Discussion document: A proposed approach to control volatile organic compounds (VOC) emissions from the storage and loading of petroleum liquids
1. Introduction
The Government of Canada is considering a regulatory approach to reduce volatile organic compounds (VOC) emissions from the storage and loading of petroleum liquids. The objective is to reduce the risks associated with the formation of smog and air pollution in Canada as well as from emissions of carcinogenic VOCs such as benzene.
Facilities such as refineries, upgraders, terminals, bulk plants and petrochemical plants that operate large aboveground storage tanks or truck, rail, or marine loading equipment would be included within the scope of these regulations.
The purpose of this discussion document is to provide background information and to seek stakeholder input on costs, technical standards, potential flexibilities and other elements of the proposed approach.
2. Background
The proposed regulations would build on control actions already in place at many of the implicated facilities. In November 2020, final regulations addressing VOC emissions from process equipment at petroleum refineries, upgraders and integrated petrochemical facilities were published in the Canada Gazette, Part II.
The Canadian Council of Ministers of the Environment (CCME) issued 2 voluntary instruments that apply to the storage and loading of petroleum liquids specifically: a national code of practice for vapour recovery from gasoline distribution networks (CCME PN 1057) in 1991, and a national guideline for controlling emissions from aboveground storage tanks (CCME PN 1180) in 1995.
Some facilities are also subject to mandatory provincial or municipal measures, largely adapted from the voluntary CCME instruments: Metro Vancouver has requirements for vapour control for gasoline loading, while Montreal, Ontario, and Newfoundland and Labrador have requirements for both vapour control and storage tank design.
Given the proximity of many petroleum storage and loading facilities to residential areas, a nationally consistent program is needed to protect all Canadians from the harmful effects of petroleum VOCs.
The Government of Canada’s determination is that the voluntary CCME instruments developed to address concerns with VOCs as smog precursors are not sufficient to manage the nationwide risks associated with emissions of specific carcinogenic VOCs. In addition, the experience gained by industry and regulatory agencies in implementing the CCME instruments has identified opportunities for more effective measures since the CCME instruments were published in 1991 and 1995. The U.S. has had national requirements in place since the 1980s, which have been updated and supplemented several times.
3. Proposed regulatory approach
While environmental and health concerns must be addressed, the Government also recognizes the integrated nature of the North American petroleum and petrochemical industries and that many Canadian petroleum and petrochemical operators are also active in the United States market. The proposed regulations would be informed by U.S. Environmental Protection Agency (EPA) regulatory measures.
The proposed regulations would include design requirements aimed at controlling evaporative emissions from large aboveground petroleum storage tanks; truck, rail, and marine loading equipment; and wastewater treatment operations. They would require regular inspections and maintenance, including leak detection and timely action to correct any identified deficiencies. They would also require recordkeeping of inspection and maintenance information.
The proposed regulations would consider the existing CCME instruments PN 1057 and PN 1180, US federal regulations (such as 40 CFR 60 Subpart Kb and 40 CFR 63 Subpart R), and Canadian provincial and municipal measures. They would modernize the current Canadian regime of voluntary codes of practice and provincial or municipal instruments, and better align with current U.S. regulations.
The general elements of the proposed regulatory approach are described below:
Scope
The proposed regulations would target VOCs emissions from the storage and loading of petroleum liquids, with specific measures to control emissions of benzene and other carcinogenic components.
- equipment
- large aboveground liquid storage tanks and truck, rail, or marine loading equipment
- facilities
- any facility operating the included equipment, including refineries, upgraders, terminals, bulk plants, and petrochemical plants
Requirements for storage tanks
Design
Facilities would be required to use measures to reduce VOC emissions from storage tanks such as:- pressure-vacuum valves
- floating roofs (with appropriate, well-functioning seals) or
vapour recovery systems
The set of acceptable measures would depend on the size of the tank and the hazard posed by the liquid it contains. Measures would be required for all tanks:- larger than 4 m in diameter or greater than 75 m3 in volume and
- containing liquids with vapour pressures > 10 kPa, or
- containing liquids with vapour pressures > 3.5 kPa and > 2% w/w of benzene
larger than 4 m3 in volume and containing liquids with vapour pressures > 76 kPa
Inspections
Facilities would be required to inspect tanks and tank fittings at regular intervals. Inspections would include visual examination, physical measurement (seal gaps, pressures), and leak detection.
Vapour recovery systems, if present, would be subject to visual examination and leak detection, and would be required to perform at or above a specified recovery percentage.
Repair
Facilities would be required to repair any identified failures in tanks and tank fittings within specified timeframes.
Documentation
Recordkeeping, reporting, and auditing would be required to demonstrate regulatory compliance and effectiveness.
Requirements for loading
Design
Facilities would be required to use vapour control for truck, rail, and marine loading. Vapour control would be required for all facilities handling liquids as follows:- vapour pressures > 10 kPa but < 35 kPa (for example, crude oil) and throughput > 80 million litres per year
vapour pressures > 35 kPa (for example, gasoline) and throughput > 25 million litres per year
Inspections
Facilities would be required to inspect vapour control systems at regular intervals. Inspections would include visual examination and leak detection. Vapour control systems would be required to perform at or above a specified recovery or destruction percentage.
Repair
Facilities would be required to repair any identified failures in vapour control systems within specified timeframes.
Documentation
Recordkeeping, reporting, and auditing would be required to demonstrate regulatory compliance and effectiveness.
Regulatory design flexibilities
The Government recognizes that the proposed regulations could create costs for some facilities. Flexibilities will be developed to minimize these costs. For example, facilities would be permitted to implement alternative tank or loading equipment designs that could be demonstrated to achieve emissions performance equal to or better than the designs specified in the proposed regulations.
Cost-benefit analysis
A cost-benefit analysis will be developed as part of the regulatory process, taking into account existing provincial and municipal requirements and current performance. The proposed regulations are expected to achieve air quality benefits and health benefits to Canadians as well as provide product recovery savings to operators. Stakeholders will have an opportunity to provide data to support the cost-benefit analysis.
Red tape reduction
These regulations would conform to the Government’s ongoing commitment to eliminating unnecessary red tape from Canada’s regulatory system, while maintaining high standards for safety and environmental protection. Innovative ways for minimizing administrative burden will be explored such as streamlined submissions and possible use of single-window reporting.
4. Next steps
The Government of Canada is seeking your views on the key elements of the proposed regulations under consideration as described above, as well as seeking other information that would help address uncertainties and inform decision making.
Building on the feedback received on this paper and through consultations, the Government will develop draft regulations.
Your input and views are important. Please submit written comments by mail or email by midnight on July 9, 2021 to ensure that they can be considered during the development of the draft regulations.
Oil, Gas and Alternative Energy Division
Energy and Transportation Directorate
Environment and Climate Change Canada
351 St Joseph Blvd 11th Floor
Gatineau QC K1A 0H3
Email: ec.covsecteurpetrolier-vocpetroleumsector.ec@canada.ca
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