Emissions & Waste
Emissions & Waste
1. What precautions will be in place to protect the chemicals and processes associated with the plant from contaminating the land, rivers, and groundwater?
- No underground hydrocarbons or chemical piping or tanks will be used, which will reduce the potential for underground leaks. See answer 6 for more details.
- Secondary containment systems around hydrocarbon and chemical storage vessels and hydrocarbon and chemical pumps. See answer 4 on Operations Background FAQ for more details.
- Site stormwater system, which segregates areas of the plant to minimize the potential for contaminants to find their way into the stormwater system. The design controls, captures and tests any collected stormwater to ensure there is no contamination prior to releasing any water to the environment. Treating and recycle of stormwater will also be considered to minimize the make-up requirement from the river.
- In the event of a secondary containment failure, the stormwater retention pond will act as a third layer of defense against contamination. See answer 4 on Operations Background FAQ for more details.
- Gas detection systems which provide early warnings, should a leak occur.
2. How will solid/liquid waste products be handled? What percentage of these is expected to stay in the local area?
- The project will generate very few liquid/solid wastes. Those which are produced will be captured, contained and shipped off site to the appropriate and accepted location for disposal. See Project Description on the BC EAO EPIC web site for a detailed list of liquid/solid wastes and the proposed management and mitigation techniques.
- WCOL has not yet completed a survey of available waste disposal facilities in BC, but Swan Hills Waste Treatment Facility in Alberta is often used for Albertan projects and is close enough to be considered an option for waste disposal for the WCOL Project. This assessment will be completed as part of the EA Application development process.
3. What considerations have been given to planning upgrades to more environmentally sustainable production methods and process?
The advantage of building a new plant is that we have the option to implement state of the art technologies, processes and methods. New plants are significantly advanced compared to those built 40 years ago. For example, the first ethylene plant in Alberta, started in 1979, used 50% more energy (and therefore produced 50% more emissions) to produce ethylene compared to the most recent Alberta plant built in the early 2000’s. We have the advantage of implementing further advancements that have been developed over the past 20 years.
4. Can WCOL provide quantitative estimates of expected VOCs, especially Benzene, 1,3‑Butadiene, and formaldehyde, as well as the tonnage per annum of fine particle emissions during all phases of the proposed development and its ongoing operation?
- At this stage of engineering development, we do not have accurate and detailed quantities for the emissions being referenced but will need to do so to get through the regulatory process. But modern facilities, such as the NGL Recovery Plant and Ethylene Plant proposed by WCOL, are designed to minimize VOC emissions through a number of design features, such as: eliminating atmospheric vents on tanks and other process equipment; implementation of vapour recovery systems and routing waste streams for safe incineration; dry gas seals on major rotating equipment; etc. See answers 1 and 6, and question 4 on the Operations Background FAQ for more details).
- FORMALDEHYDE: This chemical is not produced in our plant.
- FINE PARTICLE EMISSIONS: The NGL Recovery and Ethylene Plants will produce essentially no particulate emissions as we do not have solid products. Our fuel gas is a mixture of methane and hydrogen making it the cleanest fuel of any industrial plant, therefore resulting in extremely low levels of particulate matter being produced.
- OTHER VOC LEVELS: As noted above, estimates of VOC emissions will be developed during more detailed phases of engineering. Control and monitoring of VOC emissions typically includes multiple volatile organic compounds, including benzene, butadiene, toluene, xylene and ethylbenzene. The proposed design features will mitigate the release of all VOC’s, not just the specific compounds listed in the question.
5. Can you specifically address concerns related to benzene emissions and exposures? Publicly available data for the Nova Chemicals’ Joffre Site in Red Deer, Alberta, indicates annual benzene emissions of 3.5 tonnes/year (from the 2017 Facility and Substance Information Report from the federal government)?
It is important to note that the Joffre site has three separate ethylene plants and two of the three plants use forty-year-old technology. The site also has two very large polyethylene plants and a linear alpha olefins plant on the same site. The Project WCOL is proposing is an NGL Recovery Plant (no benzene-containing streams) and a single ethylene plant and will be using much newer technology and processes, designed to minimize VOC and benzene emissions.
We want to make it clear that West Coast Olefins is not condoning benzene emissions, and acknowledge that it is a known carcinogen. We will take extensive measures to minimize exposure to personnel and releases to the environment (See questions 1, and 6 on Emissions & Waste FAQ and question 4 on Operations Background FAQ for more detail on the systems which will be incorporated into the WCOL facility design to minimize VOC releases). However, it is important that we consider information in a real context.
The table below illustrates where the Chemicals Industry fits relative to other large emitters of benzene (note that the table is in thousands of tonnes per year).
Estimated Emissions in Kilotonnes Adapted From Benzene Emissions Inventory for Canada (1990-2010)
Environment, C. C. (2001). Companion Document- Part 1: Initial Set of Actions for Canada-Wide Standard For Benzene Phase 1.
As can be seen, the Chemicals Industry (highlighted) has one of the lowest Benzene emissions, with forest fires emitting 270 times more benzene in 2010, and residential wood (burning of wood pellets within the home for example) emitting 120 times more benzene in 2010. If the Red Deer emissions are pro-rated down to reflect a single plant (such as our Project), then our emissions would add 0.001 kilotonnes to the table or 0.0016% of total benzene emissions.
The greatest exposure that most people will encounter is when fueling your car. The maximum benzene content for gasoline is specified as 1%. About half of the exposure to benzene in the United States results from smoking tobacco or from exposure to tobacco smoke. Benzene is a by-product of the combustion of tobacco in cigarettes. The average smoker (32 cigarettes per day) takes in about 1.8 milligrams (mg) of benzene per day. This amount is about 10 times the average daily intake of benzene by non-smokers. In a study by CAREX Canada, the industries with the greatest number of exposed workers to benzene were auto repair, taxi and limousine service, the printing industry and firefighters. The WCOL facilities will follow Work Safe BC guidelines for occupational exposure and use a combination of equipment design, operating procedures and personal protective equipment (PPE) to limit the exposure of workers to benzene.
6. What are the planned procedures and technologies that will be used to address the VOC emissions potentially associated with the facilities?
- Some procedures and techniques to address VOC emissions include, but are not limited to:
- No intentional or unintentional atmospheric venting. This is the purpose of the flare and vapour recovery systems, to safely vent and burn hydrocarbon inventory/purge during plant upsets or during startup or shutdown procedures.
- Closed hydrocarbon drain systems, designed to collect small hydrocarbon liquid and gas volumes which often need to be drained or vented from equipment during normal operation and maintenance of the facility. The drain system consists of fully closed piping and vessels to avoid release of hydrocarbons to the environment during these activities.
- The closed hydrocarbon drain system eliminates underground hydrocarbon piping and hydrocarbon tanks and avoids future leaks from this equipment into the ground.
- Vapour Recovery Systems to collect vapour from storage tanks and other equipment operating at low pressure and either recycle collected hydrocarbon to the process or safely incinerate it to ensure destruction of the hydrocarbons.
- Design and monitoring of flanges on piping and equipment to identify and address leaks
- Seals and packing on valves and rotating equipment to minimize leakage of process fluids (fugitive emissions).
- Dry gas seal systems on large gas compressors, to prevent leakage of process gas to the external environment.