\\\\l\1\\\\\I1~\\\I\\\\\ l!i\ \\ii\\Iii\\\\\ [CL37CA02 0 REVIEW OF ENVIRONMEN TALPROTECTION ACTIVITIES FOR 1976 -1977 ,· t PROPRIETARY TO IMPERIAL OILAND AFFILIATES ...· IIPEIIALOil LIMITED TORONTO, ONTARIO 628. 5 134 IIO •• 11 I~ ENVIRONMENTAL PROTECTION REVIEW AND COORDINATION ACTI!ITIES 1976 - 1977 CONTENTS I. II. III. June, Page No . PERSPECTIVE 1. International 1 2. U. S. 2 3. Canadian 4. Public Review Legislation 5 1 976 - 1977 7 Attitudes PERFORMANCE, PROBLEMS AND PLANS OF OPERATING DEPARTMENTS 1. Exploration and Productio n 2. New Energy 3. Logistics 11 4. Marketing 12 5. Esso Chemical 13 6. Essa Minerals 14 7. Oil 9 Resources Spill 10 Statistics 14 COORDINATION ACTIVITIES 1. Technical 2. Industry 3. Environmental 4. Coordination 1978 Effort, Expenditures, Activities Quality De~artrnent Budgets 16 16 Committee Activities 19 20 ENVIRONMENTAL AND P HO'l'l·:C'I' I ()N -- fl W/1 J•:W COORDTNA'l' LON I\C'I' I / 1'J' 11~!, - 1976 1 'J77 SEC'r JO I PERSPECTIVE 1. - ISSUES AUD l,f•:<:1,,Lfl.'T' I ON I ternational The United Nati ons Environm0.nt.ctl now coordinates or sponsor s most, but not a tivities in the environm ent~l arc~. Proqr m (U!/F.l') all , int •r.n" i(JJ1 The Governing Council of UNEP, of which C'r1n,d I I a member , meets each year for two w ks in Iairobi, K•ny1 to hear and discuss reports on program ctivi ·ies 1nci approve program contents and budg ·s for the curr.i;:;n t incl following two or three years. The Director current issues pressing General as: - International Chart ' Resurgence control of designated of the toxic chemic wastes from four mos ls malaria - Handling of agricultur al i n c r eased food production - Ene r gy conservation. enviro J une In 19 76 and 1977 the list n menta l conferences and their 19 76 U. N. Con ference on Human Settlements Public par t i cipation in planning a n d management Mar. 1977 Sept.1977 U.N. Water of international themes included: - Vancouver the policy formation of human settlement. Conference Constraints boundary agricultur to the wise use wat e r issues, and e water supplies The U.N. Conf e r ence of water resources, community and were discussed. on Desertification Process e s cr eating deserts action plans t o combat and proposed. - Nairobi were examined reclaim deserts and 1 f - The 5th and 6th Appeared to make but were hung up and exploitation (Oil and Mineral 2 - Law of the Sea Conferences s·ome headway in certain issues by deep divisions over rights of the Deep Seabed Resources Nodules). A UNEP-IPIECA Seminar on environmental impacts of the petroleum industry was held in Paris March 29-April 1, 1977. A summary report was issued previously. Summary 1. Chart of 1977 Agreement on Conservation of Shared Resources States agree to ensure activities boundaries do not cause damage of other states. to within their the environment 2. Duty to warn neighbouring states of situations which might cause harm. 3. Responsibility to fulfill international obligations in the environmental field when using or conserving shared resources and subject to liability for damage by violation of agreements. 4. Remedies shared. 5. Environmental assessments should be made before undertaking activity which would significantly affect the environment of neighbour states. 2 for adversely affected emergency population should The agreement was sign ed by 26 countries the goal of passage by the U.N. General Assembly codification into international law by 1982. 2. u. S. Review . In the past two years, five major environmental legislation have been enacted: pieces Toxic Substances Control Act (1976) Resource Conservation and Recovery Act Safe Drinking Water Act (197 6) Clean Air Act (1977) Clean Water Act (1977) im with and T~ develop strategies plementation of the complex of (1976) and regulation for the provisions of these laws, be increas ed b u reaucrc required. Presid n over 1978 in th 1979 op , 1 .i t I 11<1 $850 mill ion to $1. l bi 1 I i 11. that I I I I Thrust and I mplications I" i V ' J\ ' t •:: The Toxic Su bstanc s Con ro l r,... th«• petroleum and oth e r indu stri s w1 lh t orup I ' X . 1 ', - i «'. of proposed rules and r e gul ations for i dl n ti t·y i ng, c; d t1 I o qu i ng, reporting and controll i n g a vast numb\. t· of. sub ~,ldtt C , ~; th Lt are toxic or potentiall y toxic . rn Lh cts, of r fin 0 ry waste waters, 65 compound s or cl.:1ss of C"Ompouncl. h ~tv been designated as toxic and will h v~ to b c ontroll ed to specified limits by th e u se of B st. Av,.\ i. l tb ll 'rt'C"hno logy (BAT) . The limits must b e set by EPA by July 1 , 1.9 80 ctnd industry must be in compli ance by 1984. Chart 3 to Under the Clean Wat er Act , EPA wa s r qui.red identify so-called convention a l poll u tants which include BOD, oil and grease, suspended s o lids and pH by March 28, 1978. The agency will determin e wh at is Best Conventional Pollution Control Technolog y (BCT) a n d industry will have to comply by July 1, 1984. Most r efiners will probably be in compliance because of the 197 2 Act requirement for BPT by July 1, 1977. The Resources Conservation an d Rec ov ery Act provides federal authority to deal with s o li d waste problems. By April 1978, EPA must publish criteria for the identification and listing of hazardou s wastes , taking into account toxicity, persistenc e , d e g radabi l ity , flarrunability, and other hazardous chara c t ert i s t ics . Then EPA must generate standards for generator s , t ransporters, and ultimate disposers of hazardous wast es . Con cer n over oil imports has put pressure on the U.S. Gov e rnm e n t to legislate the use of alcohol as an automotiv e f ue l component under this Act. Other alternate f u e l s fro m oil shale, tar sands, and coal will face land u se a n d land restoration controls under this Act. - cations disposal 4 - The Safe -rinkinc ~ate= Act ~i:l ~ave implion the undergrou.~c in~ection o= brines and the of toxic liquid wastes. The Clean Air Act 19,~ introduced new regulatory which has 9rofound i~plications for strategies and jargon u. S. industry and G. S. society. These are Prevention Areas, of Significant Deterioration (PSD), ~on-Attainment and Offsets or Trade-o==s. Under the PSD policy, the Act requires that in areas where ambient air quality standards are being met, any major new or modified sour ce of emissions must not deteriorate existing conditions by more than small specified increments. Because the permitted increments are so small, there exists the probability that most energy development and industrial expansion projects will be blocked. Of=set Policy requires that The "on-Attainment air quality in areas where one or more o= the ambient standards are not being met, any proposed new or modified u~less a greater than one-for-one source cannot proceed offset in emissions can be obtained by reduction of an existing emission source through trade-off. This policy has considerable potential for a market in pollutant emission rights. Sohio were rumoured to be buying up dry cleaning establishme nt s in Southern California for their proposed crude terminal at Long Beach. In non-attainment areas, a requirement of more immediate concern to industry is that the States must revise their State Implementation Plans to achieve air 31, 1982. quality standards for all pollutants by December Stage II service station controls, entailing 90% recovery of hydrocarbon vapour during vehicle fuelling, will be required in major centres in non-attain ment areas unless EPA considers that an API research project proves the feasibility of on-board vehicular control. Act, list, a hazardous rulemaking. polynuclear sulphates, The Administrator of EPA must, under the 1977 then regulate, any substance which is deemed air pollutant. Benzene is already subject to Other substances which are being studied are aromatics (PNA's), polycyclic aromatics, arsenic, and cadmium. Fuel additives were regulated under the 1972 Act requiring manufacturers to test and register additives, MMT has been not only to fuels, but also to motor oils. banned in California and will be phased out in other I I - 5 - states after September 1, 1978, unless a ma jo r fleet test with catalyst-equipped v ehicles p r ove s that it does not significantly reduce the effecti v eness o f catalytic emission control systems. 3. Canadian Legislation 1976-1977 Federal - Under the Clean Air setting out National smelters, chlor-alkali mills. - Guidelines Petroleum two years PACE and Act, regulations were pr omulgated, Emission Standards for: l e ad plants, asbestos mi nes and were proposed for Natural Gas Pla n ts and Refineries, but are being re v i ewed after of vigorous discussion and cri t i ci s m by CPA. - The Fisheries Act amendments, passed i n 1977, str engthened the federal power in pollution control to a pot e ntially abusive degree vis-a-vis provincial r ight s . - Regulations for Liquid Effluent Stand a r ds were promulgated for: metal mining, meat and poultr y p l an ts , chlor - alkali plants, metal finishing plants and potato proce ss ing plants. Chart - Under the Environmental Contaminants Ac t, use, including banning, were issued for: dechloranes, mercury, mirex and PBB's. regulations PCB's , on 4 - Federal Guidelines for Preparing Initial Assessment Statements were issued. - Regulations under The Canada Shipping covering Great Lakes Sewage Pollution vessels. Provincial a bearing Legislation Only legislation on the Company's and En v iro nmental Act were iss u e d Prevent i on from Regulations or regulations operations are 1976- 77 which listed. may have Alberta Environmental Impact Assessment Guidelines - Oil Sands Surface Operations Regulations Land Surface Conservation and Reclamation were issued Act. iss ued . u nde r - 6 ,~ater Effluent Guidelines for Petroleum Refineries. ,ater Effluent Guidelines for Fertilizer Plants. British - Columbia _ution Control Act e.~e=gencies section. amended ? by addition of a pollution Manitoba - ~eg _ations issued under Clean Environment Act s~ rage and Handling of Gasoline and Associated governing Products. ew Brunswick - c:ean Environment Act ?Ower to the Minister. - As9halt Paving amended Plant to give regulations greater scope and issued. Nova Scotia - S,vironrnental Protection regulated pollutants. Act amended to increase list Newfoundland - :S..,vironmental Impact Assessment Guidelines issued. Ontario - ~ater ,aste Quality Management and Discharges - Objectives - A Model Municipal - ~egulations issued. for Noise - Contingency Materials By-Law Transfer - Additions to Regulated General Air Regulations Plan for re-issued. Control of Industrial and Guidelines issued. of issued Liquid of final Industrial Pollutants issued. Spills in Wastes on Schedul Oil and form. Other e I of Hazardous Quebec - Draft regulation - Pulp draft and Paper form. on Air Mi'll Quality E f fluent under regulations revision. still in of - 7 - - R gul a t i ons c overing Liqu id Ref in erie s we re issued. E f f lu e n t fr om Petroleum - Mo nt rea l Urban Communit y issued a comp r ehensive revised Air Purification By-Law. The By -La w i s shelved pending provincial action on its overreach into ene r gy control ar e as . Saskatchewan Guidelines 4. Chart 5 Chart 6 Cha r t 7 Cha rt 8 Pu blic Environmental issued . Impact Assessment Pol icy and Attitudes In 19 7 6 and 1977, environ men t (p o ll ut ion, etc.) ra n ked fourth in the level of Can ad ia n citizen s' concerns, exceeded by unemployment, infl a ti o n a n d national unity iss u es . A poll conducted b y We ekend Magazine in February, 19 78 o f 31 urban centres found t ha t 80% of people believe ai r, water , and land pollution ar e se r ious problems . The major ity of 53% felt that pollution was a problem in the i r own area , as well as a national concern . Industry was bl amed for water pollution b y t wice as many people as th e next highest culprit (munici pa l ities). Industry by more was also named the main cause of air p o llution people, outran king a u t omo bile s b y 4 t o 3 . The mo st interesting fi n d i n g of this survey is that peopl e , al t hough blaming indus try , consider the responsibilit y fo r correcting probl e ms lies with the government. Ap pro ximately eight times a s many people believe that gover nment rather than indus try ha s this responsibility. In the p o l l conducted for the Cor p or ate Profile Study in December 197 7, while 55 % agreed t ha t Imperial does show concern for th e environment , only 21 % cla imed they were aware of an y ef f orts Imperial was doi ng . sidered Alberta Ontario and British Co lumbia the hot-beds for envir onmental following closel y . could be conaction, wi th The issues are generall y p ro ject-spawned and rapidly grow from specific to broad generalities. The process, by its nature, tend s to environmental h 7aring tur~ all frogs into.loathesome t o ads . Delays on proJects for cosmetic surgery, or j ust to wear down opponents, are almost a certai nty . mod e ll e d, - 8 - Nota b l e e xam p les or del aye d a re : of - Canadian Ch a rt 9 Arcti - Re e d Paper - Ontario - Spruce Oil - Norther Capaci Refinery for Metro Terminal and Pipeline Spraying Coal , re- n Onta r io ty - Port Hope Disposal Sites Budworm - Camrose-Ryley Waste cancelled e Mills Uranium Liquid Landfill Pulp Generating Nuclear - Nanticoke - Kitimat Company Hydro's - Eldorado - Maple c Gas P ipelin projects Mine - Nova Toronto Scoti - Calgary Ga rbage a Po wer Environmental act i on in Canada will be focussed in the next few years on nuclear proj ects , causes of acid rain, specific toxic chemicals--such a s mercury, PCB's, and benzene--and any major oil s pill from an offshore blowout or marine disaster. .. q :JI•:( ''I' I ()N ll-:11<' A I I lM1Nl'I<:, Jll{C)J\1,1•:M:l /\tJIJ 1'1,/\NS (W C P 1,;H/\'I' I N c; I )I•: PI\ l{'l'M 1,:N'I'[; ompl i~ hnk n...:.. Pro1 1 111,1d1• In C'ombc1t ing corrosion probl ms in t h p I d u ·, • l w,1l · r: hc,ncl l i ncr sys t ms at Creek nd Jo , r , m I~I, ,Ind h( numbC'r of corrosion f il u res h v b t n r ci\1 ·,•d. Dav is Str 1977 , was ~:nvir:onmtnL1l rmpact l on xl nsivC' field d o DfN/\. Judy StdtemE'nt for work in 1976 and AdditionLl in the Beaufort generally nd bujlding nd drilling mud disposal c on fir med th t isl h a d o nly minor locc limp cs on the environment and no