM2.5), and Nitrogen Oxides (NOx), in addition to collecting
meteorological data. This sampling was conducted as required under condition 15.3 of the EA
Notice of Approval to Procced with the Undertaking, which can be found in Appendix C. The
following report includes all of the data and analysis of the information collected from the site
over the three month sampling period. This pre-construction air quality data set characterizes
the baseline air quality of the area prior to any construction activities.
Throughout this monitoring period, none of the applicable standards and criteria was exceeded
for any of the parameters measures at this station.
Attachment 4 to
Municipality of Clarington Report PSD-064-16
Mobile TAGA Ambient Air Monitoring by MOECC
Summary
In 2014 and 2015, the Environmental Monitoring and Reporting Branch (EMRB) of the Ministry
of the Environment and Climate Change, conducted real time air monitoring in the vicinity of
the Durham York Energy Centre (DYEC) for selected volatile organic compounds (VOCs) at
the request of the Ministry’s York Durham District Office. Several VOCs were identified and
measured downwind of the DYEC. The VOCs for which the highest half-hour concentrations
were measured include acetone (19µg/m3) in 2014, 6.8 µg/m3 in 2015) and xylenes (7.8 µg/m3
in 2014; 3.9 µg/m3 in 2015). These concentrations are typical of urban areas in Ontario.
Measured ambient concentrations of VOCs did not exceed their respective Ontario Regulation
419/05 Air Pollution – Local Air Quality air standards or guidelines during the 2014 and 2015
survey period.
Mobile TAGA Survey, Durham York Energy Centre, Courtice, Ontario, 2014 and 2015