Imperial Oil Limited - Approval to register for a technical standard for air pollution (industry standard)

We received one comment in response to this posting on the Environmental Registry. It raised the following concerns:

1. The facility will not comply with the health-based Schedule 3 standards for benzo(a)pyrene and that the registration application materials does not demonstrate that the emissions will not cause an adverse effect. The facility's most recent emission summary and dispersion modelling report indicated that the point of impingement concentration would exceed the limit by 1940%.
    
2. The registration materials do not demonstrate that registration to the Industry Standard will prevent, eliminate, or ameliorate any adverse effect from these emissions. It is noted that the requirements are mostly related to reporting and that the Industry Standard does not have additional technical, equipment or process-related requirements for sources of benzo(a)pyrene.

Ministry response:

A technical standard is a technology-based solution designed for two or more facilities in a sector that are not able to meet an air standard due to technical or economic limitations. The goal is to have a more efficient tool to better manage air emissions in the sector and reduce overall exposure from various industrial and commercial facilities.

The technical standard compliance approach aims to reduce health and environmental risks by imposing technical requirements to address emissions in local communities. Registering facilities to the technical standards will impose rules for petroleum refineries facilities that are consistent with other jurisdictions in the United States. Facilities registered to a technical standard must adhere to the technical and operational requirements for managing emissions of contaminants they are registered for. This requires them to use the best available controls and practices to reduce the risk to public health and continue to operate responsibly.

During the development of the Petroleum Refining – Industry Standard it was determined that the contributors to the exceedance of benzo(a)pyrene do not warrant further equipment or process-related requirements when compared to facilities in other jurisdictions.

Note that a transposing error was found in the most recent emission summary and dispersion modelling report that, once corrected, indicated that the maximum point of impingement concentration would exceed the Schedule 3 limit by 194% and not 1940% as noted by the commenter.