3.0 Information on MTBE Provided Pursuant to the CEPA 1999 Notice

• 3.1 Production, import and export of gasoline containing MTBE
• 3.2 Production, import and export of MTBE
• 3.3 Reported releases of gasoline containing MTBE
• 3.4 Reported releases of MTBE
• 3.5 Reported ground water and drinking water contamination
  • 3.5.1 Ground water contamination
  • 3.5.2 Drinking water contamination
• 3.6 Procedures to monitor and prevent MTBE releases monitor contamination
• 3.7 Future use of MTBE
• 3.8 Discussion
  • 3.8.1 Summary of key findings
  • 3.8.2 Addressing the problem

Twenty three responses¹³ to the CEPA 1999 Notice were received by Environment Canada. Table 3.1 lists the companies that provided responses to the Notice:

• eleven respondents reported importing gasoline containing MTBE;
• nine respondents have produced or blended gasoline containing MTBE;
• eight respondents have imported MTBE; two have exported MTBE;
• one company reported producing MTBE;
• three companies reported that they have handled/transported MTBE.

Paragraphs 1(b) and (d) of the CEPA 1999 Notice required reporting of information relating to the production, import and export of gasoline containing MTBE in Canada between 1991 and 2000 and the intended production, and import of such gasoline from 2001 to 2005.

Companies that reported producing, exporting or importing gasoline containing MTBE between 1991 and 2000 are listed in Figure 3.1.

• Seven companies reported producing gasoline containing MTBE;
• three¹⁴ companies reported blending¹⁵ MTBE into gasoline;
• ten¹⁶ companies reported importing gasoline containing MTBE;
• two companies reported exporting gasoline containing MTBE.

It is important to note that due to commercial exchanges of gasoline between fuel companies, companies other than those listed below would have handled, stored and sold gasoline containing MTBE.

Figure C.1 in Appendix C shows the production, blending, imports and exports of gasoline containing MTBE on a regional basis from 1991 to 2000. The figure shows that imports of gasoline containing MTBE have occurred in every region of the country during the ten year period. Production or blending has also occurred in every region. Exports have occurred from the Atlantic and Western regions only.

Figure 3.2 shows the volumes of gasoline containing MTBE that were reported to have been produced in, imported into, and exported from Canada between 1991 and 2000, as well as the net volumes of gasoline containing MTBE remaining in Canada (production + imports - exports).

Between 1991 and 2000, a total of approximately 34.2 million m³ of gasoline containing MTBE, equivalent to approximately 10% of the total gasoline pool, was produced in Canada. As Figure 3.2 shows, production peaked in 1997 at about 6.5 million m³, while the net volume of gasoline containing MTBE in Canada (production + imports - exports) peaked in 1998 at about 3.5 million m³ . By 2003, net volumes are expected to fall by over 95% from the 1998 peak.

In 1998, gasoline containing MTBE at concentration in excess of 0.6% by volume accounted for 10% of the gasoline Canadian pool. This fell to 2% in 2000, and is estimated to have been less than 1% in 2001.

Only two refining companies, Irving Oil Ltd. and North Atlantic Refining Ltd., reported that they intend to continue using MTBE in gasoline in Canada post-2001. North Atlantic Refining Ltd. indicated that 90% of the gasoline it produces containing MTBE will be exported. Irving has informed Environment Canada that it no longer sells gasoline in Canada that contains MTBE.

Three companies, Cami Automotive, Honda, and Northern Transportation, indicated that they intend to continue to import small volumes of gasoline containing MTBE post -2001. In addition, Ultramar reported that imports of gasoline containing MTBE could be possible but are not planned.

Paragraphs 1(a) and (c) of the CEPA 1999 Notice required the reporting of information relating to the production, import and export of MTBE in Canada between 1991 and 2000 and the intended production, import and export of MTBE from 2001 to 2005.

Figure 3.3 lists the companies that reported producing, importing or exporting MTBE in Canada between 1991 and 2000. A total of six companies imported MTBE into Canada during this period¹⁷, two companies exported MTBE, and only one company, Alberta Envirofuels Inc., produced MTBE.

Figure C.2 in Appendix C shows the production, exports and imports of MTBE on a regional basis between 1991 and 2000. While imports of MTBE occurred in every region during the ten year period, production and exports were limited to the west of Canada.

Production of MTBE in Canada peaked in 2001. It was reported that production would cease in 2002. There were imports of MTBE into each region of Canada between 1991 and 2000, with 89% of the volume being imported into the Atlantic region.

Figure 3.4 shows the net volumes of MTBE remaining in Canada (production + imports - exports) between 1991 and 2000 as a percentage of the 1997 peak volume.

Figure 3.4 - Net volume (production + imports - exports) of MTBE in Canada, 1991-2000

The CEPA 1999 Notice required the reporting of spills or leaks into the environment of more than 150 litres at any one time of a fuel containing at least 0.6 percent by volume MTBE. Table 3.2 presents the dates, volumes and locations of the nineteen releases of gasoline containing MTBE in Canada during 1991 to 2000 as reported by three companies. These releases occurred in British Columbia (B.C.), Ontario, Quebec and Nova Scotia.

Five of the releases were reported to be due to human error (overfilling, loading errors); others were due to equipment failure, such as leaks from tanks and piping. Twelve of the nineteen releases were reported to have been contained. For the seven releases that were not contained, the follow-up action consisted of:

• soil remediation (one case);
• soil and ground water remediation (two cases);
• remedial action was not described in four cases.

In addition to the above-noted nineteen releases, three companies reported a total of 460 releases of gasoline which may have contained MTBE during 1991 to 2001. These releases occurred in Ontario, Quebec and the Atlantic provinces.

Section 1(e) (i) of the CEPA 1999 Notice required the reporting of spills or leaks into the environment of more than 10 litres of MTBE at one time resulting from the operations of the respondents. Table 3.3 presents the dates, volumes and locations of the seventeen reported releases of MTBE in Canada during 1991 to 2000. These releases were reported by six companies.

Eleven of the releases occurred in Alberta. Others occurred in Newfoundland and B.C. Three of the releases were reported to be due to human error (overfilling); others were due to equipment failure, such as leaks at valves, pumps and piping. Seven of the seventeen releases were reported to have been contained. For the ten releases that were not contained, MTBE was detected in ground water in eight cases and the follow-up action taken was:

• ground water and soil were remediated (one case);
• ground water was remediated (one case)
• soil remediated (two cases);
• ground water monitoring (three cases);
• remedial action was not described in one case.

Section 1 (e) (iii) of the Notice required the reporting of instances of MTBE detected in ground water, surface water or drinking water at a concentration exceeding 0.0005 mg/L (approximately 0.5 ppb).

MTBE was reported as having been detected in ground water at 250 locations and in every province in Canada but none of the territories. Among these, six locations in PEI were sources of drinking water and are discussed in more detail in section 3.5.2. Figure 3.5 shows the number of sites at which ground water contamination was reported for each province. Approximately three-quarters of the sites are located in western Canada.

Approximately eighty percent of incidents were reported by two companies. These two companies and one other were the only respondents that indicated that they have routine monitoring in place for MTBE contamination of ground water. It is expected, therefore, that the ground water contamination reported under the Notice may under-represent the contamination that exists in some regions.

Some form of follow-up to the incidents of ground water contamination reported under the Notice was indicated for 97% of incidents:

• remediation of contaminated soil and/or ground water was being carried out for 36% of the reported incidents;
• respondents indicated that water monitoring programs were in place for a further 20% of incidents;
• a further 27% were being investigated and remediation may have followed;
• for a further 8% of incidents remedial action had been completed.

Figure 3.6 shows the distribution of maximum reported concentrations of MTBE in ground water. Sixty percent of these concentrations were at levels above the EPA's threshold consumer advisory level for aesthetics of 20 ppb, and over seven percent were at levels exceeding B.C.'s guideline for aquatic life of 3400 ppm.

Figure 3.7 shows a breakdown of the type of facilities at which MTBE ground water contamination was reported:

• sixty-seven percent of the reported incidents of ground water contamination were measured at sites that were active or former service stations;
• contamination was also reported at bulk plants (15%), cardlocks (4%), refineries (3%), terminals (2%) and other facilities.

The cause of contamination was reported for approximately a quarter of incidents. At service stations, the most common reason provided was releases from underground storage tank systems; other causes at service stations were identified as releases from piping and handling.

Table D.1 in Appendix D provides a list of the municipalities in which ground water contamination was encountered and the level of MTBE reported.

Among the 250 locations at which MTBE was detected, six were sites where ground water was used as a source of drinking water. All six sites were located in PEI. The locations and MTBE concentrations for each of these incidents are presented in Table 3.4 below. The reported maximum concentrations of MTBE ranged from 1 to 5 ppb - all below the PEI guideline for aesthetics of 15 ppb and the threshold EPA consumer advisory for aesthetics of 20 ppb.

In all six locations the ground water was being remediated. In fact, by November 2001, the concentration of MTBE had fallen to non-detectable levels in three of the six locations.

Under section 1(f) of the Notice, companies were requested to provide descriptions of the procedures to monitor and prevent MTBE releases that they have implemented any time after January 1, 1991, or that they plan to implement before April 1, 2002. The nature of the responses was qualitative.

Sub-section 1(f) (i) requested the reporting of procedures to monitor the release of MTBE or gasoline containing at least 0.6 percent by volume MTBE. Twenty-one companies responded to this question. Of the 21 that responded, three responded with ‘No Monitoring'.

The companies that did respond cited these procedures to monitor releases:

• Volume management to identify loss (6 firms);
• Visual inspections for evidence of leakage (5 firms);
• Reporting policies and procedures for spill reporting (5 firms);
• Installation of ground water monitoring wells (4 firms);
• Following CCME Environmental Code of Practice for Underground Storage Tanks Containing Petroleum Products (2 firms);
• Leak detection system between primary and secondary containment (1 firm);
• Double-walled underground storage tanks with interstitial leak detection (1 firm);
• Environmental monitoring program (1 firm);
• Transportation of Dangerous Goods audits (1 firm);
• Leak detection system (1 firm);
• Ambient air monitoring (1 firm);
• Fugitive emission survey (1 firm);
• Effluent and cooling water monitoring (1 firm).

In general, a patchwork of procedures was identified without a consistent standard being applied for monitoring of MTBE releases.

Sub-section 1(f) (ii) requested the reporting of procedures to prevent the release of MTBE or gasoline containing at least 0.6 percent by volume MTBE. Twenty-three companies responded to this question. Of the 23 firms that responded, one felt this was not applicable and one firm does not use or intend to use MTBE. One firm indicated there were no specific procedures for the prevention of leaks.

In general, a variety of procedures was identified. Thirteen firms identified work procedures and/or spill prevention procedures. Eleven firms identified various technical solutions for containment at the tanks, piping and connectors. Nine firms identified secondary containment through the use of double walled tanks, concrete berms, liners or earth.

The companies that responded cited the following as their procedures to prevent the releases of MTBE or gasoline containing MTBE:

• Emergency response procedures (8 firms);
• Standardized work procedures to prevent spills (8 firms);
• Inspection and Maintenance program (5 firms);
• Cathodic protection (4 firms);
• Employee education (4 firms);
• Spill containment at fill locations (4 firms);
• Volume balance in system (3 firms);
• Containment at dispenser locations (3 firms);
• Following CCME Environmental Code of Practice for tanks (2 firms);
• Double-walled tanks (2 firms);
• Double-walled piping (2 firms);
• Vessel inspection before loading (2 firms);
• Volume balance upon receipt of gasoline not to exceed tank capacity (2 firms);
• Liquid accumulators (2 firms);
• Tanks located within polyethylene lined dikes (2 firms);
• Secondary containment around tanks (2 firms);
• ISO 14001 work procedures ( 2 firms);
• Spill prevention training (1 firm);
• Fibreglass reinforced plastic liner for MTBE storage tanks (1 firm);
• Interstitial leak detection on double-walled tanks (1 firm);
• Interstitial leak detection on double-walled piping (1 firm);
• Turbine pump containment (1 firm);
• Vapour recovery (1 firm);
• Tanks located within earth berm ( 1 firms);
• Spill kits located by tank system including storm sewer covers (1 firm);
• Internal floating roof tanks with rim seals and wipers (1 firm).

Sub-section 1(f) (iii) requested a description of procedures to test for contamination by MTBE of soil, ground water, surface water or drinking water. Sixteen companies responded to this question. Of the sixteen firms that responded:

• 11 have done some ground water contamination testing;
• 36 locations were identified as having some ground water monitoring or testing;
• 3 firms have performed studies on ground water contamination;
• 6 firms identified ongoing monitoring of ground water through the use of monitoring wells; and
• 1 firm identified testing for MTBE in surface water runoff.

Under section 1(g) of the Notice, companies were requested to provide information on financial impacts, compositional effects, and replacement options if MTBE were not available as a gasoline component.

Sub-section 1(g) (i) requested the costs and financial benefits associated with ceasing the use of MTBE in gasoline. Nineteen companies responded to this question:

• 4 firms felt it was not applicable to them;
• 7 firms were either not using, or plan on phasing out the use of MTBE;
• 4 firms felt there would be an increase in the cost of gasoline;
• 1 firm was performing a cost / benefit analysis;
• 1 firm was unsure of the costs or benefits from ceasing the use of MTBE;
• 1 firm indicated there would be no financial effect of reducing MTBE in gasoline;
• 1 firm identified that ceasing the use of MTBE was not feasible as long as it was required for EPA emissions testing.

Sub-section 1(g) (ii) requested the reporting of the effects, or an estimate of the effects, on the composition characteristics of gasoline if MTBE is not used in gasoline. Thirteen companies responded to this question:

• 5 firms felt it was not applicable to them;
• 2 firms identified requirements to meet Canadian General Standards Board (CGSB) specifications; and
• 2 firms were not using MTBE and therefore identified no compositional changes.

Four firms identified effects on compositional characteristics and these included:

• Replacement of MTBE with ethanol (2 firms);
• Reduction of octane may be compensated by increasing alkylate content of gasoline (2 firms);
• Use of another oxygenate (2 firms);
• Increase in lighter high octane components (1 firm);
• Some gasoline products to become heavier during distillation (1 firm);
• Increased use of t-butanol (1 firm); and
• Increased use of methanol (1 firm).

Sub-section 1(g) (iii) requested options available for replacing MTBE in gasoline with other components, along with the nature of those components. Fourteen companies responded to this question. Of these, three felt the question did not apply to them. Replacements identified for MTBE included:

• Alternative alkylate (6 firms);
• Ethanol (3 firms);
• Toluene (2 firms);
• Reformulate (1 firm);
• Alternative Oxygenates (1 firm);
• Ethyl HiTEC 3046 (MMT) (1 firm); and
• Iso-octane (2 firms).

Under section 1(h) of the Notice, companies were requested to provide information on how they would convert their MTBE production facilities. This was to include alternative uses and estimates of costs and financial benefits associated with the conversion. Nineteen companies responded to this question; eighteen of these firms did not have MTBE production facilities and therefore replied "Not Applicable". The one firm directly responsible for production of MTBE identified converting its facility to produce isooctane in 2002.

Under section 1(i) of the Notice, companies were requested to provide information on the use of other aliphatic ethers other than MTBE. The scope included past use after January 1, 1991, present use, and estimates of future annual use from 2001 through to 2005. Sixteen companies responded to this question. Of the respondents:

• 3 responded "Not Applicable";
• 11 firms indicated that they did not plan to use other aliphatic ethers;
• 1 firm identified the possible use of newly developed aliphatic ethers;
• 2 firms identified past use and potential future use of Tertiary Amyl Methyl Ether (TAME). These two firms indicated that they received gasoline that contained TAME from others.
• 1 firm purchased gasoline already containing aliphatic ethers which included Di-Methyl Ether (DME) and Diisopropylether (DIPE); and
• 1 firm mentioned importing gasoline containing Ethyl Tertiary Butyl Ether (ETBE).

i) Intended future use of MTBE in Canada

Responses to the Notice in July 2001 indicated that by 2002, use of gasoline containing MTBE would be reduced significantly - by over 95% from the 1998 peak level. The Canadian Petroleum Products Institute (CPPI), representing most Canadian refiners, has indicated that its member companies ceased adding MTBE to gasoline by the end of 2001 and that none have the intention of using MTBE in the future. CPPI noted that imports of gasoline by member companies may incidentally contain MTBE. As well, responses to the Notice indicated that there may be imports of small volumes of gasoline containing MTBE by vehicle manufacturers.

The continued addition of MTBE to gasoline for use Canada will be limited to Atlantic Canada. Only Irving Oil and North Atlantic Refining indicated that they intend to continue producing gasoline containing MTBE after 2001. Both of these Atlantic refiners export to the U.S. reformulated gasoline, which must contain oxygenate. While North Atlantic Refining reported that it plans to continue marketing MTBE-containing gasoline in Canada, Irving Oil has indicated that it will not. North Atlantic reported that 90% of the gasoline it produces containing MTBE will be exported.

ii) Reported ground water and drinking water contamination

MTBE was detected in ground water at a total of 250 locations across the country. Contamination was reported to have occurred in every province, with most incidents (78%) reported in western Canada. In 60% of cases, MTBE was found to be present at a concentration above the EPA consumer advisory for taste of 20 to 40 ppb.

Approximately 80 percent of incidents were reported by two companies. These two companies and one other were the only respondents that indicated that they have routine monitoring in place for MTBE contamination of ground water. It is expected, therefore, that the ground water contamination reported under the Notice under-represents the contamination that exists in some regions.

Most of the ground water contamination (67%) reported under the Notice occurred at sites that were active or former service stations. In most of these cases, the cause of contamination was not identified. In 11% of cases, the contamination was linked to underground storage tank systems.

Ground water contamination was also reported to have occurred at bulk plants (15% of reported incidents), cardlocks (4%), refineries (3%) and terminals (2%). The cause of the contamination was not identified for most cases.

MTBE was also detected at six sites where ground water was used as a source of drinking water. All six sites were located in PEI. The reported maximum concentrations of MTBE ranged from 1 to 5 ppb, levels below the PEI water quality guidelines for aesthetics and below the EPA consumer advisory for aesthetics of 20 to 40 ppb.

There were few reported releases of gasoline containing MTBE (nineteen) relative to the number of incidents of ground water contamination (250). Based on conversations with respondents and tank system experts, it is understood that most ground water contamination encountered at service station sites is due to leaks from underground storage tank systems, i.e. the tanks themselves and associated piping and pumps. Some sources, however, have indicated that they believe ground water contamination is due to small releases of gasoline at services stations during fill-up.

iii) Remediation of contaminated ground water and drinking water

The concentration of MTBE in contaminated water can be expected to decrease slowly without active remediation, as MTBE degrades naturally over time¹⁹. It is understood from the information provided under the Notice that remediation of contaminated soil and/or ground water was being carried out for 36% of the reported incidents. A further 27% were being investigated and subsequent remediation may have followed. For a further 20% of incidents, respondents indicated that water monitoring programs were in place. Remediation was reported to have been undertaken and completed for a further 8% of incidents. Some form of follow-up to the incidents of ground water contamination reported under the Notice was indicated for 97% of incidents.

All six locations at which MTBE was detected in ground water used as a drinking water source were being actively remediated. In fact, by November 2001, the concentration of MTBE had fallen to non-detectable levels (levels below 0.1 ppb, and below the PEI water quality guidelines of 15 ppb and the EPA consumer advisory level of 20-40 ppb) in three of these six locations.

i) Preventing releases of MTBE into the environment

Environment Canada does not expect that there will be significant use of MTBE in Canada outside of the Atlantic region post-2002. Only two refineries, both in Atlantic Canada, plan to use MTBE and one of those will use it only in gasoline that is exported. Nevertheless, it will be important to monitor the use of MTBE and replacement oxygenates in Canada. Environment Canada intends to do this by monitoring reports submitted to the department by gasoline producers and importers pursuant to requirements of the Benzene in Gasoline Regulations. Environment Canada will also monitor imports of MTBE into Canada through Statistics Canada's database of imports.

In addition, revisions to the CCME Environmental Codes of Practice are underway for the following: Underground Storage Tank Systems Containing Petroleum Products and Allied Petroleum Products, and Aboveground Storage Tanks containing Petroleum Products. The Codes of Practice, published in 1993 and 1994, respectively, specify a model set of technical requirements which are designed to protect the environment from leaking storage tank systems. The Codes also provide recommendations concerning design and installation of new systems and the upgrading of existing systems.

The CCME Codes of Practice have been adopted into regulations by all provinces, except B.C. and Newfoundland. Table 3.5 outlines the current requirements in provincial petroleum storage tanks requirements.

In 2002, the CCME updated the Codes and combined them to make requirements consistent with advances in technology and operating experience. The revised Code will be published in 2003. The Code will call for secondary containment with interstitial leak detection for all tanks within the scope of the Code, and for the removal of underground steel tanks that have never had cathodic protection. The Code will be an important measure for preventing leaks of gasoline from storage tanks and associated equipment from entering the environment. Some provinces intend to incorporate the Code into their regulations.

It is estimated that that there are approximately 10,000 tanks containing fuels that are operated by the Federal Government. In 2003, Environment Canada is intending to recommend new regulations for fuel storage tanks on federal lands, aboriginal lands, and those fuel tanks owned or operated by the Federal Government, Crown Corporations and federal works and undertakings. The regulations will include requirements consistent with the new CCME codes of practice for above ground and underground storage tanks.

ii) Detecting ground water and drinking water contamination with MTBE

Only three respondents reported that they had routine monitoring programs in place to detect ground water contamination with MTBE. It is quite possible, therefore, that the ground water contamination reported under the Notice under-represented the contamination that exists in the environment.

Protection and monitoring of ground and drinking water are areas of provincial jurisdiction. Environment Canada is aware of provincial monitoring programs in PEI, New Brunswick and B.C. as well as source or drinking water monitoring activities in all provinces and territories:

• P.E.I. has shared their data with Environment Canada; responses to the Notice are consistent with that data.
• B.C. has carried out monitoring at wells that are not located adjacent to service stations and found very little contamination. B.C. has no plans for further testing of ground water for MTBE contamination.
• At their June 2001 meeting, the Federal-Provincial-Territorial Subcommittee on Drinking Water requested that provinces and territories share information on MTBE contamination of drinking water contamination with the Subcommittee. Incidents of contamination of private wells were reported by New Brunswick. No other incidents were reported to the Secretary by other provinces or territories during the June-December 2001 response period.

Environment Canada plans to continue to monitor MTBE contamination of ground water and drinking water across Canada through information shared with the department by provinces and territories. On a broader level, Environment Canada will also continue to monitor the use of MTBE in gasoline in Canada as described in the previous section.

iii) Remediating contaminated ground water and drinking water

Remediation requirements differ by province. The Atlantic provinces have adopted a risk based approach in which remediation requirements depend upon the potential use of the ground water source. It is Environment Canada's understanding that only PEI and B.C. have guidelines for the remediation of ground water contaminated with MTBE, although guidelines may exist in other provinces for other components of gasoline, such as benzene and toluene. B.C. has set guidelines of 20 ppb for drinking water (aesthetic) and 3400 ppb for aquatic life and PEI has set a guideline of 15 ppb for drinking water (aesthetic).

In 2001, the Federal-Provincial-Territorial Subcommittee on Drinking Water undertook the development of Guidelines for Canadian Drinking Water Quality for MTBE. The CCME has work underway to develop water quality guidelines for MTBE for the protection of aquatic life. Both of these guidelines will be able to be used as clean up standards in remediating releases of MTBE into the environment.

• ¹³ Several nil responses were also submitted.
• ¹⁴ One additional company, BP, reported adding MTBE to gasoline in Canada in 2001. All of this gasoline was subsequently exported.
• ¹⁵ Blending is considered to be the addition of MTBE to gasoline at a point in the distribution system which is downstream of a refinery.
• ¹⁶ An eleventh company, Olco, imported gasoline containing MTBE, but not until 2001.
• ¹⁷ at volumes greater than 2 m³/year or greater.
• ¹⁸ Ranges in the graph were established from: California aesthetic guidelines for MTBE concentration of MTBE in drinking water (5 ppb); lower limit of EPA consumer advisory for MTBE in drinking water (20 ppb); and B.C. guidelines for MTBE in water for marine and estuarine life (440 ppb) and for aquatic life (3400 ppb).
• ¹⁹ The half-life of MTBE in ground water has been estimated to be between 56-360 days under aerobic conditions, and 112 to 720 days under anaerobic conditions (World Health Organization, International Programme on Chemical Safety, Environmental Health Criteria 206,Methyl tertiary- Butyl Ether, 1998, p. 31).