Ministry of Energy and Mines

Information Letter

This is to advise you of a program which commenced January 1, 1998, to reduce benzene emissions from glycol dehydrators.

Formulated by the Environment Canada sponsored Benzene Working Group (BWG), the program represents an important component of Canada’s overall program to reduce emissions of benzene. Benzene is a compound classified as toxic by the Canadian Environmental Protection Act. Organizations participating on the BWG included: Environment Canada, Health Canada, Natural Resources Canada, Pembina Institute for Appropriate Development, British Columbia Ministry of Environment, Lands and Parks (MELP), Saskatchewan Environment and Resource Management, Canadian Association of Petroleum Producers (CAPP), Canadian Gas Association, Small Explorers and Producers Association of Canada, Alberta Environmental Protection, and the Alberta Energy and Utilities Board.

Benzene, while considered a non-threshold carcinogen, is a naturally occurring compound. It is also released as a by-product from hydrocarbon combustion as well as many other types of human and industrial activities. Glycol dehydrators represent a disproportionate single source of benzene emissions within the upstream oil and gas industry. In response to the potential health concern that these emissions pose, the industry has published Best Management Practices for the Control of Benzene Emissions from Glycol Dehydrators (BMP), a document summarizing key information about benzene emissions from glycol dehydrators, including the reduction schedule and reporting requirements developed by the BWG, as well as methods to prevent and/or minimize emissions. It can be obtained from the following:

• Canadian Association of Petroleum Producers
  2100, 350 - 7 Avenue SW
  CALGARY, AB T2P 3N9
  Tel: (403) 267-1100 Fax: (403) 266-3214
• Small Explorers and Producers Association of Canada
  1060, 717 - 7 Avenue SW
  CALGARY, AB T2P 0Z3
  Tel: (403) 269-3454 Fax: (403) 269-3636
• Canadian Gas Association
  243 Consumer's Road, Suite 1200
  NORTH YORK, ON M2J 5E3
  Tel: (416) 498-1994 Fax: (416) 498-7465

On the Internet, the BMP can be downloaded from the following home pages:

http://www.capp.ca
http://db.nucleus.com/sepac
http://www.cga.ca

In British Columbia, MELP and the Ministry of Energy and Mines (MEM) support the guidelines as a precautionary response and agree that targeting glycol dehydrators offers a cost-effective approach to achieve meaningful emission reductions. Accordingly, they expect operators to be familiar with the guidelines and to implement any changes needed to achieve the goals, principles, and criteria contained in the BMP.

The key points of the program include:

• Industry implementation of an emission reduction schedule including regular reporting for assessment purposes. All data is to be made available to CAPP and to government agencies.
• All dehydrators commissioned on or before January 1, 1999, are to be controlled to emit not more than 9 tonnes of benzene per year by January 1, 1999. Data demonstrating attainment of this criterion is to be reported by March 1, 1999.
• All dehydrators commissioned on or before January 1, 1999 and located within 0.75 kilometres of residences are to be controlled to emit not more than 3 tonnes of benzene per year by January 1, 2001; those located at least 0.75 kilometres away from residences are to be controlled to emit not more than 5 tonnes of benzene per year by January 1, 2001.
• Glycol dehydrators commissioned after January 1, 1999 are to be designed and operated to emit not more than 3 tonnes of benzene per year. Facilities commissioned or relocated between January 1, 1999 and January 1, 2001 will not be subject to further controls that require new capital investments.
• Operators are to address the potential risks from benzene emissions in consultations with residents living in close proximity to glycol dehydrator facilities as detailed in section 5.4 of the BMP.
• All operators of dehydrators are to file a comprehensive report using the format and process described in the BMP by March 1, 2001. The reporting process will be initiated early in the year 2000.
• A Technical Advisory Team comprised of members of the BWG will assess industry’s performance in meeting the program objectives in 2001 to review the need for more formal regulation.

The BMP provides additional information respecting these and other aspects of the overall program.

Each operator has the responsibility to ensure the goals, criteria, communication, and reporting requirements of the BMP are implemented.

With the announcement of this program, we anticipate that industry’s effort to control risks associated with benzene will be highly successful, and that their commitment to significant reductions of potentially hazardous emissions will be obvious. While MELP and MEM agree that industry should be provided the opportunity and flexibility to reduce emissions without direct government involvement, we are committed to reducing benzene emissions from glycol dehydrators and are prepared to implement more formal requirements should the program described above not achieve the desired results.

Questions regarding the program and BMP may be directed to CAPP at (403) 267-1100, or MEM or MELP as indicated below.

Don Fast
Assistant Deputy Minister
Environment and Lands Headquarters Division
Ministry of Environment, Lands and Parks

and

Gerald German
Acting Assistant Deputy Minister
Energy and Minerals Division
Ministry of Energy and Mines

1998 06 05

Bill Bayrak
Audit Coordinator
Regional Oil and Gas Operations
Ministry of Energy and Mines
PO Box 6880
FORT ST. JOHN BC V1J 4J3
Telephone: (250) 262-3308
Fax: (250) 787-3445

Duncan Ferguson
A/Head, Industrial Pollution Prevention Technology
Pollution Prevention and Remediation Branch
Ministry of Environment, Lands and Parks
PO BOX 9342 STN PROV GOVT
VICTORIA BC V8W 9M1
Telephone: (250) 387-9952
Fax: (250) 953-3856