The following comments…

The following comments provides input from Suncor Energy Inc. in response to the MOECC EBR Posting 013-1374 - Amendments to the Petroleum Refining and Petrochemical - Industry Standards under the Local Air Quality Regulation (O. Reg. 419/05).

Component leak survey – general

39. (1) If the date is on or after January 1, 2018, a registered person shall ensure that a component leak survey is performed at the petroleum refining facility in accordance with this section. (2) A component leak survey shall be completed, (a) at least three times each calendar year with at least one component leak survey being completed during each of the following periods, (i) the period starting April 1 and ending June 30,

Comment: In Southern Ontario, temperatures can be mild enough for annual LDAR surveys to begin in March. Section 39. (1)(i) should have April 1 be replaced by March 1. This would help to alleviate manpower issues, and allow for the first cycle to be completed using a portable detector, which typically requires additional time.

Appendix 7-E: Optical Gas Imaging - Methodology and Instrumentation

Optical Gas Imaging – Methodology:

2. (2) states “Before first using an OGI instrument on a day, the instrument shall be calibrated, an accordance with the operating manual.”

Comment: OGI Cameras cannot be calibrated by an operator on a daily basis. This requirement should just be removed and be limited to calibrating based on frequency outlined in operating manual.

· 2. (4) states “Subject to subsection (5), a tripod support shall be used when an OGI instrument is used.”

Comment: While it can lead to unsafe circumstances (as stipulated in (5)), it may also be impossible to adequately monitor a component due to small/constricted work areas, requirement to monitor from several different angles, need to access components by ladder, due to ergonomic considerations. This requirement should be removed as the operation of the camera requires full movements around the component.

Appendix 6-D: Portable Gas Detector - Methodology and Instrumentation Definitions

2. (2) states “Before first using an OGI instrument on a day, the instrument shall be calibrated, an accordance with the operating manual.”

Comment: Calibration of portable gas detectors are typically done as a 3-point calibration using zero-gas, 1000ppm and 10,000ppm. Limiting the concentration to 1000-5000ppm, does not allow for a high point calibration.

[Original Comment ID: 211287]