May 9, 2005

Spill prevention, contingency plans found lacking at nearly 25% of Sarnia petrochemical facilities

Almost one-quarter of petrochemical facilities in the Sarnia, Ontario area either had no spill prevention plan or spill contingency plan, and virtually all were found to be out of compliance with one or more regulatory requirements, following an 11-month inspection program conducted last year by a Ministry of Environment (MOE) SWAT inspection team.

Its final report, released April 27, revealed that although conditions at the Sarnia area facilities posed no immediate dangers to human health and the environment, 34 out of 35 inspected were in violation of one or more regulatory requirements. The most common deficiencies included:

*no proper spill prevention and/or spill contingency plans;

*no certificates of approval (C of As) for wastewater collection, sewage treatment works or air emission control equipment;

*altering equipment, systems, processes or structures contrary to terms and conditions set out in existing C of As; and/or

*improper chemical handling, storage or identification.

"The Sarnia-area sweep was the most thorough examination of an entire region's industrial facilities ever conducted by the SWAT Team," said Ontario Environment Minister Leona Dombrowsky, adding that "orders to comply with environmental legislation were issued to 34 of the 35 facilities inspected."

Dombrowsky sent the SWAT team to Sarnia in February 2004 in the wake of five major chemical spills into the St Clair River between August 2003 and February 2004. Three of the spills originated from sources on the Canadian side of the river and two of them forced the closure of the water intake facilities for downstream drinking water treatment plants.

The team found more than 260 instances of non-compliance with environmental requirements, and issued a total of 32 provincial officer orders. (The report, which may be viewed on the MOE Web site, www.ene.gov.on.ca, includes a detailed list of findings for each facility.) Deadlines for coming back into compliance varied according to the severity of the violation and complexity of the problem(s) to be resolved.

SWAT officers have followed up to ensure that corrective actions have been taken, and many of the companies cited have since complied with their orders. Others are still working toward meeting their requirements within the specified time allocations.

Of all the deficiencies uncovered by the inspection sweep, spill prevention and contingency plans are considered particularly critical preventive measures for petrochemical facilities because of the significant environmental, health and social impacts of spills on a community. Consequently, the fact that approximately 23% of the facilities inspected either had no spill prevention or contingency plans, or had only one of the two, is of special concern, says the report. As a result of the inspection sweep, six facilities were ordered to develop both a spill prevention and a spill contingency plan, while two were ordered to develop a spill prevention plan (as each of these already had a contingency plan in place).

Hazardous waste generation and manifesting requirements constituted the most common non-compliance issue, with 21 facilities accounting for 23% of violations in this area. Failure to meet the requirements set out in existing C of As (e.g. relating to air emission control equipment and wastewater collection systems) accounted for 13% of instances of non-compliance, notes the report.

Many companies' sound practices need wider implementation, says SWAT team report

On a positive note, the team did find sound business and operational practices in place at roughly two-thirds of the facilities-22 out of 35-and noted these in the report. Examples include:

*Containment, including monitoring sensors at surface water intake and discharge points with the ability to use automatic trip gates, skimmers, absorbent booms and alarms to prevent discharges to the St Clair River;

*Monitoring of once-through cooling systems at intermediate points in the process to detect any leaks (a spill prevention measure);

*Operations, e.g. closed-loop systems or electric fans as alternatives to once-through cooling water systems, to prevent contaminant releases to air or water;

*Wastewater/stormwater treatment, e.g. on-site secondary containment for stormwater until it can be tested, with all ditches gated on final discharge; and

*Contingency/spill planning, e.g. process hazard analysis (HAZOP studies) of all key processes, to determine critical process areas and find ways to reduce the use of hazardous chemicals, prevent contaminant discharges and minimize upsets.

Such practices, says the report, would have a positive impact if implemented by more facilities. In a "Future Directions" section, it cites the use of monitoring sensors on surface water intake and discharge points, monitoring of once-through cooling systems, use of closed-loop systems, and the use of stormwater retention ponds as the measures that would have the most beneficial impact if implemented by the petrochemical industry in the Sarnia area.

In addition to calling for spill prevention and contingency plans to be put in place by all facilties, the report points out that in some cases, companies have, incrementally over time, obtained approvals for various processes, additions or modifications, with the result that they have more than 100 C of As. This can cause misunderstandings about the rules in effect on a facility-wide basis; the report notes that only two of the facilities inspected had consolidated C of As for their air emissions.

Many complex facilities would benefit from working with the MOE to update their C of As, and operations with multiple sources of air emissions should be encouraged to apply for comprehensive site-wide C of As, it adds.

As the first comprehensive compliance probe of a major industrial sector of this complexity, the inspection sweep and its findings provide a baseline for future inspections of the industry. It also showed areas for improvement which merit consideration by both the industry and the Ministry, concludes the report.

In a follow-up speech to the annual meeting of Ontario Chamber of Commerce in Sarnia, Environment Minister Leona Dombrowsky outlined some of the actions the province will take to address industrial spills in the Sarnia area and throughout Ontario.

A highlight is the creation of an Industrial Committee on Technology and the Environment, co-chaired by the Sarnia Lambton Environmental Association (formerly the Lambton Industrial Society). This joint committee will explore how new and emerging technologies can reduce the risk of spills. "We believe industries are in the best position to determine the solutions that make most sense for their operations," she noted. The Ministry will also conduct a community scan to consult on the concerns of residents in the Sarnia area and their role in local pollution prevention efforts.

By the end of this year, the Minister said all facilities requiring spill prevention and/or contingency plans will have them in place. "We will also reduce the risk to the community by having updated chemical storage guidelines in place by the end of the year," she added.

"What we have learned in Sarnia is a lesson for the whole province," Dombrowsky concluded. "What we will develop in Sarnia will be the blueprint for safer, healthier and more prosperous communities."

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