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Critics question LARP's air quality framework

Critics of the draft Lower Athabasca Regional Plan (LARP) are questioning why it has stringent criteria for only two potentially hazardous chemicals — compounds some would argue are not the most relevant to the area.

Critics of the draft Lower Athabasca Regional Plan (LARP) are questioning why it has stringent criteria for only two potentially hazardous chemicals — compounds some would argue are not the most relevant to the area.

The provincial government's Air Quality Management Framework under the draft LARP sets out “triggers and limits” for nitrogen dioxide (NO2) and sulphur dioxide (SO2) to keep ambient air quality below certain limits. If ambient air quality changes levels, the provincial government will take action.

The Minnie Lake Conservation Society has released a statement of concern about the draft plan stating “Neither of the proposed compounds … are the main air contaminants known to be produced by bitumen or heavy oil extraction.” The society also believes “many more contaminants must be added in order to effectively monitor air quality in this region.”

Coralee Beaulieu, along with other members of the MLCS, have reviewed the draft plan.

“That's when we noticed that the air quality framework looked to us as laypeople to be very minimal and not at all to be the compounds we know are emitted by heavy oil development,” she said.

“We don't know how this oversight came about, but somehow they managed to miss this ... It's in their (the government's) own document that these various compounds we're talking about are important in this area.”

The government released its Profile of the Lower Athabasca Region, which identifies pollutants of concern for the region.

It states, “From a human and ecological health standpoint, the primary air pollutants of concern are sulphur dioxide (SO2), nitrogen oxides (NOx), volatile organic compounds (VOCs), ground-level ozone, hydrogen sulphide (H2S), fine particulate matter, metals and polycyclic aromatic hydrocarbons (PAHs).”

The LARP draft states nitrogen dioxide and sulphur dioxide were highlighted for concern because they are two of the major substances released in the region.

They are actively monitored, predicted to increase with expanding development, and detected at increasing levels in certain areas of the region, says the government document.

Other reasons state they are regulated under the Environmental Protection and Enhancement Act, have established Alberta Ambient Air Quality Objectives, can be controlled through a range of options, and have sufficient monitoring data to allow local ambient air quality to be assessed against the air quality triggers and limits.

Dr. Ann-Lise Norman is the director of the undergraduate environmental science program at the University of Calgary and has worked with the MCLS in the past.

“We definitely know that there is health effects associated with organic contaminants in the atmosphere, with ozone, with carbon monoxide for example,” she said. “So it's not clear why those other contaminants have not been included (in the plan).”

She said sulphur dioxide and nitrogen dioxide are very good predictors of pollutant levels in the atmosphere from combustion and flaring in other parts of the province.

“But that's not appropriate in locations where you have a major industrial source that would be emitting other compounds such as volatile organic compounds.”

Volatile organic compounds, or VOCs, are known to be associated with heavy oil extraction, said Norman. She believes VOCs, along with fine particulate matter and polycyclic aromatic hydrocarbons, should be included in the LARP.

When asked if these substances are proven to be in the region, she said, “I think the only people who would debate it are perhaps the oil and gas industry, but I don't think that they would have much of a leg to stand on if you put it in front of any scientific group.”

Cara Tobin, a spokesperson for Alberta Environment, said nitrogen dioxide and sulphur dioxide were chosen as the first two substances for the draft framework and more will be added in the future.

“We had to start somewhere and so we chose these two particular substances because they are of particular concern within the region. And so we know that they're going to increase as development increases and so they were a really good starting point for the framework.”

She said sulphur dioxide is released primarily from industrial sources, while nitrogen dioxide is released from industrial sources as well as transportation and municipalities. She said they are monitored quite extensively. She noted there is already framework in place for ozone and particulate matter.

“More will be added as the framework is implemented and further developed. If we have the systems in place to do these two, it will be much more easy to add more compounds in the future.”

Tobin said she did not know how long it will take before other substances are added.

“Most of the infrastructure to monitor for these things is already in place and this is sort of a framework that – it's more about different management practices. It's really the triggers and the limits that are the new part.”

Dr. Ian Johnson is a chemist who analyzed data from projects investigating air emissions from heated bitumen storage tanks, including a study of tanks in LaCorey.

In a 2007 report entitled “Assessment of Hydrocarbon Emissions from Heated Bitumen Storage Tanks,” Johnson analyzed the data and determined what was coming out of the tanks and the flow rate, and what was toxic and potentially harmful.

The report states significant amounts of hydrocarbon emissions were released per day at some well sites in Alberta.

“All the stuff that's dangerous coming out of there, with the exception of maybe .1, .2 - maybe .5 per cent, they don't monitor for it,” explained Johnson in an interview with the Nouvelle. “And they're very reluctant to accept that it's even there.”

The methods used to monitor what is released are not sensitive or effective, he said, noting how it wouldn't take much to monitor them effectively.

“What's disturbing about the Lower Athabasca plan is they're not even monitoring for any organic hydrocarbons now.”

Johnson said if you look at health studies of residents exposed to emissions from petroleum chemical plants, volatile aromatic hydrocarbons (VACs) are the main chemicals that cause problems.

VACs tend to get neglected in Alberta Environment and ERCB studies and reports, he said.

“I don't know what the justification was for saying SO2 (sulphur dioxide) and NO2 (nitrogen dioxide) were the ones of concern,” he said of the LARP draft. “There's nothing presented in the report I can see that would actually justify that ... Where they came up with this is beyond me.”

He said nitrogen dioxide is a secondary pollutant, and is not generally emitted as a pollutant. It is formed as a result of the release of volatile aromatic hydrocarbons or compounds, and downwind of an emissions source, he added.

“Monitoring for it alone, likewise ozone too, is not really going to be very useful. It's a way of not finding a problem.”

When considering emissions from petroleum plants, nitrogen dioxide is generally not even considered, he said. Nitrogen dioxide is generally not released unless it is from diesel trucks or very high temperature boilers, he added.

“It is formed as a secondary pollutant, but it's generally not the big one for release – the hydrocarbons certainly are,” Johnson said.

“I would've expected a better rationale and I think the fact that it's so ludicrous that's why there is no rationale for excluding all the others. Excluding them is just unjustified.”

Johnson questioned why it wouldn't be easier to add all the substances to the framework at once.

“It's very difficult when industry is involved when it means adding compounds, it doesn't happen. If it's not included at the start it will never be added.”

Michael Bisaga, the Lakeland Industry & Community Association's (LICA) Airshed Zone program manager, said members have discussed the framework at a recent meeting.

When looking at historical monitoring data for the area, measurements for nitrogen dioxide and sulphur dioxide are far below triggers set in the framework, he explained.

What's driving some of the framework is what's going on in Fort McMurray where levels of nitrogen dioxide and sulphur dioxide are regularly exceeded, he said.

“We recognize that this management framework is really based on a framework that will lead to air quality improvements in Fort McMurray.”

He said he can understand concerns from those who think the management framework was designed in such a way that it's impossible not to be in compliance with it.

Bisaga said LICA's comment back to the land-use secretariat was not to lower the levels for the area.

“We're thinking that there are probably other management frameworks or other parameters that could a better suited tool for measuring where air quality is going in the region,” he said, citing the CASA (Clean Air Strategic Alliance) Particulate Matter Ozone Management Framework.

“The existing one … will likely be a better management tool to report on change in air quality in the region for our part of the Lower Athabasca area because what's going on north of the bombing range is so much different than what's going on south of the bombing range. The scale of industrial activity going on in Fort McMurray kind of dwarfs what's going on in our area.”

Bisaga said LICA has been monitoring VOCs and PAHs at its stations and has seen trace levels.

“I know it's a concern out there, but we adapted the monitoring network to try and address some of those concerns and we're not seeing an air quality issue related to VOCs at this time.”

He said historically LICA has not seen air quality issues related to VOCs or PAHs, noting how they are still in the lowest tier of concern, the surveillance level. But he said LICA is finishing a report on VOCs, so more information might be forthcoming.

As for Beaulieu, she hopes the government will add compounds to the draft LARP which it recognizes as being a concern in its Profile of the Lower Athabasca Region.

She encourages people to speak out about the issue with local politicians, noting how politicians can only respond to what the public tells them is important. She urges anyone interested in getting involved to contact her at 645-6638.

“We hope to see a framework for air quality that is a sufficient ... complete framework that covers all of the contaminants that could arise in our region that could affect human or environmental health.”

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