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Information Request Template Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 1 of 52 Metro Vancouver Information Request No.2 to Trans Mountain Pipeline ULC Table of Contents Subject Page 2.1 Common Air Contaminants 3 2.2 Volatile Organic Compounds 17 2.3 Photochemical Modelling 24 2.4 Spill Modelling 25 2.5 Health Risk Assessment 28 2.6 Socio- Economics 39 2.7 Environment and Parks 40 Attachments 1 United States Environmental Protection Agency AP-42 Compilation of Air Pollutant Emission Factors, Chapter 1.5 Liquefied Petroleum Gas Combustion, http://www.epa.gov/ttnchie1/ap42/ch01/final/c01s05.pdf 2 Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, September 25, 2014 3a Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, November 13, 2014 – Excerpt 1: Introductions and Meeting Notes and Actions from September 25, 2014 meeting 3b Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, November 13, 2014 – Excerpt 2: Operational Assumptions and Photochemical Modelling Update 4 RWDI letter to Lesley Matthews, Trans Mountain, December 22, 2014 5 Guidelines for Air Quality Dispersion Modelling in British Columbia, British Columbia Ministry of Environment, Victoria, British Columbia, March 2008http://www.bcairquality.ca/reports/pdfs/air_disp_model_08.pdf] 6 Levelton Consultants (2007) Air Toxics Emission Inventory & Health Risk Assessment Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 2 of 52 [http://www.metrovancouver.org/about/publications/Publications/Air_Toxic s_Emission.pdf] 7 Health Canada (2014) Health Canada’s response to the Request for Comments on Human Health Risks indicated by Environment Canada’s modelling of Trans Mountain Expansion (TMX) air emissions, November 27, 2014 8 Canadian Council of Ministers of the Environment (2007) Guidance Document On Continuous Improvement (CI) And Keeping-Clean-Areas- Clean (KCAC): Canada-wide Standards for Particulate Matter and Ozone. [http://www.ccme.ca/files/Resources/air/pm_ozone/1389_ci_kcac_e.pdf] 9 [Extracts from] Website of the Invasive Species Council of Metro Vancouver http://www.iscmv.ca Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 3 of 52 Trans Mountain Pipeline ULC (“Trans Mountain”) Trans Mountain Expansion Project Information Request No. 2 2.1 Common Air Contaminants 2.1.1 Particulate Matter Emission Estimates for Vapour Combustion Unit References: i) A3S1U1, Application Volume 5C, Biophysical Technical Reports, Air Quality and Greenhouse Gas Technical Report, PDF page 203 of 567. ii) A4A4E3, Supplemental Air Quality Technical Report for Technical Update No.2, August 22, 2014, page 14. iii) Attachment 1, United States Environmental Protection Agency AP-42 Compilation of Air Pollutant Emission Factors, Chapter 1.5 Liquefied Petroleum Gas Combustion, http://www.epa.gov/ttnchie1/ap42/ch01/final/c01s05.pdf, Table 1.5-1, page 1.5-3. iv) Attachment 2, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, September 25, 2014, page 3, Action 11. v) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, pages 10 to 11. vi) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, page 38, Figure 4. vii) Attachment 2, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, September 25, 2014, page 6, Action 22. viii)A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, page 21. Preamble: Reference (i) states that exceedances of Metro Vancouver’s objectives for 24-hour PM10 and PM2.5 were predicted to occur for the Application Case. It is also stated that the largest contributor to predicted PM2.5 concentrations is the existing vapour combustion unit (VCU) at Westridge Marine Terminal. Particulate matter is one of the air contaminants of greatest concern in Metro Vancouver due to its potential health effects Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 4 of 52 and because there is no known threshold for adverse effects. Any increase in particulate matter levels is expected to result in an increase in negative health impacts. Reference (ii) states that, for that update, combustion emissions of CACs associated with operation of the VCU in the Base and Application Cases were estimated based on the United States Environmental Protection Agency AP-42, Chapter 1.5: Liquefied Petroleum Gas Combustion (US EPA, 2008) for particulate matter (PM) and carbon monoxide. For nitrogen oxides (NOx), emission rates based on a vendor performance guarantee were selected for use in the CALPUFF model. Reference (iii) is the US EPA document mentioned above, and provides butane and propane emission factors for industrial and commercial boilers. Reference (iv) records that there was a discussion regarding the PM emission rates estimated for the VCU and that vendor estimates, similar to those provided for NOx, would be an improvement over AP-42 emission factors. Also recorded is an action item for Trans Mountain to provide more detailed information on the PM emissions from the vendor. Reference (v) describes a Vapour Combustion Unit (VCU) as an open combustion stack with a burner element located near ground level that is enclosed so as to contain a visible flame. It explains that the differences between a VCU and an enclosed ground flare include that a VCU has a number of safety features and that it achieves a greater combustion efficiency. Reference (v) does not explain how a VCU is similar to an industrial or commercial boiler nor does it provide more detailed information on the PM emissions from the vendor. Reference (vi) provides the VOC emission rate during ship loading as a function of time. Reference (vii) records that Greg Hill of Trans Mountain stated that it is possible that during maintenance on the vapour recovery unit (VRU) the VCU could operate continuously for 24 hours. In Action 22, RWDI committed to provide emission rates for the situation when a VCU would be running 24 hours during VRU maintenance. Reference (viii) states that modelling was completed for normal operating conditions not for a VRU maintenance scenario. This reference does not provide emissions for the VCU assuming it runs continuously for 24 hours during VRU maintenance. Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 5 of 52 Request: a) Please specify which of the four sets of emission factors from Reference (iii) were used to estimate PM emissions from the VCU. b) Please explain how a VCU is similar to an industrial or commercial boiler and why it is appropriate to use emission factors for a boiler to represent emissions from a VCU, as compared to emission estimates provided by the VCU vendor. c) Please provide more detailed information on the PM emissions from the vendor of the VCU, such as stack test results from similar equipment. d) Our understanding is that propane gas is added to the VCU to improve combustion efficiency. As a result, combustion emissions from the VCU may not be as peaked as the VOC loading emissions. Please describe how propane fuel is added to the VCU as a function of time during ship loading. e) Please provide on the same plot as the one shown in Reference (vi): the flow rate of propane gas added to the VCU and the PM and NOx combustion emissions from the VCU as a function of time. Please also include on the same plot, the 24-hour average PM and NOx emissions used in the dispersion modelling. f) Please provide information on VRU maintenance scenarios, including how often this will occur, and the duration of maintenance time. g) Please provide isopleth maps of predicted rolling 24-hour average PM2.5 and PM10 concentrations resulting from continuous operation of the VCU during a 24- hour maintenance scenario. 2.1.2 Combined Case References: i) Attachment 2, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, September 25, 2014, page 4, Action 13. ii) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, page 15. Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 6 of 52 Preamble: Reference (i) records that there was a discussion regarding an updated combined case with emissions from the Burnaby Terminal (BT), Westridge Marine Terminal (WMT) and Marine emissions using the Marine Emission Inventory Tool (MEIT). Reference (ii) provides a combined case of predicted concentrations from marine emissions plus project emissions (WMT and BT) plus the ambient background but does not provide annual emissions from these sources. Request: a) Please provide a table that includes annual emissions for an updated combined case from the Burnaby Terminal, Westridge Marine Terminal and marine emissions using the Marine Emission Inventory Tool. 2.1.3 Comparative Results References: i) Attachment 2, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, September 25, 2014, page 4, Action 17.
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