REVIEW OF ENVIRONMENTAL PROTECTION ACTIVITIES FOR 1980-1981 PROPRIETARY TO IMPERIAL OILAND AFFILIATES IIPERIAL OILLIMITED TOIOITO, ONTARIO 628.5 I34 - ' J, ENVIRONMENTAL PROTECTION REVIEW AND COORDINATION ACTIVITIES 1980 - 1981 C O N T E N T S I. PERSPECTIVE 1. International 2. U.S. 3. Canadian A. c. Review & D. II. 1 (See Appendix I) 3 Review B. 2 Legislation and Regulations Quality of the Environment Public Attitudes and Participation PERFORMANCE, PROBLEMS, AND PLANS OF OPERATING DEPARTMENTS 1. Esso A. B. C. 2. Esso A. B. 3. Esso 4. Oil Resources Canada Exploration Heavy Oil Minerals Petroleum Spill 5 and Production 7 Canada Refining, Marketing Chemical Limited Marine Canada Statistics and Pipeline 9 ENVIRONMEN'T'l\.L PHO'T'T•;C'PTONI l~V l l~W AND COORDTNJ\TTONJ\('•r rv I 'P 11,:s 1980 - 1981 C O N T E N T S Pa III. COORDINATION ACTIVITIES 1. Technical Effort, 2. Industry Activities A. B. C. D. E. F. G. 3. c. 4. Budget 11 11 Commitment of Company Resources Arctic Petroleum Producers' Association. Canadian Chemical Producers' Association Canadian Petroleum Association COOSRA Eastcoast Petroleum Operators PACE Environmental A. B. Expenditures, Quality Committee 15 Sununary of Activities Toxic Substance Control Oil Spill Contingency Planning coordination Department Activities 18 SECTIO N I PERSPECT IVE - ISSUES AND LEGISLATION 1. INTERNATIONAL The Executiv e Director of U.N.E.P., Dr. Tolba, in his 1981 report h ig h lighted three issues requiring the special program s o f study and action by national governments and int er n ati onal agencies. These were: the management of groun d water as a renewable resource; control of toxic chemi cals in the food chain; and the acceptance of environm ental cost / benefit economics in development of resources an d re-deploy ment of industries In 1982 Dr. Tolba stress e d two s erious problems; desertification the loss of six mi lli on hectares each year from grazing land to des e rt, and t h e f a ilure of nations to introduce environmental ac c ou nting systems. In his opinion, the use of such syst e ms may have prevented "biological deficit financing". The tenth annual meeti n g o f the Go v e rning Council of U.N.E.P. solemnly reaffirm ed the 197 2 Stockholm Declaration on the Human Environmen t and i t s Action Plan. They called for strengthening a n d e xpan s ion of national efforts and international coope ration in the field of environmental protection . The progress ness. has been to protect constitutions. in are: meeting noted that we have witnes s e d s ignificant in environmental sciences, educat i on and awareIn nearly all countries environmenta l legislation adopted and in a significant number prov isions the environment have been enshrined i n their There have been some notable major accomplis hments the review period under the U.N.E.P. banner. These 1. of Regional The Formation Programs for Action The Asia-Pacific (a) (b) The Caribbean Gulf The Persian (c) Seas 2. A major Study Forest 3. several Fishery Treaties to Protect and Other Wildlife of Tropical Environm ental Depletio n Marine Mammal s, Resources. 2. 2. U.S. REVIEW . The U.S. situation was reported by Mr. Al Natkin on July 8 to the Corporate Advisory committee, and a copy of that report is attached as Appendix I. 3. CANADIAN REVIEW A. Canadian Legislation and Regulations 1980 & 1981 Federal The Transportation of Dangerous Goods Act was finally passed and proclaimed in mid-1980. Regulations are still only in final draft form. The study of regulations to phase down or phase out lead alkyls in motor fuels was proposed in late 1980. The decision on whether to proceed with a draft regulation is expected this fall. The Clean Air Act was amended in late 1980 to empower the Minister of Environment to regulate specific sources which could be causing air pollution in another country. A list chemicals Act. were B. of priority was issued Guidelines issued in and under candidate (for regulation) the Environmental Contaminants for Therma l Power 1981. Generation Air Emissions Provincial British Columbia An Environmental Management Act was passed and the Pollution Control Act was amended to bring it in concordance with the foregoing. Reg~lations covering tnvironmental Impact Assessment were issued under the new Act. Manitoba The Clean Environment Act was amended to include oil with spills of hazardous substances, and regulations Substances as ·Hazardous. were issued Designating Certain Newfoundland A Department of the Environment Act was passed in 1980 setting up a separate department. An Environmental Assessment Act was proclaimed in 1981. 3. Ontario all A Consolidated environmental Hearing enquiries Act was passed which combines and concern into one hearing. Quebec Regulations for Quality of the Occupational Environment were issued under the Occupational Health and Safety Act in 1980. Regulations prescribing content and procedures for Environmental Assessment and Review were passed in 1981. Saskatchewan An Environmental Environmental Spill under the Department C. Quality of the Assessment Act was passed in 1980. Control regulations were issued of Environment Act. Environment In previous reports it has been noted that no country, not even the U.S., has as yet developed an overall performance index to gauge progress in achieving environmenta l quality goals. Air quality in both Canada and the United States has generally improved in both jurisdictions as measured by the so-called cri te -ria pollutants, total suspended particulates, SOX, NOx, Ozone and Lead. Environmentalists in the U.S. are now turning their attention to Hazardous Air Pollutants (e.g. heavy metals, P.N.A.'s etc.) and are vexed that E.P.A. has not regulated these as called for under their Clean Air Act. In Canada, the pre-occupation is focused on Acid Rain. Water quality is a much greater concern in the United States than Canada because of the greater degree of industrialization and the fact that nearly 50% of that country's drinking water supplies come from ground water aquifers. Authorities and the public have become aware of the potential for contamination of ground water supplies by toxic chemicals from unsafe waste disposal practices. If one could ignore the gradually eroding effect of acidic precipitation, the long range concern with respect to toxic pollutants on the Great Lakes and the annual ravage of forest fires and forest pests, the general quality of the Canadian environment is gradually improving. [ 4. Alth ough pollution fn J9e0 n~~ t oday, ranked low on thr; rJ•t r:rn l l l 1 in the pub lic , they h;:ivr.; rr!f''/ 1tr<,r1 views when specifically qu<:d-<;d. Chart l • 1 J When ask ed to state wh..-.t'*,;rr; C11n11d<1'. m,1jor environmental p r oblems , a.i r 1;nrJ •,r,, t_c,r r.1r.1 I 1n 1on have been f i r s t named b"J 1..ipproz:J Irri'.;l,U· l '/ lOi of' th respondents. Abuse of natura L r.r; #rJt.t.rc,; , I th ; third most ment i oned , follr.J'fi1""..:d 1'1'L,:l'f h·1 loaB of prime farmland. # Chart 2 Industry in general and somE: partlcul~c industries are s een as the major culprits. charge of i ndus t r ial chemicals into thf! air ranks considerabl y above all others. Chart 3 The public place s primarJ responsibility on the federal and provinci al governments with Ottawa designated over the provi n ces by a 4 to 3 margin. Chart 3 Chart 4 The disand water There is strong supp ort for more government regulation and little s upp ort for relaxation. Despite the recession, the publ i c sa y they are willing to pay more in taxes or prices to r educe both air and water pollution. It is also inter e s ting to note that the public is not willing to acc e pt higher levels of pollution to ensure future energy supplies. Acid Rain is perceived a s Canada's greatest environmental threat, followed closely by hazardous waste disposal. s. SECTION II PERFORMANCEI .PROBLEMSI AND PLANS . OF OPERAT.ING DEPARTMENTS 1. ESSO RESOURCES CANADALIMI'TED A. Exploration and Production Accomplishments (a) Prepared and submitted Environmental Impact Statement on Norman Wells expansion project. Completed EARP and N.W.T. water board hearings and obtained environmental approval with conditions. (b) Completed oil spill Norman Wells area. ( c) Completed Production initiated (d) Repaired and improved pipelines in Redwater, Devon, Judy Creek, Boundar y Lake, Nisku areas as well as inspections of other major pipelines. (e) Participated and improved in Alberta. (f} Reduced Redwater {g) Completed western mental task force Major Problems contingency for scientifi ·c studies for Beaufort Environmental Impact Statement preparation of EIS documents. Sea and in oil spill countermeasures efficiency of responding to H2S and smoke emissions and Quirk Creek. provinces study. at operations plants research spills in environ- Remaining (a} Obtaining production regulatory approvals and transportation. {b) Oil clean-up (c) Corrosion clean-up, spill plan in failures of rehabilitation ice-infested for Beaufort Sea waters. pipelines, high cost and compensation. of ,,. (d) B. M in 1 Utt to h, nv Ir c 111111n t tl I •o ncl Nonu Ht w I I t1ppr ov., I (e) Dispos \1 of ( f) Lon proj rm l oi 1 f I nv i. n f ron L i ~ L' r (g) Iner sing ctivit' s. (h) Incre sing cone rn by local issu s r l t d acidific tion, nd w nd delays, conflicts Heavy (i) I I .t h1 d w u1t Id r-011111< n ,1 II t 1 mcm I l orl l r , ov r.nm nt nq m11)or for 1 1• r.v•n. in Ion 1n indu•1t · ry r.s md r.r ''i i don tr, on mi, sons, soil Lor quality, rcsulllng in increased compensation. 1 ndown to ir Oil Syncrude Accomplishments (a) Improved (b) Implemented operation tailings pond. (c) Continued long and re-forestation. (d) Reduction Major response in Problems to major to S02 excursions. recov er reclamation bird kills through at tailings from re-vegetation pond. Remaining: (a) Major land (b) Periodic emissions. excessive S02, H2S and (c) Oil and from tailings (ii) Operations loss bitumen requirements odour - Pilot for tailings pond. particulat pond. Plants Accomplishments (a) Improved (b) Mud reuse water applied reuse at Leming. during drilling operations. e 7. Major C. Problems Remaining (a) Casing failures. (b) Freshwater makeup (c) Compliance with and produced S02 emission water reuse. regulations. Minerals Accomplishments (a) Midwest (b) Fish e ries and wildlife Kutch o Creek. (c) En v ir o nmental evaluations undertaken Cr ee k Collieries and Quintette Coal. (d) Air (e) Contaminatio Creek coal Major 2. Lake EIS completed. studies and wa t e r permits Problems conducted finalized at for n of research program rese rve test pit. at Byron Granduc. at Judy Remai n ing (a) Maintaining air and water (b) Lead time required impact assessment (c) Incorporating environmental minerals exploration activi quality to con duct studies . at coal mines. environmental guidelines t i es. into ESSO PETROLEUM CANADA A. Refining, Marine and Pipeline Accomplishments (a) Land farming successfully of Biox applied and oily slud ges to all ref ineries. has been 8. (b} Management programme has handle toxic materials. been installed to (c} Significant progress noise control. been made in in-plant (d) Air quality monitoring network established at response system Dartmouth and so 2 emergency set up in Sarnia. (e) Government permits obtained Montreal and Strathcona. (f) Furnace reduced (g) Spent water (h) Ninety safety and pollution were carried out on deep crude and product ships. (i) Over four thousand product transfers and tankers with only one minor spill. (j) Initiated a supervisory leak Quebec South Shore Pipeline. (k) Participated detection Major conversion so 2 emissions. caustic treating has to gas successfully systems at in development system in Alberta Problems for at projects Montreal handled Montreal has in waste and Sarnia. control inspections sea and domestic by barges detection of "one system call" leak -. Remaining (a) Operational incidents causing releases reverse flow at Dartmouth Cat Cracker soot and particulates on neighbouring (b) Meeting effluent water quality Eliminating Loading Heavy oil oil spills into - e.g., deposited homes. requirements. Biox problems at Sarnia and Effluent sheens - Dartmouth Exceedences at Montreal. (c) in Strathcona. and Sarnia. water rod leaks at Montreal spill at Ioco. bodies. on 9. B. Marketing Accomplislunents (a) Underground tank upgrading program is on schedule. To date, 2,200 locations tested, 120 tank systems replaced and current systems installed. (b) Published, through PACE, booklets on "Inventory Controls as a Means of Identification of Underground Tank Leaks". (c) Major upgrading at Finch Avenue (d) Initiated tion and chemicals (e) Communications to employees, associates and customers were developed regarding toxicity and handling procedures for used engine oil following the disclosure of skin cancer in animal tests. Ma j o r Proble 3. of drainage Terminal. system continuing have been 185 impressed and separators a review of emergency response organizacapability encompassing oil spills, (TEAP II.) and propane/butanes. ms Remaining (a) Moni to r ed devel"opments engine o il, c a n label (b) Environment Can a da are pressing industry install overfill alarms on above ground (c) Continue to wor k with Environment Canada development of pr actical regulations for maintenance and inspection of plants. regarding warnings toxicity of used may be required. to tankage. on operation, ESSO CHEMICAL CANADA Accomplishments ( a ) Reduction Redwater. of fluorine a nd particulate (b ) Reduct i on of VCM emi s s i ons at ( c) run-off Reduct i on of Redwater. surface water emissions at Sarnia. contamination at 10. Major 4. Problems (a) Control (b) Minimizing Rema ining of surfa waste ce water ge n eration run-off at at Redwater. Sarnia. OIL SPILLS Within Esso Resources, 1980 was t h e worst year on record for both numbers o f spill s an d cos t of clean-up. In 1981, both the number a nd c o s t have been reduced. Refinery spills which were contained readily recoverable. spills years. Marine and pipelin of oil during were typ i c a l ly s ma ll- v olume within th e Compa n y property e transpo rtation had 1980 o r 1 9 81, similar incidents and were no significant to previous Spills in marketing rema ined at levels similar to previous years. Truck accidents, especially in the Prairie Region, accounted for a lar ge nu mber of spills. In most cases, containment and par t i a l rec ov ery of product was possible. Overall work error continues to be responsible slight majority of the incidents, alt hough spills by equipment failure and corrosion ar e rising in As in-house training and environmental awareness and as in-place equipment (such as pip e l ines and get older, this trend is expected to co nt i nue. Chart 5 for a caused comparison. continues, tanks} As the volume of oil spilled in most inc idents was low and contingency plans were in place to re spon d , the damage caused to the local environment and person a l property was minimal during 1980 and 1981. A number of th e spills which occurred in Alberta in 1980 did resul t in s ome public and government criticism and subsequent bad pub licity. Esso Resources have made efforts to improve t h is situation through in-house spill prevention programs such as corrosion/ leak detection surveys and more effective res po nse to spills by field personnel. 11. SECTION III COORDINATION ACTIVITIES 1. Chart Chart TECHNICAL EFFORT, EXPENDITURES, BUDGET The total technical effort for Environmental Protection increased in 1980 (117 man years) and dropped back somewhat in 1981 (110 man years)compared to 1979 (103 man years). The number of full-time professionals grew from 35 in 1975 to a peak of 62 in 1980 and then fell to about 49 in 1981. The decline was principally to decreased requirements because of deferral of major projects such as Cold Lake. The effort by Region Environmental Advisors dropped about in half from 1979 to 1980. For all regions, except the Prairies, it became a part-time assignment, generally combined with marketing engineering functions. 6 Capit a l exp e nditures for environmental control peaked a t a bo ut $ 7 0 Min 1979, dropped to $66 Min 1980 and falls betw e en $ 5 5-6 5 M out to 1984, with further decline pred i cted. The r e i s a g o od deal of uncertainty in connection with the forecast numbe rs because of the current business c l imate. 7 2. to INDUSTRY ACTIVITIES A. Commitment to Industry of Com an Resou rces Environmenta l Activities Company personnel are stron gly committed in the management direction and technical ac tivities of six industry environmental associations, f our major operational oil spill cooperatives, and the enviro nme ntal committees of three trade associations (C.M . A., C.P .A. & C.C.P.A.). The total number of individuals in committee work probably ranges between thirty and forty i n an y year and probably aggregates the full time equivalent o f t hree or four man years. There is a considerable variet y o f activities, including monitoring the air and water in the vicinity of our operations; develo~ing and training for and responding to oi l ~pills; managing environmental research proJects; responding to init i ati v ~s ~nd inf o rmation needs, government regulatory and communicating with the pub lic i n a broad sense. 12. Chart 8 The dues, fees and oper ating costs (including charged to Imperial for th e s e industry activities $986,700 in 1980 and $1,416,000 in 1981. Imperial's share of th e res o urce inputs, man hours var i es from 10 to 25 %. The benefits company are probably several - fo l d the inputs the multiplier effect. research) totalled dollars to the because and of Several of the associations p ublish formal annual reports; however, a summary narr ative of the activities of the more important ones follow s herewith. B. Arctic Petroleum Operators As s o ciation The Arctic Petroleum Ope rators Association is composed of 20 oil companies ope r a ting in the Arctic. The association sponsors resea r ch projects primarily related to environmental and e n g i n eering areas of the petroleum industry's activities in t he arctic. In addition, A.P.O.A. supports workshop s and conferences on northern issues and acts as a forum f o r comunicating with local comITlunity, native and publ i c interest groups. The Environmental and Oil Spill Commit t ees of A.P.O.A. plan and coordinate studies to imp r ov e the understanding of the physical and biological Arctic e nvironment and to safeguard that environment by preve nt i ng or minimizing damage caused by petroleum activ i t i es. Projects in 1980 and 1981 have focused on invest i gatio n of effects of ice forces and permafrost on operations, cleanup of oil in ice-infested waters and improved trai ning for oil spill response. C. Canadian Chemical Producers Associatio n The Environmental Quality Committee o f C.C.P.A. has continued to play an active role in advisi ng and assisting provincial and federal government s on environmental matters related to the industry. Guid a n ce has been given to the Quebec government regarding a ir pollution control from chemical plants. The committee has conducted surveys in different provinces to assist governm ents in developing their waste disposal long-range p l ans. Assistance has been provided in the design and es t a blishment of waste transportation manifest forms . Within the increasing ~oncern ~ver hazardous chemicals, th e EnvironQuality Committee of C.C.P.A. has assisted mental governments in developing tests and methods for c on trol and monitoring purposes. New and proposed legislat ion on hazardous chemicals is closely monitored I improve emerg 7ncy response, TEAP II (Transp~rtaii~~der to Emergency Assistance Plan) has been developed for th industry as a nationwide response network. e 1.3. D. Canadian Petroleum Association Environmental Planning and Management Committee The C . P.A.'s Environmental Conunittee redefined ~hei~ role and were very active in this period. Communications, both internally across the various companies, with government agencies, the public and and ext 7rnally were stepped up and greatly improved. the media, A major project Environmental Operating the industry. for The committee various government in 1980 was the preparation Guidelines for E&P sector prepared studies several briefs and hearings. An extensive report on waste generation disposal practices in the industry was prepared Energy Resources Conservation Board. A product effort was issuance of a manual entitled "Waste ment Guidelines" . of of each year and for the of this Manage- The committee presented an industry brief in re s pon s e to th e Alberta Government's Land Management Plan fo r th e Eas te r n Slopes. Th e commit t ee actively promoted Oil Spill Cleanu p training activities. Resea r ch projects were undertaken r el ated to the de v e l op me nt and improvement of techniques and e q uipment for spil l c lea nup , containment, recovery a n d disposal. Studies were completed on t he impact of seismic a n d drilling operations on wildlif e , and the impact of drilling fluids in marine and l a nd environments. The problem of acidic water run-off f rom s ulfur block storage was surveyed and prot e c t i ve mea s ures defined. Considerable effort was s pent in addressing regulation hearings and resear ch in r espect of the effect of acid ryas emissions fr om g as plants on soils, crops, animals and humans. E. Canadian Offshor e Oil Sp i l l Rese arch Association The Canadian Offs hore Oil Spill Research Association was formed in 1980 under t he s ponsorship of A.P.O.A. and E.P.O.A. to carry out resear ch on oil s pill fate and effects countermeasures, equi pment and material developeva l ua t ions re l a ted to the marine ment and dispersant areas of Canada's offshore, where t her e i s pl a nn e d or D. Canadian Petroleum Associ tion Environmental Planning and M nct_<1;·!I1,r•ntCommi__ The C . P.A. 's Environmen ta 1 Comml t l< ' J rr,-:: 1;nvir<:>nrnental and r..'2.:;:<:.:. ~-:.- , .. ~__.... _-. in the arr;a of: Refining Marketing Distribution Pipelines Marine Technology an~ Dt::z:~~ • Represent Esso Petro:t::·.,...., _ S:;.::-.-::_":E :.~ co-ordinate attendar ~~e 0~ :..~~~=department I.O.L. ~0 -i~~e~s ~.~ Exxon committees dealir.'J w:.. "":°:'. environmental heal ~h iss·.:.Bs. • Represent Esso Petro:e•=. s~..:-.~-:.~ environmenta l affairs ?0:i-::-z ::z-:.~e=E involving: - PACE - Federal and Pro7inc:.a:.. S:.ve..:: ...e,:-.-:.E - Provincial petrole .:r: 0-::: e:-.7.:..=:.:-..::.::-.-:.a:. associa tions - Profess ional associa~i0~s Reporting to: Effective Date of Appointment: • Provide policy guidance =0r a:: ~ss~ Petrole um Canada departm.e~~s ~~ ::.a~~=rE concer ning environme nta: a==a~rs. • Provide policy guidance ~o -=.:-.e opera~~c~s Planning Commit tee and ~l..a~ase:;:.e~~ ~c:=::.~~== of EPC. • Monitor the effecti,eness programs and provide guidance appropriate. o=iepa= Executive March Vice 1, 1982 President ~~.2re -__e~~ a: APPENDIX IV ROLE OF ENVIRONMENTALAFFAIRS MANAGER ESSO CHEMICAL CANADA INVOLVES: • MONITORING AND INFLUENCING GOVERNMENTAND INDUSTRY ACTIVITIES. • MONITORING ECC OPERATIONS. • IDENTIFYING • RECOMMENDINGPOLICY. • ENSURING ADEQUATE PLANNING AND RESOURCES. • ENSURING COMPLIANCE WITH POLICIES • COORDINATING SUPPLY OF MEDICAL AND INDUSTRIAL HYGIENE SERVICES . e ARRANGING SUPPLY AND DISSEMINATION OF ENVIRONMENTAL INFORMATION. • STEWARDING TO ECC MANAGEMENT. e PARTICIPATING ACTIVITIES. REPORTING TO AND EVALUATING RISKS. AND REGULATIONS. IN IMPERIAL AND EXXON CHEMICAL MUTUAL PRESIDENT, ESSO CHEMICAL CANADA