1975 ENVIRONMENTAL
PP.OTECTIO
AND COORDINATIO ACTIIITIES

CONTENTS

I.

1.

UNEP
-

II.

III.

2.

U.

3.

Canadian

4.

Public

~

June,

S.

Issues
Burgeoning
Achievements
Law of the

1
2
2
2

Bureaucracy
Sea

Review

3

Legislation

and

Regulations

Attitude

4

6

PERFORMANCE AND PROBLEMS OF OPERATING FUNCTIONS

1.

Accomplishments

2.

Oil

3.

Major

4.

Plans

Spill

of

Operating

Incident

Problems

Departments

Report

7
9

Remaining

10
10

COORDINATION ACTIVITIES

1.

Technical

Effort,

2.

Industry

Activities

3.

Environmental

4.

Assistance

-ra...

Page
No.

PERSPECTIVE

1976

Expenditures,

Quality
to

Executive

Budgets

12
12

Committee

14

and

15

Departments

 - 1 -

1975

ENVIRONMENTALPROTECTION REVIEW
AND COORDINATION ACTIVITIES

SECTION I
PERSPECTIVE
1.

United

Nations

Environmental

Programs

There was considerable
criticism
from some quarters
that
activities
of UNEP were not focused
on finding
solutions
to.s~e~ific
regional
or global
environmental
problems.
This
criticism
sprung
from a misunderstanding
of the role
assumed
for UNEP by Maurice
Strong
and the mandate
given
to it by the
U.N.
There are encouraging
developments
of sound environmental
policies
by member states
and of the coordination
of
environmental
programs
of other
U.N. agencies
and associations.
Major concern
was also felt
by many observers
over the frequent
Tolba,
of
repetition
by Strong
and his successor,
Dr. Mostafa
the statement,
"UNEP must have a concrete
role
in leading
the
world's
governments
to the new Economic Order."
Problems

and

Issues

The Executive
Director
states
world environmental
problems
in capsule
form from two viewpoints.
In the
developed
countries,
both voluntary
and regulated
actions
will
control
recognized
pollutants,
but grave concern
is
emerging
with respect
to toxic
substances
and the physical
and emotional
effects
of noise.
Concern
is also being
expressed
over the loss
of plant
and animal
species,
natural
habitat,
and
deterioration
in the quality
of life.
In the underdeveloped
countries,
the problems
are
associated
with past or continuing
poverty,
manifested
by
poor housing,
poor health,
and unemployment.
Planned
development is UNEP's suggested
solution.
Dr. Tolba recently
enunciated
the five main issues
to be addressed
by the
Governing
Council
at their
fourth
annual
meeting.
First

is

The

Second

the question
of shared
natural
resources.
It is
proposed
to prepare
a set of guidelines
for shared
basins and shared
air sheds,
and hopefully
river
develop
a convention
on shared
resources.

h rt
2

Third,

major issue
development.
harmful
effects

the

is the question
of environment
versus
How to sustain
growth
while
avoiding
to the environment?

question
of irrational
and wasteful
use of
resources.
Criteria
are needed
to determine
rational
use for three
specific
areas
-- soil,
water,
and energy.

 -

Fourth,

the

question
of institutional
arrangements
within
the U.N. to accomplish
environmental
objectives
and programs.

Fifth,

the

final
major
issue
Settlement
Foundation
Burgeoning

Chart
3

2 -

is

funding

for

the

Human

Bureaucracy

A vast
bureaucracy
exists
to deal with world
envi~onm 7ntal
problems
which is seemingly
irresistably
growing
in both numbers
and complexity.
This trend
applies
to bot~ g~vernment
and industry
sides
of the picture.
The
c~art
indicates
our understanding
of points
of contact,
but
without
a manual,
it would be hard to decipher
who is
responsible
for what.
In simplest
terms,
UNEP is the interface
and
communication
channel
between
world industry
represented
by
the International
Chamber of Commerce,
and world government
represented
by the General
Assembly.
There is a firm conviction
amongst enivironmental
representatives
in international
bodies
that
UNEP's
activities
and programs
will
have significant
influence
on
the conduct
of national
and international
industry.
1975

Achievements

The most significan
t achievement
of UNEP in 1975
was the convening
of a meeting,
Barcelona
1, between
16
Mediterranean
states
and obtaining
agreement
between
them
of the necessity
of a Convention
on pollution
control
measures
to protect
their
common sea.
Only Albania
and
Algeria
were absent.
As a postscript,
12 of the 16 nations
signed
a Protocol
on Cooperation
and on Ocean Dumping during
Barcelona
2 in early
February
of this
year.
Chart

4

During
1975, seven internatio
nal conventions
came
into
force
as the result
of the required
numher of signatory
parties
passing
the necessary
national
legislation
to ratify
these
conventions.
Conventions
1, 2 and 6 on the chart
all
bare on our business,
but have yet to be ratified
by Canada.
Ratification
of these
conventions
and ageement
by Canada to
participate
in the International
Compensation
Fund for Oil
Pollution
would eliminate
most reasons
for continuation
of
the Maritime
Pollution
Claims Fund.
Offshore
drilling
operations
are not yet subject
to any international
regulation.
There was little
apparent
progress
made at 1975
(second)
session
of the Law of the Sea Conference
with
degree
of sovereignty
over sea and seabed
resources,
and
right
of passage
through
straits
continuing
to be the
stumbling
blocks.

 - 3 -

h
.
:n the U.S ., interminable
congressional
.ear:ngs
and deba~es
occurred
with respect
to necessar7
to their
Clean Air Act and Water Pollutio.
arrte:a~ents
On the air side,
the 9rincipal
iss~es
wer~
ion~r~l.Ac~.
· to .......
~ission
Standards
and definition
of intent
and
non-degradation
of air auality.
~
stra~egies
~o ensure
the
a~er side,
the unattainable
need for complia~ce
~'l
1- ~ with use of Best Available
Technology
EconoMical_y
by 1977 with Be-~
Achie~able
(BATEA) on top of compliance
Technology
Currently
Available
fEPC~C~ )
Pract~cable.control
has pitted
industry
and municipal
groups
solidly
aga~n~~
conqressional
and public
advocacy
groups.
Cc~p_ia~ce
stubbor~
,·1th the 1983 requirement
would drive
many U.S. co~~a~~Es
~0
the
·all,
ii not to the grave.
a~e
Environmental
Impact Assessment
requirements
adding
a~ least
a year to the lead time for obtaining
?€r~:~
and energy
projects
in the U.S.
7~is
appro·als
of mineral
sa~e procedure
has delayed
our Superior,
Wisconsin
?rocuc~a
:.'er::1-na..l.. by t ,;o years.
SPA regulations
came into
force
in 1975 rea~ir:.nc
of ·aoours
at service
statio ns in 17 of the ~a~:o~'s
control
control
regions.
Stage I required
90%
~4- air quality
con~rol
of vapour
during
the filling
of underground
service
tanks . Stage
II,which
so far has limited
a~?li.ca~:.o:-:,
stat.:.or.
req ires
control
of vapours
during
vehicle
filling.
~~e
tee.no
oqy and costs
to accomplish
stage
II has all gaso:i~e
~ar~eters
very disturbed.
_he growing

proliferation

of

state

laws

estab:~s~i~g

cornpensatio.
fund s for oil spill
damage to civil
property
a~c
natural
resource
s is a matter
of considerab
le concern
to ~~e
U.S. oil
indu s try . Exxon and the API are working
hard ~o ffi~
for the Administration's
congressio
nal bil::. whic~
supoort
-o~id create
a national
superfund
and which would preeGp~
state
:ur:ds.
Finally,
there
is a growing
tendanc y and stated
policy
of Exxon,
U.S . A. to use the courts
"whenever
it is
concluded
that
any regulatory
body is mandating
environr.:e~ta_
requirements
beyond the scope of legislative
intent."
Exxo::1
was involved
in at least
seven such challenges
o: E?~
authority,
alone,
wit~ API, or in a~icus
curiae
positio~s.
the overall
quality
o: t:e ~.s .
As a postscript,
national
environment
was assessed
by the ~ational
~i:d_i:e
Association
to have declined
slightly
in 1975.
In seve ..
major
environmental
areas
that
constitute
its
index,
t~e
Federation
found a net gain in only one area -- that
o: air
pollution.
Preservation
of timber
resources
was stab e,
but setbacks
were reported
in water
pollution,
minera:s,
wildlife,
soil
conservation
and open space.

 - 4 3.

Canadian

I

Overview

A considerable
amount of
1
· 1
·
·
in Canada
in 1975
both
t t t
new egis at i on was iss u e d
the most
.
. .. ,
s a u ory and regulator
y . Perhaps
int
t t s1gn1f :1cant
trend
and actions
demonstrated
Ottawa ' s
f den
preempt
the field.
It is now evident
that
the
e eral
government
plans
to bring
as much environmental
mana~ement
~nder
its
control
as possible.
In 1975, seven
provin<:=es
signeid
environmental
accords
with Ottawa.
Ostensiblr
th!se
~ccords
appear
to aim at cooperation
rat her
~han duplicatia>n
in programs
and regulatory
jurisdiction,
u~ ~ore than the camel's
head is in the tent
Quebec
British
Columbia,
and Newfoundland
have yet t~ sign ac~ords.

°

In this
review,
only
~hich
have dire ct or significant
industry
will
be mentioned.
Federal

or regulations
impact on our

Legislation

Ocea n Dumping
Chart
5

those
acts
indirect

Act

This Act will
prohibit
in some cases
and control
in others
the dumping of all hazardous
substances
in the
oceans.
The building
of artificial
islands
may require
in addition
to land use permits.
dumping permits,
Environmental

Contaminants

Act

This Act may be used for outright
ban of the use
of hazardous
substances,
such as PCB's,
but will
also be
and regulate
use of substances
and chemicals
used to register
of Environment
and/or
the Minister
of
which the Minister
"suspect
may be entering
the environment
Health
and Welfare
in a quantity
or concentration
that may constitute
a dan ger
to human health
or the environm ent."
The intent
is
use must be proven
safe
be subject
to regulations
section

clear
before
for

ComrnE~ncing April
4 comes into
force

1,

--

every invention
it may be marketed
use.
1976,

subsection

or novel
or else
( 6) of

and reads:

"Where,
during
a calendar
year,
a person
manufactures
or imports
a chemical
compound
of five
hundred
kilograms
and he
in eccess
manu 1:actures
or imports
that
compound in
exceJs
of that
quantity
for the first
time,
within
three
months of manufacturing
he s ~ all,
or i)porting
the said quantity,
notify
the
Minister
of the name of the compound,
of the
quan:ity
manufactured
or importe d during
that
year, and of any information
in his possession
respe~cting
any danger
to human heal th or the
environment
posed by the compound."

 -

5 -

Offences
under th
s~ve~e
in penalty
(i
. e Act are criminal
in nature
and
liability
is a fin
.e.'
(a) on sununary conviction
of g u ilt
. d.1.ctment
e not texceedin
.
. n,.
subject
.
. g $100 , 00 0, (b) on con v ictio
upon. in
liability
for off
. 0 imprisonment
for two years.
Th e
di'rentce
l.s very broadly
aoplied
to include
" any officer
~
.
'
ec
or
or
age
t
f
h
d irected,
authoriz
d
'
n o t _ e corporation
who
participated
in th: ; as~en~ed
to, acquiesced
in, or
0
of the offe:~~~~on
of the offence
is party
to
and guilty
in leaded
I mperial

A regulation
1· ·t·
grades
of .
1.~1. 1.ng the concentration
g
~asoline
to a maximum of 3.5
a 11 on was imposed January
1, 1975.

of lead
grams per

'f' 1.cant act~vity
·
and will
b Theth most signi
to our industry
was
Pe ~or~ of the PACE Air Quality
Committee
in
th e F edera~
dr f t
·a .rovinc1.al/Indus~ry
Task Force constituted
to
a
g u 1. e ines
and regulations
f or new and existing
pe ~rol eurn refineries.
The PACE group,
under the chairmansh i p o f Dr . Lee Scott
of Logistics,
spent many hours in
prep a rat ory and in committee
work on this
project.

f

Provincial

Legislation

Ontario
passed
into law the Environmental
Assessment
Act,
but as y et no regulations
have been issued.
The Act will
be applied
fi r s t to provincial
government,
and their
coroorations
and a ge n cies , then to major industrial
or commercial
activities.
hart
6

Quebec introduced
first
draft
of a regulation
re
Quality
of the Oc c upational
Environment
which has exhaustive
industrial
safety
a nd hygiene
provisions.
Interdepartmental
rivalry
has forced
th is back to a committee.
The second
official
draft
of t he Qu e b ec Air Pollution
Control
Regulation
was issued,
and alth o u gh somewhat less onerous
than the first
it has prompted
tough op p os ition
from many companies
and
industry
associations.
Prince
Edward I s l and passed
its first
Environmental
Protection
Act.
Se v e r a l provinces
passed
amendments
to their
Air Pollution
control
Acts o r their
Environmental
Protection
Acts,
which either
broad e ned t h eir scope or set stricter
standards.
l eg is lat~on
was under.con~ideration
Noise
control
in many jurisdictions.
Tor o nt o issued
an.AJ:lti-Noi~e
By-L aw
.
. sued a d raf t of a Model Municioal
ijoise Con t r ol
an d Ontar 1.0 is
~
.
By-Law.
Noise
conside r at io ns now need to be app~ied
to all
our operations'
equipm e n t p u ~dch as 7s , and dany dev 1.ces we may
1 eves.1
market
which will
af f e c t r e s i entia 1 soun

,

 - 6 4.

Public

Attitude

If one were to accept
only public
opinion
polls
~nd media.signals,
s~ch as frequency
of appearance
or column
inches
printed,
the imoortance
of environment
as an issue
in
fourth,
fifth,
or even miniscule.
Canada might
well be rated
Announcement
of environment's
death
as an issue
would I in Mark
'
I
Twains
words,
be "very ?rernature".
A few examples
of projects
which were either
delayed,
deferred,
changed,
or might be shut-down,
primarily
by intervention
on environmental
grounds,
should
serve
to illustrate
the point:
- Canadian
Hearings

Arctic
Gas Pipeline
may delay
project

- Beaufort
drilling

Sea Environmental
a year.

-for

The Berger
years.

Project

--

delayed

- Ontario
Hydro High Voltage
Transmission
-- The Solandt
Hearings
have
Corridors
delayed
building
two major high-voltage
transmission
lines
at least
three
years.
- Ontario
Hydro's
Long Range Plan for New
Generating
Capacities
-- The Porter
Commission
is starting
hearings
this
fall
which has caused
the plan to be shel ved indefinitely.
The
hearings
were forced
by the sensitivity
of the
Ontario
government
to environmental
protest
over
the plan.
- The New Pickering
Airport
-in response
to environ mental

shelved
activists'

indefinitely
protests.

- The Proposed
B.C. Govern ment Oil Refinery
-- a
location
acceptable
to local
municipal
governments and ratepayers'asso
ciations
was never
found.
- Tar Sands Project
to any additional

-- there
strip-minin

is

mounting
opposition
g type of operations.

In most cases
the questioni
ng or outright
opposition
to projects
has been led by academics
and well-informed
groups
who generally
are asking
rational
questions
reqarding
the need
for,
or environmental
effects
of, a rarticular
project.
be the

first

There is no doubt that
environmental
acceotabilitv
criterion
for all future
major projects.

will

I
I
I
I

 - 7 -

SECTI O~ II
PERFORMANCE AND PROBLEMS OF OPERATING FUNCTIONS
Our company
corporate
environmental
effort
was devoted
to
programs.

per f orman ce met the
poli cy s u ccessfully
optimizin
g facility

test
of our
. Consjderable
improvement

Interest
in the envi ro nmental
assessment
orocess
at all
levels
o f g ov e r nment.
Our first
is in~reasin~
experience
with this
has been in c onn ection
with northern
resource
development
and indir e ctl y with the IPPL terminal
ex~ansion
project
at Superior,
Wisc o nsin . Planning
for all
~aJo:
pr~jects
will
have to r e cogn i z e the cost and timing
implications
of this
process.
For exa mple , in Ontario,
up
need to b e compl ete d . It is a powerful
to 22 forms will
weapon in the hands of anti-d e v e lo pment , anti-business
, or
anti-oil
industry
groups.
1.

Accomolishments
(a)

Chart
7

Exoloration

and Production

- Completed

environmental

statement

(i)
(ii)

Taglu gas plant
Berger
hearings.

land

u se per mit

- Further

environmental

studi

e s c omp l eted

(i)
(ii)
(iii)
- Reduced
through

for:
application.
for

Artificial
island
constru c t i on .
AFOA/Governm ent Beaufort
Sea Environmental
Program
Disposal
of drilling
fluids
sulphur
improved

emissions
close-loop

- Reduced white
smoke
plant
by modifications
(b)

imp act

(S03)
to

from Quirk Creek gas plant
control
of stack
emissions.
emission
incinerator

from Jo ff r e gas
b u r ner .

Logistics
- capital
cost
water
effluent
commitment.
- Noise survey
engineering
_ New biological
on-stream.

deferral
projects
of
and

on the Montreal
and Dartmouth
wh ile still
meet i ng original

all refineries
cost planning.
oxidation

_ Development
of mathematical
of Sarnia
refinery
to the

plants

as a basis
at

fo r

Sarni a and

loco

tool
f~r t he c o ntribution.
area ambient
S02 concentration

.

 - 8 (c ) Tra n sportatio
Water

n

pol l ution

- Upgraded

Esso

- Overfill

sensors

pro t ect ion
2000

faci

in

- Continued
pressure
work errors.

liti

facilities
es

Pra i rie

at

Re gion

at

5 plants.

3 plants.
trucks.

on outs i de c a rri e rs

to

reduce

- A multi-industry
approach
was de v e l o pe d for
corrosion
protection
against
stra y currents
Toronto
subway.
Region Environmental
Distribution
staff.
Chart
8

(d)

Advisors

on Region

Marketing
- Upgraded

10 high-risk

consume r pla nts.

- Upgraded

20 consumer

- Upgraded

Stevenson,

9lants
B.C.

Maintained
significant
industry/government
standards
of product
operation.
(e)

i n place

pipeline
from

Esso

in

Que b e c to

meet

regulation.

mari n e pla n t.

ongoing
par tici p ation
in
groups
in de vel o ping improved
qualit y , faci l i ti es and

Chemical
- Com~leted
eliminate

Sarnia

studies
on trea tment methods
to
fish
toxicit
y and r e duce tainting.

- Facilities
installed
to r e d uc e VCM in
slurry
and plant
waste water.
- Comoleted
development
and d e s ign
neutralization
facilities.
Redwater

Fab.Prod.
(f)

caustic

reduced
- Ne~ process
expanded
sulphuric

total
SOx emissions
acid unit.

- Completed

fluoride

- Installed
fumes at

New Energy
- Cold

of

Lake

study

of

PVC

emi s sion

in
problem.

filtration
units
f or r o o fing
LaSalle
and Wi nn i p eg .

Resources
water

re-use

laboratory

stud y co mpleted.

machine

 - 9 -

(,)

Au

n s

D v looment
d

2.

P rmit

i.h_l _I,_ncident
M

~
spill

Y

for

Report

exploratory

decline,

and

Activities

Related

Gays

River,

N.S.

k

~h n~ sin
the reporting
procedures
in Logistics
and
tinq
in 1975 prevents
meaningful
comparison
of the total
both corporately
and for those
functions
with orevious
rs,
but should
provide
very valuable
information
in future.

~h
~reduction
Department
achieved
a siqnificant
in spills
of 25% in 1975 compared
to 1974.
The
reduction
Transportation
Department
reduced
their
spills
by employees
by 18%; but spills
by outside
carriers
increased
slightly.
hart
10

hart
11

Although
the number of reported
oil spills
increased
by
52% over 1974 (because
of the change in reporting
procedures),
the volume of oil
spilled
increased
by only 14%.
The latter
includes
the spill
by Winnipeg
refinery
of 1000 barrels
into
the Red River.
The clean-u9
of this
incident
was very well
handled
and drew favourable
comments from the government
authorities.
The contingency
planning
continued
in B.C. which led to
formation
of a major oil spill
By year-end
the legal
agreement,
Imperial
and reviewed
with other
level,
was close
to completion.
recommendations,
costing
about
study.

by an industry
task force
the recommendation
for the
cooperative
in Burrard
Inlet.
which had been drafted
by
companies
at the head office
The initial
equipment
$1.2 M.~, are receiving
further

There is interest
in the industry
and pressure
from
governments
to do similar
contingenc
y planninq
studies
in
Ontario,
Quebec,
and Atlantic
Regions.
The government
people
in the Atlantic
are becoming
a bit restive
at industry's
inaction
towards
the big spill.
Industry,
through
PACE, has prepared
a model contingency
plan for a major offshore
incident.
The Canadian
Coast Guard
are preparing
a National
Emergency Plan
Unfortunately
CCG
have not responded
to our overtures
to coordinate
the two
plans.
The Imperial
Sarnia
spill
demonstrated
the need for an
regi~nal
~orporate.re
ponse
mechanism.
Accordingly,
improved
7
JOb descriptions,
etc.,
were developed
for
the organization,
Resp~nse
Team.
Plans wer~ laid
the Region Major Oil Spill
the Response
Team in 1976.
in each region
to staff
and train
A manual was prepared
which described
Imperial's
relationshio
to and method of operation
and access
to the
Gov~rnment's
computerized
National
Emergency
Equipment
Federal
Locator
System
(NEELS).

 - 10 -

,.

a jo r Problems

Remaining

. efinement
im provement

of Beaufort
offshore
of capability
for

- En •ironmental
assessment
ffshore
operations.

contingency
control
and

and planning

for

plans,
clean-up
future

includ i n g
of spills.
East

Coast

- Greater
and more detailed
regulations
are expected
to cause
s me program
delays
and require
more effort
on environ.mental
ssessment
studies
throughout
E and P operations.
- Satisfying

environmental

requirements

- Strathcona
expansion
- Air permit
for Ioco
- so2 problem in Montreal
Minimizing
so 2 emissions
- Trend to
th
U.S.
- Ground

closed

water

vapour

- Pipeline
protection
n da and the U.S.
- Retention

of

-

~

·11\ t
1l

legislation

for

r -use

o

ons.

relating

to

the

distribution

leaking
is

tighter

both

refineries:

Dartmouth

momentum
and

controls

acid unit
from paper
Cold

Lake

system

underground

gaining

commitment

VCM emissions
fish
tainting
NOx emissions
from nitric
BOD and suspended
solids

W

in

from

associate/dealer

- G v rnment objectives
from chemical
?lants:

East
from

systems

contamination

at

in

tanks.
in

both

awareness.

on discharges

mills
and

Syncrude

.
pite

rather
sizable
and successful
efforts
throughout
in 1975, the magnitude
of the environmental
h snot
diminished
and will
continue
to demand a
nt sh re of our financial
and manpower resources.
ny

Working

with government
agencies
to develop
realistic
regulations
must continue
to have high ?riority.
l, industry
associations
have been reasonably
Ln d ling with governments.
Imoerial's
inout
to
recog~ition.
h s brought
the company favourable
fore seem advisable
to make the maximum use of
1 sin
our dealings
with government
on
m tters
wherever
it is possible
to do so.

t·l,L v bl

I

 -

11 -

.
W~thin
the comp any , envi. ronrn n t· ,1 J cone r.ns
re becoming
increa~ingly
blend e d i nto th
f bric
of our op rations
. The
bala~cing
o~ thes e con cerns with
conomic ,nd other
issues
remai~s
an . important
challenge.
A f~w xumol s of the many
~ays in which it is pl ann ed to COD wi h these problems
include:
1.

Reinforce
the use
reviews,

and training
employ ee awarcn~ss
of a v a r iety
of wor.kshops , work
regular
meetings,
and training

through
error
aids .

2.

Develop
mentally
control,
disposal).

least- c os t solutions
which
sound and meet commitments
fish
toxi ci ty of effluents,

3.

Continue
planned
pr oq rams to upgrade
facility
standards
and op e rat i ng procedures
(e . g . agency
plants ) and reduce
or eliminate
waste production
at the source
(e . g . water re - use) .

4.

Develop
specific
pro g r ams to meet needs
(e . g .
de v elop methods,
reduc e costs , eliminate
toxic
chem icals,
because
o f n ew Alberta
drilling
fluid
disposa l regulations
).

5.

Develop
e xpe rtise
for and prep aring

are environ(e.g.
noise
biox sludge

in formula t i ng the requiremen
ts
Environm e n t a l Impac t Assessm ents

.

 - 12 SECTION III
COORDINATION ACTIV!Tl~.
1.

Technic

1 Effort,
Th

t

Exoenditures

chnical

effort

and
required

Bud1
to

the
in 1975 (86.45)
compared
to 1974 (112),
the level
of 1973 (88).
The number of
by three,
while
the large
drop came in
time cat gory.
Almost
all of the deer
in the Logistics
Department
reflectinq
large
amount of construction
work (loco
development
work (Montre al and Dartmouth)

Chart
15

.ust,

nd
in

s

rnl 1)
t 74.

Environmental
expenditures
on Imp ri l
in 1975 from about
$39 million
in 1974 to
bou · $31
1975.
They are forecast
to decline
furth
r in 1976 .n 021
million,
followed
by a swing upwards
to the $35 mi I I ion r uir11 •
by 1978 and beyond.
The environmental
exp nditur.
for
th
Syncrude
project
will
peak in 1975 and 1976 in th
$2
o 530
million
range
and fall
off thereafter.
Over 11th
Comp~ny'
expenditure
will
be about
$55 million
through
1976
nd
t1l I t0
about
$40 million
through
1979.

Chart
16

It should
be noted
that
these
forecasts
do not include
any expenditures
for the Taglu Gas Plant,
Bast Coast
0ff:shor
~
exploration,
or any unexpect ed impact
of the ~~tionaJ
Air Ou~lity
Emission
Regulations
for refineries
currently
under
n gotiation.
2.

Industry

Activities

APOA and

CPA

The Arctic
Petroleum
Operators'
Association
had their
busiest
year providing
industry
liaison
to the $12 million
Beaufort
Sea Environmental
Program
with
industry's
share
being
$4.5 million.
The Association
additionally
had 17
research
projects
in progress,
funded
by industry
only.
The
completed
cost
of these
projects
is estimated
to be $2.26
million.
Guidelines
for the Disposal
of Drilling
Wastes
were
developed
by a government/AFOA
task
force
at a cost
of $200,000
to industry.
There was considerable
dialogue
and some controversy
between
CPA and PACE with respect
to the coordination
of oil
spill
contingency
planning
and oil
spill
technology
development.
This appears
to have been resolved
by the proposal
to
have the National
Coordinating
Committee
on Contingency
Planning
sponsored
by and responsible
to both associations
through
a
steering
committee.
PACE
Chart
17

and

in

In 1975,
work of

members'
the ten

involvement
in
active
committees

directors'
amounted

meeting
to the

 equ~valent
achievements
work:
{1)

Oil

of

13 -

18 man- y ears'wor
k t im e . Progress
and positive
were made in man y areas
of the Association's

Spill

Contingency

Planni

ng

The over-all
organization
a nd
oil
spill
clean-up
cooperat
i ve
Two colour
vid
in some areas.
produced
dealing
with Contingenc
Field
training
exercises
were
in all
regions.

administration
of industry
s wa s considerably
improved
eot ape training
aids
were
y Planning
and Safety.
co ndu c t e d for local
co-ops

(2) Research
In 1975,
eight
a pproximately
pleted
are:

I

{a )
{b)
{c )
{d}
{e )

research
$150,000.

projects
were
Five pro j ects

in progress,
which were

for refiner
y was tewater.
A r a pid bioassay
Characterization
of refine ry hi os ludges.
Ch arac t er ization
of bulk plant
waste water.
Re duci n g b i r d mortality
from oi l s pills
.
So lvi ng ca r wash noise
prob l e ms.

The thrust
of t h e ma j o rity
of t h ese projects
tion
of knowledge,e
ith e r to be ab l e to frame
easily
with regulat
i on s .
(3)

Briefs

to

Other

was acquisior live
more

Governments

The Association
pr e p a red
of three
ma j or briefs
to
cases,
government
reactio
positions
taken.
(4)

costing
com-

Regulation

or assisted
i n t he preparation
various
g o v er nments .
In all
n was favoura bl e to the industry

Developme n t

The Air Quality
Committee
h a d four t wo-da y s essions
with
Federal/Provincial/Industr
y Ta s k Force
fo rm e d by
Air Emission
Environment
Canada to deve l o~ National
Guidelines
for Petroleum
Refi n e ries.
Th is r e presented
only a minor portion
of the to t a l effort,
as th e bulk of
work was done in several
subco mmittees
a n d by the
industry
members working
alo n e and in t h e i r ovm conunittee.
The Water Quality
Committe e wo rked wit h Albe r ta
Ontario
government
personne
l o n the deve lopm e nt
Refinery
Wastewater
Guideli n es.

and
of

The PACE Marine
Committee
issue d an int e r p r etive
guideline
booklet
for the Federa l Government's
Pollution
Prevention
Regul a tions
f or Oil Transfer
s.
This booklet
has been well
received
by both member companies'
terminal
employers
and large
volum e customers.

 - 14 PACE provided
considerable
technical
and
support
to the provincial
and regional
petroleum
on a wide spectrum
of environmental
concerns.
3.

Environmental
1975.

Chart
18

Quality

The Environmental
The highlights

advisorr
.
associations

Committee
Quality
Committee
met
of the meetings
were as

six times
follows:

in

(1)

Legislation,
as reported
federal
and provincial
portion
of the time of

in detail
in Section
I, from
governments
occupied
a significant
the committee.

( 2)

In response
to government
pressure,
an oil
soill
contingency plan was developed
for Burrard
Inlet,
~hich
involved
forming
an oil spill
cooperative
with about
$1 million
worth of equipment.
The Committee
endorsed
Imperial
participation
and the Environmental
Protection
Department
coordinated
a corporate
presentation
for Board approval,
which was granted.

(3)

A special
meeting
was arranged
to hear a presentation
by Environment
Canada on the catastrophic
tank failure
at the Mizushima
refinery
on the Inland
Sea of Japan.
About 10 million
Imperial
gallons
of heavy bunker
blending
stock
escaped,
resulting
in a combined
clean-up
and damage claim bill
of over $160 million.

(4)

The Committee
endorsed
the Region Major Oil Spill
Response
Team organization,
which was ~reposed
by the Environmental
Protection
Department,
for adoption
and implementation
by the Regions.

(5)

The Committee
endorsed
of Region Environmental
Environmental
Protection
preparation
of the job

(6)

The problem
of ground water
conta mination
from leaking
underground
storage
tanks,and
government
concern
about
it,
was reviewed
on several
occasions
as developments
occurred
(e.g.
Manitoba
regulations).

the establishment
of the position
Advisor
within
each Region.
Department
coordinated
the
description
and funding.

( 7) Waste oil disposal
came before
the Committee for three :reasons:
an interest
by Canpac Disposals,
a study
by the Ontario
government,
and an industry
position
paper
developed
by
PACE.
The federal
government
delayed
the proposed
government/industry
task
force
for one year.
(8)

The progress
of the Environmental
Taglu Gas Plant
was reviewed
for
departments.

Impact
Assessment
the information
of

of the
other

 - 15 -

4.

Coordination

Department

Activities

.The.coordination
group represented
the company and/or
Canadian
industry
on one international,
two API, three
PACE,
~nd several
other
environmental
committees
of various
industry
and ~echnical
associations.
The group presented
sever~l
~echnical
or policy
papers
at meetings
of these
associations
•
. Leadership
was provided
in several
areas
of industry
actions,
such as chairing
the National
Coordinating
Committee
Contingency
Planning,
The Burrard
Inlet
on O~l Spill
Contingency
Plan,
response
to the Quebec Air Pollution
Regulations,
appearance
before
an Ontario
parliamentary
committee
on the Environmental
Assessment
Act.
A seminar
was arranged,
bringing
together
federal
and provincial
gov~rnment
experts
with industry
representatives
on the
subJect
of "Rehabilitation
of Oiled Birds".
Considerable
assistance
was provided
to the Production
Department
with respect
to IOL environmental
studies
in the
North,
preparation
of the application
for the Taglu ~as p~ant,
and for the Berger
Commission
Hearings.
The staff
biologist
represented
industry
on the five marine
biology
projects
included
in the Beaufort
Sea Environmental
Program.
The department
Department
regarding
permit
requirements

advised
the
environmental
for the Gays

Business
Development
studies
and operating
River Mine Project.

Directories
were compiled
with summaries
of all
mental
legislation
and regulations
pertaining
to each
five major refineries
and two major chemical
operations.

environof our

Finally,
it is gratifying
to report
that,
during
1975,
negotiations
with TOVALOP and CRISTAL on the recovery
costs
incurred
with respect
to the Imperial
Sarnia
incident
culminated
in payments
to the Company of nearly
$2.0 million.
This sum represents
the major share
of our out-of-pocket
costs
other
than repair
of damage to the vessel
and loss
of
use.

 Chart

WORLD ENVIRONMENTAL

Where

PROBLEMS

Solutions

What

IN DEVELOPED
COUNTRIES

POLLUTION
- TOXIC CHEMICALS
- NOISE

LEGISLATION
REGULATION
TECHNOLOGY
ETHICS

CONSERVATION
- RENEWABLERESOURCES
- ENDANGEREDSPECIES
- NATURAL HABITAT
- QUALITY OF LIFE
IN DEVELOPING
COUNTRIES

-

POVERTY
POORHOUSING
BAO PUBLIC HEALTH
MALNUTRITION
INADEQUATE
EMPLOYME
NT

PLANNED
DEVELOPMENT
TO AVOID URBAN
PROBLEMSOF
DEVELOPED
COUNTRIES

- EDUCATIO
N

Chart

UNEP ISSUES

1. ENVIRONMENTAL
NATURAL

CONTROL OF SHARED
RESOURCES

AIR SHEDS - WATER SHEDS
2. ENVIRONMENT
3.

VS. DEVELOP MENT

GROWTH WITHOUT ENVIRON MENTAL
DAMAGE

IRRATIONAL
RESOURCES

USE AND WASTE OF

- SOIL, WATER,, ENERGY
4.

INSTITUTIONAL
-

ARRANGEMENTS

MANAGEMENT

5. HUMAN SETILEMENTS
-

LACK OF FUNDS

FOUNDATION

2

1

 Chart

ENVIRONMENTAL

BUREAUCRACY

[:.n.
~v]
/~

3

I 1cc]
!

NAT'L.

COUN.FEDS.
U.N.

UNEp
GO',LCOUNC.

AGENCIES

8t EN~RON.

WHO
WMO
11.0

ECE
ESCAP
ECA
ECLA

FAO

~sco
IMCO
!CAO

/

\'I..,

-·I

IN! Fm
SP. IND.

ASSOCI
- NAt

NEP
ECRET.

.~

~1

INTNAT'L

CEN.INO.

\

"*

\

UNEP
PROGRAMS
INQ SEC.
IRS

IRPTC
GEMS

etc.

UNOP

I

I

ASSOC

SP.IND.
CPA

~

CCPA
/

~

Chart

INTERNATIONAL CONVENTIONS
COMING INTO FORCE IN

1975
Year
Name

Signed
-

INTERVENTION OF SHIPS ON HIGH SEAS
IN CASES OF OIL POLLUT ION CASUALTIES
- CIVIL LIABILITY FOR OIL POLLUTION
DAMAGE
- WETLANDS OF INTERNATIONAL IMPORTANCE
TO WATERFOWL

1.

1969

2.

1969

3.

1971

4.

1972

-

PROTECTION OF WORLD CULTURA L AND
NATURAL HERITAGE

5.

1972

-

PREVENTION OF MARINE POLLUTION BY
DUMPING OF WASTES

6.

1973

-

PREVENTION OF MARINE POLLUTION BY
DUMPING FROM SHIPS AND AIRCRAFT

7.

1973

- TRADE IN ENDANGERED SPECIES OF FAUNA
AND FLORA

4

 Chart

5

1975 FEDERAL LEGISLATION

OCEAN DUMPING CONTROL ACT
- PROHIBITS DUMPING VERY HAZARDOUS SUBSTANCES
- CONDITIONAL PERMITS FOR OTHER MATERIALS
- ISLAND BUILDING MIGHT REQUIRE DUMPING PERMIT
ENVIRONMENTAL

CONTAMINANTS ACT

- ENABLES OUTRIGHT BANNING OF HAZARDOUS
SUBSTANCES
- ENABLES TOTAL REGULATION OF HAZARDOUS
SUBSTANCES IN PLANTS, EMISSIONS, ANO IN
PRODUCTS
LEADED GASOLINE REGULATION
- 3.5 gms/lG MAXIMUM
PETROLEUM REFINERY AIR POLLUTION REGULATIONS
- UNDER DEVELOPMENT BY FEDERAL/PROVINCIAL/
PACE TASK FORCE

Chart~

1975 PROVINCIAL

LEGISLATION

ONTARIO
- ENVIR ONMENTAL ASSESSMENT ACT - MODEL MUNICIPAL NOISE BY-LAW
- ANTI-NOISE BY-LAW

PASSED

QUEBEC
- ECOLOGICAL RESERVES ACT -

PASSED

- 1ST DRAFT RE - QUALITY OF THE OCCUPATIONAL
ENVIRONMENT - VERSION OF OSHA
- 2ND DRAFT REG'S RE - AIR POLLUTION
- FINAL REG'S RE -

-P.E.I .-

ENVIRONMENTAL

CONTROL

LIQUID WASTE MANAGEMENT

PROTECTION ACT

SASK.• ALBERT A, N.8.
- REG'S RE - AIR POLLUTION

CONTROL

I
I
I

 Chart

7

ACCOMPLISHMENTS
EXPLORATION ANO PRODUCTION

(a)

-

(b)

ENVIRONMENTAL
FOR

IMPACT STATEMENT

(i)

TAGLU GAS PLANT LAND USE
PERMIT

(ii)

BERGER HEARINGS

LOGISTICS
- CAPITAL DEFERRAL ON MONTREAL
AND DARTMOUTH PROJECTS WITHIN
COMPLIANCE SCHEDULE
TRANSPORTATION

(c)

- WATER POLLUTION PROTECTION
FACILITIES AT 5 PLANTS

Chart

ACCOMPLISHMENTS

(Cont'd)
(d) MARKETING
(e)

UPGRADED 30 CONSUMER PLANTS

ESSO CHEMICAL
SARNIA - STUDIES ON TREATMENT METHODS
TO ELIMINATE FISH TOXICITY AND
TAINTING
REDWATER -

(f)

REDUCED SOx EMISSIONS AT
. SULPHURIC ACID PLANT

NEW ENERGY RESOURCES
- COLO LAKE WATER RE-USE STUDY

(g) BUSINESS DEVELOPMENT
-

PERMIT RECEIVED FOR GAYS RIVER
EXPLORATORY DECLINE

8

 Chart

9

NO.
OFREPORTED
OILSPILLS

1975
- BYFUNCTION
212111
200

150

132m

100

50

01...--1-~

...

--i-J.---i.........L--'--__.

_____

i.--....i.~-i...___.

'74 '75
'74 '75
'74 '75
'74 '75
PRODUCTION LOGISTICS TRANSPORTATION
MARKETING

tll OIL6.WATER
SP11.1.St2l INa..SPILLS
ON
t3l INCL
. OUTSIDE
COMPANY
PREMISES CARRIERS

t4l INCL.PRODUCT
NIXES

Chart

NUMBER
e.VOLUME
OFOILSPILLS
BYCLASSIFICATION

400------

12000

300--------

9000

272

100

10

 Chart

OIL SPILL CONTINGENCY PLANNING
INDUSTRY
-

MAJOR 01 L SPILL CO-OP
-

-

BURRARD INLET

OTHERS BEING CONSIDERED
-

ONTARIO

- QUEBEC
- ATLANTIC
-

MAJOR EQUIPMENT STOCKPI LES
- $1 -$2 MM

11

 ,I
I

REGION MAJOR OIL SPILL RESPONSE TEAM
IMPERIAL OIL LTD

IIEAD OFFICE OIL
SPILL COMMITTEE

I

-- - - - - --- -- --3

---<---

.

ON-SCENE
COMMANDER

I

Rl:GION
COMMAND

2

------

I

I

-- - -- -- ------

I

OFF -SIT -ON-SITE

,
I
I
I

I
;

I
GOV'T
AGENCY
LIAISON

I

I

5

6

I
7

PUBLIC
AFFAIRS
ADVISOR

LEGAL
ADVISOR

9

I
10

.

I

FOREMAN
(MEN)

t

I

.

WORKERS

FIELD
ACTIVITIES
SUPERINTENDENT
I

.

I

t

TEAM(S)

t

11

16 SHORE AND INLAND
CLEAN-UP
SUPERVISOR

.

I

MAY BE IOL OR CONTRACTOR

8

CLAIMS/
COMPLAINTS
ADVISOR

I
FOREMAN
(MEN)

I
WORKERS

.
t

.
t

• 12

DISPOSAL
SUPERVISOR

I
FOREMAN
(MEN)

.

WORKERS

l..f"\.A.J

SUPPORT
SUPERINTENDENT

-

.

.
'

SAFETY
ADVISOR

\
I

.
.

191 TRANSPORTATION
SUPERVISOR

"

I

201 COMMUNICATIONS
SUPERVISOR

"

211

t

I
221

WORKERS

I

t

231

TEAM(S)

-·-

I

I
14

..

t

PERSONNEL
~~

MARINE
OPERATIONS
SUPERVISOR

FOREMAN
(MEN)

t

I

!

I

.

TEAM(S)

TEAM(S)

13

I
18

I

.

OIL SPILL
ACCOUNTANT

17

i

WILDLIFE
ECOLOGY
ADVISOR

I

SECURITY
SUPERVISOR

CONTAINMENT
AND RECOVERY
SUPERVISOR

OPERATIONS
MANAGER

I

I

-

-.

-'-

.....
,

I
241

•I

0
P'
Ill

PROCUREMENT
SUPERVISOR
MANPOWER
SUPPLIER
HISTORIAN

MAINTENANCE
SUPERVISOR

11
rt

\~
\

J

·t 1~b111111 W1111

 Chart

13

Chart

14

MAJOR PROBLEMS REMAINING
-

BLOW-OUT IN BEAUFORT SEA

-

PLANNING FOR FUTURE EAST COAST
OFFSHORE OPERATIONS

-

ENVIRONMENTAL
REFINERIES

-

CLOSED VAPOUR SYSTEM IN
DISTRIBUTION

-

GROUND WATER CONTAMINATION
FROM LEAKING UNDERGROUND
TANKS

REQUIREMENTS AT

PLANS
ENVIRONMENTAL
;_ UTILIZE

CHALLENGE UNDIMINISHED

INDUSTRY GROUPS

-

REINFORCE EMPLOYEE AWARENESS AND
TRAINING

-

DEVELOP LEAST-COST ENVIRONMENT ALLYSOUND SOLUTIONS

-

CONTINUE PROGRAMS TO UPGRADE

-

-

FACILITY

STANDARDS

-

OPERATING PROCEDURES

DEVELOP EXPERTISE IN HANDLING
ENVIRONMENTAL IMPACT ASSESSMENTS

 Chart

15

ENVIRONMENTAL MANPOWER SUMMARY
(MAN YEARS)

Full Part

--

Time Time

Department

1975

1974

1973

Full

Part

16

36

--

Part

Full

-

Time Time

Time Time

13

11

18

6

18

4

6

5

4.5

4.5

0

3.5

0

3.1

3

4

3

11.5

3

11.5

NEW ENERGYAES.

0

0.1

0

1

REG. ENVIR. ADV.

6

5

6

E.P. DEPARTMENT

3

3

3

RESEARCH

1

0.5

30

58.1
88.1

11

21

EXPLORJPROO'N

3

18

3

ESSOCHEMICAL

2

10

TRANSPORTATION

1

MARKETING

LOGISTICS

---

TOTALS

--35

0.1

--38

0.25

2

1

1

48.45
86.45

77
112

EXCLUDES
OPERATING
MANPOWER

Chart

16

ENVIRONMENTAL EXPENDITURES - $MM

1978

1979

Department

1975

1976

1977

LOGISTICS

18.5

15.2

11.9 - 1 8.1

EXPLORATION/
PRODUCTION

4.8

5.8

10.7

ESSOCHEMICAL

4.2

1.8

5.1

4.3

2.6

MARKETING

1.8

2.9

2.4

2.3

1.4

TRANSPORTATION

1.4

1.3

0.9

0.9

0.9

0.4

0.1

0.1

BUSINESSDEVELOP.

11.0(1)

20.8
11.0(1)

30.7

27.

31.4

36.7

36.8

24.9

28.3

9.5

4.3
0.2

1.0
0.2

NEW ENERGYRESOURCES
SYNCRUDE
COLO LAKE/COAL
TOTAL
(1)

0.3
55.6

55.3

41.2

-41.2

38.0

DOESNOT INCLUDEANY EXPENDITURESFOR TAGLU GAS PLANT
OR ATLANTIC OFFSHOREDRILLING.

II
I
I

 Chart

17

PACE 1975 ACHIEVEMENTS
1.

OIL SPILL CONTINGENCY PLANNING ADVANCED
-

2.

3.

ORGANIZATIONALLY

AND TRAINING

ACTIVITIES

FIVE RESEARCH PROJECTS COMPLETED (e.g.)
-

RAPID BIOASSAY OF REFINERY WASTEWATER

-

REDUCING BIRD MORTALITY

FROM OIL SPILLS

THREE FORMAL BRIEFS TO GOVERNMENTS
OTTAWA - AUTOMOTIVE EMISSION STANDARDS
QUEBEC - PROPOSED AIR REGULATIONS
MANITOBA - CONTROL OF LEAKS FROM
UNDERGROUND TANKS

4.

OTHER REGULATORY DEVELOPMENTS (e.g.)
-

NATIONAL AIR EMISSION GUl:DELINES FOR
REFINERIES

- ANNUAL
SET-UP

REVIEWS WITH ENVIRONMENT CANADA

Chart

.....r

-~'..::-ENVIRONMENTAL QUALITY COMMITTEE
-' t·
' .'
1975
~

1. REVIEWED LEGISLAT ION
2. ENDORSED PARTICIPAT ION IN BURRARD
INLET OIL SPILL CO-OP

3. MIZUSHIMA OIL SPILL
4. SPONSORED REGION MAJOR OI L SPILL
RESPONSE TEAM PROGRAM

5. ENDORSED REGION ENVIRONM ENTAL
ADVISOR POSITION

6. LEAKING UNDERGROUND STORAGE
TANKS

7. ENVIRONMENTAL

IMPACT ASSESSMENT

18