Toxic Reduction Program
The Toxics Reduction Act, 2009 and the associated Regulation (Regulation 455/09) are the cornerstones of Ontario’s strategy to reduce the use and creation of prescribed toxic substances to prevent pollution and protect human health and the environment.
The Act and Regulation do not restrict the use, creation, or release of prescribed toxic substances. The Regulation requires each facility to examine how they are using or creating prescribed toxic substances and to consider opportunities for reducing prescribed toxic substances.
AV Terrace Bay completes the following actions:
1. Toxic substance accounting – updated every year in June
- Identify stages and processes that use or create the prescribed toxic substances
- Prepare process flow diagrams for each substance through these processes & stages
- Track and quantify the amounts of each prescribed toxic substance and report to Environment Canada via National Pollutant Release Inventory (NPRI)
- Publically post the most recent Toxic Reduction Accounting Summary Report.
2. Toxics reduction planning – a separate reduction plan is required for each substance, updated every 5 years
There are 53 prescribed substances that are either used or created at AV Terrace Bay.
Reduction strategies for the prescribed substances at AV Terrace Bay:
There are three categories of substances at our mill that the Reduction Act applies to:
- Substances we purchase to use in the manufacture pulp from wood chips.
- Substances that enter our process as trace impurities in wood or water feed stocks. Under the Regulation these are still considered chemicals that we “use”.
- Substances that are created as byproducts of the manufacturing process.
List of substances & reduction plans:
- Substances entering the mill as impurities: If the impurity was present in a chemical feed stock we could spend extra money to purchase higher purity chemicals. However, purchased chemicals are not a significant source of the listed metals so this is not a useful option for our facility. Almost all of the following (except nitrate) enter our process as trace minerals in wood. The concentrations of these metals in wood depend on the natural levels of metals in the soil where the trees grow. Similarly, nitrate enters our process via water taken from Lake Superior. Lake Superior water is very pure compared to many other lakes, but still contains very small amounts of nitrate ion. As we have no control over the naturally occurring trace impurities in wood or water, reduction strategies for these substances involve reducing wood waste and increase water recycling in the process to reduce water use
- Hexavalent chromium
- Purchased substances: Use of these substances will increase with mill production. Our reduction plans center on maximizing the efficiency of their use.
• Methanol (also called wood alcohol)
• Sulphuric acid
- Substances created as byproducts of our process: To reduce creation of combustion byproducts our reduction plans focus on improving energy efficiency. That is, to use less fuel per tonne of pulp produced; also, to use more renewable fuel and less fossil fuel. Creation of byproducts using the kraft pulp process is not avoidable. Since we have little opportunity to reduce the quantity created we focus our attention on pollution control measures that destroy as much of these byproducts as possible. The Regulation seeks only to reduce the creation, so these pollution control measures are not considered relevant under the Act.
- Carbon monoxide
- Dioxins (7 isomers) & Furans (10 isomers)
- Hydrochloric acid
- Hydrogen sulphide
- Nitrogen oxides
- PAHs (polyaromatic hydrocarbons)
- Particulate matter (total particulate, PM10 & PM2.5)
- Sulphur dioxide
- Total reduced sulphur (mixture of hydrogen sulphide, methyl mercaptan and other organic sulphides)
- Volatile organic compounds (VOCs)
- Alpha-pinene, beta-pinene (i.e., turpentine)
- Ethanol (ethyl alcohol)
- Isopropyl alcohol (also called rubbing alcohol)
- Methanol (also called wood alcohol)
- Methyl ethyl ketone (MEK)
AV Terrace Bay is required to evaluate the technical and financial feasibility of options for reduction and publically post a reduction plan for each substance (see below), but compliance with the Act and Regulation does not require implementation of any reduction plan. AV Terrace Bay elected to report no plan to reduce the use or creation of any of the 52 designated substances even though we have plans and have achieved reductions for some substances. The facility will strive to reduce the use and creation of toxics substances whenever feasible. However, any reductions achieved per tonne of pulp produced will not be reported by AV Terrace Bay as a planned reduction under the Act because of the excessively burdensome reporting requirements prescribed by the Regulation.