FACILITY PROFILE Irving Oil Refining G.P. Saint John ...

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FACILITY PROFILE Irving Oil Refining G.P. Saint John Refinery Prepared by: Authorizations Branch New Brunswick Department of Environment & Local Government December 2019 TABLE OF CONTENTS BACKGROUND PROCESS DESCRIPTION AIR POLLUTION CONTROL POTENTIAL AIR QUALITY CONTAMINANTS POTENTIAL IMPACTS OF AIR EMISSIONS AIR QUALITY COMPLIANCE AND ENFORCEMENT PUBLIC OUTREACH CONTACTS

Transcript of FACILITY PROFILE Irving Oil Refining G.P. Saint John ...

FACILITY PROFILE

Irving Oil Refining GP

Saint John Refinery

Prepared by

Authorizations Branch

New Brunswick Department of Environment amp Local Government

December 2019

TABLE OF CONTENTS

BACKGROUND

PROCESS DESCRIPTION

AIR POLLUTION CONTROL

POTENTIAL AIR QUALITY CONTAMINANTS

POTENTIAL IMPACTS OF AIR EMISSIONS

AIR QUALITY COMPLIANCE AND ENFORCEMENT

PUBLIC OUTREACH

CONTACTS

BACKGROUND

The Irving Oil Refinery built on a plot of farmland in 1959 in east Saint John officially

opened on July 20 1960 At the time the refinery was designed to process 38500 barrels

of crude oil per day (BPD) Two new process areas constructed in 1976 resulted in the

refinery becoming the largest in Canada with a nameplate capacity of 266000 BPD The

refinery has continued to improve unit and process efficiencies and currently has a

reference rate of 313000 barrels per day offering a secure and reliable energy supply to

customers across Eastern Canada and the Northeastern United States

In order to prepare for the requirement for cleaner burning fuels the availability of

natural gas as well as potential changes in the supply of crude oils Irving Oil Refining

GP (formerly Irving Oil Limited) registered the Refinery Upgrade Project (1) under the

Environmental Impact Assessment (EIA) Regulation in March of 1998 This project

which the Minister allowed to proceed under specific conditions (2) on August 13 1998

involved the construction of eight new units of which three were petroleum production

units and five were environmental control units These are discussed in the sections on

Process Description and Air Pollution Control By the end of 2001 all new units had

been commissioned

The Irving Oil Refining GP refinery produces a range of fuels for transportation (ultra-

low sulphur gasoline ultra-low sulphur diesel jet fuel) and combustion applications

(home heating oil kerosene Bunker C) Other fuels produced for use in more specialized

combustion and transportation applications include butane and propane The heaviest

components of crude oil are used in asphalt which is sold for paving

PROCESS DESCRIPTION

The refinery consists of units for distillation cracking reforming (molecular

rearrangement) product treating steam and hydrogen production sulphur recovery and

tanks for blending and product storage Below are brief descriptions of the process

operations

Distillation

The purpose of crude oil refining is to convert the diverse mixture of petroleum

hydrocarbons present in the crude oil into component streams having the best use and

marketability Crude oil contains a mixture of hydrocarbons of various chemical

compositions and boiling points as well as impurities such as brine and sulphur and

nitrogen compounds This mixture contains a range of petroleum hydrocarbons from the

lightest methane which is the primary constituent of natural gas to the heaviest residues

with high molecular weights that are used in paving asphalt Between these are a series

of hydrocarbons that are separated for use in gasoline jet fuel diesel fuel home heating

oil and heavy fuel oils

The first step in the refining process following removal of brine is to separate the

hydrocarbons present in the crude oil into distinct boiling ranges Some of the separated

products may be used directly in saleable products while others must be processed further

in order to make the most of their inherent value and to meet product specifications

The separation process known as distillation takes place in a distillation column as

shown in Figure 1 The crude oil is first heated to temperatures above 700 degF after which

it is fed to a distillation column containing a series of perforated trays Due to differences

in the boiling points of the hydrocarbons the crude oil vapours condense on the trays at

different levels within the distillation column The lower boiling point hydrocarbons

(heavier products) condense first and are withdrawn near the bottom of the column As

the crude oil vapours move up the column progressively lighter fractions condense and

are withdrawn Those fractions that do not condense are withdrawn as a gas at the top of

the column

The heavy ends those hydrocarbons that are too heavy to boil off in the first distillation

column collect in the bottom of the column and are withdrawn and sent to a second

distillation column which operates under a vacuum Under vacuum the hydrocarbons

boil at lower temperatures and gas oils which could not be vaporized in the first column

move up through the column and are separated out The heaviest (bottom) products are

used in asphalt The separated gas oils are further processed in the cracking units as

described under Cracking

Figure 1 Schematic of Crude Oil Distillation Column

The refinery operates two crude oil distillation units

bull Crude Unit No 3 (146000 BPD) constructed in 1976

bull Crude Unit No 4 (120000 BPD) constructed in 1999 and commissioned in

2000

Cracking

Following distillation the gas oils which represent approximately half of the crude are

broken into smaller molecules in processes referred to as cracking operations Cracking

employs a catalyst which is a material that is used to promote a reaction but which is not

consumed in the reaction The catalyst is used either to speed up the reaction or to allow

it to occur at a lower temperature which renders the process more energy efficient

Following are the three cracking units at the refinery

bull Residue Fluid Catalytic Cracking Unit (RFCCU) (85000 BPD) where residual

oil (high molecular weight residual oil) is cracked and can be separated into

fractions including fuel gas propane propylene butane butylene gasoline diesel

and decant oil

bull Fluid Catalytic Cracking Unit (FCCU) (25000 BPD) where vacuum gas oils

are cracked and separated into fractions that form gasoline diesel and liquefied

petroleum gas (LPG) and

bull Visbreaker (20000 BPD) where residue from the vacuum tower of the crude

units is cracked at high temperatures to make gasoline and diesel fuels

Molecular Rearrangement

Light molecules in the gasoline component streams can be rearranged to improve their

properties as gasoline blending components Reforming is normally carried out in the

presence of hydrogen and a catalyst at temperatures of up to 1000 o F

The refinery has five of these units which perform specific operations as follows

bull Butamer Unit (12000 BPD) where normal butane is converted to isobutene

bull Two Alkylation Units (8000 BPD and 10000 BPD) where iso-butane from other

units is combined with butylenenormal butane mixture to make alkylate a high

octane zero sulphur low vapour pressure gasoline blending component and

bull Rheniformer No 1 (11000 BPD) and Rheniformer No 2 (28000 BPD) where

gasoline blending stocks are reformed to yield a higher-octane fuel

Product Treating

Most refinery streams are treated to remove contaminants such as sulphur organic acids

metals and surfactants that might be detrimental to engines or the environment The

refinery has five units that are used to treat product streams to remove contaminants

bull Naphtha Hydrotreating Unit (NHT) (44000 BPD) where sulphur is completely

removed from the naphtha by reaction with hydrogen over a catalyst

bull Hydrocracker (45000 BPD) where heavy diesel and light cycle oil are

desulphurized in the presence of hydrogen and a catalyst resulting in the

production of ultra-low sulphur diesel products

bull Hydrodesulphurizer (HDS) (56000 BPD) where the sulphur in diesel blending

components is converted to hydrogen sulphide by reacting with hydrogen over a

catalyst

bull Merox Plants (44500 BPD) where mercaptans which are odorous compounds

are removed from gasoline and jet fuels and

bull CD-Tech Unit (58000 BPD) where sulphur compounds are removed from cat-

cracker gasoline in a two-stage process

Steam Production

Many of the process units contain heat exchangers to recapture waste heat from process

streams Steam produced in the refinery boilers and heat recovery steam generators

(HRSGs) is used to provide power in turbines and ejectors to heat processes and

materials and as part of the refining process

The refinery currently has four boilers (1 3 5 and 6) and two HRSGs which burn

refinery fuel gas The HRSGs operated as stand-alone units until late 2004 when

combustion turbines were commissioned as part of the Grandview Cogeneration Project

The combustion turbines generate up to 90 Megawatts (MW) of electricity that is sold to

NB Power a portion (approximately 65 MW) of which is re-sold to Irving Oil Refining

GP for use in the refinery The HRSGs now derive a significant portion of their heat

input from waste heat generated by the combustion turbines significantly increasing the

efficiency of steam generation

Hydrogen Production

Hydrogen required as a feedstock for the hydrocracker and the diesel and naphtha

hydrotreaters is produced by a Hydrogen Plant where natural gas is the primary feed but

naphtha or butane may also be used at high temperature and pressure and in the presence

of a catalyst is converted to hydrogen and carbon dioxide Hydrogen is also produced as

a by-product of the molecular rearrangement process

A Hydrogen Recovery Unit recovers hydrogen from various process streams within the

refinery

Storage Blending and Shipping

Approximately 15 to 20 different component streams are produced by the refinery These

products are stored in the tank field before being blended together in appropriate

proportions to make various grades of gasoline low-sulphur diesel jet fuel furnace oil

and asphalt The finished products are also stored in the refinery tank field prior to being

shipped to customers via road rail and ship The tank storage area contains 135 tanks

storing crude oil blending components and finished products There are also a total of 8

spheres and 10 bullets for storing butane and propane

AIR POLLUTION CONTROL

Owing to the complexity of the refinery air pollution control is achieved through a

variety of techniques including engineering design task and unit specific control

technologies operating strategies and procedures and programs having specific emission

reduction goals These are summarized in the following sub-sections

Fuel Combustion Controls

Generally speaking there is no air pollution control equipment on fuel combustion stacks

(although there are some exceptions) Control is typically exercised by maximizing heat

recovery at the process design stage through the choice of fuel and fuel sulphur levels and

through optimizing furnace operating conditions For example process heaters for Crude

Unit No 4 were designed to be more than 90 percent efficient in terms of energy usage

which is reported to be 20 percent more energy efficient than the furnaces associated with

Crude Unit No1 which they replaced

Sulphur Recovery

Refinery processing operations where possible are designed as closed cycle operations

This means that there are few emissions to the atmosphere There are several reasons for

this including safety environmental protection product recovery and economics The

lightest fractions produced by each processing unit are stripped of their saleable

components and the remaining gases called sour gas (because of the hydrogen sulphide it

contains) are sent to the Amine Sulphur Recovery Unit where the hydrogen sulphide is

removed The cleaned gas known as refinery fuel gas or sweet gas is used throughout

the refinery to provide product heating with minimal emissions

Recovered hydrogen sulphide gas is fed to the Sulphur Recovery UnitsHATGU where

the sulphur is recovered for sale to the fertilizer and pulp and paper industries Some

hydrogen sulphide gas is fed to the Sulphuric Acid Regeneration Unit where it is

converted to sulphuric acid and used in the alkylation process Approximately ninety nine

percent of the sulphur is recovered in this process with the rest being emitted through the

Sulphur Recovery Unit stacks as sulphur dioxide

Water is used in a variety of processes within the refinery to clean and cool product

streams Water that comes into direct contact with petroleum products becomes

contaminated and is likewise handled in a closed system The sour water that results from

these operations is cleaned of its impurities in the Sour Water Stripper where hydrogen

sulphide and ammonia are removed The recovered impurities are fed along with the

hydrogen sulphide from the Amine Recovery Unit to the Sulphur Recovery Units AND

hatgu

The refinery presently has

bull two Amine Sulphur Recovery Units (2450 mscfh recycle rate) and two Sour

Water Stripping Units (7600 BPD each) The second units in each case were

added during the upgrade to provide additional sulphur extraction capability as

well as redundancy for maintenance and other shutdown periods

bull a Tail Gas Unit to remove additional sulphur from the Sulphur Recovery Units

exhaust (tail) gas The original unit (Sulphuric Acid Tail Gas Unit) installed

during the upgrade did not operate as expected so the refinery was required to

propose a solution In 2008 a new unit was installed (the Hydrogenation Amine

Tail Gas Unit or HATGU) which is achieving the desired sulphur recovery

bull a Sulphuric Acid Regeneration Unit to regenerate spent sulphuric acid catalyst

from the Alkylation Plants and

bull two Sulphur Recovery Units (100 long tons per day each)

Flares

Process units are linked together in a system that allows for pressure relief of vessels

being shut down for maintenance or due to upset conditions such as a power interruption

The pressure is relieved by piping the excess product to one of three flares where the

hydrocarbons are combusted at a safe distance from people and equipment The flares are

equipped with smokeless technology and steam assisted air dispersion equipment The

flare system tips were upgraded in 2004 to reduce noise when additional steam is directed

to the flares In addition the No 1 flare was upgraded during the fall 2007 turnaround

and as a result of the newer technology employed noise levels have been reduced

FCCU Particulate Control

Particulate matter emissions from the FCCU are minimized by a series of cyclonic

separators Flue gases from the catalyst regenerator are passed through six sets of primary

and secondary cyclones where centrifugal forces cause the particulate matter to move to

the outside surface of the cyclones where they drop to the bottom and are removed Flue

gases from the secondary cyclones are sent to a third stage containing 80 high efficiency

cyclones and then to a fourth stage high-efficiency cyclone where the majority of the

remaining particulate is removed prior to it being released through the stack During the

2017 Turnaround the primary and secondary cyclones were replaced with an improved

design to improve steady state performance As the flue gas continues through each stage

the size and amount of the particles left in the stream decreases Recovered catalyst is

returned to the unit for re-use or recycled

FCCU Carbon Monoxide Control

As part of the 1976 refinery expansion a platinum combustion promoter was added to the

regenerator The promoter keeps the heat in the bottom of the regenerator where

combustion of carbon monoxide to carbon dioxide is completed without hazard and

reduces the concentration of the carbon monoxide emissions from approximately 10 to

001 percent

Particulate Matter and Sulphur Dioxide Control on RFCCU

A Flue Gas Scrubber (FGS) was installed as part of the Refinery Upgrade Project to

control emissions of particulate matter and sulphur dioxide from the RFCCU catalyst

regeneration process

Noise Control

Noise emissions from the refinery are controlled through the equipment selection

process a silencer to reduce noise on the FCCU was installed in 1995 in response to

concerns from neighbours around the refinery Noise mitigation is recognized as an

integral part of the design process and noise level specifications were included in the

upgrade project procurement process In the fall of 2007 the refinery conducted a noise

study as a requirement through their Approval to Operate Although the results of the

study showed noise to be within benchmark levels at their property line it did help

identify certain activities and units that contribute to slightly increased levels As a result

several process and mechanical changes were made (such as the installation of silencers)

to reduce intermittent noise levels

Hydrogen Plant Carbon Dioxide Control

Primary sources of carbon dioxide within the refinery are from fuel combustion and from

synthetic hydrogen production through steamnaphtha reforming In order to reduce the

refinerys emissions of carbon dioxide recycle a contaminant emission and produce a

saleable product Irving Oil Refining GP entered into a joint venture with Praxair

Canada Inc and constructed a carbon dioxide liquefaction plant in the Grandview

Industrial Park in 1997 Over half of the carbon dioxide emissions generated from the

hydrogen plant are recovered and recycled as a food grade product

Instrumentation and Stack Monitoring

The refinery re-instrumentation carried out between 1991 and 1993 allowed for more

frequent and precise control of all refinery processes This improved control allows the

optimization of refinery processes which contributes markedly to energy efficiency and

emission reductions During re-instrumentation a second fiber optic communication

backbone was installed which provides a backup for the control system and allows the

refinery to continue safe operation in the event that a portion of the control system

becomes inoperable

Stack emissions are monitored for a number of parameters In some cases the monitors

provide direct measurements of contaminant concentrations such as the sulphur dioxide

continuous emission monitors on the sulphur plant stacks In other cases such as the

furnaces boilers and the FCCU process parameters including fuel flow oxygen and

temperature are continuously measured These measurements allow for optimal control of

the process as well as in combination with frequent fuel sulphur analysis for the

calculation of sulphur dioxide emissions

Continuous Emission Monitors (CEMs) for sulphur dioxide and nitrogen oxides are

operational on the Flue Gas Scrubber the Tail Gas Unit and the Sulphuric Acid

Regeneration Unit During the construction of the Grandview Cogeneration Project

CEMs for sulphur dioxide and nitrogen oxides were installed on both HRSGs

Operational Procedures

The refinery burns refinery fuel gas (sweet gas) to provide heat for the refining process

Of the existing total of 26 stacks all but the FCCU emit flue gases from the combustion

of refinery fuel gas

Adherence to the Sulphur Dioxide Response Plan also contributes to reducing emissions

and minimizing their impact The operating approval requires the refinery to implement

the plan when ambient sulphur dioxide concentrations are above 8 parts per hundred

million (pphm) which is approximately one half the maximum permissible 1-hour

ground level concentrations of sulphur dioxide at any one of five ambient monitors

In order to conserve energy process heaters and boilers are operated near stoichiometric

(ideal) conditions that is the minimum amount of air required is used to enable complete

combustion of the fuels This operating objective has the benefit of minimizing emissions

of all contaminants

Shutdown start-up and maintenance procedures are designed to minimize emissions

During planned shutdowns units are steamed out and the resulting hydrocarbon mixture

is burned in the flare(s) with clean fuels such as propane or LPG to minimize the

hydrocarbon emissions Wherever possible mechanical procedures are now employed to

remove coke build-up on boiler tubes as opposed to the previous practice of slowly

burning the coke out Further during maintenance of the sulphur plants or associated

units the refinery uses low sulphur crude to reduce the load on the operating sulphur

recovery plant

Product Quality

Product (fuel) quality affects emissions at the refinery level during product distribution

and in product usage Changes to fuel quality are frequently driven by environmental and

health concerns and often become requirements of national fuel regulations in Canada

and the United States

The Alkylation Unit (to reduce volatile organic compound (VOC) emissions) and

Dehexanizer (for US reformulated gasoline) are process units that were installed between

1987 and 1994 as a result of new Canadian and US federal gasoline regulations aimed at

reducing emissions from both gasoline storage and use

More recent federal environmental initiatives necessitated the upgrade to the Diesel

Hydrodesulphurizer and the Hydrocracker in 1995 which allowed production of low

sulphur diesel This became a requirement in 1998 as a result of the Diesel Fuel

Regulations (3) The Aromatics Saturation Unit was constructed in 1997-98 to reduce the

benzene content in gasoline as required by the Benzene in Gasoline Regulations (4) The

CD-Tech Unit installed in 2003 as part of the RFCCU provides enhanced capability to

ensure that the Sulphur in Gasoline Regulations (5) are met Irving Oil has also made

infrastructure improvements such as new pipelines in preparation for adherence with the

ultra-low sulphur diesel requirements mandated under the Sulphur in Diesel Fuel

Regulations (6) In 2006 the hydrocracker was converted into a diesel treater to help

meet these requirements

The Ultra-Low Sulphur Gasoline Regulations had required an average gasoline sulphur

content of 30 ppm or lower In January 2017 Federal Tier 3 gasoline regulations were

implemented requiring an annual average gasoline sulphur content of 10 ppm The

refinery operations determined that gas desulphurization combined product sulphur of 15

ppm would be required in order to meet the Tier 3 regulation under various operating

scenarios An additional hydrotreating step was installed to the existing Gasoline

Desulphurization Unit (GDS) which is a two-step hydrotreating unit in order to meet a

desired sulphur content of 15 ppm Combining the remaining gasoline blend components

with the hydrotreated stream allows the annual average combined sulphur in gasoline to

meet the 10 ppm regulation

Fugitive Emissions Programs

In 1993 the Irving Oil Refinery began an annual program aimed at reducing its

contribution to ground-level ozone in keeping with the Code of Practice for the

Measurement and Control of Fugitive VOC Emissions from Equipment Leaks October

1993 (7) established by the Canadian Council of Ministers of the Environment (CCME)

This program is comprised of the detection and repair of leaks (fugitive emissions) from

specific process components such as pump seals valves flanges vents connectors and

compressor seals The detection component of the program began in 1993 The program

was expanded to include the repair of leaking components in 1995 When a repair cannot

be made immediately it is scheduled for the next available maintenance turnaround

In addition all Irving Oil Refining GP storage tanks are required to be maintained in

accordance with the CCME Environmental Guidelines for Controlling Emissions of

Volatile Organic Compounds from Aboveground Storage Tanks June 1995 (8) and the

requirements of this guideline have been incorporated into an annual tank reliability

program carried out by the refinery

An odour study was completed throughout the previous Approval lifetime that identified

odour issues that were addressed through various action items and process improvements

POTENTIAL AIR QUALITY CONTAMINANTS

The refinery is situated in east Saint John and although it is in an industrial area there are

several residential areas within close proximity Emissions from the refinery come from

four main source areas

bull Sulphur Block (includes two Sulphur Recovery Units the Tail Gas Unit and the

Sulphuric Acid Regeneration Unit) where although 99 percent of the sulphur fed

to the units is recovered less than 1 percent is released to the atmosphere as

sulphur dioxide as well as small amounts of nitrogen oxides particulate matter

and carbon dioxide

bull Refinery Boilers and the No 3 Crude Unit fired heaters where refinery fuel gas

combustion results in the emission of sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and

hydrocarbons

bull FCCU catalyst regenerator where sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and hydrocarbons

are emitted

bull FGS where nitrogen oxides particulate matter carbon dioxide and small amounts

of sulphur dioxide and carbon monoxide are emitted

Fugitive emissions can also have an effect on local air quality

POTENTIAL IMPACTS OF AIR EMISSIONS

Acid Deposition

Emissions of sulphur dioxide and nitrogen oxides can be transformed in the atmosphere

to acidic particles which ultimately fallout as acid deposition (acid rain is one way in

which this deposition occurs) This deposition can occur far from the original source of

the emissions The majority of the acid deposition measured in New Brunswick is caused

by emission sources in the US mid-west and central Canada Generally speaking acid

deposition in New Brunswick has shown significant improvement through national and

international efforts to reduce acid causing emissions primarily through controlling

emissions of sulphur dioxide

The Department continues to report the acid disposition measurements in the Annual Air

Quality Report

Climate Change

When fossil fuels are burned it results in the generation of greenhouse gases (GHG) such

as carbon dioxide (CO2) and methane (CH4) which are the main contributors to the

problem of climate change The Department has been working on a Climate Change

Action Plan for several years and the Approval has a number of conditions related to

reporting and improvements in greenhouse gas emissions

Ground-Level Ozone

Ozone (O3) is a reactive unstable form of oxygen It is not emitted directly from stacks or

exhaust pipes but it is formed as a result of photochemical reactions between other

pollutants most importantly nitrogen oxides and volatile organic compounds (VOCs)

such as solvent and gasoline vapours Both stationary and mobile emissions sources

contribute precursor pollutants that have the potential to result in the formation of

ground-level ozone

It has been estimated that 85 percent of ground-level ozone enters this region from the

North Eastern United States Central Canada and the American Mid-West (9) Elevated

levels generally occur in the summer under very warm conditions when large stable air

masses move up the eastern seaboard into the Fundy region Although the contribution of

local sources may pose an added stress to already deteriorating air quality conditions

during such episodes in general local sources are relatively minor contributors to ground-

level ozone levels experienced in our region Control programs in New Brunswick

specifically for ground-level ozone are therefore not able to reduce ambient

concentrations appreciably Despite this all measures which can reduce the emission of

ozone precursors are promoted such as the refinerys Fugitive Emissions Program Of

particular interest are programs where multiple environmental benefits may be expected

For example improving energy efficiency will reduce greenhouse gas emissions as well

as nitrogen oxides and sulphur dioxide Therefore efficiency measures are favoured over

measures exclusively targeting ground-level ozone

AIR QUALITY COMPLIANCE AND ENFORCEMENT

Compliance and Enforcement options used by the Department of Environment are

outlined in the Departments Compliance and Enforcement Policy (10) These may

include but are not limited to schedules of compliance warnings orders and

prosecutions Although not specifically outlined in the Policy it is also possible to amend

approvals with more stringent conditions both during its valid period or at the time of

renewal to address specific compliance issues or to improve the environmental impact of

the facility Most recently a new Regulation under the Clean Air Act allows for the

issuance of administrative penalties for minor violations as an alternative to

traditionally-used enforcement options

All sources of air emissions in the province are required to comply with the Clean Air Act

and Air Quality Regulation In addition to establishing ambient standards for

contaminants in air Section 3 of the Air Quality Regulation requires that no person shall

construct modify or operate a source without applying for and obtaining an

approvalrdquo The refinery currently operates under Approval to Operate I-8902 issued

July 1 2015 The current Approval expires on June 30 2020

APPROVAL AMENDMENTS and PROJECTS

The Approval was amended twice during the lifetime of the Approval

On November 15th 2015 the Approval was amended to update the operation and

maintenance of the ambient monitoring program that had been upgraded as well as

adding general GHG conditions to the Approval to include reporting and submitting a

Greenhouse Gas Management Plan

On December 21 2016 the Approval was amended to update the definition of Facility to

add the Hydrogen Recovery Unit (Plant 426) This was not a new unit at the Facility

however it was previously owned and operated by Air Liquid Canada and was

acquisitioned by Irving Oil on December 31 2016

On April 4 2017 an Approval to Construct the Tier 3 Gasoline Project was issued This

modification did not increase or change emissions at the refinery or increase the capacity

Compliance with the Approval to Operate

Following are the key issues addressed in the Approval to Operate for Irving Oil Refining

GP including comments on compliance with the associated conditions and actions taken

to achieve compliance with these conditions A summary of the key conditions are in

italics

Emergency Response and Reporting

Conditions 27 amp 28

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

BACKGROUND

The Irving Oil Refinery built on a plot of farmland in 1959 in east Saint John officially

opened on July 20 1960 At the time the refinery was designed to process 38500 barrels

of crude oil per day (BPD) Two new process areas constructed in 1976 resulted in the

refinery becoming the largest in Canada with a nameplate capacity of 266000 BPD The

refinery has continued to improve unit and process efficiencies and currently has a

reference rate of 313000 barrels per day offering a secure and reliable energy supply to

customers across Eastern Canada and the Northeastern United States

In order to prepare for the requirement for cleaner burning fuels the availability of

natural gas as well as potential changes in the supply of crude oils Irving Oil Refining

GP (formerly Irving Oil Limited) registered the Refinery Upgrade Project (1) under the

Environmental Impact Assessment (EIA) Regulation in March of 1998 This project

which the Minister allowed to proceed under specific conditions (2) on August 13 1998

involved the construction of eight new units of which three were petroleum production

units and five were environmental control units These are discussed in the sections on

Process Description and Air Pollution Control By the end of 2001 all new units had

been commissioned

The Irving Oil Refining GP refinery produces a range of fuels for transportation (ultra-

low sulphur gasoline ultra-low sulphur diesel jet fuel) and combustion applications

(home heating oil kerosene Bunker C) Other fuels produced for use in more specialized

combustion and transportation applications include butane and propane The heaviest

components of crude oil are used in asphalt which is sold for paving

PROCESS DESCRIPTION

The refinery consists of units for distillation cracking reforming (molecular

rearrangement) product treating steam and hydrogen production sulphur recovery and

tanks for blending and product storage Below are brief descriptions of the process

operations

Distillation

The purpose of crude oil refining is to convert the diverse mixture of petroleum

hydrocarbons present in the crude oil into component streams having the best use and

marketability Crude oil contains a mixture of hydrocarbons of various chemical

compositions and boiling points as well as impurities such as brine and sulphur and

nitrogen compounds This mixture contains a range of petroleum hydrocarbons from the

lightest methane which is the primary constituent of natural gas to the heaviest residues

with high molecular weights that are used in paving asphalt Between these are a series

of hydrocarbons that are separated for use in gasoline jet fuel diesel fuel home heating

oil and heavy fuel oils

The first step in the refining process following removal of brine is to separate the

hydrocarbons present in the crude oil into distinct boiling ranges Some of the separated

products may be used directly in saleable products while others must be processed further

in order to make the most of their inherent value and to meet product specifications

The separation process known as distillation takes place in a distillation column as

shown in Figure 1 The crude oil is first heated to temperatures above 700 degF after which

it is fed to a distillation column containing a series of perforated trays Due to differences

in the boiling points of the hydrocarbons the crude oil vapours condense on the trays at

different levels within the distillation column The lower boiling point hydrocarbons

(heavier products) condense first and are withdrawn near the bottom of the column As

the crude oil vapours move up the column progressively lighter fractions condense and

are withdrawn Those fractions that do not condense are withdrawn as a gas at the top of

the column

The heavy ends those hydrocarbons that are too heavy to boil off in the first distillation

column collect in the bottom of the column and are withdrawn and sent to a second

distillation column which operates under a vacuum Under vacuum the hydrocarbons

boil at lower temperatures and gas oils which could not be vaporized in the first column

move up through the column and are separated out The heaviest (bottom) products are

used in asphalt The separated gas oils are further processed in the cracking units as

described under Cracking

Figure 1 Schematic of Crude Oil Distillation Column

The refinery operates two crude oil distillation units

bull Crude Unit No 3 (146000 BPD) constructed in 1976

bull Crude Unit No 4 (120000 BPD) constructed in 1999 and commissioned in

2000

Cracking

Following distillation the gas oils which represent approximately half of the crude are

broken into smaller molecules in processes referred to as cracking operations Cracking

employs a catalyst which is a material that is used to promote a reaction but which is not

consumed in the reaction The catalyst is used either to speed up the reaction or to allow

it to occur at a lower temperature which renders the process more energy efficient

Following are the three cracking units at the refinery

bull Residue Fluid Catalytic Cracking Unit (RFCCU) (85000 BPD) where residual

oil (high molecular weight residual oil) is cracked and can be separated into

fractions including fuel gas propane propylene butane butylene gasoline diesel

and decant oil

bull Fluid Catalytic Cracking Unit (FCCU) (25000 BPD) where vacuum gas oils

are cracked and separated into fractions that form gasoline diesel and liquefied

petroleum gas (LPG) and

bull Visbreaker (20000 BPD) where residue from the vacuum tower of the crude

units is cracked at high temperatures to make gasoline and diesel fuels

Molecular Rearrangement

Light molecules in the gasoline component streams can be rearranged to improve their

properties as gasoline blending components Reforming is normally carried out in the

presence of hydrogen and a catalyst at temperatures of up to 1000 o F

The refinery has five of these units which perform specific operations as follows

bull Butamer Unit (12000 BPD) where normal butane is converted to isobutene

bull Two Alkylation Units (8000 BPD and 10000 BPD) where iso-butane from other

units is combined with butylenenormal butane mixture to make alkylate a high

octane zero sulphur low vapour pressure gasoline blending component and

bull Rheniformer No 1 (11000 BPD) and Rheniformer No 2 (28000 BPD) where

gasoline blending stocks are reformed to yield a higher-octane fuel

Product Treating

Most refinery streams are treated to remove contaminants such as sulphur organic acids

metals and surfactants that might be detrimental to engines or the environment The

refinery has five units that are used to treat product streams to remove contaminants

bull Naphtha Hydrotreating Unit (NHT) (44000 BPD) where sulphur is completely

removed from the naphtha by reaction with hydrogen over a catalyst

bull Hydrocracker (45000 BPD) where heavy diesel and light cycle oil are

desulphurized in the presence of hydrogen and a catalyst resulting in the

production of ultra-low sulphur diesel products

bull Hydrodesulphurizer (HDS) (56000 BPD) where the sulphur in diesel blending

components is converted to hydrogen sulphide by reacting with hydrogen over a

catalyst

bull Merox Plants (44500 BPD) where mercaptans which are odorous compounds

are removed from gasoline and jet fuels and

bull CD-Tech Unit (58000 BPD) where sulphur compounds are removed from cat-

cracker gasoline in a two-stage process

Steam Production

Many of the process units contain heat exchangers to recapture waste heat from process

streams Steam produced in the refinery boilers and heat recovery steam generators

(HRSGs) is used to provide power in turbines and ejectors to heat processes and

materials and as part of the refining process

The refinery currently has four boilers (1 3 5 and 6) and two HRSGs which burn

refinery fuel gas The HRSGs operated as stand-alone units until late 2004 when

combustion turbines were commissioned as part of the Grandview Cogeneration Project

The combustion turbines generate up to 90 Megawatts (MW) of electricity that is sold to

NB Power a portion (approximately 65 MW) of which is re-sold to Irving Oil Refining

GP for use in the refinery The HRSGs now derive a significant portion of their heat

input from waste heat generated by the combustion turbines significantly increasing the

efficiency of steam generation

Hydrogen Production

Hydrogen required as a feedstock for the hydrocracker and the diesel and naphtha

hydrotreaters is produced by a Hydrogen Plant where natural gas is the primary feed but

naphtha or butane may also be used at high temperature and pressure and in the presence

of a catalyst is converted to hydrogen and carbon dioxide Hydrogen is also produced as

a by-product of the molecular rearrangement process

A Hydrogen Recovery Unit recovers hydrogen from various process streams within the

refinery

Storage Blending and Shipping

Approximately 15 to 20 different component streams are produced by the refinery These

products are stored in the tank field before being blended together in appropriate

proportions to make various grades of gasoline low-sulphur diesel jet fuel furnace oil

and asphalt The finished products are also stored in the refinery tank field prior to being

shipped to customers via road rail and ship The tank storage area contains 135 tanks

storing crude oil blending components and finished products There are also a total of 8

spheres and 10 bullets for storing butane and propane

AIR POLLUTION CONTROL

Owing to the complexity of the refinery air pollution control is achieved through a

variety of techniques including engineering design task and unit specific control

technologies operating strategies and procedures and programs having specific emission

reduction goals These are summarized in the following sub-sections

Fuel Combustion Controls

Generally speaking there is no air pollution control equipment on fuel combustion stacks

(although there are some exceptions) Control is typically exercised by maximizing heat

recovery at the process design stage through the choice of fuel and fuel sulphur levels and

through optimizing furnace operating conditions For example process heaters for Crude

Unit No 4 were designed to be more than 90 percent efficient in terms of energy usage

which is reported to be 20 percent more energy efficient than the furnaces associated with

Crude Unit No1 which they replaced

Sulphur Recovery

Refinery processing operations where possible are designed as closed cycle operations

This means that there are few emissions to the atmosphere There are several reasons for

this including safety environmental protection product recovery and economics The

lightest fractions produced by each processing unit are stripped of their saleable

components and the remaining gases called sour gas (because of the hydrogen sulphide it

contains) are sent to the Amine Sulphur Recovery Unit where the hydrogen sulphide is

removed The cleaned gas known as refinery fuel gas or sweet gas is used throughout

the refinery to provide product heating with minimal emissions

Recovered hydrogen sulphide gas is fed to the Sulphur Recovery UnitsHATGU where

the sulphur is recovered for sale to the fertilizer and pulp and paper industries Some

hydrogen sulphide gas is fed to the Sulphuric Acid Regeneration Unit where it is

converted to sulphuric acid and used in the alkylation process Approximately ninety nine

percent of the sulphur is recovered in this process with the rest being emitted through the

Sulphur Recovery Unit stacks as sulphur dioxide

Water is used in a variety of processes within the refinery to clean and cool product

streams Water that comes into direct contact with petroleum products becomes

contaminated and is likewise handled in a closed system The sour water that results from

these operations is cleaned of its impurities in the Sour Water Stripper where hydrogen

sulphide and ammonia are removed The recovered impurities are fed along with the

hydrogen sulphide from the Amine Recovery Unit to the Sulphur Recovery Units AND

hatgu

The refinery presently has

bull two Amine Sulphur Recovery Units (2450 mscfh recycle rate) and two Sour

Water Stripping Units (7600 BPD each) The second units in each case were

added during the upgrade to provide additional sulphur extraction capability as

well as redundancy for maintenance and other shutdown periods

bull a Tail Gas Unit to remove additional sulphur from the Sulphur Recovery Units

exhaust (tail) gas The original unit (Sulphuric Acid Tail Gas Unit) installed

during the upgrade did not operate as expected so the refinery was required to

propose a solution In 2008 a new unit was installed (the Hydrogenation Amine

Tail Gas Unit or HATGU) which is achieving the desired sulphur recovery

bull a Sulphuric Acid Regeneration Unit to regenerate spent sulphuric acid catalyst

from the Alkylation Plants and

bull two Sulphur Recovery Units (100 long tons per day each)

Flares

Process units are linked together in a system that allows for pressure relief of vessels

being shut down for maintenance or due to upset conditions such as a power interruption

The pressure is relieved by piping the excess product to one of three flares where the

hydrocarbons are combusted at a safe distance from people and equipment The flares are

equipped with smokeless technology and steam assisted air dispersion equipment The

flare system tips were upgraded in 2004 to reduce noise when additional steam is directed

to the flares In addition the No 1 flare was upgraded during the fall 2007 turnaround

and as a result of the newer technology employed noise levels have been reduced

FCCU Particulate Control

Particulate matter emissions from the FCCU are minimized by a series of cyclonic

separators Flue gases from the catalyst regenerator are passed through six sets of primary

and secondary cyclones where centrifugal forces cause the particulate matter to move to

the outside surface of the cyclones where they drop to the bottom and are removed Flue

gases from the secondary cyclones are sent to a third stage containing 80 high efficiency

cyclones and then to a fourth stage high-efficiency cyclone where the majority of the

remaining particulate is removed prior to it being released through the stack During the

2017 Turnaround the primary and secondary cyclones were replaced with an improved

design to improve steady state performance As the flue gas continues through each stage

the size and amount of the particles left in the stream decreases Recovered catalyst is

returned to the unit for re-use or recycled

FCCU Carbon Monoxide Control

As part of the 1976 refinery expansion a platinum combustion promoter was added to the

regenerator The promoter keeps the heat in the bottom of the regenerator where

combustion of carbon monoxide to carbon dioxide is completed without hazard and

reduces the concentration of the carbon monoxide emissions from approximately 10 to

001 percent

Particulate Matter and Sulphur Dioxide Control on RFCCU

A Flue Gas Scrubber (FGS) was installed as part of the Refinery Upgrade Project to

control emissions of particulate matter and sulphur dioxide from the RFCCU catalyst

regeneration process

Noise Control

Noise emissions from the refinery are controlled through the equipment selection

process a silencer to reduce noise on the FCCU was installed in 1995 in response to

concerns from neighbours around the refinery Noise mitigation is recognized as an

integral part of the design process and noise level specifications were included in the

upgrade project procurement process In the fall of 2007 the refinery conducted a noise

study as a requirement through their Approval to Operate Although the results of the

study showed noise to be within benchmark levels at their property line it did help

identify certain activities and units that contribute to slightly increased levels As a result

several process and mechanical changes were made (such as the installation of silencers)

to reduce intermittent noise levels

Hydrogen Plant Carbon Dioxide Control

Primary sources of carbon dioxide within the refinery are from fuel combustion and from

synthetic hydrogen production through steamnaphtha reforming In order to reduce the

refinerys emissions of carbon dioxide recycle a contaminant emission and produce a

saleable product Irving Oil Refining GP entered into a joint venture with Praxair

Canada Inc and constructed a carbon dioxide liquefaction plant in the Grandview

Industrial Park in 1997 Over half of the carbon dioxide emissions generated from the

hydrogen plant are recovered and recycled as a food grade product

Instrumentation and Stack Monitoring

The refinery re-instrumentation carried out between 1991 and 1993 allowed for more

frequent and precise control of all refinery processes This improved control allows the

optimization of refinery processes which contributes markedly to energy efficiency and

emission reductions During re-instrumentation a second fiber optic communication

backbone was installed which provides a backup for the control system and allows the

refinery to continue safe operation in the event that a portion of the control system

becomes inoperable

Stack emissions are monitored for a number of parameters In some cases the monitors

provide direct measurements of contaminant concentrations such as the sulphur dioxide

continuous emission monitors on the sulphur plant stacks In other cases such as the

furnaces boilers and the FCCU process parameters including fuel flow oxygen and

temperature are continuously measured These measurements allow for optimal control of

the process as well as in combination with frequent fuel sulphur analysis for the

calculation of sulphur dioxide emissions

Continuous Emission Monitors (CEMs) for sulphur dioxide and nitrogen oxides are

operational on the Flue Gas Scrubber the Tail Gas Unit and the Sulphuric Acid

Regeneration Unit During the construction of the Grandview Cogeneration Project

CEMs for sulphur dioxide and nitrogen oxides were installed on both HRSGs

Operational Procedures

The refinery burns refinery fuel gas (sweet gas) to provide heat for the refining process

Of the existing total of 26 stacks all but the FCCU emit flue gases from the combustion

of refinery fuel gas

Adherence to the Sulphur Dioxide Response Plan also contributes to reducing emissions

and minimizing their impact The operating approval requires the refinery to implement

the plan when ambient sulphur dioxide concentrations are above 8 parts per hundred

million (pphm) which is approximately one half the maximum permissible 1-hour

ground level concentrations of sulphur dioxide at any one of five ambient monitors

In order to conserve energy process heaters and boilers are operated near stoichiometric

(ideal) conditions that is the minimum amount of air required is used to enable complete

combustion of the fuels This operating objective has the benefit of minimizing emissions

of all contaminants

Shutdown start-up and maintenance procedures are designed to minimize emissions

During planned shutdowns units are steamed out and the resulting hydrocarbon mixture

is burned in the flare(s) with clean fuels such as propane or LPG to minimize the

hydrocarbon emissions Wherever possible mechanical procedures are now employed to

remove coke build-up on boiler tubes as opposed to the previous practice of slowly

burning the coke out Further during maintenance of the sulphur plants or associated

units the refinery uses low sulphur crude to reduce the load on the operating sulphur

recovery plant

Product Quality

Product (fuel) quality affects emissions at the refinery level during product distribution

and in product usage Changes to fuel quality are frequently driven by environmental and

health concerns and often become requirements of national fuel regulations in Canada

and the United States

The Alkylation Unit (to reduce volatile organic compound (VOC) emissions) and

Dehexanizer (for US reformulated gasoline) are process units that were installed between

1987 and 1994 as a result of new Canadian and US federal gasoline regulations aimed at

reducing emissions from both gasoline storage and use

More recent federal environmental initiatives necessitated the upgrade to the Diesel

Hydrodesulphurizer and the Hydrocracker in 1995 which allowed production of low

sulphur diesel This became a requirement in 1998 as a result of the Diesel Fuel

Regulations (3) The Aromatics Saturation Unit was constructed in 1997-98 to reduce the

benzene content in gasoline as required by the Benzene in Gasoline Regulations (4) The

CD-Tech Unit installed in 2003 as part of the RFCCU provides enhanced capability to

ensure that the Sulphur in Gasoline Regulations (5) are met Irving Oil has also made

infrastructure improvements such as new pipelines in preparation for adherence with the

ultra-low sulphur diesel requirements mandated under the Sulphur in Diesel Fuel

Regulations (6) In 2006 the hydrocracker was converted into a diesel treater to help

meet these requirements

The Ultra-Low Sulphur Gasoline Regulations had required an average gasoline sulphur

content of 30 ppm or lower In January 2017 Federal Tier 3 gasoline regulations were

implemented requiring an annual average gasoline sulphur content of 10 ppm The

refinery operations determined that gas desulphurization combined product sulphur of 15

ppm would be required in order to meet the Tier 3 regulation under various operating

scenarios An additional hydrotreating step was installed to the existing Gasoline

Desulphurization Unit (GDS) which is a two-step hydrotreating unit in order to meet a

desired sulphur content of 15 ppm Combining the remaining gasoline blend components

with the hydrotreated stream allows the annual average combined sulphur in gasoline to

meet the 10 ppm regulation

Fugitive Emissions Programs

In 1993 the Irving Oil Refinery began an annual program aimed at reducing its

contribution to ground-level ozone in keeping with the Code of Practice for the

Measurement and Control of Fugitive VOC Emissions from Equipment Leaks October

1993 (7) established by the Canadian Council of Ministers of the Environment (CCME)

This program is comprised of the detection and repair of leaks (fugitive emissions) from

specific process components such as pump seals valves flanges vents connectors and

compressor seals The detection component of the program began in 1993 The program

was expanded to include the repair of leaking components in 1995 When a repair cannot

be made immediately it is scheduled for the next available maintenance turnaround

In addition all Irving Oil Refining GP storage tanks are required to be maintained in

accordance with the CCME Environmental Guidelines for Controlling Emissions of

Volatile Organic Compounds from Aboveground Storage Tanks June 1995 (8) and the

requirements of this guideline have been incorporated into an annual tank reliability

program carried out by the refinery

An odour study was completed throughout the previous Approval lifetime that identified

odour issues that were addressed through various action items and process improvements

POTENTIAL AIR QUALITY CONTAMINANTS

The refinery is situated in east Saint John and although it is in an industrial area there are

several residential areas within close proximity Emissions from the refinery come from

four main source areas

bull Sulphur Block (includes two Sulphur Recovery Units the Tail Gas Unit and the

Sulphuric Acid Regeneration Unit) where although 99 percent of the sulphur fed

to the units is recovered less than 1 percent is released to the atmosphere as

sulphur dioxide as well as small amounts of nitrogen oxides particulate matter

and carbon dioxide

bull Refinery Boilers and the No 3 Crude Unit fired heaters where refinery fuel gas

combustion results in the emission of sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and

hydrocarbons

bull FCCU catalyst regenerator where sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and hydrocarbons

are emitted

bull FGS where nitrogen oxides particulate matter carbon dioxide and small amounts

of sulphur dioxide and carbon monoxide are emitted

Fugitive emissions can also have an effect on local air quality

POTENTIAL IMPACTS OF AIR EMISSIONS

Acid Deposition

Emissions of sulphur dioxide and nitrogen oxides can be transformed in the atmosphere

to acidic particles which ultimately fallout as acid deposition (acid rain is one way in

which this deposition occurs) This deposition can occur far from the original source of

the emissions The majority of the acid deposition measured in New Brunswick is caused

by emission sources in the US mid-west and central Canada Generally speaking acid

deposition in New Brunswick has shown significant improvement through national and

international efforts to reduce acid causing emissions primarily through controlling

emissions of sulphur dioxide

The Department continues to report the acid disposition measurements in the Annual Air

Quality Report

Climate Change

When fossil fuels are burned it results in the generation of greenhouse gases (GHG) such

as carbon dioxide (CO2) and methane (CH4) which are the main contributors to the

problem of climate change The Department has been working on a Climate Change

Action Plan for several years and the Approval has a number of conditions related to

reporting and improvements in greenhouse gas emissions

Ground-Level Ozone

Ozone (O3) is a reactive unstable form of oxygen It is not emitted directly from stacks or

exhaust pipes but it is formed as a result of photochemical reactions between other

pollutants most importantly nitrogen oxides and volatile organic compounds (VOCs)

such as solvent and gasoline vapours Both stationary and mobile emissions sources

contribute precursor pollutants that have the potential to result in the formation of

ground-level ozone

It has been estimated that 85 percent of ground-level ozone enters this region from the

North Eastern United States Central Canada and the American Mid-West (9) Elevated

levels generally occur in the summer under very warm conditions when large stable air

masses move up the eastern seaboard into the Fundy region Although the contribution of

local sources may pose an added stress to already deteriorating air quality conditions

during such episodes in general local sources are relatively minor contributors to ground-

level ozone levels experienced in our region Control programs in New Brunswick

specifically for ground-level ozone are therefore not able to reduce ambient

concentrations appreciably Despite this all measures which can reduce the emission of

ozone precursors are promoted such as the refinerys Fugitive Emissions Program Of

particular interest are programs where multiple environmental benefits may be expected

For example improving energy efficiency will reduce greenhouse gas emissions as well

as nitrogen oxides and sulphur dioxide Therefore efficiency measures are favoured over

measures exclusively targeting ground-level ozone

AIR QUALITY COMPLIANCE AND ENFORCEMENT

Compliance and Enforcement options used by the Department of Environment are

outlined in the Departments Compliance and Enforcement Policy (10) These may

include but are not limited to schedules of compliance warnings orders and

prosecutions Although not specifically outlined in the Policy it is also possible to amend

approvals with more stringent conditions both during its valid period or at the time of

renewal to address specific compliance issues or to improve the environmental impact of

the facility Most recently a new Regulation under the Clean Air Act allows for the

issuance of administrative penalties for minor violations as an alternative to

traditionally-used enforcement options

All sources of air emissions in the province are required to comply with the Clean Air Act

and Air Quality Regulation In addition to establishing ambient standards for

contaminants in air Section 3 of the Air Quality Regulation requires that no person shall

construct modify or operate a source without applying for and obtaining an

approvalrdquo The refinery currently operates under Approval to Operate I-8902 issued

July 1 2015 The current Approval expires on June 30 2020

APPROVAL AMENDMENTS and PROJECTS

The Approval was amended twice during the lifetime of the Approval

On November 15th 2015 the Approval was amended to update the operation and

maintenance of the ambient monitoring program that had been upgraded as well as

adding general GHG conditions to the Approval to include reporting and submitting a

Greenhouse Gas Management Plan

On December 21 2016 the Approval was amended to update the definition of Facility to

add the Hydrogen Recovery Unit (Plant 426) This was not a new unit at the Facility

however it was previously owned and operated by Air Liquid Canada and was

acquisitioned by Irving Oil on December 31 2016

On April 4 2017 an Approval to Construct the Tier 3 Gasoline Project was issued This

modification did not increase or change emissions at the refinery or increase the capacity

Compliance with the Approval to Operate

Following are the key issues addressed in the Approval to Operate for Irving Oil Refining

GP including comments on compliance with the associated conditions and actions taken

to achieve compliance with these conditions A summary of the key conditions are in

italics

Emergency Response and Reporting

Conditions 27 amp 28

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

hydrocarbons present in the crude oil into distinct boiling ranges Some of the separated

products may be used directly in saleable products while others must be processed further

in order to make the most of their inherent value and to meet product specifications

The separation process known as distillation takes place in a distillation column as

shown in Figure 1 The crude oil is first heated to temperatures above 700 degF after which

it is fed to a distillation column containing a series of perforated trays Due to differences

in the boiling points of the hydrocarbons the crude oil vapours condense on the trays at

different levels within the distillation column The lower boiling point hydrocarbons

(heavier products) condense first and are withdrawn near the bottom of the column As

the crude oil vapours move up the column progressively lighter fractions condense and

are withdrawn Those fractions that do not condense are withdrawn as a gas at the top of

the column

The heavy ends those hydrocarbons that are too heavy to boil off in the first distillation

column collect in the bottom of the column and are withdrawn and sent to a second

distillation column which operates under a vacuum Under vacuum the hydrocarbons

boil at lower temperatures and gas oils which could not be vaporized in the first column

move up through the column and are separated out The heaviest (bottom) products are

used in asphalt The separated gas oils are further processed in the cracking units as

described under Cracking

Figure 1 Schematic of Crude Oil Distillation Column

The refinery operates two crude oil distillation units

bull Crude Unit No 3 (146000 BPD) constructed in 1976

bull Crude Unit No 4 (120000 BPD) constructed in 1999 and commissioned in

2000

Cracking

Following distillation the gas oils which represent approximately half of the crude are

broken into smaller molecules in processes referred to as cracking operations Cracking

employs a catalyst which is a material that is used to promote a reaction but which is not

consumed in the reaction The catalyst is used either to speed up the reaction or to allow

it to occur at a lower temperature which renders the process more energy efficient

Following are the three cracking units at the refinery

bull Residue Fluid Catalytic Cracking Unit (RFCCU) (85000 BPD) where residual

oil (high molecular weight residual oil) is cracked and can be separated into

fractions including fuel gas propane propylene butane butylene gasoline diesel

and decant oil

bull Fluid Catalytic Cracking Unit (FCCU) (25000 BPD) where vacuum gas oils

are cracked and separated into fractions that form gasoline diesel and liquefied

petroleum gas (LPG) and

bull Visbreaker (20000 BPD) where residue from the vacuum tower of the crude

units is cracked at high temperatures to make gasoline and diesel fuels

Molecular Rearrangement

Light molecules in the gasoline component streams can be rearranged to improve their

properties as gasoline blending components Reforming is normally carried out in the

presence of hydrogen and a catalyst at temperatures of up to 1000 o F

The refinery has five of these units which perform specific operations as follows

bull Butamer Unit (12000 BPD) where normal butane is converted to isobutene

bull Two Alkylation Units (8000 BPD and 10000 BPD) where iso-butane from other

units is combined with butylenenormal butane mixture to make alkylate a high

octane zero sulphur low vapour pressure gasoline blending component and

bull Rheniformer No 1 (11000 BPD) and Rheniformer No 2 (28000 BPD) where

gasoline blending stocks are reformed to yield a higher-octane fuel

Product Treating

Most refinery streams are treated to remove contaminants such as sulphur organic acids

metals and surfactants that might be detrimental to engines or the environment The

refinery has five units that are used to treat product streams to remove contaminants

bull Naphtha Hydrotreating Unit (NHT) (44000 BPD) where sulphur is completely

removed from the naphtha by reaction with hydrogen over a catalyst

bull Hydrocracker (45000 BPD) where heavy diesel and light cycle oil are

desulphurized in the presence of hydrogen and a catalyst resulting in the

production of ultra-low sulphur diesel products

bull Hydrodesulphurizer (HDS) (56000 BPD) where the sulphur in diesel blending

components is converted to hydrogen sulphide by reacting with hydrogen over a

catalyst

bull Merox Plants (44500 BPD) where mercaptans which are odorous compounds

are removed from gasoline and jet fuels and

bull CD-Tech Unit (58000 BPD) where sulphur compounds are removed from cat-

cracker gasoline in a two-stage process

Steam Production

Many of the process units contain heat exchangers to recapture waste heat from process

streams Steam produced in the refinery boilers and heat recovery steam generators

(HRSGs) is used to provide power in turbines and ejectors to heat processes and

materials and as part of the refining process

The refinery currently has four boilers (1 3 5 and 6) and two HRSGs which burn

refinery fuel gas The HRSGs operated as stand-alone units until late 2004 when

combustion turbines were commissioned as part of the Grandview Cogeneration Project

The combustion turbines generate up to 90 Megawatts (MW) of electricity that is sold to

NB Power a portion (approximately 65 MW) of which is re-sold to Irving Oil Refining

GP for use in the refinery The HRSGs now derive a significant portion of their heat

input from waste heat generated by the combustion turbines significantly increasing the

efficiency of steam generation

Hydrogen Production

Hydrogen required as a feedstock for the hydrocracker and the diesel and naphtha

hydrotreaters is produced by a Hydrogen Plant where natural gas is the primary feed but

naphtha or butane may also be used at high temperature and pressure and in the presence

of a catalyst is converted to hydrogen and carbon dioxide Hydrogen is also produced as

a by-product of the molecular rearrangement process

A Hydrogen Recovery Unit recovers hydrogen from various process streams within the

refinery

Storage Blending and Shipping

Approximately 15 to 20 different component streams are produced by the refinery These

products are stored in the tank field before being blended together in appropriate

proportions to make various grades of gasoline low-sulphur diesel jet fuel furnace oil

and asphalt The finished products are also stored in the refinery tank field prior to being

shipped to customers via road rail and ship The tank storage area contains 135 tanks

storing crude oil blending components and finished products There are also a total of 8

spheres and 10 bullets for storing butane and propane

AIR POLLUTION CONTROL

Owing to the complexity of the refinery air pollution control is achieved through a

variety of techniques including engineering design task and unit specific control

technologies operating strategies and procedures and programs having specific emission

reduction goals These are summarized in the following sub-sections

Fuel Combustion Controls

Generally speaking there is no air pollution control equipment on fuel combustion stacks

(although there are some exceptions) Control is typically exercised by maximizing heat

recovery at the process design stage through the choice of fuel and fuel sulphur levels and

through optimizing furnace operating conditions For example process heaters for Crude

Unit No 4 were designed to be more than 90 percent efficient in terms of energy usage

which is reported to be 20 percent more energy efficient than the furnaces associated with

Crude Unit No1 which they replaced

Sulphur Recovery

Refinery processing operations where possible are designed as closed cycle operations

This means that there are few emissions to the atmosphere There are several reasons for

this including safety environmental protection product recovery and economics The

lightest fractions produced by each processing unit are stripped of their saleable

components and the remaining gases called sour gas (because of the hydrogen sulphide it

contains) are sent to the Amine Sulphur Recovery Unit where the hydrogen sulphide is

removed The cleaned gas known as refinery fuel gas or sweet gas is used throughout

the refinery to provide product heating with minimal emissions

Recovered hydrogen sulphide gas is fed to the Sulphur Recovery UnitsHATGU where

the sulphur is recovered for sale to the fertilizer and pulp and paper industries Some

hydrogen sulphide gas is fed to the Sulphuric Acid Regeneration Unit where it is

converted to sulphuric acid and used in the alkylation process Approximately ninety nine

percent of the sulphur is recovered in this process with the rest being emitted through the

Sulphur Recovery Unit stacks as sulphur dioxide

Water is used in a variety of processes within the refinery to clean and cool product

streams Water that comes into direct contact with petroleum products becomes

contaminated and is likewise handled in a closed system The sour water that results from

these operations is cleaned of its impurities in the Sour Water Stripper where hydrogen

sulphide and ammonia are removed The recovered impurities are fed along with the

hydrogen sulphide from the Amine Recovery Unit to the Sulphur Recovery Units AND

hatgu

The refinery presently has

bull two Amine Sulphur Recovery Units (2450 mscfh recycle rate) and two Sour

Water Stripping Units (7600 BPD each) The second units in each case were

added during the upgrade to provide additional sulphur extraction capability as

well as redundancy for maintenance and other shutdown periods

bull a Tail Gas Unit to remove additional sulphur from the Sulphur Recovery Units

exhaust (tail) gas The original unit (Sulphuric Acid Tail Gas Unit) installed

during the upgrade did not operate as expected so the refinery was required to

propose a solution In 2008 a new unit was installed (the Hydrogenation Amine

Tail Gas Unit or HATGU) which is achieving the desired sulphur recovery

bull a Sulphuric Acid Regeneration Unit to regenerate spent sulphuric acid catalyst

from the Alkylation Plants and

bull two Sulphur Recovery Units (100 long tons per day each)

Flares

Process units are linked together in a system that allows for pressure relief of vessels

being shut down for maintenance or due to upset conditions such as a power interruption

The pressure is relieved by piping the excess product to one of three flares where the

hydrocarbons are combusted at a safe distance from people and equipment The flares are

equipped with smokeless technology and steam assisted air dispersion equipment The

flare system tips were upgraded in 2004 to reduce noise when additional steam is directed

to the flares In addition the No 1 flare was upgraded during the fall 2007 turnaround

and as a result of the newer technology employed noise levels have been reduced

FCCU Particulate Control

Particulate matter emissions from the FCCU are minimized by a series of cyclonic

separators Flue gases from the catalyst regenerator are passed through six sets of primary

and secondary cyclones where centrifugal forces cause the particulate matter to move to

the outside surface of the cyclones where they drop to the bottom and are removed Flue

gases from the secondary cyclones are sent to a third stage containing 80 high efficiency

cyclones and then to a fourth stage high-efficiency cyclone where the majority of the

remaining particulate is removed prior to it being released through the stack During the

2017 Turnaround the primary and secondary cyclones were replaced with an improved

design to improve steady state performance As the flue gas continues through each stage

the size and amount of the particles left in the stream decreases Recovered catalyst is

returned to the unit for re-use or recycled

FCCU Carbon Monoxide Control

As part of the 1976 refinery expansion a platinum combustion promoter was added to the

regenerator The promoter keeps the heat in the bottom of the regenerator where

combustion of carbon monoxide to carbon dioxide is completed without hazard and

reduces the concentration of the carbon monoxide emissions from approximately 10 to

001 percent

Particulate Matter and Sulphur Dioxide Control on RFCCU

A Flue Gas Scrubber (FGS) was installed as part of the Refinery Upgrade Project to

control emissions of particulate matter and sulphur dioxide from the RFCCU catalyst

regeneration process

Noise Control

Noise emissions from the refinery are controlled through the equipment selection

process a silencer to reduce noise on the FCCU was installed in 1995 in response to

concerns from neighbours around the refinery Noise mitigation is recognized as an

integral part of the design process and noise level specifications were included in the

upgrade project procurement process In the fall of 2007 the refinery conducted a noise

study as a requirement through their Approval to Operate Although the results of the

study showed noise to be within benchmark levels at their property line it did help

identify certain activities and units that contribute to slightly increased levels As a result

several process and mechanical changes were made (such as the installation of silencers)

to reduce intermittent noise levels

Hydrogen Plant Carbon Dioxide Control

Primary sources of carbon dioxide within the refinery are from fuel combustion and from

synthetic hydrogen production through steamnaphtha reforming In order to reduce the

refinerys emissions of carbon dioxide recycle a contaminant emission and produce a

saleable product Irving Oil Refining GP entered into a joint venture with Praxair

Canada Inc and constructed a carbon dioxide liquefaction plant in the Grandview

Industrial Park in 1997 Over half of the carbon dioxide emissions generated from the

hydrogen plant are recovered and recycled as a food grade product

Instrumentation and Stack Monitoring

The refinery re-instrumentation carried out between 1991 and 1993 allowed for more

frequent and precise control of all refinery processes This improved control allows the

optimization of refinery processes which contributes markedly to energy efficiency and

emission reductions During re-instrumentation a second fiber optic communication

backbone was installed which provides a backup for the control system and allows the

refinery to continue safe operation in the event that a portion of the control system

becomes inoperable

Stack emissions are monitored for a number of parameters In some cases the monitors

provide direct measurements of contaminant concentrations such as the sulphur dioxide

continuous emission monitors on the sulphur plant stacks In other cases such as the

furnaces boilers and the FCCU process parameters including fuel flow oxygen and

temperature are continuously measured These measurements allow for optimal control of

the process as well as in combination with frequent fuel sulphur analysis for the

calculation of sulphur dioxide emissions

Continuous Emission Monitors (CEMs) for sulphur dioxide and nitrogen oxides are

operational on the Flue Gas Scrubber the Tail Gas Unit and the Sulphuric Acid

Regeneration Unit During the construction of the Grandview Cogeneration Project

CEMs for sulphur dioxide and nitrogen oxides were installed on both HRSGs

Operational Procedures

The refinery burns refinery fuel gas (sweet gas) to provide heat for the refining process

Of the existing total of 26 stacks all but the FCCU emit flue gases from the combustion

of refinery fuel gas

Adherence to the Sulphur Dioxide Response Plan also contributes to reducing emissions

and minimizing their impact The operating approval requires the refinery to implement

the plan when ambient sulphur dioxide concentrations are above 8 parts per hundred

million (pphm) which is approximately one half the maximum permissible 1-hour

ground level concentrations of sulphur dioxide at any one of five ambient monitors

In order to conserve energy process heaters and boilers are operated near stoichiometric

(ideal) conditions that is the minimum amount of air required is used to enable complete

combustion of the fuels This operating objective has the benefit of minimizing emissions

of all contaminants

Shutdown start-up and maintenance procedures are designed to minimize emissions

During planned shutdowns units are steamed out and the resulting hydrocarbon mixture

is burned in the flare(s) with clean fuels such as propane or LPG to minimize the

hydrocarbon emissions Wherever possible mechanical procedures are now employed to

remove coke build-up on boiler tubes as opposed to the previous practice of slowly

burning the coke out Further during maintenance of the sulphur plants or associated

units the refinery uses low sulphur crude to reduce the load on the operating sulphur

recovery plant

Product Quality

Product (fuel) quality affects emissions at the refinery level during product distribution

and in product usage Changes to fuel quality are frequently driven by environmental and

health concerns and often become requirements of national fuel regulations in Canada

and the United States

The Alkylation Unit (to reduce volatile organic compound (VOC) emissions) and

Dehexanizer (for US reformulated gasoline) are process units that were installed between

1987 and 1994 as a result of new Canadian and US federal gasoline regulations aimed at

reducing emissions from both gasoline storage and use

More recent federal environmental initiatives necessitated the upgrade to the Diesel

Hydrodesulphurizer and the Hydrocracker in 1995 which allowed production of low

sulphur diesel This became a requirement in 1998 as a result of the Diesel Fuel

Regulations (3) The Aromatics Saturation Unit was constructed in 1997-98 to reduce the

benzene content in gasoline as required by the Benzene in Gasoline Regulations (4) The

CD-Tech Unit installed in 2003 as part of the RFCCU provides enhanced capability to

ensure that the Sulphur in Gasoline Regulations (5) are met Irving Oil has also made

infrastructure improvements such as new pipelines in preparation for adherence with the

ultra-low sulphur diesel requirements mandated under the Sulphur in Diesel Fuel

Regulations (6) In 2006 the hydrocracker was converted into a diesel treater to help

meet these requirements

The Ultra-Low Sulphur Gasoline Regulations had required an average gasoline sulphur

content of 30 ppm or lower In January 2017 Federal Tier 3 gasoline regulations were

implemented requiring an annual average gasoline sulphur content of 10 ppm The

refinery operations determined that gas desulphurization combined product sulphur of 15

ppm would be required in order to meet the Tier 3 regulation under various operating

scenarios An additional hydrotreating step was installed to the existing Gasoline

Desulphurization Unit (GDS) which is a two-step hydrotreating unit in order to meet a

desired sulphur content of 15 ppm Combining the remaining gasoline blend components

with the hydrotreated stream allows the annual average combined sulphur in gasoline to

meet the 10 ppm regulation

Fugitive Emissions Programs

In 1993 the Irving Oil Refinery began an annual program aimed at reducing its

contribution to ground-level ozone in keeping with the Code of Practice for the

Measurement and Control of Fugitive VOC Emissions from Equipment Leaks October

1993 (7) established by the Canadian Council of Ministers of the Environment (CCME)

This program is comprised of the detection and repair of leaks (fugitive emissions) from

specific process components such as pump seals valves flanges vents connectors and

compressor seals The detection component of the program began in 1993 The program

was expanded to include the repair of leaking components in 1995 When a repair cannot

be made immediately it is scheduled for the next available maintenance turnaround

In addition all Irving Oil Refining GP storage tanks are required to be maintained in

accordance with the CCME Environmental Guidelines for Controlling Emissions of

Volatile Organic Compounds from Aboveground Storage Tanks June 1995 (8) and the

requirements of this guideline have been incorporated into an annual tank reliability

program carried out by the refinery

An odour study was completed throughout the previous Approval lifetime that identified

odour issues that were addressed through various action items and process improvements

POTENTIAL AIR QUALITY CONTAMINANTS

The refinery is situated in east Saint John and although it is in an industrial area there are

several residential areas within close proximity Emissions from the refinery come from

four main source areas

bull Sulphur Block (includes two Sulphur Recovery Units the Tail Gas Unit and the

Sulphuric Acid Regeneration Unit) where although 99 percent of the sulphur fed

to the units is recovered less than 1 percent is released to the atmosphere as

sulphur dioxide as well as small amounts of nitrogen oxides particulate matter

and carbon dioxide

bull Refinery Boilers and the No 3 Crude Unit fired heaters where refinery fuel gas

combustion results in the emission of sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and

hydrocarbons

bull FCCU catalyst regenerator where sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and hydrocarbons

are emitted

bull FGS where nitrogen oxides particulate matter carbon dioxide and small amounts

of sulphur dioxide and carbon monoxide are emitted

Fugitive emissions can also have an effect on local air quality

POTENTIAL IMPACTS OF AIR EMISSIONS

Acid Deposition

Emissions of sulphur dioxide and nitrogen oxides can be transformed in the atmosphere

to acidic particles which ultimately fallout as acid deposition (acid rain is one way in

which this deposition occurs) This deposition can occur far from the original source of

the emissions The majority of the acid deposition measured in New Brunswick is caused

by emission sources in the US mid-west and central Canada Generally speaking acid

deposition in New Brunswick has shown significant improvement through national and

international efforts to reduce acid causing emissions primarily through controlling

emissions of sulphur dioxide

The Department continues to report the acid disposition measurements in the Annual Air

Quality Report

Climate Change

When fossil fuels are burned it results in the generation of greenhouse gases (GHG) such

as carbon dioxide (CO2) and methane (CH4) which are the main contributors to the

problem of climate change The Department has been working on a Climate Change

Action Plan for several years and the Approval has a number of conditions related to

reporting and improvements in greenhouse gas emissions

Ground-Level Ozone

Ozone (O3) is a reactive unstable form of oxygen It is not emitted directly from stacks or

exhaust pipes but it is formed as a result of photochemical reactions between other

pollutants most importantly nitrogen oxides and volatile organic compounds (VOCs)

such as solvent and gasoline vapours Both stationary and mobile emissions sources

contribute precursor pollutants that have the potential to result in the formation of

ground-level ozone

It has been estimated that 85 percent of ground-level ozone enters this region from the

North Eastern United States Central Canada and the American Mid-West (9) Elevated

levels generally occur in the summer under very warm conditions when large stable air

masses move up the eastern seaboard into the Fundy region Although the contribution of

local sources may pose an added stress to already deteriorating air quality conditions

during such episodes in general local sources are relatively minor contributors to ground-

level ozone levels experienced in our region Control programs in New Brunswick

specifically for ground-level ozone are therefore not able to reduce ambient

concentrations appreciably Despite this all measures which can reduce the emission of

ozone precursors are promoted such as the refinerys Fugitive Emissions Program Of

particular interest are programs where multiple environmental benefits may be expected

For example improving energy efficiency will reduce greenhouse gas emissions as well

as nitrogen oxides and sulphur dioxide Therefore efficiency measures are favoured over

measures exclusively targeting ground-level ozone

AIR QUALITY COMPLIANCE AND ENFORCEMENT

Compliance and Enforcement options used by the Department of Environment are

outlined in the Departments Compliance and Enforcement Policy (10) These may

include but are not limited to schedules of compliance warnings orders and

prosecutions Although not specifically outlined in the Policy it is also possible to amend

approvals with more stringent conditions both during its valid period or at the time of

renewal to address specific compliance issues or to improve the environmental impact of

the facility Most recently a new Regulation under the Clean Air Act allows for the

issuance of administrative penalties for minor violations as an alternative to

traditionally-used enforcement options

All sources of air emissions in the province are required to comply with the Clean Air Act

and Air Quality Regulation In addition to establishing ambient standards for

contaminants in air Section 3 of the Air Quality Regulation requires that no person shall

construct modify or operate a source without applying for and obtaining an

approvalrdquo The refinery currently operates under Approval to Operate I-8902 issued

July 1 2015 The current Approval expires on June 30 2020

APPROVAL AMENDMENTS and PROJECTS

The Approval was amended twice during the lifetime of the Approval

On November 15th 2015 the Approval was amended to update the operation and

maintenance of the ambient monitoring program that had been upgraded as well as

adding general GHG conditions to the Approval to include reporting and submitting a

Greenhouse Gas Management Plan

On December 21 2016 the Approval was amended to update the definition of Facility to

add the Hydrogen Recovery Unit (Plant 426) This was not a new unit at the Facility

however it was previously owned and operated by Air Liquid Canada and was

acquisitioned by Irving Oil on December 31 2016

On April 4 2017 an Approval to Construct the Tier 3 Gasoline Project was issued This

modification did not increase or change emissions at the refinery or increase the capacity

Compliance with the Approval to Operate

Following are the key issues addressed in the Approval to Operate for Irving Oil Refining

GP including comments on compliance with the associated conditions and actions taken

to achieve compliance with these conditions A summary of the key conditions are in

italics

Emergency Response and Reporting

Conditions 27 amp 28

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

The refinery operates two crude oil distillation units

bull Crude Unit No 3 (146000 BPD) constructed in 1976

bull Crude Unit No 4 (120000 BPD) constructed in 1999 and commissioned in

2000

Cracking

Following distillation the gas oils which represent approximately half of the crude are

broken into smaller molecules in processes referred to as cracking operations Cracking

employs a catalyst which is a material that is used to promote a reaction but which is not

consumed in the reaction The catalyst is used either to speed up the reaction or to allow

it to occur at a lower temperature which renders the process more energy efficient

Following are the three cracking units at the refinery

bull Residue Fluid Catalytic Cracking Unit (RFCCU) (85000 BPD) where residual

oil (high molecular weight residual oil) is cracked and can be separated into

fractions including fuel gas propane propylene butane butylene gasoline diesel

and decant oil

bull Fluid Catalytic Cracking Unit (FCCU) (25000 BPD) where vacuum gas oils

are cracked and separated into fractions that form gasoline diesel and liquefied

petroleum gas (LPG) and

bull Visbreaker (20000 BPD) where residue from the vacuum tower of the crude

units is cracked at high temperatures to make gasoline and diesel fuels

Molecular Rearrangement

Light molecules in the gasoline component streams can be rearranged to improve their

properties as gasoline blending components Reforming is normally carried out in the

presence of hydrogen and a catalyst at temperatures of up to 1000 o F

The refinery has five of these units which perform specific operations as follows

bull Butamer Unit (12000 BPD) where normal butane is converted to isobutene

bull Two Alkylation Units (8000 BPD and 10000 BPD) where iso-butane from other

units is combined with butylenenormal butane mixture to make alkylate a high

octane zero sulphur low vapour pressure gasoline blending component and

bull Rheniformer No 1 (11000 BPD) and Rheniformer No 2 (28000 BPD) where

gasoline blending stocks are reformed to yield a higher-octane fuel

Product Treating

Most refinery streams are treated to remove contaminants such as sulphur organic acids

metals and surfactants that might be detrimental to engines or the environment The

refinery has five units that are used to treat product streams to remove contaminants

bull Naphtha Hydrotreating Unit (NHT) (44000 BPD) where sulphur is completely

removed from the naphtha by reaction with hydrogen over a catalyst

bull Hydrocracker (45000 BPD) where heavy diesel and light cycle oil are

desulphurized in the presence of hydrogen and a catalyst resulting in the

production of ultra-low sulphur diesel products

bull Hydrodesulphurizer (HDS) (56000 BPD) where the sulphur in diesel blending

components is converted to hydrogen sulphide by reacting with hydrogen over a

catalyst

bull Merox Plants (44500 BPD) where mercaptans which are odorous compounds

are removed from gasoline and jet fuels and

bull CD-Tech Unit (58000 BPD) where sulphur compounds are removed from cat-

cracker gasoline in a two-stage process

Steam Production

Many of the process units contain heat exchangers to recapture waste heat from process

streams Steam produced in the refinery boilers and heat recovery steam generators

(HRSGs) is used to provide power in turbines and ejectors to heat processes and

materials and as part of the refining process

The refinery currently has four boilers (1 3 5 and 6) and two HRSGs which burn

refinery fuel gas The HRSGs operated as stand-alone units until late 2004 when

combustion turbines were commissioned as part of the Grandview Cogeneration Project

The combustion turbines generate up to 90 Megawatts (MW) of electricity that is sold to

NB Power a portion (approximately 65 MW) of which is re-sold to Irving Oil Refining

GP for use in the refinery The HRSGs now derive a significant portion of their heat

input from waste heat generated by the combustion turbines significantly increasing the

efficiency of steam generation

Hydrogen Production

Hydrogen required as a feedstock for the hydrocracker and the diesel and naphtha

hydrotreaters is produced by a Hydrogen Plant where natural gas is the primary feed but

naphtha or butane may also be used at high temperature and pressure and in the presence

of a catalyst is converted to hydrogen and carbon dioxide Hydrogen is also produced as

a by-product of the molecular rearrangement process

A Hydrogen Recovery Unit recovers hydrogen from various process streams within the

refinery

Storage Blending and Shipping

Approximately 15 to 20 different component streams are produced by the refinery These

products are stored in the tank field before being blended together in appropriate

proportions to make various grades of gasoline low-sulphur diesel jet fuel furnace oil

and asphalt The finished products are also stored in the refinery tank field prior to being

shipped to customers via road rail and ship The tank storage area contains 135 tanks

storing crude oil blending components and finished products There are also a total of 8

spheres and 10 bullets for storing butane and propane

AIR POLLUTION CONTROL

Owing to the complexity of the refinery air pollution control is achieved through a

variety of techniques including engineering design task and unit specific control

technologies operating strategies and procedures and programs having specific emission

reduction goals These are summarized in the following sub-sections

Fuel Combustion Controls

Generally speaking there is no air pollution control equipment on fuel combustion stacks

(although there are some exceptions) Control is typically exercised by maximizing heat

recovery at the process design stage through the choice of fuel and fuel sulphur levels and

through optimizing furnace operating conditions For example process heaters for Crude

Unit No 4 were designed to be more than 90 percent efficient in terms of energy usage

which is reported to be 20 percent more energy efficient than the furnaces associated with

Crude Unit No1 which they replaced

Sulphur Recovery

Refinery processing operations where possible are designed as closed cycle operations

This means that there are few emissions to the atmosphere There are several reasons for

this including safety environmental protection product recovery and economics The

lightest fractions produced by each processing unit are stripped of their saleable

components and the remaining gases called sour gas (because of the hydrogen sulphide it

contains) are sent to the Amine Sulphur Recovery Unit where the hydrogen sulphide is

removed The cleaned gas known as refinery fuel gas or sweet gas is used throughout

the refinery to provide product heating with minimal emissions

Recovered hydrogen sulphide gas is fed to the Sulphur Recovery UnitsHATGU where

the sulphur is recovered for sale to the fertilizer and pulp and paper industries Some

hydrogen sulphide gas is fed to the Sulphuric Acid Regeneration Unit where it is

converted to sulphuric acid and used in the alkylation process Approximately ninety nine

percent of the sulphur is recovered in this process with the rest being emitted through the

Sulphur Recovery Unit stacks as sulphur dioxide

Water is used in a variety of processes within the refinery to clean and cool product

streams Water that comes into direct contact with petroleum products becomes

contaminated and is likewise handled in a closed system The sour water that results from

these operations is cleaned of its impurities in the Sour Water Stripper where hydrogen

sulphide and ammonia are removed The recovered impurities are fed along with the

hydrogen sulphide from the Amine Recovery Unit to the Sulphur Recovery Units AND

hatgu

The refinery presently has

bull two Amine Sulphur Recovery Units (2450 mscfh recycle rate) and two Sour

Water Stripping Units (7600 BPD each) The second units in each case were

added during the upgrade to provide additional sulphur extraction capability as

well as redundancy for maintenance and other shutdown periods

bull a Tail Gas Unit to remove additional sulphur from the Sulphur Recovery Units

exhaust (tail) gas The original unit (Sulphuric Acid Tail Gas Unit) installed

during the upgrade did not operate as expected so the refinery was required to

propose a solution In 2008 a new unit was installed (the Hydrogenation Amine

Tail Gas Unit or HATGU) which is achieving the desired sulphur recovery

bull a Sulphuric Acid Regeneration Unit to regenerate spent sulphuric acid catalyst

from the Alkylation Plants and

bull two Sulphur Recovery Units (100 long tons per day each)

Flares

Process units are linked together in a system that allows for pressure relief of vessels

being shut down for maintenance or due to upset conditions such as a power interruption

The pressure is relieved by piping the excess product to one of three flares where the

hydrocarbons are combusted at a safe distance from people and equipment The flares are

equipped with smokeless technology and steam assisted air dispersion equipment The

flare system tips were upgraded in 2004 to reduce noise when additional steam is directed

to the flares In addition the No 1 flare was upgraded during the fall 2007 turnaround

and as a result of the newer technology employed noise levels have been reduced

FCCU Particulate Control

Particulate matter emissions from the FCCU are minimized by a series of cyclonic

separators Flue gases from the catalyst regenerator are passed through six sets of primary

and secondary cyclones where centrifugal forces cause the particulate matter to move to

the outside surface of the cyclones where they drop to the bottom and are removed Flue

gases from the secondary cyclones are sent to a third stage containing 80 high efficiency

cyclones and then to a fourth stage high-efficiency cyclone where the majority of the

remaining particulate is removed prior to it being released through the stack During the

2017 Turnaround the primary and secondary cyclones were replaced with an improved

design to improve steady state performance As the flue gas continues through each stage

the size and amount of the particles left in the stream decreases Recovered catalyst is

returned to the unit for re-use or recycled

FCCU Carbon Monoxide Control

As part of the 1976 refinery expansion a platinum combustion promoter was added to the

regenerator The promoter keeps the heat in the bottom of the regenerator where

combustion of carbon monoxide to carbon dioxide is completed without hazard and

reduces the concentration of the carbon monoxide emissions from approximately 10 to

001 percent

Particulate Matter and Sulphur Dioxide Control on RFCCU

A Flue Gas Scrubber (FGS) was installed as part of the Refinery Upgrade Project to

control emissions of particulate matter and sulphur dioxide from the RFCCU catalyst

regeneration process

Noise Control

Noise emissions from the refinery are controlled through the equipment selection

process a silencer to reduce noise on the FCCU was installed in 1995 in response to

concerns from neighbours around the refinery Noise mitigation is recognized as an

integral part of the design process and noise level specifications were included in the

upgrade project procurement process In the fall of 2007 the refinery conducted a noise

study as a requirement through their Approval to Operate Although the results of the

study showed noise to be within benchmark levels at their property line it did help

identify certain activities and units that contribute to slightly increased levels As a result

several process and mechanical changes were made (such as the installation of silencers)

to reduce intermittent noise levels

Hydrogen Plant Carbon Dioxide Control

Primary sources of carbon dioxide within the refinery are from fuel combustion and from

synthetic hydrogen production through steamnaphtha reforming In order to reduce the

refinerys emissions of carbon dioxide recycle a contaminant emission and produce a

saleable product Irving Oil Refining GP entered into a joint venture with Praxair

Canada Inc and constructed a carbon dioxide liquefaction plant in the Grandview

Industrial Park in 1997 Over half of the carbon dioxide emissions generated from the

hydrogen plant are recovered and recycled as a food grade product

Instrumentation and Stack Monitoring

The refinery re-instrumentation carried out between 1991 and 1993 allowed for more

frequent and precise control of all refinery processes This improved control allows the

optimization of refinery processes which contributes markedly to energy efficiency and

emission reductions During re-instrumentation a second fiber optic communication

backbone was installed which provides a backup for the control system and allows the

refinery to continue safe operation in the event that a portion of the control system

becomes inoperable

Stack emissions are monitored for a number of parameters In some cases the monitors

provide direct measurements of contaminant concentrations such as the sulphur dioxide

continuous emission monitors on the sulphur plant stacks In other cases such as the

furnaces boilers and the FCCU process parameters including fuel flow oxygen and

temperature are continuously measured These measurements allow for optimal control of

the process as well as in combination with frequent fuel sulphur analysis for the

calculation of sulphur dioxide emissions

Continuous Emission Monitors (CEMs) for sulphur dioxide and nitrogen oxides are

operational on the Flue Gas Scrubber the Tail Gas Unit and the Sulphuric Acid

Regeneration Unit During the construction of the Grandview Cogeneration Project

CEMs for sulphur dioxide and nitrogen oxides were installed on both HRSGs

Operational Procedures

The refinery burns refinery fuel gas (sweet gas) to provide heat for the refining process

Of the existing total of 26 stacks all but the FCCU emit flue gases from the combustion

of refinery fuel gas

Adherence to the Sulphur Dioxide Response Plan also contributes to reducing emissions

and minimizing their impact The operating approval requires the refinery to implement

the plan when ambient sulphur dioxide concentrations are above 8 parts per hundred

million (pphm) which is approximately one half the maximum permissible 1-hour

ground level concentrations of sulphur dioxide at any one of five ambient monitors

In order to conserve energy process heaters and boilers are operated near stoichiometric

(ideal) conditions that is the minimum amount of air required is used to enable complete

combustion of the fuels This operating objective has the benefit of minimizing emissions

of all contaminants

Shutdown start-up and maintenance procedures are designed to minimize emissions

During planned shutdowns units are steamed out and the resulting hydrocarbon mixture

is burned in the flare(s) with clean fuels such as propane or LPG to minimize the

hydrocarbon emissions Wherever possible mechanical procedures are now employed to

remove coke build-up on boiler tubes as opposed to the previous practice of slowly

burning the coke out Further during maintenance of the sulphur plants or associated

units the refinery uses low sulphur crude to reduce the load on the operating sulphur

recovery plant

Product Quality

Product (fuel) quality affects emissions at the refinery level during product distribution

and in product usage Changes to fuel quality are frequently driven by environmental and

health concerns and often become requirements of national fuel regulations in Canada

and the United States

The Alkylation Unit (to reduce volatile organic compound (VOC) emissions) and

Dehexanizer (for US reformulated gasoline) are process units that were installed between

1987 and 1994 as a result of new Canadian and US federal gasoline regulations aimed at

reducing emissions from both gasoline storage and use

More recent federal environmental initiatives necessitated the upgrade to the Diesel

Hydrodesulphurizer and the Hydrocracker in 1995 which allowed production of low

sulphur diesel This became a requirement in 1998 as a result of the Diesel Fuel

Regulations (3) The Aromatics Saturation Unit was constructed in 1997-98 to reduce the

benzene content in gasoline as required by the Benzene in Gasoline Regulations (4) The

CD-Tech Unit installed in 2003 as part of the RFCCU provides enhanced capability to

ensure that the Sulphur in Gasoline Regulations (5) are met Irving Oil has also made

infrastructure improvements such as new pipelines in preparation for adherence with the

ultra-low sulphur diesel requirements mandated under the Sulphur in Diesel Fuel

Regulations (6) In 2006 the hydrocracker was converted into a diesel treater to help

meet these requirements

The Ultra-Low Sulphur Gasoline Regulations had required an average gasoline sulphur

content of 30 ppm or lower In January 2017 Federal Tier 3 gasoline regulations were

implemented requiring an annual average gasoline sulphur content of 10 ppm The

refinery operations determined that gas desulphurization combined product sulphur of 15

ppm would be required in order to meet the Tier 3 regulation under various operating

scenarios An additional hydrotreating step was installed to the existing Gasoline

Desulphurization Unit (GDS) which is a two-step hydrotreating unit in order to meet a

desired sulphur content of 15 ppm Combining the remaining gasoline blend components

with the hydrotreated stream allows the annual average combined sulphur in gasoline to

meet the 10 ppm regulation

Fugitive Emissions Programs

In 1993 the Irving Oil Refinery began an annual program aimed at reducing its

contribution to ground-level ozone in keeping with the Code of Practice for the

Measurement and Control of Fugitive VOC Emissions from Equipment Leaks October

1993 (7) established by the Canadian Council of Ministers of the Environment (CCME)

This program is comprised of the detection and repair of leaks (fugitive emissions) from

specific process components such as pump seals valves flanges vents connectors and

compressor seals The detection component of the program began in 1993 The program

was expanded to include the repair of leaking components in 1995 When a repair cannot

be made immediately it is scheduled for the next available maintenance turnaround

In addition all Irving Oil Refining GP storage tanks are required to be maintained in

accordance with the CCME Environmental Guidelines for Controlling Emissions of

Volatile Organic Compounds from Aboveground Storage Tanks June 1995 (8) and the

requirements of this guideline have been incorporated into an annual tank reliability

program carried out by the refinery

An odour study was completed throughout the previous Approval lifetime that identified

odour issues that were addressed through various action items and process improvements

POTENTIAL AIR QUALITY CONTAMINANTS

The refinery is situated in east Saint John and although it is in an industrial area there are

several residential areas within close proximity Emissions from the refinery come from

four main source areas

bull Sulphur Block (includes two Sulphur Recovery Units the Tail Gas Unit and the

Sulphuric Acid Regeneration Unit) where although 99 percent of the sulphur fed

to the units is recovered less than 1 percent is released to the atmosphere as

sulphur dioxide as well as small amounts of nitrogen oxides particulate matter

and carbon dioxide

bull Refinery Boilers and the No 3 Crude Unit fired heaters where refinery fuel gas

combustion results in the emission of sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and

hydrocarbons

bull FCCU catalyst regenerator where sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and hydrocarbons

are emitted

bull FGS where nitrogen oxides particulate matter carbon dioxide and small amounts

of sulphur dioxide and carbon monoxide are emitted

Fugitive emissions can also have an effect on local air quality

POTENTIAL IMPACTS OF AIR EMISSIONS

Acid Deposition

Emissions of sulphur dioxide and nitrogen oxides can be transformed in the atmosphere

to acidic particles which ultimately fallout as acid deposition (acid rain is one way in

which this deposition occurs) This deposition can occur far from the original source of

the emissions The majority of the acid deposition measured in New Brunswick is caused

by emission sources in the US mid-west and central Canada Generally speaking acid

deposition in New Brunswick has shown significant improvement through national and

international efforts to reduce acid causing emissions primarily through controlling

emissions of sulphur dioxide

The Department continues to report the acid disposition measurements in the Annual Air

Quality Report

Climate Change

When fossil fuels are burned it results in the generation of greenhouse gases (GHG) such

as carbon dioxide (CO2) and methane (CH4) which are the main contributors to the

problem of climate change The Department has been working on a Climate Change

Action Plan for several years and the Approval has a number of conditions related to

reporting and improvements in greenhouse gas emissions

Ground-Level Ozone

Ozone (O3) is a reactive unstable form of oxygen It is not emitted directly from stacks or

exhaust pipes but it is formed as a result of photochemical reactions between other

pollutants most importantly nitrogen oxides and volatile organic compounds (VOCs)

such as solvent and gasoline vapours Both stationary and mobile emissions sources

contribute precursor pollutants that have the potential to result in the formation of

ground-level ozone

It has been estimated that 85 percent of ground-level ozone enters this region from the

North Eastern United States Central Canada and the American Mid-West (9) Elevated

levels generally occur in the summer under very warm conditions when large stable air

masses move up the eastern seaboard into the Fundy region Although the contribution of

local sources may pose an added stress to already deteriorating air quality conditions

during such episodes in general local sources are relatively minor contributors to ground-

level ozone levels experienced in our region Control programs in New Brunswick

specifically for ground-level ozone are therefore not able to reduce ambient

concentrations appreciably Despite this all measures which can reduce the emission of

ozone precursors are promoted such as the refinerys Fugitive Emissions Program Of

particular interest are programs where multiple environmental benefits may be expected

For example improving energy efficiency will reduce greenhouse gas emissions as well

as nitrogen oxides and sulphur dioxide Therefore efficiency measures are favoured over

measures exclusively targeting ground-level ozone

AIR QUALITY COMPLIANCE AND ENFORCEMENT

Compliance and Enforcement options used by the Department of Environment are

outlined in the Departments Compliance and Enforcement Policy (10) These may

include but are not limited to schedules of compliance warnings orders and

prosecutions Although not specifically outlined in the Policy it is also possible to amend

approvals with more stringent conditions both during its valid period or at the time of

renewal to address specific compliance issues or to improve the environmental impact of

the facility Most recently a new Regulation under the Clean Air Act allows for the

issuance of administrative penalties for minor violations as an alternative to

traditionally-used enforcement options

All sources of air emissions in the province are required to comply with the Clean Air Act

and Air Quality Regulation In addition to establishing ambient standards for

contaminants in air Section 3 of the Air Quality Regulation requires that no person shall

construct modify or operate a source without applying for and obtaining an

approvalrdquo The refinery currently operates under Approval to Operate I-8902 issued

July 1 2015 The current Approval expires on June 30 2020

APPROVAL AMENDMENTS and PROJECTS

The Approval was amended twice during the lifetime of the Approval

On November 15th 2015 the Approval was amended to update the operation and

maintenance of the ambient monitoring program that had been upgraded as well as

adding general GHG conditions to the Approval to include reporting and submitting a

Greenhouse Gas Management Plan

On December 21 2016 the Approval was amended to update the definition of Facility to

add the Hydrogen Recovery Unit (Plant 426) This was not a new unit at the Facility

however it was previously owned and operated by Air Liquid Canada and was

acquisitioned by Irving Oil on December 31 2016

On April 4 2017 an Approval to Construct the Tier 3 Gasoline Project was issued This

modification did not increase or change emissions at the refinery or increase the capacity

Compliance with the Approval to Operate

Following are the key issues addressed in the Approval to Operate for Irving Oil Refining

GP including comments on compliance with the associated conditions and actions taken

to achieve compliance with these conditions A summary of the key conditions are in

italics

Emergency Response and Reporting

Conditions 27 amp 28

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

bull Visbreaker (20000 BPD) where residue from the vacuum tower of the crude

units is cracked at high temperatures to make gasoline and diesel fuels

Molecular Rearrangement

Light molecules in the gasoline component streams can be rearranged to improve their

properties as gasoline blending components Reforming is normally carried out in the

presence of hydrogen and a catalyst at temperatures of up to 1000 o F

The refinery has five of these units which perform specific operations as follows

bull Butamer Unit (12000 BPD) where normal butane is converted to isobutene

bull Two Alkylation Units (8000 BPD and 10000 BPD) where iso-butane from other

units is combined with butylenenormal butane mixture to make alkylate a high

octane zero sulphur low vapour pressure gasoline blending component and

bull Rheniformer No 1 (11000 BPD) and Rheniformer No 2 (28000 BPD) where

gasoline blending stocks are reformed to yield a higher-octane fuel

Product Treating

Most refinery streams are treated to remove contaminants such as sulphur organic acids

metals and surfactants that might be detrimental to engines or the environment The

refinery has five units that are used to treat product streams to remove contaminants

bull Naphtha Hydrotreating Unit (NHT) (44000 BPD) where sulphur is completely

removed from the naphtha by reaction with hydrogen over a catalyst

bull Hydrocracker (45000 BPD) where heavy diesel and light cycle oil are

desulphurized in the presence of hydrogen and a catalyst resulting in the

production of ultra-low sulphur diesel products

bull Hydrodesulphurizer (HDS) (56000 BPD) where the sulphur in diesel blending

components is converted to hydrogen sulphide by reacting with hydrogen over a

catalyst

bull Merox Plants (44500 BPD) where mercaptans which are odorous compounds

are removed from gasoline and jet fuels and

bull CD-Tech Unit (58000 BPD) where sulphur compounds are removed from cat-

cracker gasoline in a two-stage process

Steam Production

Many of the process units contain heat exchangers to recapture waste heat from process

streams Steam produced in the refinery boilers and heat recovery steam generators

(HRSGs) is used to provide power in turbines and ejectors to heat processes and

materials and as part of the refining process

The refinery currently has four boilers (1 3 5 and 6) and two HRSGs which burn

refinery fuel gas The HRSGs operated as stand-alone units until late 2004 when

combustion turbines were commissioned as part of the Grandview Cogeneration Project

The combustion turbines generate up to 90 Megawatts (MW) of electricity that is sold to

NB Power a portion (approximately 65 MW) of which is re-sold to Irving Oil Refining

GP for use in the refinery The HRSGs now derive a significant portion of their heat

input from waste heat generated by the combustion turbines significantly increasing the

efficiency of steam generation

Hydrogen Production

Hydrogen required as a feedstock for the hydrocracker and the diesel and naphtha

hydrotreaters is produced by a Hydrogen Plant where natural gas is the primary feed but

naphtha or butane may also be used at high temperature and pressure and in the presence

of a catalyst is converted to hydrogen and carbon dioxide Hydrogen is also produced as

a by-product of the molecular rearrangement process

A Hydrogen Recovery Unit recovers hydrogen from various process streams within the

refinery

Storage Blending and Shipping

Approximately 15 to 20 different component streams are produced by the refinery These

products are stored in the tank field before being blended together in appropriate

proportions to make various grades of gasoline low-sulphur diesel jet fuel furnace oil

and asphalt The finished products are also stored in the refinery tank field prior to being

shipped to customers via road rail and ship The tank storage area contains 135 tanks

storing crude oil blending components and finished products There are also a total of 8

spheres and 10 bullets for storing butane and propane

AIR POLLUTION CONTROL

Owing to the complexity of the refinery air pollution control is achieved through a

variety of techniques including engineering design task and unit specific control

technologies operating strategies and procedures and programs having specific emission

reduction goals These are summarized in the following sub-sections

Fuel Combustion Controls

Generally speaking there is no air pollution control equipment on fuel combustion stacks

(although there are some exceptions) Control is typically exercised by maximizing heat

recovery at the process design stage through the choice of fuel and fuel sulphur levels and

through optimizing furnace operating conditions For example process heaters for Crude

Unit No 4 were designed to be more than 90 percent efficient in terms of energy usage

which is reported to be 20 percent more energy efficient than the furnaces associated with

Crude Unit No1 which they replaced

Sulphur Recovery

Refinery processing operations where possible are designed as closed cycle operations

This means that there are few emissions to the atmosphere There are several reasons for

this including safety environmental protection product recovery and economics The

lightest fractions produced by each processing unit are stripped of their saleable

components and the remaining gases called sour gas (because of the hydrogen sulphide it

contains) are sent to the Amine Sulphur Recovery Unit where the hydrogen sulphide is

removed The cleaned gas known as refinery fuel gas or sweet gas is used throughout

the refinery to provide product heating with minimal emissions

Recovered hydrogen sulphide gas is fed to the Sulphur Recovery UnitsHATGU where

the sulphur is recovered for sale to the fertilizer and pulp and paper industries Some

hydrogen sulphide gas is fed to the Sulphuric Acid Regeneration Unit where it is

converted to sulphuric acid and used in the alkylation process Approximately ninety nine

percent of the sulphur is recovered in this process with the rest being emitted through the

Sulphur Recovery Unit stacks as sulphur dioxide

Water is used in a variety of processes within the refinery to clean and cool product

streams Water that comes into direct contact with petroleum products becomes

contaminated and is likewise handled in a closed system The sour water that results from

these operations is cleaned of its impurities in the Sour Water Stripper where hydrogen

sulphide and ammonia are removed The recovered impurities are fed along with the

hydrogen sulphide from the Amine Recovery Unit to the Sulphur Recovery Units AND

hatgu

The refinery presently has

bull two Amine Sulphur Recovery Units (2450 mscfh recycle rate) and two Sour

Water Stripping Units (7600 BPD each) The second units in each case were

added during the upgrade to provide additional sulphur extraction capability as

well as redundancy for maintenance and other shutdown periods

bull a Tail Gas Unit to remove additional sulphur from the Sulphur Recovery Units

exhaust (tail) gas The original unit (Sulphuric Acid Tail Gas Unit) installed

during the upgrade did not operate as expected so the refinery was required to

propose a solution In 2008 a new unit was installed (the Hydrogenation Amine

Tail Gas Unit or HATGU) which is achieving the desired sulphur recovery

bull a Sulphuric Acid Regeneration Unit to regenerate spent sulphuric acid catalyst

from the Alkylation Plants and

bull two Sulphur Recovery Units (100 long tons per day each)

Flares

Process units are linked together in a system that allows for pressure relief of vessels

being shut down for maintenance or due to upset conditions such as a power interruption

The pressure is relieved by piping the excess product to one of three flares where the

hydrocarbons are combusted at a safe distance from people and equipment The flares are

equipped with smokeless technology and steam assisted air dispersion equipment The

flare system tips were upgraded in 2004 to reduce noise when additional steam is directed

to the flares In addition the No 1 flare was upgraded during the fall 2007 turnaround

and as a result of the newer technology employed noise levels have been reduced

FCCU Particulate Control

Particulate matter emissions from the FCCU are minimized by a series of cyclonic

separators Flue gases from the catalyst regenerator are passed through six sets of primary

and secondary cyclones where centrifugal forces cause the particulate matter to move to

the outside surface of the cyclones where they drop to the bottom and are removed Flue

gases from the secondary cyclones are sent to a third stage containing 80 high efficiency

cyclones and then to a fourth stage high-efficiency cyclone where the majority of the

remaining particulate is removed prior to it being released through the stack During the

2017 Turnaround the primary and secondary cyclones were replaced with an improved

design to improve steady state performance As the flue gas continues through each stage

the size and amount of the particles left in the stream decreases Recovered catalyst is

returned to the unit for re-use or recycled

FCCU Carbon Monoxide Control

As part of the 1976 refinery expansion a platinum combustion promoter was added to the

regenerator The promoter keeps the heat in the bottom of the regenerator where

combustion of carbon monoxide to carbon dioxide is completed without hazard and

reduces the concentration of the carbon monoxide emissions from approximately 10 to

001 percent

Particulate Matter and Sulphur Dioxide Control on RFCCU

A Flue Gas Scrubber (FGS) was installed as part of the Refinery Upgrade Project to

control emissions of particulate matter and sulphur dioxide from the RFCCU catalyst

regeneration process

Noise Control

Noise emissions from the refinery are controlled through the equipment selection

process a silencer to reduce noise on the FCCU was installed in 1995 in response to

concerns from neighbours around the refinery Noise mitigation is recognized as an

integral part of the design process and noise level specifications were included in the

upgrade project procurement process In the fall of 2007 the refinery conducted a noise

study as a requirement through their Approval to Operate Although the results of the

study showed noise to be within benchmark levels at their property line it did help

identify certain activities and units that contribute to slightly increased levels As a result

several process and mechanical changes were made (such as the installation of silencers)

to reduce intermittent noise levels

Hydrogen Plant Carbon Dioxide Control

Primary sources of carbon dioxide within the refinery are from fuel combustion and from

synthetic hydrogen production through steamnaphtha reforming In order to reduce the

refinerys emissions of carbon dioxide recycle a contaminant emission and produce a

saleable product Irving Oil Refining GP entered into a joint venture with Praxair

Canada Inc and constructed a carbon dioxide liquefaction plant in the Grandview

Industrial Park in 1997 Over half of the carbon dioxide emissions generated from the

hydrogen plant are recovered and recycled as a food grade product

Instrumentation and Stack Monitoring

The refinery re-instrumentation carried out between 1991 and 1993 allowed for more

frequent and precise control of all refinery processes This improved control allows the

optimization of refinery processes which contributes markedly to energy efficiency and

emission reductions During re-instrumentation a second fiber optic communication

backbone was installed which provides a backup for the control system and allows the

refinery to continue safe operation in the event that a portion of the control system

becomes inoperable

Stack emissions are monitored for a number of parameters In some cases the monitors

provide direct measurements of contaminant concentrations such as the sulphur dioxide

continuous emission monitors on the sulphur plant stacks In other cases such as the

furnaces boilers and the FCCU process parameters including fuel flow oxygen and

temperature are continuously measured These measurements allow for optimal control of

the process as well as in combination with frequent fuel sulphur analysis for the

calculation of sulphur dioxide emissions

Continuous Emission Monitors (CEMs) for sulphur dioxide and nitrogen oxides are

operational on the Flue Gas Scrubber the Tail Gas Unit and the Sulphuric Acid

Regeneration Unit During the construction of the Grandview Cogeneration Project

CEMs for sulphur dioxide and nitrogen oxides were installed on both HRSGs

Operational Procedures

The refinery burns refinery fuel gas (sweet gas) to provide heat for the refining process

Of the existing total of 26 stacks all but the FCCU emit flue gases from the combustion

of refinery fuel gas

Adherence to the Sulphur Dioxide Response Plan also contributes to reducing emissions

and minimizing their impact The operating approval requires the refinery to implement

the plan when ambient sulphur dioxide concentrations are above 8 parts per hundred

million (pphm) which is approximately one half the maximum permissible 1-hour

ground level concentrations of sulphur dioxide at any one of five ambient monitors

In order to conserve energy process heaters and boilers are operated near stoichiometric

(ideal) conditions that is the minimum amount of air required is used to enable complete

combustion of the fuels This operating objective has the benefit of minimizing emissions

of all contaminants

Shutdown start-up and maintenance procedures are designed to minimize emissions

During planned shutdowns units are steamed out and the resulting hydrocarbon mixture

is burned in the flare(s) with clean fuels such as propane or LPG to minimize the

hydrocarbon emissions Wherever possible mechanical procedures are now employed to

remove coke build-up on boiler tubes as opposed to the previous practice of slowly

burning the coke out Further during maintenance of the sulphur plants or associated

units the refinery uses low sulphur crude to reduce the load on the operating sulphur

recovery plant

Product Quality

Product (fuel) quality affects emissions at the refinery level during product distribution

and in product usage Changes to fuel quality are frequently driven by environmental and

health concerns and often become requirements of national fuel regulations in Canada

and the United States

The Alkylation Unit (to reduce volatile organic compound (VOC) emissions) and

Dehexanizer (for US reformulated gasoline) are process units that were installed between

1987 and 1994 as a result of new Canadian and US federal gasoline regulations aimed at

reducing emissions from both gasoline storage and use

More recent federal environmental initiatives necessitated the upgrade to the Diesel

Hydrodesulphurizer and the Hydrocracker in 1995 which allowed production of low

sulphur diesel This became a requirement in 1998 as a result of the Diesel Fuel

Regulations (3) The Aromatics Saturation Unit was constructed in 1997-98 to reduce the

benzene content in gasoline as required by the Benzene in Gasoline Regulations (4) The

CD-Tech Unit installed in 2003 as part of the RFCCU provides enhanced capability to

ensure that the Sulphur in Gasoline Regulations (5) are met Irving Oil has also made

infrastructure improvements such as new pipelines in preparation for adherence with the

ultra-low sulphur diesel requirements mandated under the Sulphur in Diesel Fuel

Regulations (6) In 2006 the hydrocracker was converted into a diesel treater to help

meet these requirements

The Ultra-Low Sulphur Gasoline Regulations had required an average gasoline sulphur

content of 30 ppm or lower In January 2017 Federal Tier 3 gasoline regulations were

implemented requiring an annual average gasoline sulphur content of 10 ppm The

refinery operations determined that gas desulphurization combined product sulphur of 15

ppm would be required in order to meet the Tier 3 regulation under various operating

scenarios An additional hydrotreating step was installed to the existing Gasoline

Desulphurization Unit (GDS) which is a two-step hydrotreating unit in order to meet a

desired sulphur content of 15 ppm Combining the remaining gasoline blend components

with the hydrotreated stream allows the annual average combined sulphur in gasoline to

meet the 10 ppm regulation

Fugitive Emissions Programs

In 1993 the Irving Oil Refinery began an annual program aimed at reducing its

contribution to ground-level ozone in keeping with the Code of Practice for the

Measurement and Control of Fugitive VOC Emissions from Equipment Leaks October

1993 (7) established by the Canadian Council of Ministers of the Environment (CCME)

This program is comprised of the detection and repair of leaks (fugitive emissions) from

specific process components such as pump seals valves flanges vents connectors and

compressor seals The detection component of the program began in 1993 The program

was expanded to include the repair of leaking components in 1995 When a repair cannot

be made immediately it is scheduled for the next available maintenance turnaround

In addition all Irving Oil Refining GP storage tanks are required to be maintained in

accordance with the CCME Environmental Guidelines for Controlling Emissions of

Volatile Organic Compounds from Aboveground Storage Tanks June 1995 (8) and the

requirements of this guideline have been incorporated into an annual tank reliability

program carried out by the refinery

An odour study was completed throughout the previous Approval lifetime that identified

odour issues that were addressed through various action items and process improvements

POTENTIAL AIR QUALITY CONTAMINANTS

The refinery is situated in east Saint John and although it is in an industrial area there are

several residential areas within close proximity Emissions from the refinery come from

four main source areas

bull Sulphur Block (includes two Sulphur Recovery Units the Tail Gas Unit and the

Sulphuric Acid Regeneration Unit) where although 99 percent of the sulphur fed

to the units is recovered less than 1 percent is released to the atmosphere as

sulphur dioxide as well as small amounts of nitrogen oxides particulate matter

and carbon dioxide

bull Refinery Boilers and the No 3 Crude Unit fired heaters where refinery fuel gas

combustion results in the emission of sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and

hydrocarbons

bull FCCU catalyst regenerator where sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and hydrocarbons

are emitted

bull FGS where nitrogen oxides particulate matter carbon dioxide and small amounts

of sulphur dioxide and carbon monoxide are emitted

Fugitive emissions can also have an effect on local air quality

POTENTIAL IMPACTS OF AIR EMISSIONS

Acid Deposition

Emissions of sulphur dioxide and nitrogen oxides can be transformed in the atmosphere

to acidic particles which ultimately fallout as acid deposition (acid rain is one way in

which this deposition occurs) This deposition can occur far from the original source of

the emissions The majority of the acid deposition measured in New Brunswick is caused

by emission sources in the US mid-west and central Canada Generally speaking acid

deposition in New Brunswick has shown significant improvement through national and

international efforts to reduce acid causing emissions primarily through controlling

emissions of sulphur dioxide

The Department continues to report the acid disposition measurements in the Annual Air

Quality Report

Climate Change

When fossil fuels are burned it results in the generation of greenhouse gases (GHG) such

as carbon dioxide (CO2) and methane (CH4) which are the main contributors to the

problem of climate change The Department has been working on a Climate Change

Action Plan for several years and the Approval has a number of conditions related to

reporting and improvements in greenhouse gas emissions

Ground-Level Ozone

Ozone (O3) is a reactive unstable form of oxygen It is not emitted directly from stacks or

exhaust pipes but it is formed as a result of photochemical reactions between other

pollutants most importantly nitrogen oxides and volatile organic compounds (VOCs)

such as solvent and gasoline vapours Both stationary and mobile emissions sources

contribute precursor pollutants that have the potential to result in the formation of

ground-level ozone

It has been estimated that 85 percent of ground-level ozone enters this region from the

North Eastern United States Central Canada and the American Mid-West (9) Elevated

levels generally occur in the summer under very warm conditions when large stable air

masses move up the eastern seaboard into the Fundy region Although the contribution of

local sources may pose an added stress to already deteriorating air quality conditions

during such episodes in general local sources are relatively minor contributors to ground-

level ozone levels experienced in our region Control programs in New Brunswick

specifically for ground-level ozone are therefore not able to reduce ambient

concentrations appreciably Despite this all measures which can reduce the emission of

ozone precursors are promoted such as the refinerys Fugitive Emissions Program Of

particular interest are programs where multiple environmental benefits may be expected

For example improving energy efficiency will reduce greenhouse gas emissions as well

as nitrogen oxides and sulphur dioxide Therefore efficiency measures are favoured over

measures exclusively targeting ground-level ozone

AIR QUALITY COMPLIANCE AND ENFORCEMENT

Compliance and Enforcement options used by the Department of Environment are

outlined in the Departments Compliance and Enforcement Policy (10) These may

include but are not limited to schedules of compliance warnings orders and

prosecutions Although not specifically outlined in the Policy it is also possible to amend

approvals with more stringent conditions both during its valid period or at the time of

renewal to address specific compliance issues or to improve the environmental impact of

the facility Most recently a new Regulation under the Clean Air Act allows for the

issuance of administrative penalties for minor violations as an alternative to

traditionally-used enforcement options

All sources of air emissions in the province are required to comply with the Clean Air Act

and Air Quality Regulation In addition to establishing ambient standards for

contaminants in air Section 3 of the Air Quality Regulation requires that no person shall

construct modify or operate a source without applying for and obtaining an

approvalrdquo The refinery currently operates under Approval to Operate I-8902 issued

July 1 2015 The current Approval expires on June 30 2020

APPROVAL AMENDMENTS and PROJECTS

The Approval was amended twice during the lifetime of the Approval

On November 15th 2015 the Approval was amended to update the operation and

maintenance of the ambient monitoring program that had been upgraded as well as

adding general GHG conditions to the Approval to include reporting and submitting a

Greenhouse Gas Management Plan

On December 21 2016 the Approval was amended to update the definition of Facility to

add the Hydrogen Recovery Unit (Plant 426) This was not a new unit at the Facility

however it was previously owned and operated by Air Liquid Canada and was

acquisitioned by Irving Oil on December 31 2016

On April 4 2017 an Approval to Construct the Tier 3 Gasoline Project was issued This

modification did not increase or change emissions at the refinery or increase the capacity

Compliance with the Approval to Operate

Following are the key issues addressed in the Approval to Operate for Irving Oil Refining

GP including comments on compliance with the associated conditions and actions taken

to achieve compliance with these conditions A summary of the key conditions are in

italics

Emergency Response and Reporting

Conditions 27 amp 28

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

NB Power a portion (approximately 65 MW) of which is re-sold to Irving Oil Refining

GP for use in the refinery The HRSGs now derive a significant portion of their heat

input from waste heat generated by the combustion turbines significantly increasing the

efficiency of steam generation

Hydrogen Production

Hydrogen required as a feedstock for the hydrocracker and the diesel and naphtha

hydrotreaters is produced by a Hydrogen Plant where natural gas is the primary feed but

naphtha or butane may also be used at high temperature and pressure and in the presence

of a catalyst is converted to hydrogen and carbon dioxide Hydrogen is also produced as

a by-product of the molecular rearrangement process

A Hydrogen Recovery Unit recovers hydrogen from various process streams within the

refinery

Storage Blending and Shipping

Approximately 15 to 20 different component streams are produced by the refinery These

products are stored in the tank field before being blended together in appropriate

proportions to make various grades of gasoline low-sulphur diesel jet fuel furnace oil

and asphalt The finished products are also stored in the refinery tank field prior to being

shipped to customers via road rail and ship The tank storage area contains 135 tanks

storing crude oil blending components and finished products There are also a total of 8

spheres and 10 bullets for storing butane and propane

AIR POLLUTION CONTROL

Owing to the complexity of the refinery air pollution control is achieved through a

variety of techniques including engineering design task and unit specific control

technologies operating strategies and procedures and programs having specific emission

reduction goals These are summarized in the following sub-sections

Fuel Combustion Controls

Generally speaking there is no air pollution control equipment on fuel combustion stacks

(although there are some exceptions) Control is typically exercised by maximizing heat

recovery at the process design stage through the choice of fuel and fuel sulphur levels and

through optimizing furnace operating conditions For example process heaters for Crude

Unit No 4 were designed to be more than 90 percent efficient in terms of energy usage

which is reported to be 20 percent more energy efficient than the furnaces associated with

Crude Unit No1 which they replaced

Sulphur Recovery

Refinery processing operations where possible are designed as closed cycle operations

This means that there are few emissions to the atmosphere There are several reasons for

this including safety environmental protection product recovery and economics The

lightest fractions produced by each processing unit are stripped of their saleable

components and the remaining gases called sour gas (because of the hydrogen sulphide it

contains) are sent to the Amine Sulphur Recovery Unit where the hydrogen sulphide is

removed The cleaned gas known as refinery fuel gas or sweet gas is used throughout

the refinery to provide product heating with minimal emissions

Recovered hydrogen sulphide gas is fed to the Sulphur Recovery UnitsHATGU where

the sulphur is recovered for sale to the fertilizer and pulp and paper industries Some

hydrogen sulphide gas is fed to the Sulphuric Acid Regeneration Unit where it is

converted to sulphuric acid and used in the alkylation process Approximately ninety nine

percent of the sulphur is recovered in this process with the rest being emitted through the

Sulphur Recovery Unit stacks as sulphur dioxide

Water is used in a variety of processes within the refinery to clean and cool product

streams Water that comes into direct contact with petroleum products becomes

contaminated and is likewise handled in a closed system The sour water that results from

these operations is cleaned of its impurities in the Sour Water Stripper where hydrogen

sulphide and ammonia are removed The recovered impurities are fed along with the

hydrogen sulphide from the Amine Recovery Unit to the Sulphur Recovery Units AND

hatgu

The refinery presently has

bull two Amine Sulphur Recovery Units (2450 mscfh recycle rate) and two Sour

Water Stripping Units (7600 BPD each) The second units in each case were

added during the upgrade to provide additional sulphur extraction capability as

well as redundancy for maintenance and other shutdown periods

bull a Tail Gas Unit to remove additional sulphur from the Sulphur Recovery Units

exhaust (tail) gas The original unit (Sulphuric Acid Tail Gas Unit) installed

during the upgrade did not operate as expected so the refinery was required to

propose a solution In 2008 a new unit was installed (the Hydrogenation Amine

Tail Gas Unit or HATGU) which is achieving the desired sulphur recovery

bull a Sulphuric Acid Regeneration Unit to regenerate spent sulphuric acid catalyst

from the Alkylation Plants and

bull two Sulphur Recovery Units (100 long tons per day each)

Flares

Process units are linked together in a system that allows for pressure relief of vessels

being shut down for maintenance or due to upset conditions such as a power interruption

The pressure is relieved by piping the excess product to one of three flares where the

hydrocarbons are combusted at a safe distance from people and equipment The flares are

equipped with smokeless technology and steam assisted air dispersion equipment The

flare system tips were upgraded in 2004 to reduce noise when additional steam is directed

to the flares In addition the No 1 flare was upgraded during the fall 2007 turnaround

and as a result of the newer technology employed noise levels have been reduced

FCCU Particulate Control

Particulate matter emissions from the FCCU are minimized by a series of cyclonic

separators Flue gases from the catalyst regenerator are passed through six sets of primary

and secondary cyclones where centrifugal forces cause the particulate matter to move to

the outside surface of the cyclones where they drop to the bottom and are removed Flue

gases from the secondary cyclones are sent to a third stage containing 80 high efficiency

cyclones and then to a fourth stage high-efficiency cyclone where the majority of the

remaining particulate is removed prior to it being released through the stack During the

2017 Turnaround the primary and secondary cyclones were replaced with an improved

design to improve steady state performance As the flue gas continues through each stage

the size and amount of the particles left in the stream decreases Recovered catalyst is

returned to the unit for re-use or recycled

FCCU Carbon Monoxide Control

As part of the 1976 refinery expansion a platinum combustion promoter was added to the

regenerator The promoter keeps the heat in the bottom of the regenerator where

combustion of carbon monoxide to carbon dioxide is completed without hazard and

reduces the concentration of the carbon monoxide emissions from approximately 10 to

001 percent

Particulate Matter and Sulphur Dioxide Control on RFCCU

A Flue Gas Scrubber (FGS) was installed as part of the Refinery Upgrade Project to

control emissions of particulate matter and sulphur dioxide from the RFCCU catalyst

regeneration process

Noise Control

Noise emissions from the refinery are controlled through the equipment selection

process a silencer to reduce noise on the FCCU was installed in 1995 in response to

concerns from neighbours around the refinery Noise mitigation is recognized as an

integral part of the design process and noise level specifications were included in the

upgrade project procurement process In the fall of 2007 the refinery conducted a noise

study as a requirement through their Approval to Operate Although the results of the

study showed noise to be within benchmark levels at their property line it did help

identify certain activities and units that contribute to slightly increased levels As a result

several process and mechanical changes were made (such as the installation of silencers)

to reduce intermittent noise levels

Hydrogen Plant Carbon Dioxide Control

Primary sources of carbon dioxide within the refinery are from fuel combustion and from

synthetic hydrogen production through steamnaphtha reforming In order to reduce the

refinerys emissions of carbon dioxide recycle a contaminant emission and produce a

saleable product Irving Oil Refining GP entered into a joint venture with Praxair

Canada Inc and constructed a carbon dioxide liquefaction plant in the Grandview

Industrial Park in 1997 Over half of the carbon dioxide emissions generated from the

hydrogen plant are recovered and recycled as a food grade product

Instrumentation and Stack Monitoring

The refinery re-instrumentation carried out between 1991 and 1993 allowed for more

frequent and precise control of all refinery processes This improved control allows the

optimization of refinery processes which contributes markedly to energy efficiency and

emission reductions During re-instrumentation a second fiber optic communication

backbone was installed which provides a backup for the control system and allows the

refinery to continue safe operation in the event that a portion of the control system

becomes inoperable

Stack emissions are monitored for a number of parameters In some cases the monitors

provide direct measurements of contaminant concentrations such as the sulphur dioxide

continuous emission monitors on the sulphur plant stacks In other cases such as the

furnaces boilers and the FCCU process parameters including fuel flow oxygen and

temperature are continuously measured These measurements allow for optimal control of

the process as well as in combination with frequent fuel sulphur analysis for the

calculation of sulphur dioxide emissions

Continuous Emission Monitors (CEMs) for sulphur dioxide and nitrogen oxides are

operational on the Flue Gas Scrubber the Tail Gas Unit and the Sulphuric Acid

Regeneration Unit During the construction of the Grandview Cogeneration Project

CEMs for sulphur dioxide and nitrogen oxides were installed on both HRSGs

Operational Procedures

The refinery burns refinery fuel gas (sweet gas) to provide heat for the refining process

Of the existing total of 26 stacks all but the FCCU emit flue gases from the combustion

of refinery fuel gas

Adherence to the Sulphur Dioxide Response Plan also contributes to reducing emissions

and minimizing their impact The operating approval requires the refinery to implement

the plan when ambient sulphur dioxide concentrations are above 8 parts per hundred

million (pphm) which is approximately one half the maximum permissible 1-hour

ground level concentrations of sulphur dioxide at any one of five ambient monitors

In order to conserve energy process heaters and boilers are operated near stoichiometric

(ideal) conditions that is the minimum amount of air required is used to enable complete

combustion of the fuels This operating objective has the benefit of minimizing emissions

of all contaminants

Shutdown start-up and maintenance procedures are designed to minimize emissions

During planned shutdowns units are steamed out and the resulting hydrocarbon mixture

is burned in the flare(s) with clean fuels such as propane or LPG to minimize the

hydrocarbon emissions Wherever possible mechanical procedures are now employed to

remove coke build-up on boiler tubes as opposed to the previous practice of slowly

burning the coke out Further during maintenance of the sulphur plants or associated

units the refinery uses low sulphur crude to reduce the load on the operating sulphur

recovery plant

Product Quality

Product (fuel) quality affects emissions at the refinery level during product distribution

and in product usage Changes to fuel quality are frequently driven by environmental and

health concerns and often become requirements of national fuel regulations in Canada

and the United States

The Alkylation Unit (to reduce volatile organic compound (VOC) emissions) and

Dehexanizer (for US reformulated gasoline) are process units that were installed between

1987 and 1994 as a result of new Canadian and US federal gasoline regulations aimed at

reducing emissions from both gasoline storage and use

More recent federal environmental initiatives necessitated the upgrade to the Diesel

Hydrodesulphurizer and the Hydrocracker in 1995 which allowed production of low

sulphur diesel This became a requirement in 1998 as a result of the Diesel Fuel

Regulations (3) The Aromatics Saturation Unit was constructed in 1997-98 to reduce the

benzene content in gasoline as required by the Benzene in Gasoline Regulations (4) The

CD-Tech Unit installed in 2003 as part of the RFCCU provides enhanced capability to

ensure that the Sulphur in Gasoline Regulations (5) are met Irving Oil has also made

infrastructure improvements such as new pipelines in preparation for adherence with the

ultra-low sulphur diesel requirements mandated under the Sulphur in Diesel Fuel

Regulations (6) In 2006 the hydrocracker was converted into a diesel treater to help

meet these requirements

The Ultra-Low Sulphur Gasoline Regulations had required an average gasoline sulphur

content of 30 ppm or lower In January 2017 Federal Tier 3 gasoline regulations were

implemented requiring an annual average gasoline sulphur content of 10 ppm The

refinery operations determined that gas desulphurization combined product sulphur of 15

ppm would be required in order to meet the Tier 3 regulation under various operating

scenarios An additional hydrotreating step was installed to the existing Gasoline

Desulphurization Unit (GDS) which is a two-step hydrotreating unit in order to meet a

desired sulphur content of 15 ppm Combining the remaining gasoline blend components

with the hydrotreated stream allows the annual average combined sulphur in gasoline to

meet the 10 ppm regulation

Fugitive Emissions Programs

In 1993 the Irving Oil Refinery began an annual program aimed at reducing its

contribution to ground-level ozone in keeping with the Code of Practice for the

Measurement and Control of Fugitive VOC Emissions from Equipment Leaks October

1993 (7) established by the Canadian Council of Ministers of the Environment (CCME)

This program is comprised of the detection and repair of leaks (fugitive emissions) from

specific process components such as pump seals valves flanges vents connectors and

compressor seals The detection component of the program began in 1993 The program

was expanded to include the repair of leaking components in 1995 When a repair cannot

be made immediately it is scheduled for the next available maintenance turnaround

In addition all Irving Oil Refining GP storage tanks are required to be maintained in

accordance with the CCME Environmental Guidelines for Controlling Emissions of

Volatile Organic Compounds from Aboveground Storage Tanks June 1995 (8) and the

requirements of this guideline have been incorporated into an annual tank reliability

program carried out by the refinery

An odour study was completed throughout the previous Approval lifetime that identified

odour issues that were addressed through various action items and process improvements

POTENTIAL AIR QUALITY CONTAMINANTS

The refinery is situated in east Saint John and although it is in an industrial area there are

several residential areas within close proximity Emissions from the refinery come from

four main source areas

bull Sulphur Block (includes two Sulphur Recovery Units the Tail Gas Unit and the

Sulphuric Acid Regeneration Unit) where although 99 percent of the sulphur fed

to the units is recovered less than 1 percent is released to the atmosphere as

sulphur dioxide as well as small amounts of nitrogen oxides particulate matter

and carbon dioxide

bull Refinery Boilers and the No 3 Crude Unit fired heaters where refinery fuel gas

combustion results in the emission of sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and

hydrocarbons

bull FCCU catalyst regenerator where sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and hydrocarbons

are emitted

bull FGS where nitrogen oxides particulate matter carbon dioxide and small amounts

of sulphur dioxide and carbon monoxide are emitted

Fugitive emissions can also have an effect on local air quality

POTENTIAL IMPACTS OF AIR EMISSIONS

Acid Deposition

Emissions of sulphur dioxide and nitrogen oxides can be transformed in the atmosphere

to acidic particles which ultimately fallout as acid deposition (acid rain is one way in

which this deposition occurs) This deposition can occur far from the original source of

the emissions The majority of the acid deposition measured in New Brunswick is caused

by emission sources in the US mid-west and central Canada Generally speaking acid

deposition in New Brunswick has shown significant improvement through national and

international efforts to reduce acid causing emissions primarily through controlling

emissions of sulphur dioxide

The Department continues to report the acid disposition measurements in the Annual Air

Quality Report

Climate Change

When fossil fuels are burned it results in the generation of greenhouse gases (GHG) such

as carbon dioxide (CO2) and methane (CH4) which are the main contributors to the

problem of climate change The Department has been working on a Climate Change

Action Plan for several years and the Approval has a number of conditions related to

reporting and improvements in greenhouse gas emissions

Ground-Level Ozone

Ozone (O3) is a reactive unstable form of oxygen It is not emitted directly from stacks or

exhaust pipes but it is formed as a result of photochemical reactions between other

pollutants most importantly nitrogen oxides and volatile organic compounds (VOCs)

such as solvent and gasoline vapours Both stationary and mobile emissions sources

contribute precursor pollutants that have the potential to result in the formation of

ground-level ozone

It has been estimated that 85 percent of ground-level ozone enters this region from the

North Eastern United States Central Canada and the American Mid-West (9) Elevated

levels generally occur in the summer under very warm conditions when large stable air

masses move up the eastern seaboard into the Fundy region Although the contribution of

local sources may pose an added stress to already deteriorating air quality conditions

during such episodes in general local sources are relatively minor contributors to ground-

level ozone levels experienced in our region Control programs in New Brunswick

specifically for ground-level ozone are therefore not able to reduce ambient

concentrations appreciably Despite this all measures which can reduce the emission of

ozone precursors are promoted such as the refinerys Fugitive Emissions Program Of

particular interest are programs where multiple environmental benefits may be expected

For example improving energy efficiency will reduce greenhouse gas emissions as well

as nitrogen oxides and sulphur dioxide Therefore efficiency measures are favoured over

measures exclusively targeting ground-level ozone

AIR QUALITY COMPLIANCE AND ENFORCEMENT

Compliance and Enforcement options used by the Department of Environment are

outlined in the Departments Compliance and Enforcement Policy (10) These may

include but are not limited to schedules of compliance warnings orders and

prosecutions Although not specifically outlined in the Policy it is also possible to amend

approvals with more stringent conditions both during its valid period or at the time of

renewal to address specific compliance issues or to improve the environmental impact of

the facility Most recently a new Regulation under the Clean Air Act allows for the

issuance of administrative penalties for minor violations as an alternative to

traditionally-used enforcement options

All sources of air emissions in the province are required to comply with the Clean Air Act

and Air Quality Regulation In addition to establishing ambient standards for

contaminants in air Section 3 of the Air Quality Regulation requires that no person shall

construct modify or operate a source without applying for and obtaining an

approvalrdquo The refinery currently operates under Approval to Operate I-8902 issued

July 1 2015 The current Approval expires on June 30 2020

APPROVAL AMENDMENTS and PROJECTS

The Approval was amended twice during the lifetime of the Approval

On November 15th 2015 the Approval was amended to update the operation and

maintenance of the ambient monitoring program that had been upgraded as well as

adding general GHG conditions to the Approval to include reporting and submitting a

Greenhouse Gas Management Plan

On December 21 2016 the Approval was amended to update the definition of Facility to

add the Hydrogen Recovery Unit (Plant 426) This was not a new unit at the Facility

however it was previously owned and operated by Air Liquid Canada and was

acquisitioned by Irving Oil on December 31 2016

On April 4 2017 an Approval to Construct the Tier 3 Gasoline Project was issued This

modification did not increase or change emissions at the refinery or increase the capacity

Compliance with the Approval to Operate

Following are the key issues addressed in the Approval to Operate for Irving Oil Refining

GP including comments on compliance with the associated conditions and actions taken

to achieve compliance with these conditions A summary of the key conditions are in

italics

Emergency Response and Reporting

Conditions 27 amp 28

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

This means that there are few emissions to the atmosphere There are several reasons for

this including safety environmental protection product recovery and economics The

lightest fractions produced by each processing unit are stripped of their saleable

components and the remaining gases called sour gas (because of the hydrogen sulphide it

contains) are sent to the Amine Sulphur Recovery Unit where the hydrogen sulphide is

removed The cleaned gas known as refinery fuel gas or sweet gas is used throughout

the refinery to provide product heating with minimal emissions

Recovered hydrogen sulphide gas is fed to the Sulphur Recovery UnitsHATGU where

the sulphur is recovered for sale to the fertilizer and pulp and paper industries Some

hydrogen sulphide gas is fed to the Sulphuric Acid Regeneration Unit where it is

converted to sulphuric acid and used in the alkylation process Approximately ninety nine

percent of the sulphur is recovered in this process with the rest being emitted through the

Sulphur Recovery Unit stacks as sulphur dioxide

Water is used in a variety of processes within the refinery to clean and cool product

streams Water that comes into direct contact with petroleum products becomes

contaminated and is likewise handled in a closed system The sour water that results from

these operations is cleaned of its impurities in the Sour Water Stripper where hydrogen

sulphide and ammonia are removed The recovered impurities are fed along with the

hydrogen sulphide from the Amine Recovery Unit to the Sulphur Recovery Units AND

hatgu

The refinery presently has

bull two Amine Sulphur Recovery Units (2450 mscfh recycle rate) and two Sour

Water Stripping Units (7600 BPD each) The second units in each case were

added during the upgrade to provide additional sulphur extraction capability as

well as redundancy for maintenance and other shutdown periods

bull a Tail Gas Unit to remove additional sulphur from the Sulphur Recovery Units

exhaust (tail) gas The original unit (Sulphuric Acid Tail Gas Unit) installed

during the upgrade did not operate as expected so the refinery was required to

propose a solution In 2008 a new unit was installed (the Hydrogenation Amine

Tail Gas Unit or HATGU) which is achieving the desired sulphur recovery

bull a Sulphuric Acid Regeneration Unit to regenerate spent sulphuric acid catalyst

from the Alkylation Plants and

bull two Sulphur Recovery Units (100 long tons per day each)

Flares

Process units are linked together in a system that allows for pressure relief of vessels

being shut down for maintenance or due to upset conditions such as a power interruption

The pressure is relieved by piping the excess product to one of three flares where the

hydrocarbons are combusted at a safe distance from people and equipment The flares are

equipped with smokeless technology and steam assisted air dispersion equipment The

flare system tips were upgraded in 2004 to reduce noise when additional steam is directed

to the flares In addition the No 1 flare was upgraded during the fall 2007 turnaround

and as a result of the newer technology employed noise levels have been reduced

FCCU Particulate Control

Particulate matter emissions from the FCCU are minimized by a series of cyclonic

separators Flue gases from the catalyst regenerator are passed through six sets of primary

and secondary cyclones where centrifugal forces cause the particulate matter to move to

the outside surface of the cyclones where they drop to the bottom and are removed Flue

gases from the secondary cyclones are sent to a third stage containing 80 high efficiency

cyclones and then to a fourth stage high-efficiency cyclone where the majority of the

remaining particulate is removed prior to it being released through the stack During the

2017 Turnaround the primary and secondary cyclones were replaced with an improved

design to improve steady state performance As the flue gas continues through each stage

the size and amount of the particles left in the stream decreases Recovered catalyst is

returned to the unit for re-use or recycled

FCCU Carbon Monoxide Control

As part of the 1976 refinery expansion a platinum combustion promoter was added to the

regenerator The promoter keeps the heat in the bottom of the regenerator where

combustion of carbon monoxide to carbon dioxide is completed without hazard and

reduces the concentration of the carbon monoxide emissions from approximately 10 to

001 percent

Particulate Matter and Sulphur Dioxide Control on RFCCU

A Flue Gas Scrubber (FGS) was installed as part of the Refinery Upgrade Project to

control emissions of particulate matter and sulphur dioxide from the RFCCU catalyst

regeneration process

Noise Control

Noise emissions from the refinery are controlled through the equipment selection

process a silencer to reduce noise on the FCCU was installed in 1995 in response to

concerns from neighbours around the refinery Noise mitigation is recognized as an

integral part of the design process and noise level specifications were included in the

upgrade project procurement process In the fall of 2007 the refinery conducted a noise

study as a requirement through their Approval to Operate Although the results of the

study showed noise to be within benchmark levels at their property line it did help

identify certain activities and units that contribute to slightly increased levels As a result

several process and mechanical changes were made (such as the installation of silencers)

to reduce intermittent noise levels

Hydrogen Plant Carbon Dioxide Control

Primary sources of carbon dioxide within the refinery are from fuel combustion and from

synthetic hydrogen production through steamnaphtha reforming In order to reduce the

refinerys emissions of carbon dioxide recycle a contaminant emission and produce a

saleable product Irving Oil Refining GP entered into a joint venture with Praxair

Canada Inc and constructed a carbon dioxide liquefaction plant in the Grandview

Industrial Park in 1997 Over half of the carbon dioxide emissions generated from the

hydrogen plant are recovered and recycled as a food grade product

Instrumentation and Stack Monitoring

The refinery re-instrumentation carried out between 1991 and 1993 allowed for more

frequent and precise control of all refinery processes This improved control allows the

optimization of refinery processes which contributes markedly to energy efficiency and

emission reductions During re-instrumentation a second fiber optic communication

backbone was installed which provides a backup for the control system and allows the

refinery to continue safe operation in the event that a portion of the control system

becomes inoperable

Stack emissions are monitored for a number of parameters In some cases the monitors

provide direct measurements of contaminant concentrations such as the sulphur dioxide

continuous emission monitors on the sulphur plant stacks In other cases such as the

furnaces boilers and the FCCU process parameters including fuel flow oxygen and

temperature are continuously measured These measurements allow for optimal control of

the process as well as in combination with frequent fuel sulphur analysis for the

calculation of sulphur dioxide emissions

Continuous Emission Monitors (CEMs) for sulphur dioxide and nitrogen oxides are

operational on the Flue Gas Scrubber the Tail Gas Unit and the Sulphuric Acid

Regeneration Unit During the construction of the Grandview Cogeneration Project

CEMs for sulphur dioxide and nitrogen oxides were installed on both HRSGs

Operational Procedures

The refinery burns refinery fuel gas (sweet gas) to provide heat for the refining process

Of the existing total of 26 stacks all but the FCCU emit flue gases from the combustion

of refinery fuel gas

Adherence to the Sulphur Dioxide Response Plan also contributes to reducing emissions

and minimizing their impact The operating approval requires the refinery to implement

the plan when ambient sulphur dioxide concentrations are above 8 parts per hundred

million (pphm) which is approximately one half the maximum permissible 1-hour

ground level concentrations of sulphur dioxide at any one of five ambient monitors

In order to conserve energy process heaters and boilers are operated near stoichiometric

(ideal) conditions that is the minimum amount of air required is used to enable complete

combustion of the fuels This operating objective has the benefit of minimizing emissions

of all contaminants

Shutdown start-up and maintenance procedures are designed to minimize emissions

During planned shutdowns units are steamed out and the resulting hydrocarbon mixture

is burned in the flare(s) with clean fuels such as propane or LPG to minimize the

hydrocarbon emissions Wherever possible mechanical procedures are now employed to

remove coke build-up on boiler tubes as opposed to the previous practice of slowly

burning the coke out Further during maintenance of the sulphur plants or associated

units the refinery uses low sulphur crude to reduce the load on the operating sulphur

recovery plant

Product Quality

Product (fuel) quality affects emissions at the refinery level during product distribution

and in product usage Changes to fuel quality are frequently driven by environmental and

health concerns and often become requirements of national fuel regulations in Canada

and the United States

The Alkylation Unit (to reduce volatile organic compound (VOC) emissions) and

Dehexanizer (for US reformulated gasoline) are process units that were installed between

1987 and 1994 as a result of new Canadian and US federal gasoline regulations aimed at

reducing emissions from both gasoline storage and use

More recent federal environmental initiatives necessitated the upgrade to the Diesel

Hydrodesulphurizer and the Hydrocracker in 1995 which allowed production of low

sulphur diesel This became a requirement in 1998 as a result of the Diesel Fuel

Regulations (3) The Aromatics Saturation Unit was constructed in 1997-98 to reduce the

benzene content in gasoline as required by the Benzene in Gasoline Regulations (4) The

CD-Tech Unit installed in 2003 as part of the RFCCU provides enhanced capability to

ensure that the Sulphur in Gasoline Regulations (5) are met Irving Oil has also made

infrastructure improvements such as new pipelines in preparation for adherence with the

ultra-low sulphur diesel requirements mandated under the Sulphur in Diesel Fuel

Regulations (6) In 2006 the hydrocracker was converted into a diesel treater to help

meet these requirements

The Ultra-Low Sulphur Gasoline Regulations had required an average gasoline sulphur

content of 30 ppm or lower In January 2017 Federal Tier 3 gasoline regulations were

implemented requiring an annual average gasoline sulphur content of 10 ppm The

refinery operations determined that gas desulphurization combined product sulphur of 15

ppm would be required in order to meet the Tier 3 regulation under various operating

scenarios An additional hydrotreating step was installed to the existing Gasoline

Desulphurization Unit (GDS) which is a two-step hydrotreating unit in order to meet a

desired sulphur content of 15 ppm Combining the remaining gasoline blend components

with the hydrotreated stream allows the annual average combined sulphur in gasoline to

meet the 10 ppm regulation

Fugitive Emissions Programs

In 1993 the Irving Oil Refinery began an annual program aimed at reducing its

contribution to ground-level ozone in keeping with the Code of Practice for the

Measurement and Control of Fugitive VOC Emissions from Equipment Leaks October

1993 (7) established by the Canadian Council of Ministers of the Environment (CCME)

This program is comprised of the detection and repair of leaks (fugitive emissions) from

specific process components such as pump seals valves flanges vents connectors and

compressor seals The detection component of the program began in 1993 The program

was expanded to include the repair of leaking components in 1995 When a repair cannot

be made immediately it is scheduled for the next available maintenance turnaround

In addition all Irving Oil Refining GP storage tanks are required to be maintained in

accordance with the CCME Environmental Guidelines for Controlling Emissions of

Volatile Organic Compounds from Aboveground Storage Tanks June 1995 (8) and the

requirements of this guideline have been incorporated into an annual tank reliability

program carried out by the refinery

An odour study was completed throughout the previous Approval lifetime that identified

odour issues that were addressed through various action items and process improvements

POTENTIAL AIR QUALITY CONTAMINANTS

The refinery is situated in east Saint John and although it is in an industrial area there are

several residential areas within close proximity Emissions from the refinery come from

four main source areas

bull Sulphur Block (includes two Sulphur Recovery Units the Tail Gas Unit and the

Sulphuric Acid Regeneration Unit) where although 99 percent of the sulphur fed

to the units is recovered less than 1 percent is released to the atmosphere as

sulphur dioxide as well as small amounts of nitrogen oxides particulate matter

and carbon dioxide

bull Refinery Boilers and the No 3 Crude Unit fired heaters where refinery fuel gas

combustion results in the emission of sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and

hydrocarbons

bull FCCU catalyst regenerator where sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and hydrocarbons

are emitted

bull FGS where nitrogen oxides particulate matter carbon dioxide and small amounts

of sulphur dioxide and carbon monoxide are emitted

Fugitive emissions can also have an effect on local air quality

POTENTIAL IMPACTS OF AIR EMISSIONS

Acid Deposition

Emissions of sulphur dioxide and nitrogen oxides can be transformed in the atmosphere

to acidic particles which ultimately fallout as acid deposition (acid rain is one way in

which this deposition occurs) This deposition can occur far from the original source of

the emissions The majority of the acid deposition measured in New Brunswick is caused

by emission sources in the US mid-west and central Canada Generally speaking acid

deposition in New Brunswick has shown significant improvement through national and

international efforts to reduce acid causing emissions primarily through controlling

emissions of sulphur dioxide

The Department continues to report the acid disposition measurements in the Annual Air

Quality Report

Climate Change

When fossil fuels are burned it results in the generation of greenhouse gases (GHG) such

as carbon dioxide (CO2) and methane (CH4) which are the main contributors to the

problem of climate change The Department has been working on a Climate Change

Action Plan for several years and the Approval has a number of conditions related to

reporting and improvements in greenhouse gas emissions

Ground-Level Ozone

Ozone (O3) is a reactive unstable form of oxygen It is not emitted directly from stacks or

exhaust pipes but it is formed as a result of photochemical reactions between other

pollutants most importantly nitrogen oxides and volatile organic compounds (VOCs)

such as solvent and gasoline vapours Both stationary and mobile emissions sources

contribute precursor pollutants that have the potential to result in the formation of

ground-level ozone

It has been estimated that 85 percent of ground-level ozone enters this region from the

North Eastern United States Central Canada and the American Mid-West (9) Elevated

levels generally occur in the summer under very warm conditions when large stable air

masses move up the eastern seaboard into the Fundy region Although the contribution of

local sources may pose an added stress to already deteriorating air quality conditions

during such episodes in general local sources are relatively minor contributors to ground-

level ozone levels experienced in our region Control programs in New Brunswick

specifically for ground-level ozone are therefore not able to reduce ambient

concentrations appreciably Despite this all measures which can reduce the emission of

ozone precursors are promoted such as the refinerys Fugitive Emissions Program Of

particular interest are programs where multiple environmental benefits may be expected

For example improving energy efficiency will reduce greenhouse gas emissions as well

as nitrogen oxides and sulphur dioxide Therefore efficiency measures are favoured over

measures exclusively targeting ground-level ozone

AIR QUALITY COMPLIANCE AND ENFORCEMENT

Compliance and Enforcement options used by the Department of Environment are

outlined in the Departments Compliance and Enforcement Policy (10) These may

include but are not limited to schedules of compliance warnings orders and

prosecutions Although not specifically outlined in the Policy it is also possible to amend

approvals with more stringent conditions both during its valid period or at the time of

renewal to address specific compliance issues or to improve the environmental impact of

the facility Most recently a new Regulation under the Clean Air Act allows for the

issuance of administrative penalties for minor violations as an alternative to

traditionally-used enforcement options

All sources of air emissions in the province are required to comply with the Clean Air Act

and Air Quality Regulation In addition to establishing ambient standards for

contaminants in air Section 3 of the Air Quality Regulation requires that no person shall

construct modify or operate a source without applying for and obtaining an

approvalrdquo The refinery currently operates under Approval to Operate I-8902 issued

July 1 2015 The current Approval expires on June 30 2020

APPROVAL AMENDMENTS and PROJECTS

The Approval was amended twice during the lifetime of the Approval

On November 15th 2015 the Approval was amended to update the operation and

maintenance of the ambient monitoring program that had been upgraded as well as

adding general GHG conditions to the Approval to include reporting and submitting a

Greenhouse Gas Management Plan

On December 21 2016 the Approval was amended to update the definition of Facility to

add the Hydrogen Recovery Unit (Plant 426) This was not a new unit at the Facility

however it was previously owned and operated by Air Liquid Canada and was

acquisitioned by Irving Oil on December 31 2016

On April 4 2017 an Approval to Construct the Tier 3 Gasoline Project was issued This

modification did not increase or change emissions at the refinery or increase the capacity

Compliance with the Approval to Operate

Following are the key issues addressed in the Approval to Operate for Irving Oil Refining

GP including comments on compliance with the associated conditions and actions taken

to achieve compliance with these conditions A summary of the key conditions are in

italics

Emergency Response and Reporting

Conditions 27 amp 28

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

to the flares In addition the No 1 flare was upgraded during the fall 2007 turnaround

and as a result of the newer technology employed noise levels have been reduced

FCCU Particulate Control

Particulate matter emissions from the FCCU are minimized by a series of cyclonic

separators Flue gases from the catalyst regenerator are passed through six sets of primary

and secondary cyclones where centrifugal forces cause the particulate matter to move to

the outside surface of the cyclones where they drop to the bottom and are removed Flue

gases from the secondary cyclones are sent to a third stage containing 80 high efficiency

cyclones and then to a fourth stage high-efficiency cyclone where the majority of the

remaining particulate is removed prior to it being released through the stack During the

2017 Turnaround the primary and secondary cyclones were replaced with an improved

design to improve steady state performance As the flue gas continues through each stage

the size and amount of the particles left in the stream decreases Recovered catalyst is

returned to the unit for re-use or recycled

FCCU Carbon Monoxide Control

As part of the 1976 refinery expansion a platinum combustion promoter was added to the

regenerator The promoter keeps the heat in the bottom of the regenerator where

combustion of carbon monoxide to carbon dioxide is completed without hazard and

reduces the concentration of the carbon monoxide emissions from approximately 10 to

001 percent

Particulate Matter and Sulphur Dioxide Control on RFCCU

A Flue Gas Scrubber (FGS) was installed as part of the Refinery Upgrade Project to

control emissions of particulate matter and sulphur dioxide from the RFCCU catalyst

regeneration process

Noise Control

Noise emissions from the refinery are controlled through the equipment selection

process a silencer to reduce noise on the FCCU was installed in 1995 in response to

concerns from neighbours around the refinery Noise mitigation is recognized as an

integral part of the design process and noise level specifications were included in the

upgrade project procurement process In the fall of 2007 the refinery conducted a noise

study as a requirement through their Approval to Operate Although the results of the

study showed noise to be within benchmark levels at their property line it did help

identify certain activities and units that contribute to slightly increased levels As a result

several process and mechanical changes were made (such as the installation of silencers)

to reduce intermittent noise levels

Hydrogen Plant Carbon Dioxide Control

Primary sources of carbon dioxide within the refinery are from fuel combustion and from

synthetic hydrogen production through steamnaphtha reforming In order to reduce the

refinerys emissions of carbon dioxide recycle a contaminant emission and produce a

saleable product Irving Oil Refining GP entered into a joint venture with Praxair

Canada Inc and constructed a carbon dioxide liquefaction plant in the Grandview

Industrial Park in 1997 Over half of the carbon dioxide emissions generated from the

hydrogen plant are recovered and recycled as a food grade product

Instrumentation and Stack Monitoring

The refinery re-instrumentation carried out between 1991 and 1993 allowed for more

frequent and precise control of all refinery processes This improved control allows the

optimization of refinery processes which contributes markedly to energy efficiency and

emission reductions During re-instrumentation a second fiber optic communication

backbone was installed which provides a backup for the control system and allows the

refinery to continue safe operation in the event that a portion of the control system

becomes inoperable

Stack emissions are monitored for a number of parameters In some cases the monitors

provide direct measurements of contaminant concentrations such as the sulphur dioxide

continuous emission monitors on the sulphur plant stacks In other cases such as the

furnaces boilers and the FCCU process parameters including fuel flow oxygen and

temperature are continuously measured These measurements allow for optimal control of

the process as well as in combination with frequent fuel sulphur analysis for the

calculation of sulphur dioxide emissions

Continuous Emission Monitors (CEMs) for sulphur dioxide and nitrogen oxides are

operational on the Flue Gas Scrubber the Tail Gas Unit and the Sulphuric Acid

Regeneration Unit During the construction of the Grandview Cogeneration Project

CEMs for sulphur dioxide and nitrogen oxides were installed on both HRSGs

Operational Procedures

The refinery burns refinery fuel gas (sweet gas) to provide heat for the refining process

Of the existing total of 26 stacks all but the FCCU emit flue gases from the combustion

of refinery fuel gas

Adherence to the Sulphur Dioxide Response Plan also contributes to reducing emissions

and minimizing their impact The operating approval requires the refinery to implement

the plan when ambient sulphur dioxide concentrations are above 8 parts per hundred

million (pphm) which is approximately one half the maximum permissible 1-hour

ground level concentrations of sulphur dioxide at any one of five ambient monitors

In order to conserve energy process heaters and boilers are operated near stoichiometric

(ideal) conditions that is the minimum amount of air required is used to enable complete

combustion of the fuels This operating objective has the benefit of minimizing emissions

of all contaminants

Shutdown start-up and maintenance procedures are designed to minimize emissions

During planned shutdowns units are steamed out and the resulting hydrocarbon mixture

is burned in the flare(s) with clean fuels such as propane or LPG to minimize the

hydrocarbon emissions Wherever possible mechanical procedures are now employed to

remove coke build-up on boiler tubes as opposed to the previous practice of slowly

burning the coke out Further during maintenance of the sulphur plants or associated

units the refinery uses low sulphur crude to reduce the load on the operating sulphur

recovery plant

Product Quality

Product (fuel) quality affects emissions at the refinery level during product distribution

and in product usage Changes to fuel quality are frequently driven by environmental and

health concerns and often become requirements of national fuel regulations in Canada

and the United States

The Alkylation Unit (to reduce volatile organic compound (VOC) emissions) and

Dehexanizer (for US reformulated gasoline) are process units that were installed between

1987 and 1994 as a result of new Canadian and US federal gasoline regulations aimed at

reducing emissions from both gasoline storage and use

More recent federal environmental initiatives necessitated the upgrade to the Diesel

Hydrodesulphurizer and the Hydrocracker in 1995 which allowed production of low

sulphur diesel This became a requirement in 1998 as a result of the Diesel Fuel

Regulations (3) The Aromatics Saturation Unit was constructed in 1997-98 to reduce the

benzene content in gasoline as required by the Benzene in Gasoline Regulations (4) The

CD-Tech Unit installed in 2003 as part of the RFCCU provides enhanced capability to

ensure that the Sulphur in Gasoline Regulations (5) are met Irving Oil has also made

infrastructure improvements such as new pipelines in preparation for adherence with the

ultra-low sulphur diesel requirements mandated under the Sulphur in Diesel Fuel

Regulations (6) In 2006 the hydrocracker was converted into a diesel treater to help

meet these requirements

The Ultra-Low Sulphur Gasoline Regulations had required an average gasoline sulphur

content of 30 ppm or lower In January 2017 Federal Tier 3 gasoline regulations were

implemented requiring an annual average gasoline sulphur content of 10 ppm The

refinery operations determined that gas desulphurization combined product sulphur of 15

ppm would be required in order to meet the Tier 3 regulation under various operating

scenarios An additional hydrotreating step was installed to the existing Gasoline

Desulphurization Unit (GDS) which is a two-step hydrotreating unit in order to meet a

desired sulphur content of 15 ppm Combining the remaining gasoline blend components

with the hydrotreated stream allows the annual average combined sulphur in gasoline to

meet the 10 ppm regulation

Fugitive Emissions Programs

In 1993 the Irving Oil Refinery began an annual program aimed at reducing its

contribution to ground-level ozone in keeping with the Code of Practice for the

Measurement and Control of Fugitive VOC Emissions from Equipment Leaks October

1993 (7) established by the Canadian Council of Ministers of the Environment (CCME)

This program is comprised of the detection and repair of leaks (fugitive emissions) from

specific process components such as pump seals valves flanges vents connectors and

compressor seals The detection component of the program began in 1993 The program

was expanded to include the repair of leaking components in 1995 When a repair cannot

be made immediately it is scheduled for the next available maintenance turnaround

In addition all Irving Oil Refining GP storage tanks are required to be maintained in

accordance with the CCME Environmental Guidelines for Controlling Emissions of

Volatile Organic Compounds from Aboveground Storage Tanks June 1995 (8) and the

requirements of this guideline have been incorporated into an annual tank reliability

program carried out by the refinery

An odour study was completed throughout the previous Approval lifetime that identified

odour issues that were addressed through various action items and process improvements

POTENTIAL AIR QUALITY CONTAMINANTS

The refinery is situated in east Saint John and although it is in an industrial area there are

several residential areas within close proximity Emissions from the refinery come from

four main source areas

bull Sulphur Block (includes two Sulphur Recovery Units the Tail Gas Unit and the

Sulphuric Acid Regeneration Unit) where although 99 percent of the sulphur fed

to the units is recovered less than 1 percent is released to the atmosphere as

sulphur dioxide as well as small amounts of nitrogen oxides particulate matter

and carbon dioxide

bull Refinery Boilers and the No 3 Crude Unit fired heaters where refinery fuel gas

combustion results in the emission of sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and

hydrocarbons

bull FCCU catalyst regenerator where sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and hydrocarbons

are emitted

bull FGS where nitrogen oxides particulate matter carbon dioxide and small amounts

of sulphur dioxide and carbon monoxide are emitted

Fugitive emissions can also have an effect on local air quality

POTENTIAL IMPACTS OF AIR EMISSIONS

Acid Deposition

Emissions of sulphur dioxide and nitrogen oxides can be transformed in the atmosphere

to acidic particles which ultimately fallout as acid deposition (acid rain is one way in

which this deposition occurs) This deposition can occur far from the original source of

the emissions The majority of the acid deposition measured in New Brunswick is caused

by emission sources in the US mid-west and central Canada Generally speaking acid

deposition in New Brunswick has shown significant improvement through national and

international efforts to reduce acid causing emissions primarily through controlling

emissions of sulphur dioxide

The Department continues to report the acid disposition measurements in the Annual Air

Quality Report

Climate Change

When fossil fuels are burned it results in the generation of greenhouse gases (GHG) such

as carbon dioxide (CO2) and methane (CH4) which are the main contributors to the

problem of climate change The Department has been working on a Climate Change

Action Plan for several years and the Approval has a number of conditions related to

reporting and improvements in greenhouse gas emissions

Ground-Level Ozone

Ozone (O3) is a reactive unstable form of oxygen It is not emitted directly from stacks or

exhaust pipes but it is formed as a result of photochemical reactions between other

pollutants most importantly nitrogen oxides and volatile organic compounds (VOCs)

such as solvent and gasoline vapours Both stationary and mobile emissions sources

contribute precursor pollutants that have the potential to result in the formation of

ground-level ozone

It has been estimated that 85 percent of ground-level ozone enters this region from the

North Eastern United States Central Canada and the American Mid-West (9) Elevated

levels generally occur in the summer under very warm conditions when large stable air

masses move up the eastern seaboard into the Fundy region Although the contribution of

local sources may pose an added stress to already deteriorating air quality conditions

during such episodes in general local sources are relatively minor contributors to ground-

level ozone levels experienced in our region Control programs in New Brunswick

specifically for ground-level ozone are therefore not able to reduce ambient

concentrations appreciably Despite this all measures which can reduce the emission of

ozone precursors are promoted such as the refinerys Fugitive Emissions Program Of

particular interest are programs where multiple environmental benefits may be expected

For example improving energy efficiency will reduce greenhouse gas emissions as well

as nitrogen oxides and sulphur dioxide Therefore efficiency measures are favoured over

measures exclusively targeting ground-level ozone

AIR QUALITY COMPLIANCE AND ENFORCEMENT

Compliance and Enforcement options used by the Department of Environment are

outlined in the Departments Compliance and Enforcement Policy (10) These may

include but are not limited to schedules of compliance warnings orders and

prosecutions Although not specifically outlined in the Policy it is also possible to amend

approvals with more stringent conditions both during its valid period or at the time of

renewal to address specific compliance issues or to improve the environmental impact of

the facility Most recently a new Regulation under the Clean Air Act allows for the

issuance of administrative penalties for minor violations as an alternative to

traditionally-used enforcement options

All sources of air emissions in the province are required to comply with the Clean Air Act

and Air Quality Regulation In addition to establishing ambient standards for

contaminants in air Section 3 of the Air Quality Regulation requires that no person shall

construct modify or operate a source without applying for and obtaining an

approvalrdquo The refinery currently operates under Approval to Operate I-8902 issued

July 1 2015 The current Approval expires on June 30 2020

APPROVAL AMENDMENTS and PROJECTS

The Approval was amended twice during the lifetime of the Approval

On November 15th 2015 the Approval was amended to update the operation and

maintenance of the ambient monitoring program that had been upgraded as well as

adding general GHG conditions to the Approval to include reporting and submitting a

Greenhouse Gas Management Plan

On December 21 2016 the Approval was amended to update the definition of Facility to

add the Hydrogen Recovery Unit (Plant 426) This was not a new unit at the Facility

however it was previously owned and operated by Air Liquid Canada and was

acquisitioned by Irving Oil on December 31 2016

On April 4 2017 an Approval to Construct the Tier 3 Gasoline Project was issued This

modification did not increase or change emissions at the refinery or increase the capacity

Compliance with the Approval to Operate

Following are the key issues addressed in the Approval to Operate for Irving Oil Refining

GP including comments on compliance with the associated conditions and actions taken

to achieve compliance with these conditions A summary of the key conditions are in

italics

Emergency Response and Reporting

Conditions 27 amp 28

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

Hydrogen Plant Carbon Dioxide Control

Primary sources of carbon dioxide within the refinery are from fuel combustion and from

synthetic hydrogen production through steamnaphtha reforming In order to reduce the

refinerys emissions of carbon dioxide recycle a contaminant emission and produce a

saleable product Irving Oil Refining GP entered into a joint venture with Praxair

Canada Inc and constructed a carbon dioxide liquefaction plant in the Grandview

Industrial Park in 1997 Over half of the carbon dioxide emissions generated from the

hydrogen plant are recovered and recycled as a food grade product

Instrumentation and Stack Monitoring

The refinery re-instrumentation carried out between 1991 and 1993 allowed for more

frequent and precise control of all refinery processes This improved control allows the

optimization of refinery processes which contributes markedly to energy efficiency and

emission reductions During re-instrumentation a second fiber optic communication

backbone was installed which provides a backup for the control system and allows the

refinery to continue safe operation in the event that a portion of the control system

becomes inoperable

Stack emissions are monitored for a number of parameters In some cases the monitors

provide direct measurements of contaminant concentrations such as the sulphur dioxide

continuous emission monitors on the sulphur plant stacks In other cases such as the

furnaces boilers and the FCCU process parameters including fuel flow oxygen and

temperature are continuously measured These measurements allow for optimal control of

the process as well as in combination with frequent fuel sulphur analysis for the

calculation of sulphur dioxide emissions

Continuous Emission Monitors (CEMs) for sulphur dioxide and nitrogen oxides are

operational on the Flue Gas Scrubber the Tail Gas Unit and the Sulphuric Acid

Regeneration Unit During the construction of the Grandview Cogeneration Project

CEMs for sulphur dioxide and nitrogen oxides were installed on both HRSGs

Operational Procedures

The refinery burns refinery fuel gas (sweet gas) to provide heat for the refining process

Of the existing total of 26 stacks all but the FCCU emit flue gases from the combustion

of refinery fuel gas

Adherence to the Sulphur Dioxide Response Plan also contributes to reducing emissions

and minimizing their impact The operating approval requires the refinery to implement

the plan when ambient sulphur dioxide concentrations are above 8 parts per hundred

million (pphm) which is approximately one half the maximum permissible 1-hour

ground level concentrations of sulphur dioxide at any one of five ambient monitors

In order to conserve energy process heaters and boilers are operated near stoichiometric

(ideal) conditions that is the minimum amount of air required is used to enable complete

combustion of the fuels This operating objective has the benefit of minimizing emissions

of all contaminants

Shutdown start-up and maintenance procedures are designed to minimize emissions

During planned shutdowns units are steamed out and the resulting hydrocarbon mixture

is burned in the flare(s) with clean fuels such as propane or LPG to minimize the

hydrocarbon emissions Wherever possible mechanical procedures are now employed to

remove coke build-up on boiler tubes as opposed to the previous practice of slowly

burning the coke out Further during maintenance of the sulphur plants or associated

units the refinery uses low sulphur crude to reduce the load on the operating sulphur

recovery plant

Product Quality

Product (fuel) quality affects emissions at the refinery level during product distribution

and in product usage Changes to fuel quality are frequently driven by environmental and

health concerns and often become requirements of national fuel regulations in Canada

and the United States

The Alkylation Unit (to reduce volatile organic compound (VOC) emissions) and

Dehexanizer (for US reformulated gasoline) are process units that were installed between

1987 and 1994 as a result of new Canadian and US federal gasoline regulations aimed at

reducing emissions from both gasoline storage and use

More recent federal environmental initiatives necessitated the upgrade to the Diesel

Hydrodesulphurizer and the Hydrocracker in 1995 which allowed production of low

sulphur diesel This became a requirement in 1998 as a result of the Diesel Fuel

Regulations (3) The Aromatics Saturation Unit was constructed in 1997-98 to reduce the

benzene content in gasoline as required by the Benzene in Gasoline Regulations (4) The

CD-Tech Unit installed in 2003 as part of the RFCCU provides enhanced capability to

ensure that the Sulphur in Gasoline Regulations (5) are met Irving Oil has also made

infrastructure improvements such as new pipelines in preparation for adherence with the

ultra-low sulphur diesel requirements mandated under the Sulphur in Diesel Fuel

Regulations (6) In 2006 the hydrocracker was converted into a diesel treater to help

meet these requirements

The Ultra-Low Sulphur Gasoline Regulations had required an average gasoline sulphur

content of 30 ppm or lower In January 2017 Federal Tier 3 gasoline regulations were

implemented requiring an annual average gasoline sulphur content of 10 ppm The

refinery operations determined that gas desulphurization combined product sulphur of 15

ppm would be required in order to meet the Tier 3 regulation under various operating

scenarios An additional hydrotreating step was installed to the existing Gasoline

Desulphurization Unit (GDS) which is a two-step hydrotreating unit in order to meet a

desired sulphur content of 15 ppm Combining the remaining gasoline blend components

with the hydrotreated stream allows the annual average combined sulphur in gasoline to

meet the 10 ppm regulation

Fugitive Emissions Programs

In 1993 the Irving Oil Refinery began an annual program aimed at reducing its

contribution to ground-level ozone in keeping with the Code of Practice for the

Measurement and Control of Fugitive VOC Emissions from Equipment Leaks October

1993 (7) established by the Canadian Council of Ministers of the Environment (CCME)

This program is comprised of the detection and repair of leaks (fugitive emissions) from

specific process components such as pump seals valves flanges vents connectors and

compressor seals The detection component of the program began in 1993 The program

was expanded to include the repair of leaking components in 1995 When a repair cannot

be made immediately it is scheduled for the next available maintenance turnaround

In addition all Irving Oil Refining GP storage tanks are required to be maintained in

accordance with the CCME Environmental Guidelines for Controlling Emissions of

Volatile Organic Compounds from Aboveground Storage Tanks June 1995 (8) and the

requirements of this guideline have been incorporated into an annual tank reliability

program carried out by the refinery

An odour study was completed throughout the previous Approval lifetime that identified

odour issues that were addressed through various action items and process improvements

POTENTIAL AIR QUALITY CONTAMINANTS

The refinery is situated in east Saint John and although it is in an industrial area there are

several residential areas within close proximity Emissions from the refinery come from

four main source areas

bull Sulphur Block (includes two Sulphur Recovery Units the Tail Gas Unit and the

Sulphuric Acid Regeneration Unit) where although 99 percent of the sulphur fed

to the units is recovered less than 1 percent is released to the atmosphere as

sulphur dioxide as well as small amounts of nitrogen oxides particulate matter

and carbon dioxide

bull Refinery Boilers and the No 3 Crude Unit fired heaters where refinery fuel gas

combustion results in the emission of sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and

hydrocarbons

bull FCCU catalyst regenerator where sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and hydrocarbons

are emitted

bull FGS where nitrogen oxides particulate matter carbon dioxide and small amounts

of sulphur dioxide and carbon monoxide are emitted

Fugitive emissions can also have an effect on local air quality

POTENTIAL IMPACTS OF AIR EMISSIONS

Acid Deposition

Emissions of sulphur dioxide and nitrogen oxides can be transformed in the atmosphere

to acidic particles which ultimately fallout as acid deposition (acid rain is one way in

which this deposition occurs) This deposition can occur far from the original source of

the emissions The majority of the acid deposition measured in New Brunswick is caused

by emission sources in the US mid-west and central Canada Generally speaking acid

deposition in New Brunswick has shown significant improvement through national and

international efforts to reduce acid causing emissions primarily through controlling

emissions of sulphur dioxide

The Department continues to report the acid disposition measurements in the Annual Air

Quality Report

Climate Change

When fossil fuels are burned it results in the generation of greenhouse gases (GHG) such

as carbon dioxide (CO2) and methane (CH4) which are the main contributors to the

problem of climate change The Department has been working on a Climate Change

Action Plan for several years and the Approval has a number of conditions related to

reporting and improvements in greenhouse gas emissions

Ground-Level Ozone

Ozone (O3) is a reactive unstable form of oxygen It is not emitted directly from stacks or

exhaust pipes but it is formed as a result of photochemical reactions between other

pollutants most importantly nitrogen oxides and volatile organic compounds (VOCs)

such as solvent and gasoline vapours Both stationary and mobile emissions sources

contribute precursor pollutants that have the potential to result in the formation of

ground-level ozone

It has been estimated that 85 percent of ground-level ozone enters this region from the

North Eastern United States Central Canada and the American Mid-West (9) Elevated

levels generally occur in the summer under very warm conditions when large stable air

masses move up the eastern seaboard into the Fundy region Although the contribution of

local sources may pose an added stress to already deteriorating air quality conditions

during such episodes in general local sources are relatively minor contributors to ground-

level ozone levels experienced in our region Control programs in New Brunswick

specifically for ground-level ozone are therefore not able to reduce ambient

concentrations appreciably Despite this all measures which can reduce the emission of

ozone precursors are promoted such as the refinerys Fugitive Emissions Program Of

particular interest are programs where multiple environmental benefits may be expected

For example improving energy efficiency will reduce greenhouse gas emissions as well

as nitrogen oxides and sulphur dioxide Therefore efficiency measures are favoured over

measures exclusively targeting ground-level ozone

AIR QUALITY COMPLIANCE AND ENFORCEMENT

Compliance and Enforcement options used by the Department of Environment are

outlined in the Departments Compliance and Enforcement Policy (10) These may

include but are not limited to schedules of compliance warnings orders and

prosecutions Although not specifically outlined in the Policy it is also possible to amend

approvals with more stringent conditions both during its valid period or at the time of

renewal to address specific compliance issues or to improve the environmental impact of

the facility Most recently a new Regulation under the Clean Air Act allows for the

issuance of administrative penalties for minor violations as an alternative to

traditionally-used enforcement options

All sources of air emissions in the province are required to comply with the Clean Air Act

and Air Quality Regulation In addition to establishing ambient standards for

contaminants in air Section 3 of the Air Quality Regulation requires that no person shall

construct modify or operate a source without applying for and obtaining an

approvalrdquo The refinery currently operates under Approval to Operate I-8902 issued

July 1 2015 The current Approval expires on June 30 2020

APPROVAL AMENDMENTS and PROJECTS

The Approval was amended twice during the lifetime of the Approval

On November 15th 2015 the Approval was amended to update the operation and

maintenance of the ambient monitoring program that had been upgraded as well as

adding general GHG conditions to the Approval to include reporting and submitting a

Greenhouse Gas Management Plan

On December 21 2016 the Approval was amended to update the definition of Facility to

add the Hydrogen Recovery Unit (Plant 426) This was not a new unit at the Facility

however it was previously owned and operated by Air Liquid Canada and was

acquisitioned by Irving Oil on December 31 2016

On April 4 2017 an Approval to Construct the Tier 3 Gasoline Project was issued This

modification did not increase or change emissions at the refinery or increase the capacity

Compliance with the Approval to Operate

Following are the key issues addressed in the Approval to Operate for Irving Oil Refining

GP including comments on compliance with the associated conditions and actions taken

to achieve compliance with these conditions A summary of the key conditions are in

italics

Emergency Response and Reporting

Conditions 27 amp 28

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

(ideal) conditions that is the minimum amount of air required is used to enable complete

combustion of the fuels This operating objective has the benefit of minimizing emissions

of all contaminants

Shutdown start-up and maintenance procedures are designed to minimize emissions

During planned shutdowns units are steamed out and the resulting hydrocarbon mixture

is burned in the flare(s) with clean fuels such as propane or LPG to minimize the

hydrocarbon emissions Wherever possible mechanical procedures are now employed to

remove coke build-up on boiler tubes as opposed to the previous practice of slowly

burning the coke out Further during maintenance of the sulphur plants or associated

units the refinery uses low sulphur crude to reduce the load on the operating sulphur

recovery plant

Product Quality

Product (fuel) quality affects emissions at the refinery level during product distribution

and in product usage Changes to fuel quality are frequently driven by environmental and

health concerns and often become requirements of national fuel regulations in Canada

and the United States

The Alkylation Unit (to reduce volatile organic compound (VOC) emissions) and

Dehexanizer (for US reformulated gasoline) are process units that were installed between

1987 and 1994 as a result of new Canadian and US federal gasoline regulations aimed at

reducing emissions from both gasoline storage and use

More recent federal environmental initiatives necessitated the upgrade to the Diesel

Hydrodesulphurizer and the Hydrocracker in 1995 which allowed production of low

sulphur diesel This became a requirement in 1998 as a result of the Diesel Fuel

Regulations (3) The Aromatics Saturation Unit was constructed in 1997-98 to reduce the

benzene content in gasoline as required by the Benzene in Gasoline Regulations (4) The

CD-Tech Unit installed in 2003 as part of the RFCCU provides enhanced capability to

ensure that the Sulphur in Gasoline Regulations (5) are met Irving Oil has also made

infrastructure improvements such as new pipelines in preparation for adherence with the

ultra-low sulphur diesel requirements mandated under the Sulphur in Diesel Fuel

Regulations (6) In 2006 the hydrocracker was converted into a diesel treater to help

meet these requirements

The Ultra-Low Sulphur Gasoline Regulations had required an average gasoline sulphur

content of 30 ppm or lower In January 2017 Federal Tier 3 gasoline regulations were

implemented requiring an annual average gasoline sulphur content of 10 ppm The

refinery operations determined that gas desulphurization combined product sulphur of 15

ppm would be required in order to meet the Tier 3 regulation under various operating

scenarios An additional hydrotreating step was installed to the existing Gasoline

Desulphurization Unit (GDS) which is a two-step hydrotreating unit in order to meet a

desired sulphur content of 15 ppm Combining the remaining gasoline blend components

with the hydrotreated stream allows the annual average combined sulphur in gasoline to

meet the 10 ppm regulation

Fugitive Emissions Programs

In 1993 the Irving Oil Refinery began an annual program aimed at reducing its

contribution to ground-level ozone in keeping with the Code of Practice for the

Measurement and Control of Fugitive VOC Emissions from Equipment Leaks October

1993 (7) established by the Canadian Council of Ministers of the Environment (CCME)

This program is comprised of the detection and repair of leaks (fugitive emissions) from

specific process components such as pump seals valves flanges vents connectors and

compressor seals The detection component of the program began in 1993 The program

was expanded to include the repair of leaking components in 1995 When a repair cannot

be made immediately it is scheduled for the next available maintenance turnaround

In addition all Irving Oil Refining GP storage tanks are required to be maintained in

accordance with the CCME Environmental Guidelines for Controlling Emissions of

Volatile Organic Compounds from Aboveground Storage Tanks June 1995 (8) and the

requirements of this guideline have been incorporated into an annual tank reliability

program carried out by the refinery

An odour study was completed throughout the previous Approval lifetime that identified

odour issues that were addressed through various action items and process improvements

POTENTIAL AIR QUALITY CONTAMINANTS

The refinery is situated in east Saint John and although it is in an industrial area there are

several residential areas within close proximity Emissions from the refinery come from

four main source areas

bull Sulphur Block (includes two Sulphur Recovery Units the Tail Gas Unit and the

Sulphuric Acid Regeneration Unit) where although 99 percent of the sulphur fed

to the units is recovered less than 1 percent is released to the atmosphere as

sulphur dioxide as well as small amounts of nitrogen oxides particulate matter

and carbon dioxide

bull Refinery Boilers and the No 3 Crude Unit fired heaters where refinery fuel gas

combustion results in the emission of sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and

hydrocarbons

bull FCCU catalyst regenerator where sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and hydrocarbons

are emitted

bull FGS where nitrogen oxides particulate matter carbon dioxide and small amounts

of sulphur dioxide and carbon monoxide are emitted

Fugitive emissions can also have an effect on local air quality

POTENTIAL IMPACTS OF AIR EMISSIONS

Acid Deposition

Emissions of sulphur dioxide and nitrogen oxides can be transformed in the atmosphere

to acidic particles which ultimately fallout as acid deposition (acid rain is one way in

which this deposition occurs) This deposition can occur far from the original source of

the emissions The majority of the acid deposition measured in New Brunswick is caused

by emission sources in the US mid-west and central Canada Generally speaking acid

deposition in New Brunswick has shown significant improvement through national and

international efforts to reduce acid causing emissions primarily through controlling

emissions of sulphur dioxide

The Department continues to report the acid disposition measurements in the Annual Air

Quality Report

Climate Change

When fossil fuels are burned it results in the generation of greenhouse gases (GHG) such

as carbon dioxide (CO2) and methane (CH4) which are the main contributors to the

problem of climate change The Department has been working on a Climate Change

Action Plan for several years and the Approval has a number of conditions related to

reporting and improvements in greenhouse gas emissions

Ground-Level Ozone

Ozone (O3) is a reactive unstable form of oxygen It is not emitted directly from stacks or

exhaust pipes but it is formed as a result of photochemical reactions between other

pollutants most importantly nitrogen oxides and volatile organic compounds (VOCs)

such as solvent and gasoline vapours Both stationary and mobile emissions sources

contribute precursor pollutants that have the potential to result in the formation of

ground-level ozone

It has been estimated that 85 percent of ground-level ozone enters this region from the

North Eastern United States Central Canada and the American Mid-West (9) Elevated

levels generally occur in the summer under very warm conditions when large stable air

masses move up the eastern seaboard into the Fundy region Although the contribution of

local sources may pose an added stress to already deteriorating air quality conditions

during such episodes in general local sources are relatively minor contributors to ground-

level ozone levels experienced in our region Control programs in New Brunswick

specifically for ground-level ozone are therefore not able to reduce ambient

concentrations appreciably Despite this all measures which can reduce the emission of

ozone precursors are promoted such as the refinerys Fugitive Emissions Program Of

particular interest are programs where multiple environmental benefits may be expected

For example improving energy efficiency will reduce greenhouse gas emissions as well

as nitrogen oxides and sulphur dioxide Therefore efficiency measures are favoured over

measures exclusively targeting ground-level ozone

AIR QUALITY COMPLIANCE AND ENFORCEMENT

Compliance and Enforcement options used by the Department of Environment are

outlined in the Departments Compliance and Enforcement Policy (10) These may

include but are not limited to schedules of compliance warnings orders and

prosecutions Although not specifically outlined in the Policy it is also possible to amend

approvals with more stringent conditions both during its valid period or at the time of

renewal to address specific compliance issues or to improve the environmental impact of

the facility Most recently a new Regulation under the Clean Air Act allows for the

issuance of administrative penalties for minor violations as an alternative to

traditionally-used enforcement options

All sources of air emissions in the province are required to comply with the Clean Air Act

and Air Quality Regulation In addition to establishing ambient standards for

contaminants in air Section 3 of the Air Quality Regulation requires that no person shall

construct modify or operate a source without applying for and obtaining an

approvalrdquo The refinery currently operates under Approval to Operate I-8902 issued

July 1 2015 The current Approval expires on June 30 2020

APPROVAL AMENDMENTS and PROJECTS

The Approval was amended twice during the lifetime of the Approval

On November 15th 2015 the Approval was amended to update the operation and

maintenance of the ambient monitoring program that had been upgraded as well as

adding general GHG conditions to the Approval to include reporting and submitting a

Greenhouse Gas Management Plan

On December 21 2016 the Approval was amended to update the definition of Facility to

add the Hydrogen Recovery Unit (Plant 426) This was not a new unit at the Facility

however it was previously owned and operated by Air Liquid Canada and was

acquisitioned by Irving Oil on December 31 2016

On April 4 2017 an Approval to Construct the Tier 3 Gasoline Project was issued This

modification did not increase or change emissions at the refinery or increase the capacity

Compliance with the Approval to Operate

Following are the key issues addressed in the Approval to Operate for Irving Oil Refining

GP including comments on compliance with the associated conditions and actions taken

to achieve compliance with these conditions A summary of the key conditions are in

italics

Emergency Response and Reporting

Conditions 27 amp 28

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

Fugitive Emissions Programs

In 1993 the Irving Oil Refinery began an annual program aimed at reducing its

contribution to ground-level ozone in keeping with the Code of Practice for the

Measurement and Control of Fugitive VOC Emissions from Equipment Leaks October

1993 (7) established by the Canadian Council of Ministers of the Environment (CCME)

This program is comprised of the detection and repair of leaks (fugitive emissions) from

specific process components such as pump seals valves flanges vents connectors and

compressor seals The detection component of the program began in 1993 The program

was expanded to include the repair of leaking components in 1995 When a repair cannot

be made immediately it is scheduled for the next available maintenance turnaround

In addition all Irving Oil Refining GP storage tanks are required to be maintained in

accordance with the CCME Environmental Guidelines for Controlling Emissions of

Volatile Organic Compounds from Aboveground Storage Tanks June 1995 (8) and the

requirements of this guideline have been incorporated into an annual tank reliability

program carried out by the refinery

An odour study was completed throughout the previous Approval lifetime that identified

odour issues that were addressed through various action items and process improvements

POTENTIAL AIR QUALITY CONTAMINANTS

The refinery is situated in east Saint John and although it is in an industrial area there are

several residential areas within close proximity Emissions from the refinery come from

four main source areas

bull Sulphur Block (includes two Sulphur Recovery Units the Tail Gas Unit and the

Sulphuric Acid Regeneration Unit) where although 99 percent of the sulphur fed

to the units is recovered less than 1 percent is released to the atmosphere as

sulphur dioxide as well as small amounts of nitrogen oxides particulate matter

and carbon dioxide

bull Refinery Boilers and the No 3 Crude Unit fired heaters where refinery fuel gas

combustion results in the emission of sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and

hydrocarbons

bull FCCU catalyst regenerator where sulphur dioxide particulate matter nitrogen

oxides carbon dioxide and small amounts of carbon monoxide and hydrocarbons

are emitted

bull FGS where nitrogen oxides particulate matter carbon dioxide and small amounts

of sulphur dioxide and carbon monoxide are emitted

Fugitive emissions can also have an effect on local air quality

POTENTIAL IMPACTS OF AIR EMISSIONS

Acid Deposition

Emissions of sulphur dioxide and nitrogen oxides can be transformed in the atmosphere

to acidic particles which ultimately fallout as acid deposition (acid rain is one way in

which this deposition occurs) This deposition can occur far from the original source of

the emissions The majority of the acid deposition measured in New Brunswick is caused

by emission sources in the US mid-west and central Canada Generally speaking acid

deposition in New Brunswick has shown significant improvement through national and

international efforts to reduce acid causing emissions primarily through controlling

emissions of sulphur dioxide

The Department continues to report the acid disposition measurements in the Annual Air

Quality Report

Climate Change

When fossil fuels are burned it results in the generation of greenhouse gases (GHG) such

as carbon dioxide (CO2) and methane (CH4) which are the main contributors to the

problem of climate change The Department has been working on a Climate Change

Action Plan for several years and the Approval has a number of conditions related to

reporting and improvements in greenhouse gas emissions

Ground-Level Ozone

Ozone (O3) is a reactive unstable form of oxygen It is not emitted directly from stacks or

exhaust pipes but it is formed as a result of photochemical reactions between other

pollutants most importantly nitrogen oxides and volatile organic compounds (VOCs)

such as solvent and gasoline vapours Both stationary and mobile emissions sources

contribute precursor pollutants that have the potential to result in the formation of

ground-level ozone

It has been estimated that 85 percent of ground-level ozone enters this region from the

North Eastern United States Central Canada and the American Mid-West (9) Elevated

levels generally occur in the summer under very warm conditions when large stable air

masses move up the eastern seaboard into the Fundy region Although the contribution of

local sources may pose an added stress to already deteriorating air quality conditions

during such episodes in general local sources are relatively minor contributors to ground-

level ozone levels experienced in our region Control programs in New Brunswick

specifically for ground-level ozone are therefore not able to reduce ambient

concentrations appreciably Despite this all measures which can reduce the emission of

ozone precursors are promoted such as the refinerys Fugitive Emissions Program Of

particular interest are programs where multiple environmental benefits may be expected

For example improving energy efficiency will reduce greenhouse gas emissions as well

as nitrogen oxides and sulphur dioxide Therefore efficiency measures are favoured over

measures exclusively targeting ground-level ozone

AIR QUALITY COMPLIANCE AND ENFORCEMENT

Compliance and Enforcement options used by the Department of Environment are

outlined in the Departments Compliance and Enforcement Policy (10) These may

include but are not limited to schedules of compliance warnings orders and

prosecutions Although not specifically outlined in the Policy it is also possible to amend

approvals with more stringent conditions both during its valid period or at the time of

renewal to address specific compliance issues or to improve the environmental impact of

the facility Most recently a new Regulation under the Clean Air Act allows for the

issuance of administrative penalties for minor violations as an alternative to

traditionally-used enforcement options

All sources of air emissions in the province are required to comply with the Clean Air Act

and Air Quality Regulation In addition to establishing ambient standards for

contaminants in air Section 3 of the Air Quality Regulation requires that no person shall

construct modify or operate a source without applying for and obtaining an

approvalrdquo The refinery currently operates under Approval to Operate I-8902 issued

July 1 2015 The current Approval expires on June 30 2020

APPROVAL AMENDMENTS and PROJECTS

The Approval was amended twice during the lifetime of the Approval

On November 15th 2015 the Approval was amended to update the operation and

maintenance of the ambient monitoring program that had been upgraded as well as

adding general GHG conditions to the Approval to include reporting and submitting a

Greenhouse Gas Management Plan

On December 21 2016 the Approval was amended to update the definition of Facility to

add the Hydrogen Recovery Unit (Plant 426) This was not a new unit at the Facility

however it was previously owned and operated by Air Liquid Canada and was

acquisitioned by Irving Oil on December 31 2016

On April 4 2017 an Approval to Construct the Tier 3 Gasoline Project was issued This

modification did not increase or change emissions at the refinery or increase the capacity

Compliance with the Approval to Operate

Following are the key issues addressed in the Approval to Operate for Irving Oil Refining

GP including comments on compliance with the associated conditions and actions taken

to achieve compliance with these conditions A summary of the key conditions are in

italics

Emergency Response and Reporting

Conditions 27 amp 28

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

Emissions of sulphur dioxide and nitrogen oxides can be transformed in the atmosphere

to acidic particles which ultimately fallout as acid deposition (acid rain is one way in

which this deposition occurs) This deposition can occur far from the original source of

the emissions The majority of the acid deposition measured in New Brunswick is caused

by emission sources in the US mid-west and central Canada Generally speaking acid

deposition in New Brunswick has shown significant improvement through national and

international efforts to reduce acid causing emissions primarily through controlling

emissions of sulphur dioxide

The Department continues to report the acid disposition measurements in the Annual Air

Quality Report

Climate Change

When fossil fuels are burned it results in the generation of greenhouse gases (GHG) such

as carbon dioxide (CO2) and methane (CH4) which are the main contributors to the

problem of climate change The Department has been working on a Climate Change

Action Plan for several years and the Approval has a number of conditions related to

reporting and improvements in greenhouse gas emissions

Ground-Level Ozone

Ozone (O3) is a reactive unstable form of oxygen It is not emitted directly from stacks or

exhaust pipes but it is formed as a result of photochemical reactions between other

pollutants most importantly nitrogen oxides and volatile organic compounds (VOCs)

such as solvent and gasoline vapours Both stationary and mobile emissions sources

contribute precursor pollutants that have the potential to result in the formation of

ground-level ozone

It has been estimated that 85 percent of ground-level ozone enters this region from the

North Eastern United States Central Canada and the American Mid-West (9) Elevated

levels generally occur in the summer under very warm conditions when large stable air

masses move up the eastern seaboard into the Fundy region Although the contribution of

local sources may pose an added stress to already deteriorating air quality conditions

during such episodes in general local sources are relatively minor contributors to ground-

level ozone levels experienced in our region Control programs in New Brunswick

specifically for ground-level ozone are therefore not able to reduce ambient

concentrations appreciably Despite this all measures which can reduce the emission of

ozone precursors are promoted such as the refinerys Fugitive Emissions Program Of

particular interest are programs where multiple environmental benefits may be expected

For example improving energy efficiency will reduce greenhouse gas emissions as well

as nitrogen oxides and sulphur dioxide Therefore efficiency measures are favoured over

measures exclusively targeting ground-level ozone

AIR QUALITY COMPLIANCE AND ENFORCEMENT

Compliance and Enforcement options used by the Department of Environment are

outlined in the Departments Compliance and Enforcement Policy (10) These may

include but are not limited to schedules of compliance warnings orders and

prosecutions Although not specifically outlined in the Policy it is also possible to amend

approvals with more stringent conditions both during its valid period or at the time of

renewal to address specific compliance issues or to improve the environmental impact of

the facility Most recently a new Regulation under the Clean Air Act allows for the

issuance of administrative penalties for minor violations as an alternative to

traditionally-used enforcement options

All sources of air emissions in the province are required to comply with the Clean Air Act

and Air Quality Regulation In addition to establishing ambient standards for

contaminants in air Section 3 of the Air Quality Regulation requires that no person shall

construct modify or operate a source without applying for and obtaining an

approvalrdquo The refinery currently operates under Approval to Operate I-8902 issued

July 1 2015 The current Approval expires on June 30 2020

APPROVAL AMENDMENTS and PROJECTS

The Approval was amended twice during the lifetime of the Approval

On November 15th 2015 the Approval was amended to update the operation and

maintenance of the ambient monitoring program that had been upgraded as well as

adding general GHG conditions to the Approval to include reporting and submitting a

Greenhouse Gas Management Plan

On December 21 2016 the Approval was amended to update the definition of Facility to

add the Hydrogen Recovery Unit (Plant 426) This was not a new unit at the Facility

however it was previously owned and operated by Air Liquid Canada and was

acquisitioned by Irving Oil on December 31 2016

On April 4 2017 an Approval to Construct the Tier 3 Gasoline Project was issued This

modification did not increase or change emissions at the refinery or increase the capacity

Compliance with the Approval to Operate

Following are the key issues addressed in the Approval to Operate for Irving Oil Refining

GP including comments on compliance with the associated conditions and actions taken

to achieve compliance with these conditions A summary of the key conditions are in

italics

Emergency Response and Reporting

Conditions 27 amp 28

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

AIR QUALITY COMPLIANCE AND ENFORCEMENT

Compliance and Enforcement options used by the Department of Environment are

outlined in the Departments Compliance and Enforcement Policy (10) These may

include but are not limited to schedules of compliance warnings orders and

prosecutions Although not specifically outlined in the Policy it is also possible to amend

approvals with more stringent conditions both during its valid period or at the time of

renewal to address specific compliance issues or to improve the environmental impact of

the facility Most recently a new Regulation under the Clean Air Act allows for the

issuance of administrative penalties for minor violations as an alternative to

traditionally-used enforcement options

All sources of air emissions in the province are required to comply with the Clean Air Act

and Air Quality Regulation In addition to establishing ambient standards for

contaminants in air Section 3 of the Air Quality Regulation requires that no person shall

construct modify or operate a source without applying for and obtaining an

approvalrdquo The refinery currently operates under Approval to Operate I-8902 issued

July 1 2015 The current Approval expires on June 30 2020

APPROVAL AMENDMENTS and PROJECTS

The Approval was amended twice during the lifetime of the Approval

On November 15th 2015 the Approval was amended to update the operation and

maintenance of the ambient monitoring program that had been upgraded as well as

adding general GHG conditions to the Approval to include reporting and submitting a

Greenhouse Gas Management Plan

On December 21 2016 the Approval was amended to update the definition of Facility to

add the Hydrogen Recovery Unit (Plant 426) This was not a new unit at the Facility

however it was previously owned and operated by Air Liquid Canada and was

acquisitioned by Irving Oil on December 31 2016

On April 4 2017 an Approval to Construct the Tier 3 Gasoline Project was issued This

modification did not increase or change emissions at the refinery or increase the capacity

Compliance with the Approval to Operate

Following are the key issues addressed in the Approval to Operate for Irving Oil Refining

GP including comments on compliance with the associated conditions and actions taken

to achieve compliance with these conditions A summary of the key conditions are in

italics

Emergency Response and Reporting

Conditions 27 amp 28

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

Notify the Department immediately (or the Coast Guard if not during business hours)

following an environmental emergency and provide a written report within five

business days of the incident

The refinery continues to notify the Department of all environmental emergency

incidents following the emergency response conditions in the approval Environmental

incidents of a non-emergency status are reported to the Department via email to the

regional office as well as the approvals engineer

Notable environmental emergencies during the lifetime of the Approval that impacted the

neighbouring community included

bull On February 21 2015 strong odours were reported from a broken seal in the

internal floating roof of Tank 100 The tank was taken out of service for repairs

A temporary odour control unit was installed that included a caustic scrubber and

carbon filter unit while it was being emptied and taken out of service

bull On November 12 2017 an upset occurred in the FCCU where 21 metric tonnes of

catalyst was released Additional details are provided in the FCCU Condition 36

discussion

bull On June 17 2018 a fuel oil release of 92-100 barrels occurred from the FCCU

Additional details are provided in the FCCU Condition 36 discussion

bull On October 8 2018 a Hydrodesulphurization (HDS) unit fire occurred during the

Turnaround period that impacted the HDS and the 2 Rheniformer Ambient air

quality monitoring in the surrounding area did not indicate any air quality

concerns throughout the incident as the plume from the fire dispersed well in the

direction of the Bay Water used for fire suppression was directed to the industrial

wastewater treatment unit which was at normal operation and met all water

quality limits

Additional VOC testing was completed by a third-party consultant around the

refinery to confirm there were no lingering air quality impacts to the environment

A thorough investigation that included third-party consultants such as forensic fire

investigators and metallurgists concluded the HDS reactor effluent line failed due

to an area of localized pipe thinning as a result of internal corrosion The units

were rebuilt with a primary focus of increasing the corrosion resistance to prevent

any recurrence of the problem

The units were approved to be put back into service on June 28 2019

bull On July 5th 2019 a trip in the Residue Fluid Catalytic Cracking Unit (RFCCU)

while the refinery was in a steam shortage caused a particularly noticeable flaring

event with black smoke The steam shortage occurred due to other units being

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

down for planned and unplanned maintenance A review was completed to assess

preventive measures to reduce the chance or a recurrence of a steam shortage

during a flaring event

Condition 29

Provide the Department with training on the IOLGP Environmental Emergency

Response Plan

This training is scheduled for early 2020 at the refinery

Limits

Condition 31

Limit annual emissions of sulphur dioxide to 5200 tonnes per calendar year and 30

day rolling average emissions to 145 tonnes per day

The refinery consistently has been below these limits during the period of the approval

(see Table 1 for a summary of annual emissions) Over the past five years average

annual emissions of sulphur dioxide have remained well below the limit

Table 1 Annual SO2 Emissions (Tonnesyear)

SO2 2015 2016 2017 2018 Average

Flue Gas Scrubber 114 123 116 96 112

FCCU 1051 1077 914 1006 1012

Sulphur Block 637 474 539 562 553

Boilers HRSGs and Process Heaters 18 10 54 47 32

Flares 2 1 83 51 34

Total SO2 Emissions (tonnesyear) 1822 1685 1706 1762 1744

Prior to 2000 the Irving Oil refinery had an annual sulphur dioxide emissions cap of

9500 tonnes In the EIA for the Refinery Upgrade Project Irving Oil Refining GP

proposed a reduction in the annual sulphur dioxide cap to 8000 tonnes This cap was

included in their Approval to Operate issued in October 2000 and the cap was reduced

again to 7200 tonnes when the Approval was renewed in 2005 and to 5500 tonnes in

2010 Sulphur dioxide emissions from the refinery have typically been stable and

consistent as shown in Table 1

Condition 32

Limit the annual emission of Sulphur compounds (SO2) from the Sulphur Block to less

than 4000 kgday based on an annual average

The refinery consistently has been below these limits during the period of the approval

(see Table 2 for a summary of annual emissions)

Table 2 Average SO2 Emissions from the Sulphur Block

Year Average SO2 (kgday)

2015 1745

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

2016 1299

2017 1477

2018 1540

Condition 33

Limit the annual emission of Nitrogen Oxides (NO2) to less than 5500 metric tonnes

per year

The refinery consistently has been below these limits during the period of the approval

(see Table 3 for a summary of annual emissions)

Nitrogen oxide emissions reported by the refinery are based on a variety of sources

including stack tests mass and energy balances US EPA emission factors and design

data The refinery has NOx CEMs on the FGS SRUs SARU and HRSGs

Table 3 Annual NOx Emissions

NOx 2015 2016 2017 2018 Average

Flue Gas Scrubber 811 987 1227 787 953

FCCU 15 15 16 179 56

Sulphur Block 24 23 28 28 26

Boilers HRSGs and Process Heaters 1800 1813 1622 1540 1694

Flares 65 26 29 45 41

Total NOx Emissions (tonnesyear) 2715 2865 2923 2579 2771

Condition 34

Limit the annual point source emissions of particulate matter (PM) to less than 500

metric tonnes per year

The refinery consistently has been below these limits during the period of the approval

(see Table 4 for a summary of annual emissions)

Particulate matter emissions from the refinery are measured in two ways material

balances on the catalyst being used in the FCCU and periodic stack tests Fuel

combustion the FCCU catalyst regenerator stack and the FGS are the major sources of

particulate matter emissions from the refinery

Table 4 Annual PM Emissions

PM 2015 2016 2017 2018 Average

Flue Gas Scrubber 238 265 235 219 239

FCCU 105 93 104 80 96

Sulphur Block 2 2 2 3 2

Boilers HRSGs and Process Heaters 109 110 98 98 104

Flares 0 0 0 0 0

Total PM Emissions (tonnesyear) 454 471 439 400 441

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

Condition 35

Operate the Flue Gas Scrubber so that an emission rate of 50 mgNm3 particulate

matter on a dry basis is achieved

Annual performance tests conducted on the Flue Gas Scrubber indicate that particulate

emissions were below the target emission rate except for the testing in July 2019 An

additional source testing survey was completed on the flue gas scrubber in September

2019 to verify the previous results The September 2019 testing demonstrated the

particulate matter emission rate is below the target and no further work was required

Stack testing results are summarized in Table 5

During the Fall Turnaround in 2018 the internal components in Flue Gas Scrubber were

replaced for optimal performance

Table 5 Source Testing Results for PM in the FGS

Year Average PM (mgNm3)

2015 489

2016 410

2017 365

2018 418

2019 (July) 594

2019 (Sep) 341

Condition 36

Maintain particulate matter emissions from the fluidized catalytic cracking unit within

an annual average limit of 300 kilograms per day during normal operation

Particulate emissions in the Fluidized catalytic cracking unit (FCCU) are reported

monthly based on a calculated rate that is very conservative There have been several

occasions when the estimate has been over 300 kgday for the month however source

testing results have consistently demonstrated the unit operates are within the limits

Table 6 Source Testing Results for PM in the FCCU

Year PM (kgh) PM (kgd)

Sep 2015 845 203

Feb 2016 97 233

Oct 2017 828 199

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

May 2018 614 147

July 2018 280

Nov 2018 124

Feb 2019 121

FCCU Upsets

During the 2017 Turnaround upgrades were completed to the FCCU to improve catalyst

particulate losses from the stack On November 12 2017 during start-up following the

completed optimization project an upset occurred where 21 metric tonnes of catalyst was

released The upset was caused by the modifications completed to the operating

parameters

Mitigative actions included developing a FCCU Catalyst Release dispersion model to

provide an indication of the extent of the particulate deposition from the upset and assess

environmental impacts to the surrounding area The model can also assess normal

operation emissions from the FCCU as well as any historical or future releases to the

community The model was used to prepare a response plan for future occurrences to

determine affected areas for community notifications and mitigation Irving Oil also

performed 3 additional source testing events in 201819 to demonstrate the improvements

in emissions from the FCCU optimization project

The Approval Holder is required to provide actions taken to prevent the recurrence of the

problem following an environmental emergency For the catalyst release the risk of a

catalyst release during start up and shut down has been reduced with mitigation measures

implemented to the operating parameters and controls and the full implementation of the

optimization project

On June 17 2018 a fuel oil release occurred from the FCCU An unplanned shutdown

occurred on the unit During the emergency shutdown process a supply feed valve was

left partially open While the unit was being restarted 92-100 barrels of fuel oil was

released due to a pressure release in the unit from the partially opened feed valve

A dispersion model was completed to provide an indication of the extent of the liquid

droplets deposition It was estimated that 4-6 barrels (600 ndash 1000 litres) of fuel oil was

released outside the refinery boundary Soil samples were also taken at a location within

the deposition zone The samples showed trace amounts of total petroleum hydrocarbon

(TPH) but were well within the RBCA Tier 1 Risk Base Screening Limit criteria for No

6lube oil and the Tier II Pathway Specific Screening Levels soil ingestion for No 6lube

oil

For preventative measures piping was re-routed to ensure the feed valves remain closed

when the unit trips

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

In the two FCCU upset occurrences both the DELG and the Department of Health were

involved in the assessment of the impacts from the releases and approval of the mitigative

actions

Environmental Quality Limits

Condition 37

Limit ambient total reduced sulphur concentrations to 13 μgm3 (9 ppb) as a 10 minute

average and 7 μgm3 (5 ppb) as a 24 hour average

Reduced sulphur compounds are highly malodorous

Three permanent ambient monitoring stations collect TRS data Champlain Heights

Midwood Avenue and Forest Hills

There are very few issues with TRS at the Champlain Heights and Forest Hills

monitoring stations The Midwood Avenue monitoring station has had a number of

exceedances in the past few years however based on wind direction and refinery

operations they are not attributed to the refinery operations

Condition 38

All activities at the facility related to the maintenance decommissioning construction

and commissioning of any units are carried out in a manner to remain under these

noise levels at the nearest receptor

Time 90th Percentile Noise Limit

700 ndash 2300 55

2300 ndash 700 50

During the turnaround period periodic noise monitoring is completed around the refinery

to verify compliance with this condition and Condition 55 (noise monitoring)

Condition 39

The Refinery shall ensure that the sour-gas-to-sweet-gas by-pass valve remains closed

and secured

The valve is not capable of opening It is locked with a numbered tag

Condition 40

Maintain tanks storing volatile organic compounds in accordance with CCME

guidelines Environmental Guidelines for Controlling Emissions of Volatile Organic

Compounds from Aboveground Storage Tanks June 1995

The refinery continues to perform tank inspection maintenance and repair under their

tank upgrade program Irving Oil operates a Storage Tank Maintenance and Inspection

Program which incorporates the requirements of the Canadian Council of Ministers of the

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

Environment (CCME) Environmental Guidelines for Controlling Emissions of Volatile

Organic Compounds from Aboveground Storage Tanks VOC emissions reported to the

Department from this source have averaged approximately 113 Tonnes from 2015 to

2018

EPISODE CONTROL

Condition 41 amp 42

Maintain and provide updates to the Director as they are prepared a Sulphur Dioxide

Response Plan the purpose of which is to prevent exceedances of the maximum

permissible ground-level concentrations of sulphur dioxide as per Schedule C of the

Air Quality Regulation - Clean Air Act

Implement procedures as required to prevent exceedances of the maximum permissible

ground-level concentrations of sulphur dioxide as per Schedule C of the Air Quality

Regulation - Clean Air Act This includes but is not necessarily limited to

implementation of procedures invoked by the Irving Oil Refining GP Sulphur Dioxide

Response Plan

The refinery continues to implement the Sulphur Dioxide Response Plan when necessary

Sulphur dioxide concentrations are monitored 24 hours a day by operators within the

Refinery Control Centre If sulphur dioxide levels rise beyond pre-set limits at any one of

the six monitors the refinery takes action to reduce sulphur dioxide emissions in an effort

to prevent exceedances of the regulated standards The information received at the

refinery consists of instantaneous sulphur dioxide concentrations 5-minute rolling

averages and hourly and 24 hour sulphur dioxide averages

Condition 43amp 44

Ensure that within sustainable limits the feed to the HATGU is maximized so as to

minimize sulphur dioxide emissions from the Sulphur Block

Ensure that the gaseous effluent from the Amine Sulphur Recovery Units and the Sour

Water Stripping Units is directed during normal operation to the Sulphur Recovery

Units and HATGU andor the Sulphuric Acid Regeneration Unit and during upset

conditions to flare stacks No 2 andor No 3 where upset means an inability to

beneficially operate any of the components associated with the recovery of sulphur

The HATGU is an integral part of the pollution control system and refinery operations

The SO2 emissions from the Sulphur block remain steady and well within the limits set

out in Condition 32

These conditions are in place to ensure Sulphur emissions are reduced as much as

possible

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

Condition 45 amp 46

Conduct all Maintenance and Turnaround operations in a manner that minimizes

emissions to the environment All necessary and reasonable measures shall be taken to

prevent impacts on the ambient environment including the creation of odorous or noisy

emissions Where Turnarounds are conducted the Approval Holder shall continue to

conduct all operations in compliance with the Approval

The Approval Holder shall ensure that maintenance decommissioning construction

andor commissioning activities which are known or suspected to be noisy shall be

limited to the hours between 0700 and 2300 Monday to Saturday During periods

when noisy activities are scheduled to be conducted either between the hours of 2300

and 0700 on Sunday or on Statutory Holidays the Approval Holder shall provide the

Departments Saint John Regional Office with advance notification of 2 days

These conditions are in place to ensure periods of potentially increased noise levels are

minimized as much as possible

Condition 47

At least once per year conduct training for its staff with respect to the impacts of its

operation (normal and abnormal) such that operation staff are aware of the potential

for environmental impacts on the surrounding communities and are thereby better

prepared to operate the Facility in a manner which is pro-active in identifying and

mitigating impacts

350 employees have been trained in an hour presentation in 2019 alone Following this

all new employees will receive this training This ensures that if there is an upset or issue

operational staff are aware of the notification protocols and potential environmental

impacts

TESTING AND MONITORING

Condition 49

The Approval Holder shall continuously monitor the flow rate temperature and

sulphur dioxide concentrations from the Sulphur Recovery Units (SRUs) when flue

gases are being directed through the SRU stacks The Approval Holder shall also

continuously monitor the flow rate temperature sulphur dioxide and nitrogen oxide

concentrations from stacks associated with the Sulphuric Acid Regeneration Unit the

Flue Gas Scrubber and the Heat Recovery Steam Generators Continuous Emission

Monitors shall be maintained and performance tested in accordance with the

CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) CODE dated 1998

as published by Alberta Environmental Protection Environmental Service Records of

quality-assured data shall be maintained for a minimum of three years and made

available in electronic or hard copy when requested by the Department

The CEMS testing allows operators to effectively operate these units and minimize

sulphur emissions

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

Condition 51

Continue to implement the Fugitive Volatile Organic Compound Emissions

Measurement and Reduction Program in accordance with the Environmental Code of

Practice for the Measurement and Control of Fugitive Emissions from Equipment

Leaks as published by the Canadian Council of Ministers of the Environment

(CCME) dated October 1993

The Leak Detection and Repair (LDAR) Program is completed annually at the refinery as

per the current federal CCME Code of Practice The program includes through

identification inspection and analysis of all assessible components susceptible to volatile

organic compounds (VOCs) leaks including pumps valves and their seals as well as

flanges and their gaskets

The LDAR Program helps to improve plant operation and reduces the release of VOCs

When leaks are identified and as conditions allow repairs are made to correct leaks

Table 7 demonstrates the reduction in fugitive VOC emissions from the Detection and

Maintenance Program

Year Reduction in Fugitive

Emissions

2015 33

2016 18

2017 17

2018 24

Condition 52

By September 30 of each year investigate odour mitigation as it may be applied the

tank farm and in particular the tanks within the tank farm that are or have been

determined to have the greatest contribution to odorous impacts As part of this on-

going investigation the Approval Holder shall prepare annual reports that delineate the

efforts to control odours from these source types the results of these investigations any

mitigation to be permanently applied and any further investigations that are planned

for the succeeding year If the Approval Holder determines that there is a no more that

can be done to mitigate odours the report submitted is to reflect this conclusion

The refinery has multiple programs and procedures in place to continue to mitigate

odours from petroleum storage tanks These include the Tank Life Extension Program

odour abatement systems third party tank degassing systems and operation of tanks

according to the CCME Environmental Guidelines for Controlling Emissions from

Above Ground Storage Tanks

Irving Oil maintains tanks through the Tank Life Extension Program The Program

objective is to achieve compliance with the American Petroleum Institute (API) 653 for

above ground storage tanks The maintenance work reduces VOC emissions and the

potential associated odours

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

The odour abatement system is used to mitigate odours in the community from the tank

field This system is on standby and is always available in the event that odours are

detected

During the 2016 Turnaround the third-party degassing system was used at the refinery as

a preventative measure No concern calls were received in relation to odours during this

turnaround period The system has proven to be an effective way to minimize tank odours

and VOCs and will be considered on a case-by-case basis during future turnarounds and

tank maintenance

Reid vapour pressure testing and tank temperatures are routinely monitored to maintain

products within the CCME Guidelines to protect the integrity of internal floating rooves

and seals

Odour concern calls have reduced overall from this Approval period compared to the last

Approval period In 2015 there was a spike due to internal seal damage on the recovered

oil tank This tank was taken out of service and repairs were made to address this issue

Conditions 53amp54

Operate and maintain six sulphur dioxide ambient monitors in the east Saint John

area and provide the refinery and the Department with real-time access to the

information gathered by these monitors Operate and maintain the appropriate

hardware and software to provide the Facility with independent and real-time access to

data

As a condition of the amended air quality approval to operate Irving Oil Refining GP is

required to operate and maintain six ambient sulphur dioxide monitoring stations in east

Saint John These are located north of the refinery at the Silver Falls Irving to the south-

south east at the Irving Forest Products site in the Grandview Industrial Park to the south

at the blower building for the Irving Paper lagoon (known as Grandview West 1)

Midwood Avenue Champlain Heights subdivision and Forest Hills The Department and

the refinery both have rapid access to the information collected at the six monitoring

stations

The refinery is one of several significant sources of sulphur dioxide in the Saint John

region and elevated ambient concentrations of sulphur dioxide may result from emissions

from any or all of these sources The exceedances of the sulphur dioxide ambient

objectives at various monitoring locations in East Saint John are shown in Table 8

Exceedances have decreased dramatically since the installation of the HATGU and there

have been only a few exceedances throughout the lifetime of the Approval

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

Table 8 Exceedances of Maximum Permissible Ground Level Concentrations

(Provincial Objectives) for SO2 East Saint John

Midwood Avenue

Champlain Heights

Grandview West 1

Forest Hills Forest Products

Silver Falls

1-HR OBJECTIVE

2015 0 0 4 0 0 0

2016 0 0 1 1 0 0

2017 0 0 0 0 0 0

2018 0 0 0 3 0 0

2019 0 0 2 0 0 0

24-HR OBJECTIVE

2015 0 0 0 0 0 0

2016 0 0 0 0 0 0

2017 0 0 0 0 0 0

2018 0 0 0 0 0 0

2019 0 0 1 0 0 0

2015

The one-hour objective was exceeded on 4 occasions all occurring at the Grandview

West (Irving Oil Limited - IOL) monitoring station during January and February Some

operational issues were experienced with the Hydrogenation Amine Tail Gas Unit at IOL

which were assessed and mitigated

2016

The one-hour objective was exceeded once (one-hour duration) at the Grandview West

station (Irving Oil Ltd) on November 24th This was associated with a short interruption

of the operation of the sulphur plant at the refinery

2019

The one-hour objective was exceeded twice (one-hour duration) on November 7th amp 8th

and the 24-hour objective was also exceeded Nov 8th The SO2 exceedance source was

identified as elevated SO2 emissions from the Sulfuric Acid Regeneration Unit (SARU)

stack On the 7th an unplanned maintenance outage occurred and on the 8th the SARU was

in heat-up mode from a planned maintenance outage

Condition 56

The Approval Holder shall continue to implement the Refinery Implementation

Strategy Plan for Continuous Improvements in Odour Management and prepare an

annual update to summarize the years work to address odours andor odour

assessment

In 2010 an Odour Impact Assessment Follow Up study was completed that included a

strategy for continued improvements in odour mitigation initiatives and monitoring The

recommendations included

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

bull Continued focus on minimizing odour calls from flaring activity

bull Maintain community concern call program

bull Tank Maintenance and monitoring program

bull Utilizing refinery odour dispersion model

For flaring activity efforts have focussed on optimizing the flare steam to fuel ratio to

reduce concern calls and exceedances related to Total Reduced Sulphur (TRS) at the

ambient monitoring stations In 2014 reported concern calls for flaring was 29 compared

to 2 in 2018 There were only 3 reported TRS Exceedances combined from 2015 to 2018

The community concern call program and tank maintenance and monitoring program are

described in other sections of the Facility Profile

In 2013 an air dispersion model system of odour emissions generated by sources at the

refinery was purchased The refinery was modelled according to various refinery

scenarios using weather station data in order to evaluate odour impacts to the surrounding

neighbourhood

The model was initially utilized to help identify areas for improvement within the

refinery odour footprint and reduce concern calls Since this initial period the key

sources of odours have been recognized and the model has been used less frequently The

model is available in the event that it might be required for future identification of odour

sources

Condition 57

Prior to February 01 2016 develop an Ambient VOC Monitoring Plan to implement

around the refinery boundary to better quantify the ambient air quality in relation to

VOCs

Irving Oil developed a VOC Fenceline Monitoring Study which was completed from

June 2016 Through August 2017 Irving contracted a local engineering firm to prepare

the plan and conduct the testing Twelve sample locations were selected around the

refinery perimeter with a total of 312 samples collected The air contaminants monitored

included benzene 13-butadiene ethylbenzene toluene and xylenes

Irving Oil was the first refinery in Canada to conduct this type of study and selected the

USEPA method 325AB This method is a regulatory requirement in the United States for

oil refineries for fenceline monitoring In this method VOCs are collected from air using

a diffusive passive sampler at specified locations around the facility boundary

The US EPA fenceline benzene action level (limit) is 9ugm3 and all measured results at

the selected refinery fenceline sample locations were below the action level (limit) by a

significant margin Table 9 summarizes the results obtained from the study

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

Table 9 Summary of Results from the VOC Fenceline Monitoring

Location Benzene

(ugm3)

13-butadiene

(ugm3)

Ethylbenzene

(ugm3)

Toluene

(ugm3)

Xylenes

(ugm3)

1 082 lt030 06 348 234

2 248 037 193 127 827

3 115 037 072 35 285

4 155 033 107 481 444

5 18 032 108 589 443

6 08 lt030 lt055 263 209

7 058 lt030 lt041 111 102

8 042 lt030 lt040 066 lt080

9 042 lt030 lt050 19 153

10 035 lt030 lt041 075 lt089

11 048 lt030 lt045 154 11

12 052 lt030 lt041 124 093

Annual Average Ambient

Guidelines (ugm3)

3 and 045

and 9

03 and 2 200 - -

Alberta guideline is 3 ugm3 Ontario guideline is 045 ugm3

Quebec guideline is 03 ugm3 and Ontario guideline is 2 ugm3

USEPA action rule is 9 ugm3

REPORTING

Condition 63

Submit any updates to the Five-Year Source Testing Plan

Performance tests have been completed as required based on the approved 5 Year Source

Testing Plan

General

Monthly and annual reports are submitted as required Irving Oil Refining is in

compliance with all report submission requirements Additional information in the

reports that have not been discussed in the Facility Profile are described below

Condition 64 d)

Summary of emissions of VOCs and benzene

Table 10 demonstrates the annual VOC emissions and Table 11 demonstrates the annual

Benzene emissions

Table 10 Annual VOC Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive emissions 86 149 147 151

Tank Farm 101 112 126 114

Fuel Distribution 77 78 75 73

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

Stack emissions 87 87 68 65

Spills 2 2 0 1

Flares 77 36 41 54

Wwtp 35 32 34 36

TOTAL 467 497 491 493

Table 11 Annual Benzene Emissions (Tonnes)

Source 2015 2016 2017 2018

Fugitive Emissions 1081 1346 1590 1644

Tank Farm 0445 0399 0334 0301

Fuel Distribution 0025 0026 0025 0025

Stack emissions 0000 0000 0000 0

Spills 0001 0001 0000 0

Flares 0000 0000 0000 0

Wwtp 0611 0545 0580 0621

TOTAL 2162 2317 2528 2591

VOC and Benzene emission have remained fairly consistent over the lifetime of the

Approval

Condition 64 e)

the annual average maximum and standard deviation of the daily mean

concentrations of sulphur (expressed as hydrogen sulphide) in Refinery Fuel Gas

Table 12 H2S Concentration in Fuel Gas

H2S 2015 2016 2017 2018

Average vol 00013 00007 00007 00006

Maximum mean vol 01050 00143 00711 00033

Standard deviation vol 00068 00011 00037 00007

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

Refinery fuel gas composition has remained fairly consistent over the lifetime of the

Approval

Enforcement

Enforcement options used by the Department of Environment are outlined in the

Departments Compliance and Enforcement Policy These may include but are not limited

to schedules of compliance verbal and written warnings orders and prosecutions

Although not specifically outlined in the Policy it is also possible to amend approvals

with more stringent conditions both during its valid period or at the time of renewal to

address specific compliance issues or to improve the environmental impact of the facility

Most recently a new Regulation under the Clean Air Act allows for the issuance of

administrative penalties for minor violations as an alternative to traditionally used

enforcement options

During the life of the current Approval Irving Oil Refinery GP Saint John Refinery has

had no warnings or orders issued nor have there been any prosecutions initiated by this

agency during this period related to air quality

PUBLIC OUTREACH

Call Monitoring

The Irving Oil Refinery receives calls related to air quality noise and other issues in east

Saint John The refinery has a call response procedure that must be followed by the

person who receives the information All calls are investigated and response is provided

to those callers who identify themselves Table shows the number of calls received by the

refinery in the last 4 years

Table 6 Concern calls received directly by the refinery

Year Odour Noise Misc PM Total

2015 48 4 5 10 67

2016 21 14 4 0 39

2017 17 15 2 8 42

2018 11 19 98 0 128

Overall the number of concern calls has decreased for the lifetime of the Approval

compared to the previous one The spikes are contributed to specific upsets at the Facility

including

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

bull Odour complaints in 2015 following an upset of the floating roof of Tank 100 in

February and a mercaptan leak in September

bull Miscellaneous concern calls in 2018 following the fuel gas oil release from the

FCCU in June

Community Outreach

Community Liaison Committee

The Irving Oil Community Liaison Committee was formed in 1998 as a requirement of

the Environmental Impact Assessment Determination on the refinery Upgrade Project

The purpose of the committee was to liaise with stakeholders on issues associated with

the Refinery Upgrade Project The committee made up of neighbours government

representatives and employee team members continues to operate even though the

Upgrade Project has been completed The Community Liaison Committee meets

quarterly to discuss new projects and review developments on the refineryrsquos safety and

environmental performance

Neighbourhood Tours

Tours are conducted in the neighbourhood using a hybrid vehicle as required The car

was selected for its environmental performance and is used daily by members of the

Environment Group to identify noise andor odours that may be coming from the

refinery If an odour or noise is detected the refinery is inspected for potential sources

Actions are promptly taken to mitigate or eliminate the concern

The tour includes 18 test points including points on Loch Lomond Road Forest Hills

Church Creighton Avenue and four locations along Grandview Avenue The tour also

includes inside the refinery Areas such as the tank farms are inspected for harsh smells

and wind direction

Letters to Neighbours

Irving Oil keeps neighbours informed of events occurring at the refinery through letters

that our either mailed or hand delivered to nearby homes Topics discussed in these

letters include maintenance turnarounds construction notices and project notifications

For both the FCCU catalyst release and fuel gas release letters were hand delivered to

affected neighbours to provide information on the occurrence

Neighbourly News

The Irving Oil Refinery delivers two newsletters annually to approximately six thousand

residents around the Refinery This newsletter serves as a link between the refinery and

the neighbours to keep them up-to-date on the refinerys activities as well as their

environmental initiatives

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

CONTACTS

For further information on the operation of the Irving Oil Refining GP refinery please

contact

Robyn McMullen

Environment Manager

Irving Oil Refining GP

PO Box 1260

Saint John New Brunswick

E2L 4H6

Telephone (506) 202-2361

Fax (506) 202-4050

E-mail RobynMcMullenirvingoilcom

Principal Contact Saint John Region

Patrick Stull

Regional Director

Region 4 Office

Program Operations and Enforcement Branch

NB Department of Environment amp Local Government

8 Castle Street PO Box 5001

Saint John New Brunswick

E2L 4Y9

Telephone (506) 658-2558

Fax (506) 658-3046

E-mail PatrickStullgnbca

For further information on this document or on environmental regulations relating to air

quality please contact

Sheryl Johnstone

Senior Approvals Engineer

Authorizations Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 444-4599

Fax (506) 457-7805

E-mail SherylJohnstonegnbca

For comments or enquiries on the public participation process please contact

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca

Chandra Clowater

Acting Manager

Public Education Stakeholder and Fist Nation Engagement Branch

New Brunswick Department of Environment amp Local Government

PO Box 6000 20 McGloin St

Fredericton New Brunswick

E3B 5H1

Telephone (506) 457-7511

Fax (506) 453-3843

E-mail ChandraClowatergnbca