Petrochemical - Industry Standard under the Local Air Quality Regulation (O. Reg. 419/05)
Local Air Quality Regulation (O. Reg. 419/05)
Bill or Act:
Environmental Protection Act, R.S.O. 1990
Summary of Decision:
Development of the Petrochemical - Industry Standard involved a comprehensive and transparent process including: a detailed review of current air emissions and point of impingement concentrations of benzene and 1,3 butadiene; dispersion modelling and on-site monitoring to identify the most significant sources of air emissions within petrochemical facilities; a technology and jurisdictional review of best available air pollution control methods; and an experts' review to support efforts by representatives of Aamjiwnaang First Nation and Walpole Island First Nation to assess appropriateness of the proposed Petroleum Refining - Industry Standard, of which many requirements are similar for petrochemical facilities.
The Petrochemical - Industry Standard targets the most significant sources of benzene and 1,3 butadiene air emissions from Ontario petrochemical facilities. Based upon assessment of the overall risk and experience with implementing air pollution rules, the ministry believes that a combination of an incremental approach (e.g., initially focusing on sources that include at least 2 percent by weight benzene); on-going monitoring and auditing; collaboration with affected communities; and a planned review of performance is the most appropriate approach to ensure the implementation of best available air pollution control; best use of resources; and continuous improvement.
The publication entitled: "Technical Standards to Manage Air Pollution" has been updated to include the Petrochemical - Industry Standard. Requirements of the Industry Standard only apply to sites and contaminants that a facility registers for. The ministry maintains a list of facilities registered under a technical standard: the list is posted on the ministry website so that the public is aware of the compliance requirements for these facilities. In addition each request for registration under a technical standard is posted on the Environmental Registry for a minimum 45 days of public comment.
March 9, 2016
Summary of Proposal:
A summary of the proposed requirements are included in the attached rationale document and the draft Petrochemical - Industry Standard. Highlights include the following proposed requirements for benzene emissions:
beginning January 1, 2018, storage vessels that are at least 75 cubic metres in capacity and store liquid with at least 2% by weight benzene, are to be equipped with internal floating roof (IFR), external floating roof (EFR) or closed vent and control systems;
oil and water separators are to install by January 1, 2019, IFR, EFR or closed vent and control systems or monitor ambient air or inlet/outlet benzene levels in wastewater starting July 1, 2017;
implement by January 1, 2019 air pollution control plans for all process drains with junction boxes within 200 metres of the property-line or monitor for benzene in wastewater starting July 1, 2017;
within 18 months of recording certain product loading thresholds, require closed vent and air pollution control systems for product loading areas with 2% by weight benzene or more;
a Leak Detection and Repair (LDAR) program for components that are in contact with fluid that contains 2% by weight benzene or more;
one survey per year must be completed using a method specified in the proposed technical standard (i.e., similar to United States Environmental Protection Agency (US EPA) Method 21) and the other surveys in a year may be completed using an optical gas imaging (OGI) technology (benzene and 1,3-butadiene);
leak repairs must be completed within specified time-frames beginning January 1, 2020;
a "delay of repair list" is allowed to delay the repair of a component until the next process unit is shutdown if the combined total of all leaks on the "delay of repair" list (for in service components with 50% benzene or more) is less than 250,000 parts per million by volume as benzene;
benzene or VOC emission limits for all air pollution control devices must be source tested every two years;
flares that are used as air pollution control devices, must meet comparable requirements as the US EPA by January 1, 2023;
as of January 1, 2018, a requirement for the installation and operation of twelve property-line monitors for benzene at each facility that registers with the technical standard;
annual ambient monitoring reports including a summary of actions taken to address any statistically significant higher monitoring results must be posted on the facility web-site (benzene and 1,3-butadiene);
tracking of complaints;
more stringent requirements that phase-in over time; and
public reporting, notification and recordkeeping requirements.
It is proposed that the ministry will continue to work with industry stakeholders and community partners as the new air pollution requirements are implemented. In particular, due to the proximity of many of the petroleum refining and petrochemical facilities along with ongoing concerns from the communities themselves, a collaborative approach with the Aamjiwnaang First Nation and the Walpole Island First Nation will be undertaken to verify air quality improvements and to identify additional air pollution control requirements as necessary. These implementation efforts are anticipated to culminate in a review of the petroleum refining and petrochemical sector requirements in 2023.
Air Pollution Control Engineer
Ministry of the Environment and Climate Change
Environmental Sciences and Standards Division
Standards Development Branch
40 St. Clair Avenue West
Phone: (416) 327-5513
Fax: (416) 327-2936
July 27, 2016