The History of Alberta Air Management Systems

Dust, Smoke and Sour Gas The First 65 years of Air Quality Management in the Alberta Government 1945-2010

Dust, Smoke, and Sour Gas: The First 65 years of Air Quality Management in the Alberta Government, 1945-2010

Randolph P. Angle Retired 36-year veteran of Alberta Environment

October 2016

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ISBN No. (pdf) 978-0-9953357-0-7

Except as permitted under the Canadian Copyright Act, no part of this publication may be reproduced, distributed, or transmitted in any form or by any means, or stored in a database or retrieval system, without the prior written permission of the author (email: [email protected]).

While the author has used best efforts in preparing this book, no representations or guarantees can be provided with respect to the completeness or accuracy of the content. Mention of trade names or commercial products does not constitute endorsement or recommendation.

Preface

History is a means to understand both the past and present. Through history we interpret why things developed as they did and learn what influences may shape the future. The analysis and interpretation of history provides an essential context for evaluating contemporary approaches. History also provides a sense of identity and shared heritage. George Santayana (1863-1952), Spanish-American philosopher, essayist, poet, and novelist is often quoted or paraphrased in asserting that “Those who cannot remember the past are condemned to repeat it.” Much earlier Edmund Burke (1729-1797), Anglo-Irish statesman, author, orator, political theorist, and philosopher had expressed the same sentiment: “Those who don't know history are doomed to repeat it.”

As organizations adapt to a rapidly changing world, the importance of organizational history is often forgotten.1 An understanding of an organization’s history is important because static, “present-only” views of organizations seldom full explain why an organization succeeded or failed, and why it currently behaves the way it does. Choices made during an organization’s developmental stages get reinforced and stabilized to form the organization’s deep structure, activity patterns, and “mythology.” History shapes culture and responses to change. The world is prone to “fads”; what many may see as a “new” idea may actually be an old idea recycled in different terminology.

This document strives to capture the history of air quality management in the Government of Alberta. It provides a corporate memory of past initiatives and issues. It describes the foundations of the management system, identifies significant events, and recognizes the contributions of various individuals. Documentation is cited wherever available. When none could be found, the author has relied on his own files, notes and recollections supplemented by those of other air quality retirees. Many changes would lend themselves to more detailed analysis of causes, contributing factors, and ultimate outcomes. This has been left for others to pursue. On a broader scale, the history of air quality management in Canada as a nation of provinces and a federal government is recounted in a recent book published by Springer.2

1 Prywes, Yaron (2011) Organization History (OHx) Making the Construct Explicit in Organization Change Literature. OD Practitioner 43 (2): 40-45 2 Taylor, Eric and Ann McMillan, eds (2013) Air Quality Management: Canadian Perspectives on a Global Issue. Springer, 406 pp

Acknowledgements

The concept of an Alberta air management history originated with Chow Seng Liu in 2000 while he was with the Air and Water Pollution Control Program of Alberta Environment. Chow Seng arranged a meeting with some of the pioneers in the Department of Environment and collected some of the early legislative materials. This prompted the author to begin collecting historical materials. The publication 3 of The Last Stack , the history of the first environmental consulting firm in Alberta, also stimulated interest in the history of air management in Alberta. When Knowledge Management emerged briefly as a corporate priority, in 2005/2006 the Systems Development Branch of Alberta Environment was able to assign a student intern, Jennifer Martin, to the task of organizing the collection. Under the supervision of Dr. Raymond Wong, she produced a spreadsheet of dates and events, together with a covering narrative. Her work and report provided the starting point for this history.

The author retired from Alberta Environment in 2009, but was not able to work on the history until 2013. The Alberta Government Library, having absorbed the holdings of the old Alberta Environment Library, proved to be a valuable resource, with at least one copy of documents not already in the author’s collection. Additional information and input has been provided by a number of retired Alberta Environment employees: Jerry Lack, Al Schulz, John Torneby, Chow Seng Liu, Ray Brassard, and Harry Benders. Bill Calder reviewed the penultimate draft and made a number of valuable suggestions. Special thanks go to Randy Dobko of the Air Policy Branch, Alberta Environment and Parks, for his numerous contributions to this history. His personal document collection filled important gaps, his memory enabled a fuller account of source standards, and his careful review caught a number of mistakes in earlier drafts.

3 Stenson, Fred (2000) The Last Stack: Entrepreneurism and the Environment. CETAC-WEST, Calgary, AB. 367 pp

Contents Preface ...... v Acknowledgements ...... vi Figures ...... ix Tables ...... x Introduction ...... 1 Legislation ...... 3 The Public Health Act ...... 3 The Department of Environment Act ...... 6 The Clean Air Act ...... 7 Regulations under the Clean Air Act ...... 10 The Environmental Protection and Enhancement Act ...... 13 Environment Conservation Act ...... 15 The Alberta Environmental Research Trust Act ...... 16 The Energy Resources Conservation Act ...... 16 Summary of Legislation ...... 17 General Approach ...... 19 Policies and Programs ...... 19 Principles and Strategies ...... 19 Compliance Assurance ...... 29 Recognition of Good Performance ...... 32 Geographical Solutions ...... 33 Stakeholder Relations ...... 35 Organization for Air Quality Management ...... 38 Intergovernmental Cooperation ...... 43 Summary of General Approach ...... 46 Sources and Emissions ...... 47 Source Performance Standards ...... 47 Sour Gas Plants ...... 49 Electrical Power Plants ...... 52 Opacity ...... 53 Reciprocating Engines ...... 53 Oil Sands Plants ...... 54 Kraft Pulp Mills ...... 55 Chemical Plants ...... 56

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Fertilizer Plants ...... 56 Refineries ...... 56 Prill Towers ...... 57 Common Industrial Equipment ...... 57 Source Monitoring ...... 58 Stack Surveys...... 58 Continuous Emission Monitoring Systems (CEMS) ...... 59 Visible Emissions Monitoring ...... 60 Fugitive Emissions Monitoring ...... 61 Mobile Emissions Monitoring ...... 61 Emissions Inventories ...... 62 Urban Inventories ...... 62 Point Source Inventories ...... 63 Inventory Data Management ...... 66 Summary of Sources and Emissions ...... 66 Ambient Monitoring and Reporting ...... 68 Fixed Station Networks ...... 68 Air Quality Surveys ...... 77 Air Quality Reporting ...... 82 Data Quality Assurance ...... 84 Plans for Monitoring ...... 85 Summary of Ambient Air Quality Monitoring ...... 88 Ambient Air Quality Objectives ...... 90 Summary of Ambient Air Quality Objectives ...... 94 Dispersion Modelling ...... 95 Point Source Modelling ...... 95 Area Source Modelling ...... 100 Deposition Modelling ...... 103 Sour Gas Modelling ...... 105 Dispersion Meteorology ...... 107 Summary of Dispersion Modelling and Meteorology ...... 111 Science, Research and Technology ...... 112 Summary of Science, Research and Technology ...... 122 Conclusion ...... 123 Appendix A. Chronology of Significant Events in Alberta Air Quality Management ...... 126

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Appendix B. Individuals Who Worked in Air Quality Management ...... 134 Appendix C. Photographs of Some of the People Listed in Appendix B ...... 139 Appendix D. Summary of Findings and Recommendations of the Environment Conservation Authority Sour Gas Hearings (1972) ...... 143 Appendix E. Summary of Recommendations from the Environmental Law Enforcement Review Panel (1988) ...... 150 Appendix F. Organizational Structures and People ...... 153 Appendix G. Environment Department Logos ...... 159 Year Index ...... 161

Figures

Figure 1. The physical components of the air quality system and related major activities ...... 2 Figure 2. Serge Dobko, first air pollution engineer in the Alberta government (1982 photo) ...... 19 Figure 3. Cover of the 1969 guidance document for the gas processing industry ...... 20 Figure 4. Alberta’s Industrial Air Quality Management System 1996 ...... 26 Figure 5. Air quality management framework of the Clean Air Strategic Alliance ...... 36 Figure 6. Jerry Lack, first Head of the Air Quality Control Branch (1990 photo) ...... 39 Figure 7. Placemat form of the business plan...... 41 Figure 8. Members of the Federal-Provincial Committee on Air Pollution 1974 ...... 44 Figure 9. Chow Seng Liu at work in his office (1998 photo) ...... 47 Figure 10. The changes in sulphur recovery requirements from 1971 to 1988 ...... 51 Figure 11. Stack survey in progress (May 1977) ...... 59 Figure 12. Alberta Environment visible emissions chart...... 60 Figure 13. Vehicle emission testing ...... 62 Figure 14. Air monitoring in Edmonton 1973 ...... 69 Figure 15. Air monitoring in Calgary 1973 ...... 70 Figure 16. Edmonton air monitoring 1976 ...... 71 Figure 17. Calgary Air Monitoring 1976 ...... 72 Figure 18. Tape sampler used for smoke and dust in coefficient of haze units ...... 73 Figure 19. Dustfall station (left) and louvered shelter for the exposure cylinders (right), 1970s ...... 74 Figure 20. Don Kupina, senior monitoring technologist in Edmonton (1996 photo) ...... 74 Figure 21. Dave Bensler checking charts in Calgary continuous ambient monitoring station ...... 74 Figure 22. Ray Brassard at work in the electronics shop (1983 photo) ...... 75 Figure 23. Static and precipitation monitoring in Alberta 1994 ...... 76 Figure 24. Punch card for sour gas air monitoring data, late 1960s ...... 77 Figure 25. Wayne Buck (left), Whitecourt Office, circa 1985; Luke Stang (right), Red Deer Office, 1973 .. 78 Figure 26. Portable air monitoring unit of the 1980s ...... 78 Figure 27. Examples of air quality survey reports ...... 78 Figure 28. The Air Quality Measurement Laboratory (AQML) went into service in 1982 ...... 80 Figure 29. Harry Benders reviewing AQML data (1984 photo) ...... 80 Figure 30. Mobile Air Monitoring Laboratory (MAML), 1997 ...... 81

Figure 31. Examples of urban air monitoring reports ...... 82 Figure 32. Al Schulz (1986 photo) made many contributions to air quality management...... 83 Figure 33. John Torneby, supervisor of provincial air monitoring activities (1996 photo) ...... 87 Figure 34. The stakeholder-recommended process for AQO development...... 93 Figure 35. Randy Angle, Alberta’s first dispersion meteorologist (1999 photo) ...... 96 Figure 36. Cover of First Modelling Guideline ...... 97 Figure 37. User’s Manual for Alberta Environment Dispersion Models ...... 99 Figure 38. High air pollution days in Edmonton (Left ) and Calgary (Right) ...... 101 Figure 39. Urban air pollution model reports ...... 102 Figure 40. Cover of Deposition Model Report ...... 104 Figure 41. Joe Godin tracking a minisonde at the Ellerslie Meteorological station (1983 photo) ...... 108 Figure 42. Cover of book summarizing knowledge of dispersion meteorology in Alberta up to 1990 .... 110 Figure 43. Dr. Harby Sandhu, chief scientist for the air research program (1986 photo) ...... 113 Figure 44. Covers of symposium/workshop proceedings ...... 119

Tables

Table 1. Maximum Permissible Concentrations as specified in Regulation 10/73 ...... 12 Table 2. Minimum guidelines for monitoring required of gas processing industry in 1972 ...... 23 Table 3. Ambient monitoring requirements for sour gas plants in 1998 ...... 23 Table 4. Minimum separation distances between sour gas facilities and residences ...... 34 Table 5. CASA accomplishments ...... 37 Table 6. Source performance guidelines in place by 1990 ...... 49 Table 7. The Air Monitoring Plan of 1970 ...... 85 Table 8. Research themes under the Air Research Users Group ...... 118

Introduction

Alberta is situated between latitudes 49°N and 60°N and longitudes 110°W and 120°W, in the central belt of the northern cool temperate zone. The Rocky Mountains immediately to the west of the province prevent any extensive moderation by the Pacific Ocean, producing a continental climate characterized by extremes, typically long, cold winters and short, cool summers. In 1905 when Alberta became a province of Canada, the dominant industry was agriculture although coal mining in the southwest corner of the province made an important contribution. Coal production grew steadily and peaked in 1946. The forest products industry has also grown substantially.4

In May 1914 oil was discovered near Turner Valley, but there were only minor finds for many years after. Natural gas had already been discovered at Aldersyde in 1883 and numerous wells had been drilled in the Medicine Hat area. In 1909, near Bow Island, a very high production well nicknamed “Old Glory” prompted the construction one of the longest and largest pipelines of its time. The modern petroleum industry in Alberta did not really get going until the 1947 oil gusher near Leduc. “Sour” (containing hydrogen sulphide) crude oil and natural gas were first discovered in 1924 and the first plant to remove the sulphur was built near Turner Valley with the hydrogen sulphide being flared or vented to the atmosphere. A major sour gas find west of Calgary prompted the construction in 1952 of the first sulphur recovery at Jumping Pound. The elemental suphur became a valuable by-product that could be sold in the market.5

The production and use of fossil fuels (coal, oil, and natural gas) inevitably results in waste, some of which enters the atmosphere. Neighbouring farmers and residents expressed concerns about nuisances, odours and possible health effects. By the 1960s there was a broader environmental awareness among citizens and politicians. Dealing with air pollution became a government priority. Air management is concerned with the air system, wherein waste products are emitted to the atmosphere, dispersed over large areas through wind action, and ultimately received by various components of the ecosystem. The physical system is shown in Figure 1 with the main air quality activities of a management agency listed below the three main components.

4 MacGregor, James (1972) A History of Alberta. Hurtig Publishers, Edmonton, 335 pp 5 Bott, Robert D (2004) EVOLUTION of Canada’s oil and gas industry: A historical companion to Our Petroleum Challenge, 7th Edition, Canadian Centre for Energy Information, Calgary

Figure 1. The physical components of the air quality system and related major activities

The history of air quality management in the Alberta government is documented by identifying and describing the major developments in each of these individual system components. A chronology of significant events appears in Appendix A. It is focused on the Department of Environment in its various forms. While the Energy Resources Conservation Board played an important role in the regulation of the energy industry, its significant history has been addressed elsewhere6 and is mentioned here only where it intersected significantly with the Department of Environment.

6 Jaremko, Gordon (2013) Steward: 75 years of Alberta energy regulation. Energy Resources Conservation Board. 179 pp.

Legislation

Legislation is the law that is made by elected representatives. Statutes are publicly debated by the provincial legislature and voted upon before coming into force. Statutes generally state the broad principles or rules that are to govern in the jurisdiction. Regulations are the details that operationalize and allow for implementation of the statute. The power to enact regulations is delegated by statute to a Minister, or to cabinet (Lieutenant Governor –in-Council) or to an administrative body. Governments also employ “quasi-regulations” such as standards, guidelines permits, approvals, and mandatory codes of practice issued under authority of an Act or Regulation.

The Public Health Act

The Public Health Act of 1907 created a provincial Board of Health and made explicit mention of water pollution, but not air pollution.7 Although air pollution was not recognized as an issue at the time the provision that the Board may by such rules, orders, and regulations provide for and regulate… (b) the prevention and removal of nuisances;…(r) general, all such matters, acts and things as may be necessary for the protection of the public health would have provided some authority to take action. In 1919 the Alberta Legislature created the Department of Public Health to administer the Public Health Act and other acts dealing with health matters.8 Alberta was the second province to create such a department, the first having been New Brunswick.9

The first explicit mention of air pollution was included in the Public Health Act amendments of 1945:10

15a (1) The Provincial Board of Health may inquire into and hear and determine any complaint made...to the effect that dust, vapour, smoke or fumes …is being discharged into the atmosphere…and that as a result…the quality of air is being impaired or corrupted and the comfort or health of the public…is being injuriously affected.

The Board was empowered to make a report to the Minister on the person responsible and the remedial measures that were deemed just. Moreover the Board could order the responsible person to submit a report on the types of equipment available to eliminate the injury or invasion of right. Refusal to follow an order of the Provincial Board was an offence with a fine of between $20 and $50 for each day of default. Any person directly affected or the Minister could apply to a judge for a court order for the elimination or alleviation of the injury as described in the report of the Provincial Board of Health.

The following year (1946) the Public Health Act was further amended to address the issue of blowing dust around coal mines:11

15(b) (1) In any case where complaints have been received that any person or corporation is making or maintaining deposits of coal, slag, coal dust or other similar material...from which…when a wind blows dust or other material…over the premises of persons living near…the

7 Legislative Assembly (1907) Statutes of Alberta, Chapter 12: An Act Respecting Public Health, 234-264 8 Legislative Assembly (1919) Statutes of Alberta, Chapter 16: An Act Respecting the Department of Public Health, 123-123 9 Bow, MR and FT Cook (1935) The history of the department of public health of Alberta. Canadian Journal of Public Health. 26:384 396 10 Legislative Assembly (1945) Statutes of Alberta, Chapter 51: An Act to Amend the Public Health Act, 355-358 11 Legislative Assembly (1946) Statutes of Alberta , Chapter 49: An Act to Amend the Public Health Act, 311-312 3

said Board...may issues an order …to remove such deposits of coal, slag, coal dust or other material…to a distance designated.

The fine for failure to comply with the order was specified as between $100 and $500 for each day of default. The amendment was prompted by problems that were being experienced by the residents of the Crowsnest Pass as a result of a local coal mining and processing facility.12

In 1955, authority to manage air pollution was broadened with a Public Health Act Amendment adding authority with respect to:13

(r1) the prevention of the pollution, defilement or fouling of the atmosphere and the regulation of plants or industries discharging chemical or other waste matter into the atmosphere.

Contravention of an order, rule or regulation was subject to a fine of up to $500 for each day of contravention.

The first specific air pollution control regulation (Alberta Regulation 262/61)14 under the Public Health Act was promulgated in September of 1961. It:

a. Defined terms, for example:

“air contaminant” means any solid, liquid or gas or combination of any of them in the outdoor atmosphere resulting from the activities of man; “air pollution” means the presence in the outdoor atmosphere of any air contaminant in quantities that may cause discomfort to persons or endanger their health or safety, or that may cause injury or damage to property or to plant or animal life.

b. Required, for a variety of enterprises, the submission of plans for review and approval:

the Provincial Board of Health may require any person or corporation proposing or planning to construct a pipeline which will contain dangerous or noxious materials or an industrial plant, or other premises, which may be a source of air pollution in the Province of Alberta to submit plans and specifications… for review before construction is commenced. …no construction shall be undertaken or proceeded with until approval in writing…has been granted by the Provincial Board of Health. The Provincial Board of Health may direct such changes as …necessary in the public interest.

c. Introduced the Ringelmann Chart for the determination of smoke density and restricted smoke emissions according to the following chart:

Smoke Density Urban Areas over Urban Areas under Rural Areas 50,000 Population 50,000 Population No. 1 No Restrictions No restrictions No restrictions No 2 20 smoke units in any No restrictions No restrictions

12 Lack 2006, personal communication with Jennifer Martin 13 Legislative Assembly (1955) Statutes of Alberta , Chapter 30: An Act to Amend the Public Health Act, 81-82 14 Government of Alberta (1961) Alberta Regulation 262/61. Alberta Regulations 1961: 530-533

one hour No 3 10 smoke units in any 40 smokes units in any No restrictions one hour one hour No. 4 Not permitted 40 smokes units in any 80 smoke units in any one hour one hour No. 5 Not permitted Not permitted 75 smokes units in any one hour

A more relaxed set of standards was provided for building new fires, banking or cleaning fires, soot blowing or process purging. Exemptions were provided for fire-fighter training, ground thawing, and operations specifically authorized by the Board of Health.

d. Limited dust concentrations:

The concentration of dust in air effluents resulting from combustion or a processing or manufacturing operation shall not exceed 0.85 lbs per 1000 lbs of air effluent, adjusting to 50% excess air, and of this amount not more than 0.4 lbs shall be retained on a 325 mesh screen.

The amounts were to be determined following a test code from the American Society of Mechanical Engineers.

e. Specified an ambient objective for dustfall:

A dust fall in the surrounding area of 15 tons per square mile per month in residential areas or 45 tons per square mile per month in industrial or commercial areas shall be deemed excessive.

f. Restricted odours:

Odourous materials shall not be released or be permitted to escape to the atmosphere at such a rate as to interfere with the use and enjoyment of property or to endanger the health or safety of the public.

g. Prohibited release of toxic or noxious materials:

Toxic or noxious material shall only be released to the atmospheres after written approval has been obtained from the Provincial Board of Health and then only in such amounts and under such controls and safeguards as may be specified by the said Board.

In 1962 the Public Health Act was amended to extend the power to make orders, rules and regulations for air pollution to pipelines by adding the words and pipelines after industries.15

An amendment to the Control of Air Pollution Regulation in 1966:16

15 Legislative Assembly (1962) Statutes of Alberta, Chapter 69: An Act to Amend the Public Health Act, 275-276

a. Introduced a particulate emission standard and a method of measurement:

The concentration of particulates in effluents to the atmosphere resulting from combustion of fuels shall not exceed 0.85 lbs per 1000 lbs of effluent, adjusted to 50% excess air for products of combustion.

A similar standard applied to effluents from incineration and industrial processing or manufacturing.

b. Made the regulation applicable to

any pipeline, plant or premises…which is subsequently reconstructed or enlarged, or where processing or manufacturing operations are substantially changed or modified.

In 1967 Regulation 262/61 was amended to include pulp and paper products.17 In 1968 the Regulation was again amended18 to require that

Every incinerator, except those for one family dwellings, shall be designed and constructed in accordance with the latest edition of “Incinerator Standards for the Province of Alberta” as approved by the Provincial Board of Health.

This represents the first instance of an air pollution regulation making reference to a more technical Alberta document, whereas the original Regulation had referenced a third-party technical document.

The Department of Environment Act

On March 31, 1971 just a few months before the provincial election in which their 36 year reign came to an end, the Social Credit government of Alberta created Canada’s first Department of Environment19 with responsibility for:

a) the conservation, management and utilization of natural resources; b) the prevention and control of pollution of natural resources; c) the prevention of noise and the control of noise…; d) economic factors that directly or indirectly affect the ability of persons to carry out measures that relate to …(a), (b) or (c); e) any operations or activities (i) that adversely affect or are likely to adversely affect the quality or quantity of the any natural resource, or (ii) that destroy, disturb, pollute or alter or make use of a natural resource or are likely to do so;

16 Government of Alberta (1966) Alberta Regulation 276/66 Provincial Board of Health Regulations for the Control of Air Pollution, The Alberta Gazette, August 31, 1966: 636-641 17 Government of Alberta (1967) Alberta Regulation 231/67 Provincial Board of Health Regulations for the Control of Air Pollution Amended. The Alberta Gazette, June 30, 1967: 530 18 Government of Alberta (1968) Alberta Regulation 261/68 Regulations to Amend the Regulations for the Control of Air Pollution, The Alberta Gazette, August 31, 1968: 654 19 Legislative Assembly (1971) Statutes of Alberta. Chapter 24. The Department of the Environment Act, 98-111

f) the preservation of natural resources for their aesthetic value; g) laws in force in Alberta that relate to or directly or indirectly affect the ecology of the environment or natural resources.

The Act gave the Minister the authority to engage experts and establish advisory or administrative bodies. It also required him to prepare an annual report. The Minister’s duties included: coordination within the departments of Government, liaison with other governments, compilation and assessment of environmental information, conduct of environmental research, review of environmental research, funding of environmental research, promotion of environmental improvements, economic analysis of environmental matters, examination of fund-raising methods, and preparation of long range plans. The Minister was empowered to issues “stop” orders for contraventions of Acts or Regulations and the Lieutenant Governor in Council to make regulations about a wide variety of environmental matters. Environmental responsibilities were transferred from the Department of Health to the Department of the Environment.

During the March 7, 1972 Alberta Legislature throne speech debate, the first Progressive Conservative Minister of the Environment, Honourable Bill Yurko, outlined his objectives for the Department of the Environment:20

“(first)…create the climate of responsibility and awareness for environmental problems and instigate preventative measures where possible… (second), establish a level of understanding of the problems before us and those that are expected to arise because of urbanization and resource development…(third), establish meaningful legislation and regulations which are enforceable and establish the methods required for adequate enforcement…(and fourth)…balance environmental preservation against resource development (through short and long range planning) and to adopt such management practices as to maintain our renewable resources perpetuity and maintain a healthful and quality environment…”

The Clean Air Act

The Alberta Clean Air Act21 was passed on April 16, 1971 shortly before the federal Clean Air Act was passed in June. The Act gave the Minister the power to: a) prescribe maximum levels of density of any air contaminant, b) prescribe methods for determining the density. Such levels were not to exceed levels specified by the Provincial Board of Health.

Various types of “plant, structures, or thing” were listed as requiring a construction approval from the Director of the Division of Pollution Control. The Director was authorized to issue an Emission Control Order if an air contaminant exceeded maximum permissible levels prescribed by the regulations or if an offensive odour was present. The Minister was empowered to issue a Stop Order for contraventions of the Act or Regulations, failure to comply with an Emission Control Order, or if there were an immediate danger to human life or property. Investigators were granted the right to enter any premises. A person who failed to provide information requested by the Director was subject to a fine of up to $1000 per

20 Yurko, W (1972) Throne speech debate. Alberta Hansard, March 7, 1972 21 Legislative Assembly (1971) Statutes of Alberta. Chapter 16. The Clean Air Act, 63-73

day. A person guilty of an offense under the Act or Regulations was subject to a fine of up to $5000 per day and three months imprisonment.

The Lieutenant Governor in Council was empowered to make regulations concerning: a) applications and exemptions, b) procedures and fees, c) adoption of codes, and d) general controls for air pollution.

In 1976 among a package of amendments (including the Clean Water Act and Department of the Environment Act), the Clean Air Act was amended substantially.22 It now recognized the existence of both a Director of Pollution Control and a Director of Standards and Approvals (and hence the two Divisions of the department). The Minister was given authority for:

a) prescribing the maximum permissible calculated ground-level concentration… for all or any part of Alberta; b) prescribing the maximum concentration ..that may be emitted…from a plant, structure or thing; c) prescribing the maximum weight of an air contaminant that may be emitted…; d) prescribing the maximum rate of emission…; e) prescribing the method …for ..determining: a. the concentration…; b. the calculated ground-level concentration…; c. the concentration of an air contaminant emitted…; d. the weight of an air contaminant emitted…; e. the rate of emission…from any plant, structure or thing; f. the visible emissions from a plant, structure or thing. f) prescribing the point at which a measurement… is to take place…;

Regulations were permitted to refer to, incorporate or adopt, in whole, in part or with modifications, documents that set out standards of or relate to air quality, the prevention or control of air pollution or the design, construction, maintenance or operation of a plant, structure or thing that may be a source of air pollution.

The Director of Standards and Approvals was authorized to issues permits with terms and conditions for construction, air pollution measurements and pre-operational testing. The Director was also authorized to issue licenses for any plant, structure or thing with terms, conditions and requirements for operation. In extenuating circumstances when the terms, conditions or requirements could not be met, the Minster was empowered to issue a Certificate of Variance for a prescribed period of time.

The situations in which the Director of Pollution Control could issue an emission control order were broadened to include: a) Air contaminants in the atmosphere i. In concentrations exceeding maximum permissible concentrations; ii. In concentrations exceeding maximum permissible calculated ground-level concentrations; iii. exceeding maximum permitted visible emissions;

22 Legislative Assembly (1976) Statutes of Alberta. Chapter 65. The Environment Statutes Amendment Act, 1976, 422-436

iv. with an offensive odour; v. likely to be detrimental to life or health or to adversely affect property; and b) emissions exceeding the values specified in regulations.

In November of 1983 the Clean Air Act and the Clean Water Act were amended23 amid much controversy over the need for and intent of the changes. For more than a decade, Alberta Environment had a policy allowing public access to pollution monitoring reports filed by industry in compliance with statutory and license requirements. In 1983 legal advice from the Attorney General’s department suggested that the reports were the property of the industry preparing them and that the government could face legal action for the unauthorized release of such propriety and confidential information.24 The department found itself in a dilemma, having always held a commitment to provide monitoring data to the public, yet realizing it also had a contrary commitment to respect the confidential nature of industrial processes reported to the department. The 1983 amendment was intended to provide the department with the legal right to meet both needs.25 Industry viewed the legislation as simply providing a legal framework for the release of information it had always assumed would be in public domain once submitted to government. A preference was expressed for industry to respond directly to requests so there would be an opportunity to interpret the data and discuss pertinent issues.26 Some saw the amendment as an entrenching of ministerial discretion, providing no guarantee for public right of access and restricting information that was previously available.27

In 1985, the Environment Council of Alberta published a review28 of the Clean Air Act and the associated regulations, policies and related programs. There were twelve recommendations:

Purpose 1. An explicit goal for air quality management should be developed with public input. Setting Ambient Standards 2. Alberta Environment should publish a single document containing all of Alberta’s ambient air quality standards and their associated criteria. 3. Provisions should be made to allow public input during the development of ambient air quality standards. Industrial Emissions 4. Alberta Environment should reassess its policy regarding the utilization of the “assimilative capacity” of the environment for waste disposal. Setting Emissions Standards 5. The use of economic mechanisms to encourage industry to limit emissions should be examined and, for a selected industry, a pilot project should be mounted to test the operational feasibility of economic controls. Regulating Industry 6. Guidelines for the application of administrative discretion in allowing exemptions from emissions standards should be developed to clarify this aspect of regulation for Department administrators, regulated industry and the interested public.

23 Legislative Assembly (1983) Statutes of Alberta. Chapter 77. The Environment Statutes Amendment Act, 1983, 177-178 24 Duncan, Linda F (1984) Point Counterpoint. Environment Views, March/April 1984: 4 25 Kupchanto, Eugene (1984) Point Counterpoint. Environment Views, March/April 1984: 4-5 26 Worbets, BW (1984) Point Counterpoint. Environment Views, March/April 1984: p 5 27 Sniatynski, Gilian (1984) Regulating the industry, a shared responsibility. Environment Views, Nov/Dec 1984:19-21 28 Environment Council of Alberta (1985) Alberta’s Clean Air Act: Conclusions and Recommendations of the Review of the Clean Air Act. Staff report prepared by Mary Gordon and Brian Free. Environment Council of Alberta, March 1985

Monitoring Air Quality 7. An effort should be made to promote public awareness of the Department’s urban air quality monitoring activities. 8. A more comprehensive air quality monitoring program for larger urban communities…should be examined. 9. The Department’s quality assurance program for company monitoring data should be re- evaluated to determine its adequacy. Enforcement 10. The Department should examine its policy favouring negotiation of compliance to ensure that the willingness to prosecute is clearly established as an option in both the industry and public mind. Other sources of Air Pollution 11. Alberta Environment should investigate how sources of air pollution not regulated by the Clean Air Act should be reduced. Research 12. The Provincial Government should encourage and support further research into health and environmental effects of air contaminants in Alberta.

While the immediate reaction of the Government is not entirely clear, virtually all of these recommendations were eventually implemented as the history of the various components illustrates.

Regulations under the Clean Air Act

Shortly after passage of the Clean Air Act, The Clean Air Regulations29 were published. They stipulated that: 1. the construction of a new plant must be approved by the Director; 2. the plans and specifications submitted to the Director must contain certain specific information; 3. an expert report may be required, especially as concerns air contaminant releases; 4. additions, alternations or changes to a plant require approval from the Director; 5. the Director must also consider: other nearby plants emitting air contaminants, effects on people and the environment, atmospheric (meteorological) conditions, topography, likely development in the area, and calculated ground-level concentrations alone and combined with other plants. 6. the owner of each plant submit, reports, returns and information as specified in the approval; 7. an application fee of $25 be paid; 8. the approval use the format provided in an attached Schedule.

One of the significant features of this regulation is that it addressed what in the early 2000s came to be called “cumulative effects”. From the beginning of air quality management in the province the impact of multiple plants was being considered in making concentration calculations and issuing approvals.

In 1973 the Clean Air Regulations30 changed the approval process into two parts: (1) Permit to Construct, and (2) Licence to Operate. The Clean Air General Regulations31 replaced the 1971

29 Government of Alberta (1971) Alberta Regulation 299/71 Clean Air Regulations. The Alberta Gazette, October 30, 1971: 1170-1174 30 Government of Alberta (1973) Alberta Regulation 33/73 Clean Air Regulations. The Alberta Gazette, February 28, 1973: 74-79

regulation and recognized the two different divisions of the department with responsibilities for air pollution. The regulation: 1. permitted the department to publish guidelines and standards for construction and operation; 2. prohibited the release of toxic air contaminants without the approval of the Director of Standards and Approvals; 3. imposed a fine of $1000 per day for any unauthorized release; 4. required that reports be prepared as specified by the Director of Pollution Control; 5. set out a tariff of fees for permits and licences; 6. required that unauthorized releases be reported within 72 hours; 7. provided for transition from the previous licencing authorities.

The 1973 regulation was itself replaced in 1975 by an expanded version32 which: 1. included the concepts of burnable debris and prohibited debris, the latter requiring approval from the Director of Standards and Approvals; 2. defined restricted burning areas around the cities of Edmonton and Calgary and allowed open burning only with the approval of the Director of Standards and Approvals.

A 1980 amendment exempted from approvals small portable incinerators used to dispose of camp wastes from exploration sites and in use at one location for less than a year.33 In 1982, restricted burning areas were removed from the regulation.34 A minor amendment in 1984 added hazardous waste facilities to those plants requiring approvals.35 Regulation 24/86 exempted from approval small sweet natural gas processing plants with emissions of oxides of nitrogen less than 16 kg/h.36

Also published shortly after the passage of the Clean Air Act were the Air Contaminant (Maximum Levels) Regulations.37 They specified: 1. a method for determining the degree of blackness of a visible emission (the Ringelmann chart first introduced by the Board of Health); 2. allowable densities for urban areas with populations less than 50,000, urban areas with populations more than 50,000 and rural areas; 3. the concentration of particulates in an effluent stream should not exceed 0.85 lbs per 1000 lbs of effluent adjust to 50% excess air for products of combustion. 4. any releases of toxic, noxious or odorous contaminants require a written approval from the Director.

This was largely a restatement of the previous regulation under the Provincial Board of Health.

31 Government of Alberta (1973) Alberta Regulation 34/73 Clean Air (General) Regulations. The Alberta Gazette, February 28, 1973: 80-82 32 Government of Alberta (1975) Alberta Regulation 216/75. Clean Air (General) Regulations. The Alberta Gazette, August 20, 1975: 608-611 33 Government of Alberta (1980) Alberta Regulation 215/80. Clean Air (General) Amendment Regulation. The Alberta Gazette, July 31, 1980: 758 34 Government of Alberta (1982) Alberta Regulation 342/82. Clean Air (General) Amendment Regulation. The Alberta Gazette, August 31, 1982: 1715 35 Government of Alberta (1984) Alberta Regulation 407/84. Clean Air (General) Amendment Regulation. The Alberta Gazette, January 15, 1985: 1805 36 Government of Alberta (1986) Alberta Regulation 24/86. Clean Air (General) Amendment Regulation. The Alberta Gazette, February 15, 1986: 64 37 Government of Alberta (1971) Alberta Regulation 303/71. The Air Contaminant (Maximum Levels) Regulations. The Alberta Gazette, November 15, 1971: 1190-1193

These were replaced by an expanded Regulation 10/73 which specified the maximum permissible concentrations38 of air contaminants in the ambient air for sulphur dioxide, hydrogen sulphide, total oxides of nitrogen as equivalent nitrogen dioxide, carbon monoxide, total oxidants as equivalent ozone, and suspended particulates, as shown in Table 1. Dustfall readings were not to exceed 53 mg/100 cm2/30 days in residential and recreational areas and 158 mg/100cm2/30 days in commercial and industrial areas.

Table 1. Maximum Permissible Concentrations as specified in Regulation 10/73

Contaminant ½-hour 1-hour 24-hour Annual other (µg/m3) (µg/m3) (µg/m3) (µg/m3) Sulphur dioxide 525 450 150 30 Hydrogen sulphide 17 14 4 Oxides of nitrogen 400 200 60 Carbon monoxide 15,000 6 mg/m3 as 8-h average Total oxidants 100 30 Suspended particulates 100 60 Dustfall 53 mg/100 cm2/30 days in residential & recreational areas 158 mg/100 cm2/30 days in commercial & industrial areas

The regulation tightened the allowable particulate emissions for all new plants to 0.2 lbs per 1000 lbs of effluent, 0.4 lbs per 1000 lbs effluent for portable asphalt plants, and 0.6 lbs per 1000 lbs effluent for the incineration of refuse.

Regulation 218/75 replaced Regulation 10/73 to provide greater clarity with additional definitions and more specific wording.39 An amendment in 1977 established a program for the certification of visible emission readers with reference to a department publication A Manual for Training and Certification of Observers and Evaluation of Visible Emissions.40 A further amendment applied the same emission standard to portable asphalt plants as to stationary asphalt plants.41 An amendment in 1978 introduced emission standards for secondary lead smelters42 and referenced the Alberta Stack Sampling Code for emissions measurements and Environment Canada’s Standard Reference Method for the Determination of Lead in Particulates (Atomic Absorption Spectrophotometry) for atmospheric measurements. Effluent stream surveys were to be conducted in the presence of a Department employee. Further amendments in 1979 introduced source performance standards for vinyl chloride and polyvinyl chloride plants with

38 Government of Alberta (1973) Alberta Regulation 10/73. Clean Air (Maximum Levels) Regulations. The Alberta Gazette, January 31, 1973: 23-28 39 Government of Alberta (1975) Alberta Regulation 218/75. Clean Air (Maximum Levels) Regulations. The Alberta Gazette, August 30, 1975:612-618 40 Government of Alberta (1977) Alberta Regulation 224/77. Clean Air (Maximum Levels) Amendment Regulations. The Alberta Gazette, August 31, 1977: 1012-1014 41 Government of Alberta (1977) Alberta Regulation 334/77. Clean Air (Maximum Levels) Amendment Regulation. The Alberta Gazette, December 31, 1977: 1308 42 Government of Alberta (1978) Alberta Regulation 167/78. Clean Air (Maximum Levels) Amendment Regulation. The Alberta Gazette, May 15, 1978: 653-655

requirements for source surveys and atmospheric monitoring of vinyl chloride concentrations.43 Incidentally it raised the maximum permissible concentrations for oxidants as equivalent ozone to 50 µg/m3 as a 24-h average and 160 µg/m3 as a 1-h average. This aligned with the National Maximum Acceptable Level whereas previously the values were aligned with the National Maximum Desirable Level.

In 1984, the half-hour maximum permissible concentrations for sulphur dioxide and hydrogen sulphide were removed.44

Four other regulations were also issued under the Clean Air Act. Regulation 9/74 granted the right to appeal a Ministerial stop order to the Environmental Conservation Authority.45 Regulation 88/74 delegated the powers of the Director of Pollution Control to the Energy Resources Conservation Board for natural gas processing plants.46 Regulation 89/74 did the same for thermal electrical power plants.47 After the controversial amendments to the Act around information release, Regulation 403/84 provided an application form for the release of information.48

The Environmental Protection and Enhancement Act

During the late 1980s there was growing discontent with the apparently piecemeal approach to the environmental management which had resulted in nine different Acts to manage different aspects of environment. Industry was unhappy with the requirement to obtain several different permits and licenses for the same activity. Public interest groups were concerned that an integrated approach was not being taken. Consequently the Environmental Protection and Enhancement Act (EPEA)49 was developed with significant consultation and passed on June 26, 1992. It came into force on September 1, 1993. EPEA was the consolidation of nine acts: the Agricultural Chemicals Act, the Beverage Container Act, the Clean Air Act, the Clean Water Act, the Ground Water Development Act, the Hazardous Chemicals Act, the Land Surface Conservation and Reclamation Act, the Litter Act, and some sections of the Department of Environment Act. Unlike previous legislation, EPEA provided a clearly stated purpose and principles:

The purpose of this Act is to support and promote the protection, enhancement and wise use of the environment while recognizing the following: (a) the protection of the environment is essential to the integrity of ecosystems and human health and to the well-being of society;

43 Government of Alberta (1979) Alberta Regulation 319/79 Clean Air (Maximum Levels) Amendment Regulation. The Alberta Gazette, September 29,1979: 1097-1100 44 Government of Alberta (1984). Alberta Regulation 40/84. Clean Air (Maximum Levels) Amendment Regulation. The Alberta Gazette, February 15, 1984: 155-156 45 Government of Alberta (1974) Alberta Regulation 9/74 Stop Order Appeal Regulations. The Alberta Gazette, January 31, 1974: 21-22 46 Government of Alberta (1974) Alberta Regulation 88/74. Natural Gas Processing Plant Delegation Regulations. The Alberta Gazette, April 15, 1974: 219-220 47 Government of Alberta (1974) Alberta Regulation 89/74. Thermal Electric Power Plant Delegation Regulations. The Alberta Gazette, April 15, 1974: 220 48 Government of Alberta (1984) Alberta Regulation 403/84. Release of Monitoring Information Order. The Alberta Gazette, January 15, 1985: 1794-1795 49 Legislative Assembly (1992) Environmental Protection and Enhancement Act. Revised Statutes of Alberta 2000. Chapter E-12

(b) the need for Alberta’s economic growth and prosperity in an environmentally responsible manner and the need to integrate environmental protection and economic (c) the principle of sustainable development, which ensures that the use of resources and the environment today does not impair prospects for their use by future generations, (d) the importance of preventing and mitigating the environmental impact of development and of government policies, programs and decisions; (e) the need for Government leadership in areas of environmental research, technology and protection standards; (f) the shared responsibility of all Alberta citizens for ensuring the protection, enhancement and wise use of the environment through individual actions; (g) the opportunities made available through this Act for citizens to provide advice on decisions affecting the environment; (h) the responsibility to work co-operatively with governments of other jurisdictions to prevent and minimize transboundary environmental impacts; (i) the responsibility of polluters to pay for the costs of their actions; (j) the important role of comprehensive and responsive action in administering this Act.

The two-stage process of Permit to Construct and Licence to Operate was replaced by a single Approval. The single Approval would include all terms and conditions for all aspects of the environment that previously required separate approvals under separate acts. A cornerstone of EPEA was the involvement of the public in decisions about the environment, including environmental assessment and approvals. An Appeals Board was also created to provide an opportunity for certain decision to be reviewed by an independent tribunal.

Air pollutants were defined as “substances” and the terms “air quality” or “air pollution” were not explicitly mentioned in the Act. The Substance Release Regulation50 restated much of the content of the former Clean Air (General) and Clean Air (Maximum Levels) Regulations. Codes of Practice were adopted for activities with low environmental risk. The Ozone Depleting Substances Regulation of 199351 was replaced by the Ozone Depleting Substances and Halocarbon Regulation52 in 2000 and amended in 2004.53 The Emissions Trading Regulation54 established a trading program for power plants at their end-of-design-life to meet Alberta Air Emissions Standards for Electricity Generation, which were an outcome of the Clean Air Strategic Alliance electricity project team recommendations. The Mercury Emissions from Coal-fired Power Plants Regulation55 was proclaimed to implement the CCME Canada- Wide Standards for Mercury, which was also part of the CASA work, which led to the adoption of the Electricity Emission Management Framework. Elements common to other parts of the environment were contained in broad regulations pertaining to designation of activities, administrative penalties, approvals and registrations procedures, environmental appeal board, environmental assessment, and release reporting.

50 Substance Release Regulation. Alberta Regulation 124/1993 51 Ozone-depleting Substances Regulation. Alberta Regulation 125/1993 52 Ozone-depleting Substances and Halocarbons Regulation. Alberta Regulation 181/2000 53 Alberta Regulation 132/2004 54 Emission Trading Regulation. Alberta Regulation 33/2006 55 Mercury Emissions from Coal-Fired Power Plants Regulation. Alberta Regulation 34/2006

Environment Conservation Act

Prior to the creation of the Department of Environment, in 1970, the Legislative Assembly passed The Environment Conservation Act, which established the Environment Conservation Authority56 and gave it authority to:

• Conduct a continuing review of polies and programs of the Government and government agencies on matters pertaining to environment conservation; • Inquire into any matter pertaining to environment conservation and makes its recommendations and report thereon to the Lieutenant Governor in Council;… • Hold public hearings for the purpose of receiving briefs and submissions on any matter pertaining to environmental conservation; • Hold joint meeting with public advisory committees; • Refer any matter… to the Conservation and Utilization Committee; • Engage the services of persons having special technical or other knowledge… • Achieve coordination of policies, programs and administrative procedures of the Government and government agencies relating to matter pertaining to environment conservation.

The Act also created a Conservation and Utilization Committee comprising employees of government departments and agencies for the purpose of coordinating activities pertaining to environment conservation.

An Amendment in 1972 altered the structure somewhat and changed the reporting to the Minister of Environment rather than the Lieutenant Governor in Council.57

In 1972 the ECA published a major report and recommendations on the environmental effects of the operation of sulphur extraction gas plants in Alberta.58 Air relevant findings and recommendations are included in Appendix D. No record could be found of a formal response to these recommendations by the Alberta Government. However, as history shows virtually all of the recommendations listed above were ultimately to be acted upon.

In 1977 The Environment Council Act narrowed the scope of the former Authority to inquiries or public hearings specifically requested by the government.59

In 1982 the Environment Council undertook a comparative study of Canadian standards, standard setting process and enforcement.60 Air-related conclusions and recommendations included:

• Alberta …has adopted the Canadian Federal “desirable” level for particulates, carbon monoxide, oxides of nitrogen (annual average), and sulphur dioxide, and the Canadian Federal acceptable level for oxides of nitrogen (24-h and 1-h) and oxidants (ozone). However, a standard for

56 Legislative Assembly (1970) An Act Respecting Environmental Conservation. Statutes of Alberta. Chapter 36: 202-207 57 Legislative Assembly (1972) The Environment Conservation Amendment Act, 1972. Statutes of Alberta, Chapter 38: 134-144 58 Environment Conservation Authority (1972) Environmental effects of the operation of sulphur extraction gas plants in Alberta: Report and Recommendations. October 1972 59 Legislative Assembly (1977) The Environment Conservation Amendment Act, 1977. Statutes of Alberta, Chapter 66: 521-526 60 Franson MAH, Franson RT and Lucas AR (1982) Environmental Standards: A Comparative Study of Canadian Standards, Standard Setting Processes and Enforcement. Report prepared for the Environment Council of Alberta, September 1982

hydrocarbons…because it is important in the formation of photochemical smog…should be considered. • Alberta has special standards only for the fertilizer, vinyl chloride, natural gas-processing, and secondary lead smelting industries. …standards could be developed for other industries…or the Clean Air Regulations could be expanded to include other effluent quality parameters. • The setting of standards consists of a number of processes in which both technical and socio- political variables are considered and evaluated. …1. Formulation of objectives…2. Selection of criteria…3. Establishment of ambient standards…4. Establishment of effluent standards…5. Monitoring and enforcement. • Generally, goals and objectives upon which standards are based are not clearly articulated…Nor is the judgmental aspect of ambient standard specification made clear. Generally, the process of standard-setting is treated as a technical process by government and industry. … In our view public participation should be an essential part of standard setting • After our review, we do not know how well environmental standards are being enforced. We do know that there are public officials who are committed to enforcement…And we know that they encounter difficulties, but seem to be experimenting with new ways of dealing with those difficulties. But we also observe a lot of public criticism. Many observers seem to feel that government is not making a serious effort. We feel that an information gap may be responsible for this lack of public confidence, and recommend that a greater effort be made to explain the enforcement process to the public and to document its successes.

As a result of government downsizing in 1995, the Environment Council of Alberta was eliminated along with the Alberta Environmental Research Trust.61 Nevertheless, many of the recommendations made by the Environment Council were implemented through EPEA, including the establishment of an Environmental Appeal Board and the extension of accountability for industry compliance to senior corporate officials.

The Alberta Environmental Research Trust Act

In 1971 the government established a corporation with a mandate: a) To seek and receive property by gift, bequest, devise, transfer or otherwise, and b) …to hold, use and administer it for the purpose of provincial expansion of applied and fundamental research relative to environmental improvement.

In 1981 an amendment added “development” to the research support mission.62 Restructuring in the Department of Environmental Protection in 1994 resulted in the phasing out of the Alberta Environmental Research Trust along with the Environment Council.

The Energy Resources Conservation Act

After the federal government transferred natural resources to provincial jurisdiction in 1930, the provincial government, in 1938, established the Petroleum and Natural Gas Conservation Board whose purpose was the regulation of the production of oil and gas. The Oil and Gas Conservation Act of 1957

61 Legislative Assembly (1995) Environmental Protection Statutes Repeal Act. Statutes of Alberta, Chapter 15: 287-288 62 Legislative Assembly (1981) Environment Statutes Amendment Act, 1981. Statutes of Alberta, Chapter 67: 907

replaced the Petroleum and Natural Gas Conservation Board with the Oil and Gas Conservation Board.63 In 1971, the Energy Resources Conservation Act created the Energy Resources Conservation Board (ERCB) with a mandate that now included to control pollution and ensure environment conservation in the exploration for, processing, development and transportation of energy resources and energy.64 Subsequently the staff of the ERCB worked closely with Alberta Environment on matters related to air quality policy and regulation in the oil and gas sector.

The effective discharge of the Alberta Energy Resources Conservation Board’s (ERCB) responsibilities for the oil and gas industry required ongoing co-operation with the Alberta government departments managing air quality in Alberta. Two information letters issued in 1970 (IL-70-11 and IL-70-33) outlined the ERCB and the Department of Health responsibilities pertaining to “…pollution and environmental control related to drilling and production operations in the oil and gas industry” and pertaining to “environmental control at natural gas processing plants”. In later years various aspects of the cooperation between Alberta Environment and the ERCB were documented in Memoranda of Understanding.65

In 1982, the ERCB summarized the concerns raised by interveners at hearing on the processing of sour gas.66 These were discussed under the headings: sulphur dioxide and soil acidification, emissions in relation to livestock diseases, sulphur dioxide emission and their impact on streams and lakes, trace metal and other chemical emissions from sour gas plants, sulphur recovery, and surveillance of sour gas processing operations. Subsequently, the Energy Resources Conservation Board commissioned a study to answer the question about heavy metals in the emissions.67 Aside from its Decision Reports after public hearings, the ERCB also published data summaries and information reports, for example, facts on sour gas.68 Public hearings and the inquiry following the Lodgepole sour gas well blowout raised a number of concerns about the public health impact of sulphur compounds (H2S, SO2, COS, CS2 and mercaptans) and resulted in significant regulatory increases through the ERCB on sour gas well drilling and processing.

Summary of Legislation

63 Provincial Archives of Alberta ( 2006) An Administrative History of the Government of Alberta 1905-2006., Chapter 19 – Energy 1986-present 64 Legislative Assembly (1971) The Energy Resources Conservation Act. Statutes of Alberta, Chapter 30: 132-161 65 Informational Letter IL 98-1, IL 94-5 and IL 96-10 A Memorandum of Understanding Between Alberta Environmental Protection and the Alberta Energy and Utilities Board Regarding Coordination of Release Notification Requirements and Subsequent Regulatory Response; Informational Letter IL 96-07: EUB/AEP Memorandum of Understanding on the Regulation of Oil Sands Developments 66 ERCB (1982) Sour Gas Processing in Alberta: A Review of Evidence Presented at Recent ERCB Hearing Respecting the Impacts and Surveillance of Sour Gas Plants. Energy Resources Conservation Board, April 1982, 67 Gnyp, AW, CC St. Pierre, DS Smith, and S Viswanathan (1986) A trace element emission study at selected sour gas plant incinerator stacks in the province of Alberta. Prepared by the Industrial Research Institute of the University of Windsor for the Energy Resources Conservation Board, September 1986, 204 pp 68 ERCB (1983) Facts on Sour Gas Operation in Alberta. August, 1983. 11 pp.

Department of Environment was created in 1971 the basic infrastructure was in place. Air quality was given some focus with the passage of the Clean Air Act. The Department of Environment subsequently added to the regulations, expanded the permitting regime and developed quasi-regulatory instruments. The legislative focus on air quality was reduced with the passage of the Environmental Protection and Enhancement Act, which absorbed the Clean Air Act and its regulations. The authority granted to the Energy Resources Conservation Board (with variations in the name) under the Energy Resources Conservation Act gave the Department of Environment a powerful ally in addressing air pollution issues related to the Oil and Gas Industry. The Environmental Conservation Authority (later the Environment Council of Alberta) provided broad support in the form of public input and independent investigation while the Alberta Environmental Research Trust funded research projects until the belt tightening of the early 1990s eliminated these two agencies.

General Approach

An approach to air pollution control is a set of fundamental principles of action which reflect the basic philosophy or attitude of the regulator about the means that will be used to reach long term air management goals. Different strategies and tactics may then be employed for different types of sources or different pollutants. Policies and Programs

“Policy” may be defined as “a definite course or method of action selected from among alternatives and in light of given conditions to guide and determine present and future decisions”. Often policy is implicit in the programs operated by the organization. A “program” is a planned, coordinated group of activities, procedures, and projects to achieve a specific organizational purpose. People are employed by the organization to deliver these programs. Government programs are generally created in response to issues that have garnered the attention of influential citizens and politicians.

Principles and Strategies

In 1957 the British American Oil Company (BA) started operating a sour gas processing plant near Pincher Creek. The farm and ranch community around the plant became very concerned about the rotten egg smells (hydrogen sulphide), discoloration of paint (lead-based), barbed wire corrosion and potential health impacts. BA began monitoring sulphur dioxide and hydrogen sulphide levels using sulphation candles and insisted there was no serious pollution problem. The Department of Health brought in continuous monitors, and after its study required that the emission stacks be extended to ensure better dispersion. According to Stenson,69 the problems at Pincher Creek led to political recognition of the need to manage air pollution in the growing sour gas industry. In 1958 the Provincial Board of Health hired Sergius L. Dobko (Figure 2) as the first engineer to deal exclusively with air quality issues.

Serge Dobko, P.Eng., Alberta’s first air pollution engineer hired in 1958 laid the foundations for Alberta’s air quality management system. Serge also served as the Chairman of the Federal/Provincial Sub- Committee on Air Quality Objectives, thereby playing an integral part in national air quality management. He led the development and implementation of approvals policies, source emission standards and ambient guidelines. At his retirement in 1992, there had been significant sulphur dioxide emission reductions in the sour gas processing industry during a period of significant expansion. In negotiating industry approvals, he always pushed hard for additional pollution control.

Figure 2. Serge Dobko, first air pollution engineer in the Alberta government (1982 photo)

69 Stenson, F (2000) The Last Stack: Entrepreneurism and the Environment. CETAC-WEST, Calgary, Alberta

A 1966 article describes the program of the Division of Sanitary Engineering, Department of Public Health after the regulations of 1961 were passed.70 The standards set out in the regulation were in four areas: smoke, dust, odorous material and toxic or noxious materials. All new industry required a pollution control approval. After commencing operations, there were requirements for stack monitoring and area monitoring with permanent stations and with mobile units in summer and winter. Urban monitoring in Edmonton was for smoke at six locations, NO2 and NOx at one location, a portable oxidant analyzer, a high volume sampler and a network of four exposure cylinders (H2S and SO2), and eight dustfall stations. In Calgary there were two locations for smoke, exposure cylinders (H2S and SO2), dustfall and suspended particulates. A study of sources and their significance was carried out in 1964. Yearly reports were compiled for permanent stations and campaign reports for mobile units.

In 1969 the growth of the sour gas processing sector in the province led to the issuance of the first guidance document,71 the famous cover page of which is shown in Figure 3 .

Figure 3. Cover of the 1969 guidance document for the gas processing industry

70 Dobko, SL (1966) Air Pollution in Alberta. Canadian Journal of Public Health 57: 84-86 71 Alberta Department of Health, Division of Environmental Health Services (1969) Air Pollution Control at Gas Processing and Sulfur Recovery Plants. February 1969 20

This important document:

a. Gave an overview of the air pollution in general, b. Described methods of control at source and by dilution, c. Outlined the air pollution control system in Alberta at the time, d. Restated the legislation and regulations in place, e. Set out the ambient objectives that were to be met for sulphur dioxide, hydrogen sulphide and sulphur trioxide, f. Explained the approval process, g. Listed the considerations in designing a sour gas processing plant, h. Provided formulas for the computation of ½-h ground-level concentrations by two different methods, along with FORTRAN code for main-frame computers, i. Detailed flue gas sampling techniques and method of reporting, j. Identified sources associated with the sour gas and oil industry and the appropriate methods of emission control, k. Described the types of ambient monitoring surveys and the measurement methods that could be employed, and l. Specified the laboratory analysis methods used for determining concentrations.

This key document of early air management was produced by the Air Pollution Control Section, Division of Environmental Health Services. Serge Dobko, Head of the section, wrote in the preface to the document:

Air pollution knows no boundaries as such atmospheric pollutants are readily transportable and dispersed by the wayward action of winds. No one group has the sole right to contaminate our greatest resource, Air, to the detriment of his surrounding neighbors and because of this there is an obligation for control at the source.

This document also provided what seems to be the first explicit public air quality policy:

Regardless of the air pollution problem to be attached…that is, whether it be a community-side problem or merely a single-source problem…there are two fundamental approaches to control, the first being control of the pollutant at the source so that excessive amounts are not emitted to the atmosphere in the first place, and the second is natural dilution of the pollutant after it has been emitted to the atmosphere to such a concentration that man, animals, vegetation, and material will not be harmed.

Implementation of these two approaches led to:

• A requirement to submit plans and specifications for all new industries; • Compliance with regulatory limits, both source emission and ambient; • Follow-up to an approval by (a) actual measurement of the emissions , and (b) by area monitoring for the specific contaminants involved; and • Elimination or reduction of odour so as not to create a nuisance in the general vicinity of the plant.

These were the foundations of the air pollution control program in Alberta. By 1980 the program had evolved and a number of operational principles were stated:72

• Environmental protection can be best achieved if government and industry work together. In setting ambient air objectives the government sets the rules; in establishing source emission standards, industry can bring extensive expertise to assist the government. • Source emission standards can be tied to ambient air objectives through the use of dispersion models. • Regulations should be clear and consistently enforced • Rules and regulation must be realistic. • Ambient objectives become enforceable through licence requirements. • Stack design objectives must be more stringent than the ambient objectives. • Where there is a possibility of plume overlap, each emitting plant is allocated a portion of the design objective. • Best practicable technology (BPT) must be used to control emissions. BPT is defined by a government-industry task force. • Environmental Impact Assessments (EIAs) are useful in considering potential effects and choosing sites. • Ambient and source monitoring requirements (frequency, duration, and number) are based on emissions rates and potential toxicity of the pollutants. • Industry is responsible for environmental monitoring related to its own emissions; government is responsible for codes of practice and spot checking data quality and instrument operations. • Reporting of monitoring data to the government is essential to track performance. • Enforcement is an escalating series of actions.

The plume overlap principle was applied to the development of the oil sands in northeastern Alberta from the very beginning. Oil sands plants were allowed a little less than one third of the ambient air quality objective (0.06 ppmv out of 0.20 ppmv, ½-h averages).73 This was to provide “room” for additional oil sands plants to be built in the future. The plume overlap approach was an early example of what later became known as the management of “cumulative effects”.

Under the “polluter pay” principle industry is required to monitor ambient air quality in the vicinity of their operations, usually at sites based on maximum predicted concentrations or at sites with sensitive receptors. The data were used to evaluate the adequacy of source performance. Monitoring requirements were generally based on an informal sliding scale74 first established in 1972 and shown in Table 2.

72 Lack, Jerry C (1980) Development of an Industrial oriented air pollution control program. Presented at the 5th international Clean Air Congress, 20-25 October, 1980, Buenos Aires, Argentina. 20 pp 73 Alberta Environment (1972) Tar Sands Processing Plants Standards: air pollution control and emission standards for new and existing plants. November 20, 1972 74 Standards and Approvals Division (1972) Gas Processing Plant Standards: air pollution control and emission standards for new and existing plants. December 21, 1972

Table 2. Minimum guidelines for monitoring required of gas processing industry in 1972

Maximum Number. of Number of Number of Total Number of Stack Allowable Sulphur Continuous Months operation Sulphation and Surveys per year Emission Rates Monitoring per year Hydrogen Sulphide (long tons per day) Stations Exposure Cylinders 120-149 5 12 40 8 90-119 4 12 35 7 60-89 3 12 30 6 30-59 2 12 25 5 15-29 1 12 20 4 10-14.9 1 9 16 3 5-9.9 1 6 12 2 3-4.9 1 3 8 1 1-2.9 1 2 4 As required <1 As required As required 2 As required

Sulphur Production (long Number of Sulphur Dustfall tons sulphur per day) Exposure Cylinders >1000 12 100-1000 8 <100 4

The requirements were updated periodically and adjustments were often made to address local concerns, other types of emissions, operator commitments at hearings and other factors. Table 3 shows the ambient monitoring requirements as set out in 1998.75

Table 3. Ambient monitoring requirements for sour gas plants in 1998

Allowable SO2 Number of Number of Number of Emission Rate Continuous Months Static (tonnes /day) Monitoring Operated per Monitoring Stations Year Stations >244 5 12 40 183-244 4 12 35 122-183 3 12 30 61-122 2 12 25 30-61 1 12 20 20-30 1 9 16 10-20 1 6 12 6-10 1 3 8

75 Liu, Chow Seng (1998) Air Quality Criteria for Sour Gas Processing Industry: A Summary. Updated June 11, 1998 from an earlier 1990 document.

2-6 1 2 4 0.5-2 To be To be 2 determined determined <0.5 To be To be To be determined determined determined

Other policy requirements for the sour gas industry were:

For Sulphur Dioxide:

1. Sulphur dioxide emissions are expected to be controlled to meet the Alberta Ambient Air Quality Guideline of 0.17 ppm on an hourly average. 2. For new plants, incinerator stacks must be designed for an hourly emission rate that is a factor of 1.4 times the maximum daily emissions divided by 24 hours in a day. This provides for hour to hour variations in sulphur plant operations. 3. Stack gas exit temperature must be at least 538°C to ensure complete combustion of all sulphur compounds to SO2. 4. Stack gas exit temperature may be reduced to enhance energy conservation while maintaining an MGLC SO2 <0.17 ppm and TRS < 300 ppmv at point of measurement.

For Nitrogen Dioxide:

1. NO2 emissions must meet the Alberta Ambient Air Quality Guideline of 0.21 ppm on an hourly average. 2. All emissions of nitrogen oxides must be declared, such as those coming from compressors engines, reboilers, boilers, generators, heaters, etc. 3. Compressor engine exhaust stacks must be designed in accordance with the guidelines in EUB/AEP IL 88-5. 4. Compressor engine exhaust stacks must not be less than the building peak height. 5. Compressor engine must meet the low NOx requirement in accordance with the guidelines in EUB/AEP IL 88-5 for reciprocating engines and the guidelines in CCME for turbine engine.

For Hydrogen Sulphide:

1. H2S emissions from any source must not exceed the Alberta Ambient Air Quality Guideline of 0.01 ppm on an hourly average. 2. However, fugitive sources of H2S do exist from leaks, liquid and block sulphur. A fugitive emissions control program will generally keep these emissions under control and in compliance with regulations. 3. Hydrogen sulphide is not usually emitted to the atmosphere. It must be incinerated. 4. For new plants, liquid sulphur should be degassed before further processing. The H2S from the degasser or the liquid sulphur storage tank should be vented to the incinerator.

For Sulphur Handling

1. Solid sulphur must be handled in a dust-free manner.

2. In-situ remelt methods must be used for sulphur block reclamation instead of mechanical break-up methods unless it can be justified otherwise. 3. Sulphur forming and handling facilities must be designed to minimize dust emissions. CAPP's Sulphur Handling Guide may be referred to. 4. Solid sulphur loadout facilities should be enclosed to minimize dusting. 5. Conveyors should be covered to reduce dusting due to wind effects. 6. All conveyor transfer points must be enclosed; conveyor drop points must have a sock or tube and the drop distance minimized. 7. All areas subject to sulphur spills should be either asphalt or concrete paved to facilitate clean-up. 8. For all new sulphur handling operations, no loose sulphur shall be stored in the open. Silos and bins must be used. 9. Regulatory requirements are outlined in IL 84-11 and GB 92-4.

Monitoring (on an individual plant basis)

1. Continuous ambient monitoring of H2S, SO2, wind speed and wind direction is required. The number of stations required is related to the sulphur dioxide emission. 2. Static stations are required to monitor for H2S and sulphation on a monthly basis. The number of stations depends on the sulphur dioxide emission rate. 3. Soil monitoring is required annually to document changes in soil due to sulphur dusting. This is generally required of plants with sulphur blocks or sulphur forming operations. 4. Two stack surveys per year are required for all incinerator stacks to determine actual sulphur dioxide emissions. 5. Continuous stack emission monitors shall be installed in all sulphur recovery process unit incinerator stacks to continuously monitor the effluent stream for SO2 concentration and mass emission, volumetric flow rate, temperature, and oxygen content. These CEMs must meet the performance requirements as specified with the CEMS Code.

By 1987, the Air Quality Branch of the Standards and Approval Division reported the issuance of nine documents:76

1. Guidelines for location of stationary bulk ammonia storage facilities 2. Environmental control guidelines for asphalt paving plants 3. Guidelines for limiting contaminant emissions to the atmosphere from fertilizer planta and related industries in Alberta 4. Guidelines for plume dispersion calculation 5. Incinerator standards – Guidelines for design and operation of refuse incinerators in Alberta 6. Emission guidelines for fossil fuel fired thermal power generating plants in Alberta 7. Plume visualization techniques 8. A field investigation of stack aerodynamic downwash 9. Industrial projects – the Clean Air Act – How to obtain a licence or permit.

76 Standards and Approvals Division (1987) An overview of the standard setting and permitting and licensing procedures and practices of the Standards and Approvals Division. Prepared for the Review Panel on Environmental Law Enforcement in Alberta. August 1987.

The Branch continued to reiterate Alberta’s two-pronged approach: (1) technology-based source control using BPT and (2) meeting ambient standards. If BPT is insufficient to meet acceptable ambient air quality levels, a higher degree of control is required.

It was not until 1996 that a complete description of the Alberta Industrial Air Management system was clearly articulated77 complete with an explanatory diagram (Figure 4).

Figure 4. Alberta’s Industrial Air Quality Management System 1996

The paper noted that Alberta Environmental Protection was responsible for ensuring that emissions are minimized to protect human health and the environment, and that the Alberta Energy and Utilities Board was responsible for ensuring that energy resources are developed in a safe, efficient, and environmentally responsible manner. These responsibilities were seen as complementary, so both regulatory bodies work together to ensure their respective objectives are achieved. The industrial air quality management system had two main goals: (1) emissions from industrial facilities are minimized

77 Macdonald, WS and BF Bietz (1996) Management of industrial sulphur dioxide and nitrogen oxides emissions in Alberta – description of the existing system. Proceedings of the Acidifying Emissions Symposium, April 15-17,1996 Red Deer, Alberta, Clean Air Strategic Alliance, Edmonton

through the use of “best available demonstrated technology”, and (2) ambient levels of air contaminants in the vicinity of industrial facilities do not exceed Alberta’s guidelines.

Four main policies were listed in support of these goals:

• emissions from each industrial source must be controlled using the best available demonstrated technology that is economically achievable, • residual emissions must be dispersed through a stack designed to keep ambient concentrations below the Alberta ambient air quality guidelines. • industrial operators must monitor emissions and air quality around their facilities and report the measurements to the government, and • cumulative emissions from industrial sources are considered with respect to ambient guidelines and regional air pollution deposition.

A number of system components were described: ambient guideline levels, source emission standards, plume dispersion modelling, ambient air monitoring, source emission monitoring, environmental reporting, emissions inventories, approvals, inspection/abatement, enforcement and research.

In response to the global, national, and regional concerns about toxic substances in the environment, Alberta published a description of its air toxics management program in 1998.78 It used the same fundamentals as had been described in 1996 for acidifying emissions, supplemented with lists of specific chemicals being regulated in Alberta through approvals (including prescribed ambient levels), and those on the various Priority Substance lists being used by Environment Canada.

In a 2008 strategy document, reference was made to the two long-standing principles of polluter pay and pollution prevention as well as two more recent principles of continuous improvement and shared responsibility.79 These were elaborated as:

Polluter Pay:

• All emitters are responsible for controlling their emissions and bearing all costs associated with measuring emissions, monitoring potential effects, and mitigating any impacts on air quality and the environment. • Operators of significant point sources must monitor and report their performance both in terms of stack emissions and the resulting ambient concentration around their facilities.

Pollution Prevention

• Pollution prevention (the use of processes, practices, materials, products or energy that avoid or minimize the creation of pollutants or wastes at the source) is preferred over end-of-pipe treatment. • Emissions from significant point sources must use technology that allows for a high level of control while considering economic factors (use best available demonstrated technology).

78 Air Emissions Branch and Air Issues & Monitoring Branch (1998) Air Toxics Management Program in Alberta. Environmental Services, Alberta Environmental Protection, April 1998, 19 pp 79 Air Policy Branch (2008) Air Management Strategy for Alberta Environment. October 2008

• Residual emissions must be dispersed through a stack designed to keep ambient concentrations below ambient objectives. • Cumulative impacts from multiple sources must be minimized and must never exceed the assimilative capacity of the airshed (as defined by ambient objectives or regional outcomes.) • Reductions in air pollution must not result in additional waste burdens on surface water, groundwater, or land.

Continuous Improvement • All emitting sources must strive to improve their emissions performance with upgrades at appropriate time intervals. • Ambient objectives are not “pollute up to” levels; in clean areas or areas of high cumulative development better environmental performance may be expected. • Knowledge of Alberta’s air quality is the foundation for effective decision-making.

Shared Responsibility: • Alberta corporate and private citizens, as well as other Government Departments, need to consider air quality in their decision-making. • People affected by air emissions have a right to information and to be involved in decisions that affect them. • Citizens, communities, industry and government must share responsibility for air quality management in Alberta, and work together to improve conditions within their local airshed. • While all stakeholders have a role in managing air emissions and air quality, the ultimate accountability rests with Alberta Environment. • Alberta Environment decisions are informed by and made in the context of broader Government of Alberta outcomes and goals. • Albertans must recognize there are limits to the capacity of the atmosphere to accept waste and that Alberta’s air resources must be managed within the capacity of the individual airshed.

A description of the overall air quality management system80 was also finalized. There were now three parts: industrial regulation, comprehensive regional air management and air quality planning. Eleven principles guided industrial regulation:

1. industrial facilities must be designed and operated to prevent pollution; 2. emissions from each industrial source must use technology that allows for a high level of control while considering economic factors; 3. residual emissions must be dispersed through a stack designed to keep ambient concentrations below ambient objectives; 4. cumulative impacts from multiple sources must not exceed the assimilative capacity of the airshed as defined by ambient air quality objectives; 5. industrial operators are generally responsible for monitoring stack emissions and the resulting ambient concentrations around their facilities, to demonstrate compliance with emission limits and ambient objectives;

80 Alberta Environment (2009) Air Management in Alberta. Air Policy Section, Alberta Environment, January 2009.26 pp

6. industrial operators must report the monitoring results to the government; 7. cumulative emissions must be within regional emission targets where applicable 8. all emitters are responsible for controlling their emissions and bearing all costs associated with measuring emissions, monitoring potential effects and mitigating any impacts on air quality and the environment (Polluter Pay); 9. pollution prevention (the use of processes, practices, materials, products or energy that avoid or minimize the creation of pollutants or wastes at the source) is preferred over end-of-pipe treatment; 10. reductions in air pollution must not result in additional waste burdens on surface water, groundwater, or land; and 11. all emitting sources must strive to improve their emissions performance with upgrades at appropriate time intervals (continuous improvement).

Although the Department of the Environment Act set out responsibilities of the department, it did not provide any specific mission or purpose statement. For many years the department operated with the mission statement given in Minister Yurko’s speech in the Legislative Assembly: “balance environmental preservation against resource development”. However, in 1988 and in advance of proposed new environmental legislation, a new mission was stated: “to achieve the protection, improvement, and wise use of Alberta’s environment now and in the future”.81 This was enshrined in the Environmental Protection and Enhancement Act whose stated purpose was to support and promote the protection, enhancement and wise use of the environment.

The specific mission around air quality has taken various forms over the years. As above, it was generally some form of “minimize emissions and meet ambient objectives”. From 2002 to 2005, the business plan stated this as a result “Alberta’s clean air remains clean”. The brief statement was elaborated by the Air Policy Team as meaning:

The department ensures that emissions from the human activities taking place in the province will be minimized and that the province’s air quality continues to be better than the Ambient Air Quality Objectives now and in the future.

It was also stated that in the future, concentrations should be well below guideline values. In the 2008 air management strategy, the mission was stated as improving emissions performance and assuring good air quality. Good air quality was defined as concentrations of pollutants in the air below the Alberta Ambient Air Quality Objectives. The idea that ambient objectives are not “pollute up to” levels has been reflected in the Acid Deposition Management Framework, the PM and Ozone Management Framework, and in later frameworks and systems.

Compliance Assurance

Under the Clean Air Act, source performance was assessed using a variety of information inputs. The primary means was the review of monthly and annual reports from licensed facilities. The reports contained the results of industry self-monitoring, both stack and ambient as well as summaries of operational operations and other data as required by their License to Operate. The Pollution Control

81 Alberta Environment. 1988. Department of Environment annual report 1987/88.

staff could also use the findings of government stack and ambient surveys, and the number and type of complaints received from Albertans. Complaints were received on a toll-free number and investigated by staff to identify responsible parties and potential resolutions. When problems with a licensed facility were identified, Pollution Control engineers would work with the facilities to bring them into compliance with the relevant regulations, standards and license conditions. These abatement activities generally resulted in performance improvements. In some situations, an Emission Control Order would be issued with specific dates for the completion of different steps towards compliance. The Air Quality Control Branch was very active in compliance, for example, in the fiscal year 1978/79 the Branch received 407 complaints, accepted 2612 monthly reports, reviewed 222 annual reports, conducted 57 stack surveys and issued 32 emission control orders.82

Complaint investigation often involved tracing odours back to a source, which can be a difficult task given wind direction changes and intermittent sources. Albert Poulette, as the air quality control branch member of the Pollution Emergency Response Team (PERT) formed in 1980, investigated many such complaints in the Edmonton area.83 In winter, ground thawing for the installation of services at construction sites was a common source of odour complaints. To soften the ground for excavation, a mixture of soft coal and straw was burned for several days, giving off smoke and unpleasant smells. Eventually better technology replaced this practice and removed this nuisance.

In 1987 an uncontrolled release from a fertilizer plant in Calgary caused a number of people to become sick and visit the emergency room of the hospital. Unable to lay charges against the responsible party for a variety of reasons, Minister Ken Kowalski ordered a review of environmental law enforcement in the province. The review panel found that the general approach to enforcement was sound, but that administrative practices were in need of significant improvement, particularly the lack of clear direction for enforcement response, the large degree of discretion within the system, and the lack of an opportunity for public involvement.84 A formal enforcement policy should include detailed criteria for enforcement response and clear direction to enforcement officers. Initially, enforcement policy was developed as actions and enforcement reports were published quarterly.

The passage of the Environmental Protection and Enhancement Act in 1992 enlarged the task of this group. After several drafts, in 2000 a set of compliance assurance principles was published.85 It described how Alberta Environment used education, prevention and enforcement tools to ensure compliance with legislation. Eleven core principles were articulated:

1. Education, prevention and enforcement will be used to achieve compliance. 2. Legislative requirements will be clear, enforceable and widely known. 3. All staff undertaking compliance assurance activities will have adequate training and authority. Staff will carry out their duties in a competent, safe and professional manner. 4. Compliance assurance activities will be delivered in a lawful, fair, consistent and timely manner. 5. Every suspected violation that comes to the department’s attention will be assessed and responded to in an appropriate and timely manner. 6. Departmental responses to non-compliance will consider all applicable legislation and will use the most appropriate legislation and compliance assurance response.

82 Alberta Environment (1979) Annual Report; March 31, 1979 83 Spearman, Jack (1982) Detecting urban air pollution: one sniff is enough for some pollutants; others are more subtle. Environment Views, May/June 1982. 84 The Review Panel on Environmental Law Enforcement (1988) An Action Plan for Environmental Law Enforcement in Alberta. 85 Alberta Environment (2000) Compliance Assurance Principles. June 2000. 30 pp

7. Enforcement will be firm and fair. 8. Enforcement will use remediation, deterrence and/or punishment to ensure compliance with legislation. Enforcement responses will be based on a "polluter pays"/"resource restitution" philosophy. 9. Follow-up to enforcement responses will be taken to bring the situation into compliance and, where appropriate, to recover costs associated with bringing the situation into compliance. 10. Alberta Environment will measure and report on the effectiveness of its compliance assurance programs and activities. 11. Alberta Environment will foster partnerships with other government agencies and the public to promote compliance.

In 2004, the Compliance Inspection Program86 noted that Department inspectors can review and inspect all aspects of a facility’s approval or registration, in one visit to the facility. Inspections generally included: meeting with facility personnel to explain purpose of inspection and discuss inspection plan; conducting the inspection; taking any required air, effluent, soil, waste or groundwater samples; meeting with facility representative(s) to discuss inspection results, areas of noncompliance and follow- up requirements. Soon after each inspection, Alberta Environment sent the facility a report on the results, and in cases involving significant non-compliance, a request for a written explanation of how the situation would be corrected. Follow-up inspections ensured the appropriate actions had been taken. Failure to take the requested actions could result in enforcement action. The majority of inspections were unannounced. The frequency of inspections depended on a variety of factors, including: potential to cause an adverse effect, compliance history, environmental performance, and time elapsed since the last inspection. Good performance was rewarded with less frequent inspections.

The description of the compliance assurance program was updated87 in 2005 and summarized in a later fact sheet.88 Education promotes compliance by raising awareness of environmental protection and management, regulatory requirements, how to comply with those requirements, and the consequences of non-compliance. Education also encourages continuous improvement and environmental stewardship. Prevention is intended to support compliance by building capacity and the willingness within the regulated community to comply with the regulatory requirements, and to identify and address potential problems before they cause environmental damage. Enforcement is to ensure that there are consequences for non-compliance. Parties that are in non-compliance are required to remedy problems, correct the non-compliance and to mitigate any damages.

A variety of enforcement tools can be used to ensure compliance: • Written Warnings: for minor contraventions or when there is the potential for an adverse environmental effect. • Administrative Penalties: monetary fines designed to deal with minor administrative offenses, such as failure to file reports required under an approval or code of practice. • Orders: issued when immediate action is required to prevent or stop an adverse environmental effect. An Environmental Protection Order is issued to prevent or stop contraventions to the Environmental Protection and Enhancement Act and ensure action is taken to fix environmental problems. An Enforcement Order is issued to compel a regulated party to remedy a contravention and, where appropriate, require actions to prevent future contraventions

86 Compliance Assurance Program (2004) Facts at your fingertips. Alberta Environment. August 2004 87 Alberta Environment (2005) Compliance Assurance Principles and Program. March 20, 2005. 54 pp. 88 Alberta Environment Compliance Assurance Program (2009) Facts at your Fingertips. Government of Alberta. October 2009

• Prosecutions: Penalties depend on the severity of the contraventions and may include fines or jail time for serious offenses. • Creative Sentences: used to make prosecution penalties more meaningful and result in clear benefits for the environment. Coupled with a standard fine, creative sentences are imposed in situations where a monetary penalty may be inappropriate because of limited financial resources. • Appeals: companies or individuals can appeal an Order or an Administrative Penalty to the Environmental Appeals Board. All prosecutions may also be appealed in court.

Any spill, release or emergency that poses a possible threat to the environment must be reported immediately to Alberta Environment. Immediate reporting allows Alberta Environment, industry, and local response teams to respond quickly and prevent further damage to the environment through timely containment and effective clean up. Failure to report will result in stringent enforcement action. Albertans were also encouraged to report information about a spill, release or other environmental emergency to a toll-free number, 24-hours a day, seven days a week.

In addition to routine unannounced inspections, Alberta Environment conducted annual education and inspection sweeps, targeted to a geographic area or specific industry. Specific, detailed information about regulations and requirement were sent to the relevant businesses. Then unannounced inspections were done to ensure businesses were following the requirements.

The Law Enforcement Review Panel had also recommended that an annual report be published outlining all environmental enforcement actions that have been initiated, the status of these action, the success of the actions, and a summary of the record of compliance with any applicable order. After the Environmental Protection and Enhancement Act came into force, the first annual enforcement report 89 was published in 1996. Subsequent annual reports were published variously as Enforcement Activities, Compliance Assessment and Enforcement Activities, Compliance Assessment and Enforcement Initiatives, and more recently as Compliance Assurance Annual Reports.

Recognition of Good Performance

Several jurisdictions have used performance recognition systems as a way to motivate good environmental performance. In 2005 Alberta Environment introduced a voluntary incentive program, EnviroVista, to recognize excellence in performance and promote environmental leadership and stewardship. Ten facilities were recognized in the first year. Developed by George Murphy and his staff, EnviroVista encourages industry to go beyond just compliance with the terms of its permit by providing a number of incentives. The facility name, company name and company logo are featured on the government website. Company names appear in printed material published by the department and in presentations by the senior department staff. Participants are issued a certificate and have the right to use the EnviroVista logo on their printed and electronic materials, signs and on other products. Participants will have a say in the design of any future refinements to the Program. Participants who commit to a Stewardship Agreement receive a simplified permit that provides facilities with operational, regulatory and administrative flexibility.

89 Pollution Control Division (1996) Enforcement of the Environmental Protection and Enhancement Act, September 1, 1993- December 31, 1995. Environmental Regulatory Service, Alberta Environmental Protection, April 1996, 45 pp

The program evolved to have two levels. The EnviroVista Leader level recognized facilities that have a minimum history of five years of exemplary emissions performance, a comprehensive, publicly- accessible, audited environmental management system and five years without any enforcement activity. The EnviroVista Champion level additionally provides access to a streamlined permit when participants commit to enhanced environmental performance through a Stewardship Agreement. In 2011 EnviroVista recognized twenty-nine industrial, manufacturing and municipal facilities for going above and beyond their basic environmental requirements.90

Geographical Solutions

Another way to manage air quality problems is to maintain a separation between sources and the affected public. In the 1970s, the Alberta Government provided financial aid to relocate industries that were creating issues for residents. The Money’s Mushrooms operation near Airdrie was the source of many odour complaints from the residents. No pollution control equipment could rectify the problem, so the operation was relocated to a rural area far from the town. In another case, a sour gas pipeline near the village of Crossfield created an unacceptable risk to residents and was subsequently relocated.

Alberta also used separation distances to manage the risks to urban developments in the vicinity of sour gas facilities. After the 1973 New Norway sour gas well blowout, the petroleum industry expressed concern about the encroachment of population centres on existing sour gas operations. In 1974 an industry-government committee examined the geographical extent of sour gas facilities, the history of previous releases, the toxicology of hydrogen sulphide, the dispersion of sour gas once released and the existing regulatory situation.91 They recommended that that regulations be enacted to prohibit new subdivision development within a calculated 100 ppm isopleth around a sour gas operation. Considerable effort ensued and in 1979 Alberta adopted a set of minimum separation requirements92 shown in Table 4. The details have continued to evolve under the leadership of the Energy Resources Conservation Board (in its various forms). After the Lodgepole Blowout, emergency planning for a sour gas release became a priority and the Government of Alberta developed and tested a series of plans.93 The Energy Resources Conservation Board also required all sour gas operators to prepare emergency response plans for the areas within an emergency planning zone calculated from potential release size.94

90 Alberta Environment (2011) Envirovista Backgrounder and Questions and Answers. Alberta Environment, Edmonton 91 Alberta Industry-Government Sour Gas Environmental Committee (1974) Guidelines for Urban Development in Relation to the Sour Gas Industry. October 1974 92 Angle, RP (1982) Sour gas facilities: a case study of a public risk in Alberta. In: Living with Risk: Environmental Risk Management in Canada. Institute for Environmental Studies, University of Toronto, IES monograph #3 ,September 1982 93 For example, (a) Alberta Disaster Services (1985) Government of Alberta peacetime emergency operations plan for a sour gas release, May 1985, Second Edition; (b) Alberta Public Safety Services (1988) Government of Alberta emergency response plan for a sour gas release, January 1988, edition 4. 94 For example, Energy and Utilities Board (2003) Directive 071 Emergency Preparedness and Response Requirements For the Upstream Petroleum Industry (formerly Guide 71) June 2003.47 pp

Table 4. Minimum separation distances between sour gas facilities and residences

Potential H2S Potential H2S Minimum Distance to Various Developments Release Rate from Release Volume (greater distances may be required at the discretion of the Sour Gas Well (m3/s) from Sour Gas responsible authority) Pipeline (m3) <0.3 <300 Easement for right-of-way (usually about 15 m) 0.3-2.0 300-2000 0.1 km to individual permanent dwellings up to 8 per quarter section 0.5 km to urban centre or public facility 2.0-6.0 2000-6000 0.1 km to individual permanent dwelling up to 8 per quarter section 0.5 km to unrestricted country development 1.5 km to an urban centre or public facility >6.0 >6000 Case by case basis, but no less than the previous level

A variety of setback distances have been recommended for approval of subdivisions in an effort to prevent future environmental problems.95 The Natural Resources Conservation Board has also established Minimum Distance Separation (MDS) for the management of odours from confined feeding operations.96

95 Standards and Guidelines Branch (1996) Environmental Reference Manual for the Review of Subdivisions in Alberta. Alberta Environment, November 1996, 92 pp 96 Standards and Administration Regulation (2001) Alberta Regulation 267/2001, Agricultural Operation Practices Act.

Stakeholder Relations

A variety of mechanisms have been used to consult with stakeholders. In the early years of the air quality management program the discussions were between department experts and industry representatives over technical matters related to emission standards, for example, the sulphur recovery guidelines of 1988. As environmental issues grew in public importance, discussions expanded to include other interested parties and other aspects of the air quality management program. The process used in the 2001 sulphur recovery guidelines included the public, academics, and environmental groups. Martha Kostuch, a prominent Alberta environmentalist at the time, often served as the point person for Alberta environmental groups.

In 1972 the Alberta Petroleum Industry-Government Environment Committee (APIGEC) was formed to provide a mechanism for high-level communication between the provincial government and the oil and gas industry. It was chaired by the Deputy Minister of Environment and included representatives of the department, the Energy Resources Conservation Board, and the petroleum industry. Its early objectives included: minimizing sulphur dioxide emissions, gaining public acceptance of the industry, meeting ambient air quality standards, reviewing design flexibility and technical feasibility, and reviewing the economics and total resource budget.97

In 1985 the Fort McKay First Nation expressed concerns about environmental effects related to the operation of oil sands plants. In response the ERCB and Alberta Environment established the Fort McKay interface Committee; consisting of government agencies, the native community and the two oil sands operators. To address air quality issues, the committee established an Air Quality Task Force in 1986. The Task Force reported on its work describing the issues in the region and establishing priorities. Perhaps most important was a recommendation for on-going dialogue and a consensus based approach to air quality concerns. As a result, in 1990 the Regional Air Quality Coordinating Committee (RAQCC) was formed. This committee’s task was to continue to identify and prioritize regional air quality concerns and to coordinate a program to manage air quality in the region. RAQCC set up subcommittees to look into ambient air quality monitoring, environmental effects monitoring, zone management and acidification. In 1992 the Acidification Working Report put forward recommendations on acidic deposition research for the area. The 1994 Decision of the ERCB on the Syncrude Mildred Lake Development directed Syncrude to improve environmental monitoring using a multi-stakeholder process such as the Regional Air Quality Coordinating Committee or a similar CASA regional committee. Ultimately the multi-stakeholder Wood Buffalo Environmental Association was formed in 1997 (as a CASA zone) to monitor and manage air quality in the region.

Throughout the 1980s there were growing concerns about acid deposition, climate change, smog, and toxic air pollutants, especially in relation to emissions from the oil and gas industry. These concerns were being expressed locally at ERCB Hearings and globally in international commitments to stabilize or reduce emissions. The old management system was viewed as static and unable to respond to the new environmental challenges and to the broader societal issues of regional differences, cost effectiveness, flexibility, scientific and economic uncertainty, international initiatives and public involvement. It became clear to all that changes were needed. Recognizing this situation, the Alberta government on March 15, 1990 announced a broadly based, public consultation process on energy and air quality, the

97 Gainer, JG (1973) The industry-government sour gas environmental committee. P 189 in Proceedings of a Workshop on Sulphur Gas Research in Alberta, Hocking, Drake and David Retier (eds). Information Report NOR-X-72, Northern Forest Research Centre, Edmonton, Alberta, December 1973.

outcome of which was the establishment of a new, multi-stakeholder organization known as the Clean Air Strategic Alliance (CASA) to operate a more comprehensive system for managing air quality.98 The Alliance had clearly defined responsibility for strategic air quality planning.

The Alliance represented a move away from confrontational and adversarial positioning to a collaborative, co-operative, consensus-building and problem-solving approach. It achieved a more efficient and effective allocation of industry and government resources. The role of the government was transformed from that of arbitrator between competing lobbies to that of a facilitator and partner. The new comprehensive air management system screened and scoped issues, set priorities and delegated tasks, designed and approved actions plans, and then evaluated implementation of the plans.99 This was done within the context of the air quality management framework shown in Figure 5.

Figure 5. Air quality management framework of the Clean Air Strategic Alliance

CASA’s vision for Alberta is “the air will be odourless, tasteless, look clear and have no measurable short or long-term adverse effects on people, animals or the environment”. The three goals for air quality management are: (1) protect the environment by preventing short- and long-term adverse effects on people, animals and the ecosystem; (2) optimize economic efficiency; and (3) promote pollution prevention and continuous improvement. CASA has been active in gathering information and developing management frameworks.

Table 5 shows some of the major accomplishments.

98 (a) Advisory Group (1991) Clean Air Strategy for Alberta Report to Ministers. Clean Air Strategic Alliance, Edmonton, 90 pp;(b) Wharton, DC, RH Mitchell, J Shires and HS Sandhu (1992) Consultation and consensus-building to manage energy-related emissions: The Clean Air Strategy for Alberta. Environmental Issues and Waste Management I Energy and Minerals Production, Sinhal et al (eds) AA Balkema, Rotterdam: 137-148; (c) Sandhu, HS, RP Angle, RH Mitchell, I Burn and S Washington (1992) The Clean Air Strategy for Alberta, Canada.9th World Clean Air Congress & Exhibition, Montreal, Aug 30-Sept 4, 1992; 11 pp 99 (a) Sandhu, HS, RP Angle, and M Kelly (1995) Implementation of the Clean Air Strategy for Alberta, Canada. Proceedings of the 10th World Clean Air Congress held at ESPP, Finland May 28-June 2, 1995: 538-541. (b) Angle, RP and HS Sandhu (2001) Proactive Management of Air Quality. Environmental Management 27: 225-233

Table 5. CASA accomplishments

Category Accomplishment Year Information Strategic Plan for Air Quality Monitoring in Alberta; Ambient Air 1995, 2009 Monitoring Strategy for Alberta CASA Data Warehouse 1998 Framework for human health monitoring system 1998 Symposia on air issues: climate change, acidifying emissions, air 1995, 1996, quality and health, nitrogen 2002 Remote sensing survey of poorly tuned automobiles 1998 ROVER Vehicle Emission Surveys 1998, 2006 Herd Environmental Record System 2003 “Breathe Easy” Vehicle Retirement 2003 Diesel Particulate Filter Demonstration 2003

Management Zone Air Quality Management Guidelines; Airshed Zones Guidelines 1995, 2004 Frameworks Sulphur Dioxide Management in Alberta 1997 Management of Routine Solution Gas Flaring in Alberta 1998 Acid Deposition Management Framework 1999 Particulate Matter and Ozone Management Framework 2003 Emissions Management Framework for the Alberta Electricity Sector 2003 Recommendations for a renewed Clean Air Strategy for Alberta 2009 Framework for pollution prevention and continuous improvement 2002 Priorities for ambient air quality objective setting 2000, 2004, 2009 Managing Air Emissions from Confined Feeding Operations in Alberta 2009

The department enabled the formation of “airsheds” or regional air quality management systems in 2001 by allowing amendments to approvals so that compliance ambient monitoring could be reduced in favour of enhanced zonal monitoring provided certain criteria were met.100

Concurrent with the Clean Air Strategy development, the industry participants in APIGEC developed a discussion paper on air quality management in Alberta.101 It proposed a system with three parts: (1) ambient monitoring to address concerned and affected publics in place of point-source oriented monitoring, (2) creation of that an Alberta Air Resources Institute to conduct air quality research, develop more efficient methods to monitor air pollutants, manage a database, and provide technical advice; and (3) public consultation to increase information exchange, and provide accountability for participants. The Clean Air Strategy that emerged in 1991 and was implemented in 1994 ultimately addressed most of the elements except for the creation of an independent institute. (However, in 2013

100 Environmental Sciences Division (2001) Program Procedure, Oct 30, 2001, Alberta Environment; (b) Sandhu, HS (2000) Criteria for Reducing Compliance-Based Air Quality Monitoring Requirements for Zonal Air Quality Management in Alberta. Science and Technology Branch, Alberta Environment, January 2000, 18 pp 101 Authors unspecified (1990) A Discussion Paper Regarding Air Quality Management in Alberta. June 1990, 15 pp

air monitoring became the responsibility of an independent agency, The Alberta Environmental Monitoring, Evaluation and Reporting Agency.102)

Organization for Air Quality Management

In order to perform work and meet its goals, all organizations including government, must arrange people and jobs to define roles, responsibilities and relationships. Traditionally three main structural types have been identified: (1) functional, grouping by similar occupational specialties; (2) divisional, grouping by similarity of purpose such as product, services, customer, clients, or geographic region; and (3) matrix, combining functional and divisional chains of command in a grid. More recently team, network and modular structures have been used.103 Each has advantages and disadvantages, so many organizations use different types at different levels. In government, it is commonplace for a new Executive team to rearrange the groups in support of a new initiative. The main occupations involved in air quality management are engineers, technologists and scientists.

The first mention of air pollution in the Department of Public Health appears to be in the 1958 annual report under Sanitary Engineering following a section on stream pollution: Investigations are made of complaints received of adverse air pollution in the province. Increased industrial operations in Alberta have resulted in additional activities in this field in the last two years.104 That same year the Department of Health hired its first air pollution engineer and by 1960, an Air Section existed within the Division of Sanitary Engineering. The 1966 annual report noted:

The division conducts surveys to assess pollution of the atmosphere in urban and industrial areas. This is done to evaluated complaints received, to measure air quality before certain industries are established, and to assess the present levels of air pollution in areas of concentrated urban and industrial development. A fully equipped chemical laboratory is used in conjunction with field equipment, which includes a mobile trailer unit for this work. The increasing industrialization of the province has made it necessary to expand this service very materially in the past couple of years.

In 1967 this Division became Environmental Health Services. By 1969 the Air Pollution Control Section of the Environmental Health Services Division was staffed with four engineers, two environmental engineering technicians, four industrial laboratory technical, one laboratory assistant and at least two engineering summer students. Laboratory support was provided by the Environmental Health Laboratory.105

In 1971 the newly formed Department of the Environment consisted of three services: Environmental Coordination, Environmental Planning & Research, and Environmental Protection Services. Air quality management was housed in the Protections Services, Pollution Control Division, and Standards and

102 Legislative Assembly of Alberta (2014) Protecting Alberta’s Environment. Statutes of Alberta 2013, Chapter P-26.8 103 Kinicki, Angelo and Brian Williams (2010) Management: A Practical Introduction, 5th edition. McGraw Hill, 608 pp. 104 Alberta’s Health Services Program. Health Services provided by the Province of Alberta, Department of Public Health Annual Report 1958. 105 Alberta Department of Health, Division of Environmental Health Services (1969) Air Pollution Control at Gas Processing and Sulfur Recovery Plants. February 1969

Approvals Division. Air quality research was included in the mandate of the Research Secretariat. Permits and licences were the purview of the Air Quality Branch in the Standards and Approvals Division while monitoring and enforcement were the responsibility of the Air Quality Control Branch in the Pollution Control Division.106 Minister Yurko stated:107

I think we might look at Standards and Approvals as the judiciary arm of the department and the Division of Pollution Control as the police force.

Serge Dobko became the Head of the Air Quality Branch in the Standards and Approvals Division and Jerry Lack (Figure 6) became the Head of the Air Quality Control Branch in Pollution Control Division.

Jerry Lack, P.Eng., joined the Pollution Control Section, Department of Public Health in 1966. Under his leadership in the Department of Environment Alberta developed its first air quality index, completed major inventories of emission sources in Edmonton and Calgary, developed an automated urban ambient data recording and transmission system, expanded ambient air monitoring in major cities, and commissioned Alberta’s first self-contained fully mobile air monitoring unit. Partnerships with others produced numerous vehicle exhaust testing clinics, a major Pincher Creek Health Study, and coordinated industrial ambient monitoring by the Strathcona Industrial Association. In 1985 Jerry became the Director of Standards and Approvals Division and in 1993, the Director of the Chemicals Assessment and Management Division, a position he held until his retirement in 1998.

Figure 6. Jerry Lack, first Head of the Air Quality Control Branch (1990 photo)

In April 1980, a new Research Management Division was formed by consolidating the Research Secretariat and the Alberta Oil Sands Environmental Research Program (AOSERP).108 Other structures remained stable until 1988.

In 1988 the Environmental Law Enforcement Review Panel made a number of far-reaching recommendations about standard-setting, ambient air quality standards, permitting procedures, permit requirements, monitoring, administrative responses to non-compliance, prosecution, offenses and penalties, and enforcement structures. A summary of the recommendations can be found in Appendix E. As a result, Pollution Control Division was restructured to focus on investigations (following law enforcement procedures) and enforcement (using legal means and the courts). Jillian Flett, who was on the review panel, was hired as Compliance Branch Manager and Dene Berry as Investigations Branch

106 Standards and Approvals Division (1994) Air quality branch – program review and summary. Alberta Environmental Protection, Environmental Regulatory Services, March 9, 1994 107 Yurko, W (1972) Throne speech debate. Alberta Hansard, March 7, 1972 108 Alberta Environment, Research Management Division (1982) Research Management Division annual report for the fiscal year 1981/1982; RMD report 82/11.

Manager. A prosecutor, Susan McRory, was assigned to environmental cases and Administrative Penalties were initiated because prosecutions were cumbersome, expensive and took a long time.109

Most of the engineers and all of the scientists in the Pollution Control Division were moved to the new Air Quality Branch in the Standards and Approvals Division, now headed by Bill Macdonald with Jerry Lack as Director. Most of the monitoring technologists were moved to the new Environmental Quality Monitoring Branch in the Environmental Assessment Division. Also created was a new Standards Development Branch with staff moved from the former Research Management Division and a few others. Pollution Control Division, with Al Schulz as Director, took on the recommended enforcement role. Ambient air quality objectives were removed from the maximum levels regulation and Research Management Division was eliminated.

In 1992 the idea of integrated resource management led to the amalgamation of responsibilities for environment, forests, fish and wildlife, and parks and protected areas. Three departments were merged into a new large department, Alberta Environmental Protection. One benefit was that regulating groups in the individual departments were more cognizant of cross-departmental impacts, where addressing an issue in one department could actually have a negative impact in another. The move was intended to keep Alberta on the leading edge of environmental protection.110 Integration was a theme across Canada and led to the Canadian Environmental Protection Act in 1985 as well as Alberta’s Environmental Protection and Enhancement Act of 1992.

Following the merger there was a strong motivation for the environmental protection groups to align with the strongly regionalized structures of the natural resources management components of the new department. The intent was to provide better service to clients and stakeholders and to have staff available locally and closer to regulated facilities. Environmental compliance and permitting were no longer handled from the central office, but rather through six regional offices and several district offices. A small core of air experts remained in Edmonton to provide advice, conduct training, and develop policies, but the majority of the approvals engineers were dispersed to the regions where they became generalists handling all aspects of environmental protection. During the late 1990’s the government focus was on debt reduction, which resulted in budget and resource limitations. In 1999 following a provincial election, the previously combined responsibilities were once again separated and Alberta Environment reverted back to its previous responsibilities. Soon after, for staff efficiency and cost reduction, the number of regions was reduced to three.

Each year, the divisions and services produced business plans in different forms. For several years, a one page “placemat” was used after its introduction by Deputy Minister Roger Palmer (Figure 7).

109 Schulz, Al (2015) personal communication 110 Alberta Environment Protection (1993) Annual report 1992/1993.

Figure 7. Placemat form of the business plan

In 1994, a minor restructuring saw the dissolution of the Environmental Quality Monitoring Branch and the transfer of air monitoring staff to a new Air Issues and Monitoring Branch in the Chemicals Assessment and Management Division. Randy Angle became the Head of the new Branch; Jerry Lack was the Division Director. Two scientific officers, Lawrence Cheng and Randall Barrett, were hired to handle the various atmospheric issues that were in play: acid deposition, ozone-depleting substances, climate change, and air toxics. In 1998 a major reorganization took place. The Standards and Approvals Division was converted to an Environmental Sciences Division with a new Director, David Spink. Air Quality was nowhere identified in a unit title; emissions policy was assigned to the Industrial Program Development Branch, while ambient policy and issues management were the responsibility of the Science and Technology Branch headed by Randy Angle. Air monitoring was moved back to the Environmental Assessment Division.

The breakup of Alberta Environmental Protection in June 2001 saw the Environmental Sciences Division reorganized into a Science and Standards Division under Director Bill Macdonald, with an Air Branch headed by Randy Angle. Air policy was briefly combined with water policy in the Air and Water Branch. The year 2002 saw a significant change in management nomenclature, which was widely perceived as a downgrading of authority. What was previously known as a “Service” was now called a “Division”, headed by an Assistant Deputy Minister. What was previously called a “Division” was now a “Branch”, headed by a Director, and what was previously a “Branch” was now called a “Section”, headed by a Senior Manager.

A new Strategic Directions Division was introduced to handle special projects and environmental relations. Bill Macdonald later became part of this group, swapping Directorships with Keith Leggat. Bill Calder headed Environmental Relations and became progressively more involved with intergovernmental air quality matters, bilaterally with Saskatchewan and multilaterally through the Canadian Council of Ministers of Environment and the federal government. Technical support was provided by the air quality units with scientists and engineers. Bev Yee, the Assistant Deputy Minister, together with the federal government and Ontario, co-chaired extensive negotiations toward a national Air Quality Management System.111 (The system was adopted by Canadian Environment Ministers, except Quebec, in October 2012.).

In 2004 reflecting the department’s interest in “systems thinking”, Director Keith Leggat restructured the Science and Standards Branch into the Environmental Policy Branch. Air policy professionals were spread across three new Sections: Systems Development, Policy Integration, and Science & Innovation. With the loss of media identifiers – air, water, groundwater, and soil -- those outside the department found it difficult to find the appropriate individuals to contact about policy matters. Consequently, in 2007 the Assistant Deputy Minister John Knapp replaced the Environmental Policy Branch with a number of Business Units responsible for the policy in their respective areas in the Environmental Assurance Division. One of these was an Air Policy Business Unit headed by Randy Angle. After the elections of 2008, John Knapp moved to become a Deputy Minister in a different department. The new Assistant Deputy Minister, Ernie Hui, was uncomfortable with the large number of direct reports, so the business units were collapsed. Air became part of the Climate Change, Air and Land Policy Branch of the now combined Environmental Assurance and Oil Sands Management Divisions.

A listing of staff involved in air quality management is included in Appendix B and photographs of some of the individuals appear in Appendix C. The various organizational structures that have housed the components of the air quality management system are named in Appendix F. Appendix G shows the different logos used by the department.

Resourcing of air quality management has sometimes been a challenge. The core from the Department of Health was expanded substantially when the Department of the Environment was formed. Throughout the 1970s and the early 1980s, resources generally kept pace with expectations. In the late 1980s and into the 1990s, resources shrank in the face of increasing demands. A review of manpower allocations in 1993 concluded that Alberta Environment operated its air program with about half the staff of an equivalent air management agency in the United States.112 While a variety of new initiatives had been announced (for example, implementation of the federal-provincial NOx/VOC Management Plan) additional resources had not been provided. The catch phrase of the times was “do more with less”. With resources spread thin, commitments could not always be kept, the best information was not always available, and new issues could not always be anticipated. The 2000s saw a shift from technical specialists to policy generalists and fragmentation by numerous reorganizations.

For the first 17 years sir quality management was housed within a single organization unit in the Department of Health and within two units (“judicial” and “policing”) of the Department of Environment. Since 1988 the department has been restructured numerous times, each dividing air

111 Steering Committee (2010) Comprehensive Air Management System: A Proposed Framework to Improve Air Quality Management. Canadian Council of Ministers of the Environment, Winnipeg 112 Angle, RP (1993) Air Quality Functional Review (December 15, 1993), Environmental Regulatory Services, Alberta Environmental Protection

quality responsibilities in different ways. To many staff members the situation was well captured by the quotation “we tend to meet any new situation by reorganizing; and what a wonderful method it can be for creating the illusion of progress while producing confusion, inefficiency, and demoralization.“113 Some speculated that such frequent restructuring was deliberate and intended to keep the Environment Department off-balance and unable to impose any greater environmental restrictions on the oil and gas industry. Others accepted that the changes were well-intentioned efforts to transform departmental mindsets and improve efficiency. Air quality personnel were dedicated to their work despite the overall low public service morale that emerged as an issue for Premier Jim Prentice in 2014. Barnetson114 attributed low public service morale to: workload, instability, interference, inattention and attacks. Vivone115 blamed the Klein era mistrust of public servants.

Intergovernmental Cooperation

Alberta Environment has participated in federal-provincial undertakings and interprovincial agreements. In 1969 the federal Department of National Health and Welfare established an Air Pollution Control Division and an ad hoc Federal-Provincial Committee on Air Pollution. The National Air Pollution Surveillance (NAPS) program was also established in 1969 to monitor and assess the quality of ambient (outdoor) air in the populated regions of Canada. A subcommittee of senior officials was struck in 1970 to develop national ambient air quality standards. Serge Dobko represented Alberta and for a time served as chair. A formal Federal-Provincial Committee on Air Pollution was established when the federal Department of Environment was created in 1971. Committee members in 1974 are shown in Figure 8.

Subsequent to the federal Clean Air Act, Alberta agreed to establish and enforce environmental requirements at least as stringent as federal requirements. When the federal government consolidated its legislation under the Canadian Environmental Protection Act in 1988, there was provision for similar “equivalency agreements”. Initially Alberta had two such agreements, but as the complexity of renewing them increased, they lapsed. A National Advisory Committee replaced the previous media specific committees.

113 Ogburn, Charlton Jr (1959) Merrill’s Marauders: The Truth about an Incredible Adventure, Harper & Brothers Publishers, New York 114 Barnetson, Bob (2014) http://albertalabour.blogspot.ca/2014/11/public-service-morale-is-low-you-dont.html 115 Vivone, Rich (2014) Opinion: No mystery behind civil servant discontent. Edmonton Journal December 24, 2014

Figure 8. Members of the Federal-Provincial Committee on Air Pollution 1974

The Canadian Council of Resource Ministers was expanded in 1971 to become the Canadian Council of Resource and Environment Ministers with a full time secretariat. However, as environment issues rose to the forefront, in 1988 the organization refocused as the Canadian Council of Ministers of the Environment (CCME), to serve as “a principal forum for members to develop national strategies, norms, and guidelines that each environment ministry across the country can use”. Participation in CCME allowed provinces and territories to leverage limited resources, exchange ideas, build neighbour relationships, and showcase environmental successes. Alberta was a strong supporter. To control ozone formation, in 1990 a Management Plan for Nitrogen Oxides and Volatile Organic Compounds was published. This “smog” plan contained a prevention program led by the federal government, a remedial program for non-attainment areas led by the respective provincial governments, and a series of studies and investigations to support future planning. In 2000 CCME published the Canada-Wide Standards for

Particulate Matter and Ozone116, Alberta’s George Murphy and Long Fu having made major contributions.

Recognition that energy production and use is largely responsible for Canadian air emissions led to the first meeting the Canadian Council of Ministers of the Environment and the Council of Energy Ministers and in November 1993, the Joint Ministers approved a Comprehensive Air Quality Management Framework for Canada. Jerry Lack and Harby Sandhu, working with the Assistant Deputy Minsters (ADMs) and Deputy Minister (DM) and having successfully linked energy and environment in Alberta through the Clean Air Strategy in 1990-91, were instrumental in creating this framework. A National Air Issues Coordinating Mechanism (NAICM) consisted of a steering committee and a coordinating committee. Reporting to the Joint Ministers, the National Air Issues Steering Committee (NAISC) comprised federal, provincial and territorial deputy ministers of environment and energy, reporting to the Joint Ministers. Reporting to NAISC, the National Air Issues Coordinating Committee (NAICC), consisting of senior officials from the environment and energy departments, had the primary responsibility for implementation of the mechanism under the Framework. The NAICC was supported by a Stakeholder Advisory Committee. NAICC worked on acid rain, hazardous air pollutants, ozone depleting substances, emissions and projections, and smog plan codes and guidelines. In 1998 The Canada-Wide Acid Rain Strategy for Post 2000 was completed and in 2001, the National Framework for Petroleum Refinery Emission Reductions. Department staff participated in most of these initiatives and co-chaired some of them with the federal government.

The development of oil sands in northeastern Alberta led to a variety of concerns about acid deposition. The prevailing winds carry emissions into Saskatchewan, a concern recognized early and the subject of several AOSERP studies. The potential impact of emissions from the oil sands on downwind provinces prompted the formation of the Western and Northern Canada Long-Range Transport of Atmospheric Pollutants (WNC-LRTAP) program in September of 1980. All participants in that program agreed that activities in their respective jurisdictions should not have negative effect on the environment in another jurisdiction.117 The Government of Alberta reaffirmed that commitment in its own Acid Deposition Framework.118 Since the WNC program had ended and acid deposition was still a concern, Saskatchewan sought an agreement with Alberta to ensure cooperation in managing acidic deposition. The Memorandum of Agreement119 signed in 2002 formalized the work that would occur jointly in subsequent years.

Acid deposition had long been a concern in eastern Canada. In 1985 the Eastern Canada Acid Rain Program put a cap on the sulphur dioxide (SO2) emissions at 2.3 million tonnes a year. The cap applied to the seven easternmost provinces (Manitoba eastward) and each province then adopted its own provincial cap. The United Nations Economic Commission for Europe (UN-ECE) First Sulphur Protocol of 1985 committed Canada to a national cap on SO2 emissions of 3.2 million tonnes. The Canada-United States Air Quality Agreement of 1991 enshrined the 2.3 million tonne cap for eastern Canada and reiterated the 3.2 million tonne cap on national SO2 emissions. The implication was that western

116 Angle, RP (2013) Federal-Provincial Relations in Air Quality Management. Chapter 15 in: Taylor E, McMillan A (eds) Air Quality Management: Canadian Perspectives on a Global Issue. Springer, Dordrecht, 303-315 117 Interim Acid Deposition Critical Loadings Task Group (1990) Interim Acid Deposition Critical Loadings for Western and Northern Canada. Prepared for the Technical Committee, Western and Northern Canada Long Range Transport of Atmospheric Pollutants. 31 pp. 118 Target Loading Subgroup (1999) Application of Critical, Target and Monitoring Loads for the Evaluation and Management of Acid Deposition, Clean Air Strategic Alliance and Alberta Environment, November 1999, 67 pp. 119 Saskatchewan-Alberta Memorandum of Understanding on Acidic Deposition Management, signed 6 May and 11 June, 2002.

Canada is subject to an SO2 emissions cap of 0.9 million tonnes a year. However, there was no push for western provinces to adopt provincial caps. Indeed, with the expected expansion of the oil sands, Alberta was nervous about this potential limitation. The ADM at the time often said “a cap if necessary, but not necessarily a cap.”

Summary of General Approach

In 1969 the Air Pollution Control Section of the Department of Health articulated a two-pronged approach to air quality management in Alberta: (1) control of pollutants at the source, and (2) dilution of the residual to levels harmless to receptors. By 1980 a number of operating principles had been added, including: use of best practicable technology for emission control, joint government-industry setting of emission standards, industry self-monitoring and reporting of emissions and resulting air quality with government checking data quality, and considering multiple sources in meeting ambient air quality objectives. These were restated many times in different forms, for example, in 2008 as: polluter pay, pollution prevention, continuous improvement and shared responsibility. A complete description of the industrial air quality management was provided in 1996 and of a broader system including regional air management in 2008.

In the early years only industrial stakeholders were consulted primarily on emissions standards. As public interest in environment matters grew, consultation processes evolved to include environmental groups, citizens at large, and sometimes academics and health groups. The Alberta Petroleum Industry Government Environmental Committee was formed in 1972. The Fort McKay Interface Committee was formed in 1985 to create a dialogue between First Nations, oil sands operators and the government. The Clean Air Strategy for Alberta brought a multi-stakeholder approach to problem solving and air quality planning. A vision of “clean air” was defined and numerous management frameworks were developed following a structured consensus-based methodology.

In the Department of Health, the central components of air quality management all resided in the Air Pollution Control Section. When the Department of Environment was formed, air quality management was split between two different units, one responsible for developing rules and issuing permits, and the other, for monitoring and abatement. In 1988 enforcement was strengthened and monitoring moved to a third area of the department in a major realignment. In 1994 scientific and monitoring functions were combined, but in 1998 a drive to “integration” created a structure where “air quality” could not be found in any unit names. Restructuring then became more frequent with air quality appearing, disappearing and then reappearing as the department explored different ways of doing its business. Fragmentation of resources remained a concern.

Alberta worked closely with the federal government and the other provinces in the federal-provincial committees set up under the federal Clean Air Act. The replacement Canadian Environmental Protection Act reduced the emphasis on air quality and changed the relationship with the provinces to “advisory only”. As part of the Canadian Council of Ministers of the Environment, Alberta participated in urban air quality and various standards initiatives. For a time, work on air issues was conducted under the Joint Ministers of Energy and Environment. Acid Rain concerns from oil sands emissions led to a western Canada LRTAP program and to an agreement with Saskatchewan. Alberta has generally been a strong supporter of intergovernmental initiatives and frequently has played a leading role.

Sources and Emissions

A source of air pollution is any activity that causes undesirable substances to enter the atmosphere. Such emissions can be from either mobile sources (such as automobiles) or stationary sources. Stationary sources are classified as either point sources (such as a smokestack of storage tank) or area sources (such as household furnaces). Source Performance Standards

Source performance standards seek to minimize emissions from a category of sources based on industrial process and equipment considerations. The standard may be quantitative or qualitative, specifying a numerical rate, such as mass per unit of production/time, a concentration of a substance in fuel or effluent, a type of equipment or procedure, or a prohibited practice. The term “standard” is often taken to denote a particular legal status, but in general a standard can be defined as something considered by an authority as a basis of comparison and judgement. The department tended to use the softer terminology of “guidelines” as a reflection of its “work with industry” approach.

When an approval is issued for an industrial operation, emission standards are translated into specific emission limits for the facility. Chow Seng Liu (Figure 90) was one of the long-serving approvals engineers who performed this function, negotiated limits with industry and participated in setting standards.

After emigrating from Singapore in 1976 Chow Seng Liu began work with Alberta Environment, first in Water Quality and then in Air Quality until retirement in 2003. During 27 years of practice as a Professional Engineer (P.Eng.) he was involved in standards setting, licensing, monitoring, enforcement, program planning and policy for almost every industrial sector in Alberta. Representing the Department, Chow Seng has appeared in public hearings before the Energy Resources Conservation Board and participated in numerous municipal, provincial, federal and non-governmental committees. One of the highlights of his work was the Sulphur Recovery Guidelines still in use today.

Figure 9. Chow Seng Liu at work in his office (1998 photo)

In the absence of an Alberta standard, the approval writer could look to the Canadian Council of Ministers of the Environment, the federal government, the United States Environmental Protection Agency, or some other jurisdiction as an appropriate basis for establishing emission limits. If nothing suitable could be found, the emission minimization principle was applied to evaluate the proposed equipment against what would be considered “best practical technology" (for both technological and economic feasibility). Over the years, the Department used different terms to characterize this balancing of costs and controls: Best Practicable Technology (BPT), Best Available Demonstrated Technology (BADT) and Best Available Technology Economically Achievable (BATEA). The general steps in developing a sector-specific technology limit were outlined in a later policy document.120

120 Environmental Sciences Division (2000) Industrial Release Limits Policy. Alberta Environment, November 2000,12 pp

Other than for the sulphur recovery guidelines, there was no well-defined Alberta process for developing or updating source performance standards. The permit/licence/approvals system allowed flexibility to adopt or create a new standard as part of establishing an emission limit for any unique type of industrial facility. Formal processes were set in motion only when a sector-wide need was identified. In 2002 a draft work plan121 for industrial source standards development was produced and an initial attempt was made to describe a source standard-setting process that would roughly parallel that being used for ambient air quality objectives. The creation of the Clean Air Strategic Alliance (CASA) in 1994 ultimately led to another avenue for source standards. While CASA was a strategy and policy- recommendation body,122 two broad management frameworks also included performance standards: fossil-fuel fired electricity generation and petroleum industry flaring, implemented respectively by Alberta Environment and the ERCB.123 Regular updates were included in these frameworks.

In 1965 the Division of Sanitary Engineering published guidance about air pollution control for incinerators used for the disposal of solid refuse124 and for air pollution control in the petroleum and petrochemical industries.125 In 1966 a Provincial Board of Health Regulation limited smoke density in various sized urban areas, imposed an effluent particulate loading limit of 0.85 lb/1000 lbs, limited the release of odorous substances, and required an approval for the release of toxic or noxious materials.

Part 2 and 3 of the Maximum Levels Regulation under the Clean Air Act specified the opacity of visible emissions and the quantity and size range of particulates for most stationary sources. For most sources the standard was 0.2 lbs of particulates per 1000 lbs of emissions. Higher levels were permitted for some activities such as seed cleaning and wood processing plants in less populated areas. There were also specific emission standards for secondary lead smelters and vinyl chloride/polyvinyl chloride plants, both of which reflected federal guidelines.

By 1990 Alberta Environment had published source performance standards for 10 types of industrial operations (Table 6).

121 Air and Water Branch (2002) Industrial Source Standards Development Work Plan. Draft #4, Science and Standards Division, Alberta Environment, April 2002, 17 pp 122 CASA (2007) The Comprehensive Air Quality Management System: CASA’s Decision-making Process. Clean Air Strategic Alliance, Edmonton, Alberta, 20 pp 123 (a) Environmental Policy Branch (2005) Alberta Emission Standards for Electricity generation and Alberta air emission guidelines for Electricity Generation. Alberta Environment, 10 pp; (b) ERCB (2011) Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting. Revised edition November 3, 2011 replaces previous edition issued November 16, 2006 124 Dobko, SL (1965) Air pollution control in disposal of solid refuse through the utilization of proper incinerators or other methods in the Edmonton Metropolitan area. Air and Water Pollution Control Section, Department of Public Health and City of Edmonton Local Board of Health, 15 Feb 1965. Foreword by HL Hogge, Director Division of Sanitary Engineering 125 Kupchanko, E (1965) Air pollution control in the petroleum and petrochemical industries in the Edmonton metropolitan area. Foreword by HL Hogge, Director, Division of Sanitary Engineering

Table 6. Source performance guidelines in place by 1990

Industry Year Name of Document Origin Secondary lead 1971 Clean Air (Maximum Levels) Regulations Equivalent to smelters Federal regulations Vinyl 1971 Clean Air (Maximum Levels) Regulations Equivalent to chloride/polyvinyl Federal chloride plants regulations Fertilizer 1976 Guidelines for Limiting Contaminant Emissions Based on USEPA to the Atmosphere from Fertilizer Plants and requirements Related Industries in Alberta Asphalt 1977 Environmental Control Guidelines for Asphalt Based on Paving Plants information gathered during a tour of US plants Ammonia storage 1977 Guidelines for the Location of Stationary Bulk Ammonia Storage Facilities Refuse incinerators 1983 Guidelines for Design and Operation of Refuse Incinerators in Alberta Power 1984 Emission Guidelines for Fossil Fuel Fired Environment Thermal Power Generating Plants in Alberta Canada for SO2; CCME for NOx Sour gas with 1988 IL 88-13 Sulphur Recovery Guidelines for Sour Alberta review application to sulphur Gas Plants in Alberta process recovery at oil sands plants, and petroleum refineries Compressor engines 1988 IL 88-5 Application for Approval of Natural Gas- Alberta review Driven Compressors process

The development of source performance standards followed different paths for different industries and types of equipment. Sour Gas Plants

The 1969 guidance document for the sour gas processing industry provided a comprehensive set of requirements. Actual measurements rather than calculations were to be used to make periodic assessments of emissions. All tail gas from sour gas processing plants was to be incinerated to convert all H2S to SO2 and then exhausted to the atmosphere at a temperature of at least 1000°F through a stack of sufficient height so as to give resulting maximum ground level concentrations of SO2 within the prescribed ambient levels. Plant emergency releases of sour gas were to be flared in specially designed flare stacks with an adequate amount of fuel gas so as to ensure the successful conversion H2S to SO2. A minimum low heat value of 250 BTU/ft3 was required. Whenever condensate was stored at the plant, true vapour pressure of the stored condensate was not to exceed 12 psia to reduce evaporative hydrocarbon emissions.

The guide also gave detailed directions for stack surveys, how to : (1) locate and size sampling ports (2) determine the average velocity of the flue gases, (2) determine the average temperature of the flue gases, (3) determine the amounts of the principal constituents (O2, CO, N2 and CO2) in the flue gases, (4) determine the pollutant content of the flue gases, (4) use the collected data to calculate the rate of pollutant emission to the atmosphere, (6) report the data to the Provincial Board of Health.

Alberta had sour gas plant sulphur recovery requirements dating back to the 1960s. The status of guideline development between 1970 and 1974 was reviewed in a 1974 background document.126 The recovery guidelines were updated in 1971, 1980 and 1988. The 1988 revision was accomplished through a multi-stakeholder process involving Alberta Environment (then Alberta Environmental Protection), the ERCB (then the Energy and Utilities Board), industry and the public. Previous updates did not involve the public. Guidelines for sulphur emissions at oil sands operations were set out in 1973.127 The change in requirements over this period is shown in Figure 10.128 In May 1999, the Alberta Energy and Utilities Board, with Alberta Environment, initiated a review of the sulphur recovery guidelines. A discussion paper was released in September 1999 for stakeholder input. A multi- stakeholder Advisory Group consisting of representatives from the industry and non-governmental organizations was formed to examine the various options available and to provide its assessments of the relative costs and benefits. The Advisory Group issued its report in April 2000. In 2001 the new Sulphur Recovery Guidelines phased out grandfathering of sour gas, clarified the application of the sulphur recovery guidelines to other sour and acid gas facilities, and provided non-proliferation guidelines for small gas plants and other facilities.129

Owing to high gas prices in the mid-1970s, industry was eager to reduce fuel use in sour gas incinerators. Western Research and Development limited conducted a study to determine the operating conditions of sulphur plant incinerators that both minimize fuel consumption and ensure complete incineration of sulphur gases. Fuel savings of up to 30% were anticipated. A computer program was prepared and made available for industry to use in determining the minimum operating temperature that could be sustained without H2S breakthrough. Thereafter sour gas policy reflected a gas conservation objective.

126 Standards & Approvals Division (1974) Background document concerning sulphur recovery & sulphur emissions at gas processing plants in Alberta. Alberta Department of the Environment, August 1974, 148 pp 127 Western Research and Development Ltd (1976) Evolution of pollution abatement technology as applied to the Alberta oil sands. Prepared for Standards and Approvals Division, Alberta Environment 128 Macdonald, WS and BF Bietz (1996) Management of industrial sulphur dioxide and nitrogen oxides emissions in Alberta – description of the existing system. In: Proceedings of the Acidifying Emissions Symposium, April 15-17, 1996, Red Deer, Alberta, Clean Air Strategic Alliance, Edmonton, 29 pp 129 (a) Alberta Environment, Alberta Department of Resource Development, and Alberta Energy and Utilities Board (2001) Staff Report on the Review of the Sulphur Recovery Guidelines , January 2001, 47 pp; (b) Alberta Energy and Utilities Board and Alberta Environment (2001) Interim Directive ID 2001-3 Sulphur Recovery Guidelines for the Province of Alberta., August 29, 2001

Figure 10. The changes in sulphur recovery requirements from 1971 to 1988

Electrical Power Plants

Unlike other Provinces, Alberta has few hydroelectric generation opportunities. Instead, Alberta has vast fossil fuel resources that can and have been used to generate the base load of electricity needed by Albertans. The first coal-fired units were built starting in 1956 in both the Forestburg area and on Lake Wabamun. While these units did have substantial emissions, they were originally built without any air pollution control equipment. Gas-fired electricity generation was developed where gas was in abundant supply (such as the Medicine Hat area). However, as the demand for electricity increased there needed to be regulatory direction on whether gas or coal would be the fuel of choice. At an ERCB hearing in the mid-70s, a decision was made that coal would be the fuel of choice. Also, there was a need to ensure that newer units would meet a particulate matter emission standard determined through the application of either fabric filter baghouses or electrostatic precipitators. Also, as some units did not have this equipment in place, they were given specific requirements to install the necessary equipment. For all of Alberta, there were no requirements at that time to control SO2 as Alberta coals being used were considered low sulphur (<1 weight % sulphur). NOx emissions requirements were set based on unit specific design considerations.

As the demand for electricity increased and there was a likelihood of seeing more coal units being installed, Jafir Jaferi prepared the early 1980s document on emission standards for power plants.130 The thermal power plant guidelines reflected Environment Canada’s 1981 national emission guidelines for new thermal power plants commencing operation after May 1, 1982. Only a few units were approved under these requirements. The economic turndown in the early 1980s resulted in the construction of a number of approved facilities being postponed until the early 1990s. As a result of the CCME NOx/VOC Management Plan, there were some minor upgrades to federal requirements for coal-fired units that were never applied in Alberta. At the time, it was generally thought that owing to the abundance of cheap natural gas, new electricity generation would be gas-fired.

131 Guidelines for gas-fired turbines had been developed under the CCME NOx/VOC Management Plan. The turbine guideline was “technology forcing” at that time and drew heavily on the advancement around dry low-NOx combustors for turbines as opposed to “add-on” controls. Randy Dobko was an active member on this subgroup and the guideline was implemented within Alberta upon its release. These guidelines became emission standards by reference in an approval.

In the late 1980s and early 1990s there was a desire by the government to provide an incentive for renewable and alternate forms of generation (specifically biomass or waste-to-energy). The Small Power Producer Program set aside a grid allocation of 100 MW with a guaranteed rate for produced electricity to allow for these different generation technologies. In addition to a number of small hydroelectric projects , three biomass/ wood waste power plants were approved and have been operational ever since. An electrical generation plant burning all the used tires in the Province was also approved, but never built.

This situation changed dramatically in the 2000/2001. Significant economic and population increases in Alberta coupled with historically high gas prices led to proposals for new coal-fired units. The existing emission requirements were viewed as being “stale-dated” and not representative of what would be

130 Standards and Approvals Division (1984) Emission Guidelines for Fossil Fuel Fired Thermal Power Generating Plants in Alberta. Alberta Environment. April 1984. 19 pp 131 CCME (1992) National Emission Guidelines for Stationary Combustion Turbines. Canadian Council of Ministers of the Environment, Winnipeg, CCME=EPC/AITG-49E, December 1992. 9 pp

considered an acceptable emission standard. To address both the short term need, an interim guideline was announced by then Minister Lorne Taylor, and a commitment was made at the ensuing power plant hearings (held in the fall of 2001) to develop a process to manage air emissions from the electricity industry moving forward. This management framework would not only deal with new units but existing units as well.

Opacity

Coal-fired power plants in Alberta are major sources of air contaminant emissions, including primary particulate matter, and have significant continuous emission monitoring (CEM) requirements, which are laid out in the facility’s operating approval. Unlike the direct measurements made for SO2 and NOx, particulate emissions were correlated to the measurement of in-stack opacity. While there is a compliance component to all continuous emission monitoring, these measurement can also be utilized by an operator to take proactive actions to minimize emissions.

The magnitude of the potential number of opacity exceedance incidents (and possible excessive particulate matter emissions) was originally discovered when CEM reporting was changed from a longer term averaging period to reporting on a six-minute average. When the measurement records were moved to an environmental computer as opposed to a circular chart recorder, the issue of opacity exceedance became obvious to all parties.

Two problems that have been addressed in the past to better deal with particulate matter emissions include improvements in the operation of pollution control equipment at steady state conditions, and setting of performance requirements during transient conditions (that is during periods of start-up and shutdown). This work has been ongoing for more than twenty years. Performance improvements of particulate control equipment during steady state operation included upgraded maintenance (replacement of wires and their connectors, removal of particulate matter build-up on plates) and major capital projects (replacement of T/R controllers, air flow modifications, and chemical conditioning of particulate to change resistivity of the fly ash).

Improvements in performance during transient conditions came from the results of work done by the Opacity Task Force Working Group, which consisted of Alberta Environment staff (Bill Macdonald and Randy Dobko), industry and pollution control equipment suppliers and was formed in late 1991. This working group identified limitations based on particulate control equipment design and Fire Code requirements, and the group’s findings led to operational changes but no equipment modifications. Additionally, a new requirement for longer averaging times for opacity limits during start-up and shutdown was implemented. As a follow-up, an abatement program on improved particulate emission control operated throughout the 1990s significantly improving particulate emission control.

Reciprocating Engines

The emissions of nitrogen oxides from natural gas-fired reciprocating engines were a growing concern as Alberta’s oil and gas industry continued to expand. Control technology for compressor engines had

been examined by APIGEC in 1982.132 The first regulatory requirements were laid out in Informational Letter IL-OG-PL-76-15. These requirements were superseded by the requirements outlined in Informational Letter IL 80-30 which identified environmental objectives to be achieved by stack design requirements available through the Standards and Approvals Division of Alberta Environment. At this time, a compression facility had to meet the ambient objective for NO2 as predicted by dispersion modelling and if the facility was over, they were required to do ambient monitoring. There was no source emission standard at that time.

In light of an industry commitment to fund a major study of compressor exhaust chemistry and wake diffusion,133 IL 80-30 was amended in 1984 to suspend the above requirements for stack modification and ambient monitoring. The subsequent study led to the issuance of Informational Letter IL 88-5 which, while it updated the exhaust stack design method, it also included the concept of minimization of NOx emissions through the regulatory requirement for “low NOx” engines. The requirements were to be applied to new engines >600 kW of installed power and while many existing facilities were grandfathered as long as they did not increase site gas-fired compression, Alberta Environment also initiated a special study to review and require emission improvement in a number of facilities with significant numbers of engines. At this time the Alberta Environment dispersion model SEEC was introduced to evaluate the predicted maximum ground-level concentration of NO2 resulting from a facility’s NOx emissions.

Oil Sands Plants

An oil sands processing plant is composed of interdependent operations and processes which convert natural bitumen into synthetic crude oil, sulphur, process gas and various residue fuels. The first plant, called Great Canadian Oil Sands (GCOS), came on line in 1967 and the much larger Syncrude plant followed in 1978. Substantial quantities of sulphur compounds, oxides of nitrogen, particulates and heavy metals can be released from such operations. Indeed, these two plants were among the largest point sources of sulphur dioxide in all of Canada.

Emission requirements included:134 • air contaminants are to be released from one main stack designed to serve the entire plant complex, • a duplicate standby sulphur recovery train is to be idling as a backup, • daily releases of sulphur dioxide are limited to 1 long ton per 1000 barrels of bitumen processed, • maximum calculated one-half hour average ground level concentrations of sulphur dioxide and oxides of nitrogen are not to exceed 0.06 ppm by volume, • tankage is to be designed and equipped for vapour control, • sulphur recovery must meet the sour gas sulphur recovery guidelines, and

132 Zelensky, MJ (1982) NOx Control technology for Compressor Engines in Alberta. Prepared for Alberta Petroleum Industry Government Environmental Committee by Western Research, Acid Deposition Research Program, 76 pp + references and appendices 133 Vet, RJ, NW Reid, E Alp, and SJ Diehl (1982) Compressor exhaust chemistry and wake diffusion. Prepared by Concord Scientific Corporation for Alberta Petroleum Industry Government Environmental Committee, Acid Deposition Research Program, April 1982, 205 pp 134 Standards and Approvals Division (1972) Tar Sands Processing Plants Standards: Air Pollution Control and Emission Standards for New and Existing Plants. November 20, 1972. Alberta Environment, 20 pp.

• common industrial equipment such as heaters, boilers, and gas-fired turbines to meet all existing standards.

Comprehensive source and ambient monitoring were also required, paralleling the emission-linked criteria for sour gas plants and extended to particulate matter and heavy metal content (source monitoring).

Coke produced during the processing of the bitumen was used as fuel in coke boilers to generate the massive amounts of steam and hot water used in the process. This prompted emission control requirements for particulates from the coke-fired boilers. Dramatic expansion of the oil sands industry was expected at the time of initial approval of the GCOS facility. Based on the anticipated construction a line of oil sands processing facilities North of Fort McMurray, only a portion of the airshed’s assimilative capacity (as defined by the ambient air quality objective) was allocated to each facility.

The original oil sands plants were amongst the highest emitters of SO2 and NOx, both within Alberta and Canada. While many attempts by multiple Department staff members to get either company to reduce those emissions, those efforts led to limited success. However, as both facilities applied for major expansions, requirements were put in place to dramatically reduce SO2 emissions through the application of flue gas desulphurization technology.

Control technologies for the oil sands and for the upstream petroleum industry have been periodically 135 reviewed. The growth of NOx emissions in the oil sands prompted a 2007 interim policy applying tighter limits to new boilers, heaters and turbines in the Regional Municipality of Wood Buffalo north of Fort McMurray.136

Kraft Pulp Mills

Kraft pulp mills emit, in addition to the common air contaminants, very odorous substances known as mercaptans. Some people directly involved in the industry describe a kraft pulp mill as “a home with a thousand skunks.” The effluent streams, apart from being highly odorous, have high heat content, so there is value in combining and then combusting them to recover the energy. A kraft pulp mill can be designed to recover the heat value of all its waste products for the production of steam and electricity. Excess amount of electricity can be exported onto the electricity grid.

The first pulp mills in the province were required to meet the emission standards of the United States Environmental Protection Agency. In the early 1990s, a new pulp mill was proposed for the Athabasca area and was not well received by area residents. This started a thorough review of pulp mill standards. Subsequent to an Environmental Impact Assessment and a lengthy public hearing, the Department upgraded the emission standards used to set approval limits for this project and all future kraft mills in the Province.

135 (a) Western Research and Development (1976) Evolution of pollution abatement technology as applied to the Alberta oil sands. Prep for Standards and Approvals Division; (b) Bhardwaj, S (2002) Inventory of nitrogen oxide emissions and control technologies in Alberta’s upstream oil and gas industry. Prepared for Science and Standards Division, Alberta Environment 136 Oil Sands Environmental Management Division (2007) Interim Emission Guidelines for Oxides of Nitrogen (NOx) for New Boilers, Heaters and Turbines using Gaseous Fuels for the Oil Sands Region in the Regional Municipality of Wood Buffalo North of Fort McMurray based on a Review of Best Available Technology Economically Achievable (BATEA), December 14, 2007, 5 pp.

Chemical Plants

Not all industrial sectors lend themselves to a “one size fits all” emission standard or guideline. The chemical sector produces a variety of products using very different chemical processes. Common equipment standards for such things as heaters, boilers, and gas-fired turbines are applicable in determining some of the emission limits in approvals. For process-specific limits, approval staff applied the principle of pollutant minimization through control technology before assessing whether a source meets the relevant ambient objective. For those compounds that didn’t have an applicable Alberta objective, staff would review ambient objectives from other jurisdictions where similar plants were approved (mainly Ontario or Texas) and apply their objectives in assessing the acceptability of the emission.137 The Canadian Chemical Producers Association (CCPA) initiated a “Responsible Care Program” that required its members to minimize overall emissions and reduce the emissions of the most toxic chemicals. Participation in this national program was a condition imposed on Alberta plants in their approvals.

Fertilizer Plants

The fertilizer sector also has multiple chemical processes to produce multiple products. These products can be multiple types of fertilizers but also include such products as nitric acid, phosphoric acid, and sulphuric acid. In addition to the common air contaminants, plants also emit uncommon air contaminants such as hydrogen fluoride (a constituent of the phosphate rock needed to produce phosphoric acid) and ammonia. Emission control during fertilizer production is based on minimizing chemical reactants that feed into the process and dust releases from the handling of the final product. Emissions from the production of the chemicals used to make fertilizer (sulphuric acid, nitric acid, and ammonia) were limited based on the capabilities of the production equipment. However, processes used to produce these chemicals, especially sulphuric acid, became a major concern during the start-up of a sulphuric acid plant in Calgary in 1987 when there was an uncontrolled release of sulphur dioxide. Emission control equipment is not effective during a start-up, so minimizing emissions in such transient conditions presents a constant challenge.

Refineries

The refinery sector is another industrial sector with multiple processes to produce multiple hydrocarbon products. Some people within this industrial sector describe a refinery as” a collection of pots and pans used to boil and condense material for gasoline.” Common equipment standards for heaters, boilers, and gas-fired turbines were used to set some emission limits. Process-specific limits were derived from best practicable technology to minimize pollutants. Then the source would need to meet the relevant ambient objective.

Carbon monoxide (CO) is a unique pollutant generated in a conventional refinery. It is formed when the catalyst used in the fluidized catalytic cracking unit (FCCU) is regenerated. Effluent streams of ~40,000 ppmv of CO could be released. There is significant useable energy when CO is combusted to CO2. The department required the use of CO boilers to control emissions and recover the energy.

137 Air Emissions Branch and Air Issues & Monitoring Branch (1998) Air Toxics Management Program in Alberta. Environmental Services, Alberta Environmental Protection, April 1998, 19 pp

In 2001 the Canadian Petroleum Products Institute approached the provincial and federal governments with a proposal to develop a new regulatory approach to stimulate innovation in the Canadian petroleum refining industry while protecting human health and the environment. A framework138 was approved in September 2004. It consisted of four elements:

• Methodologies to assist jurisdictions with prioritizing (Health Effects Indicators Decision Index) and setting emission caps (benchmarking), • A strategy to monitor and report on refinery emissions and reductions, • A 10 year plan to keep the framework tools updated, measure performance and report on progress, and • Jurisdictional management of refineries.

The emission caps: • Set maximum emission levels for criteria air pollutants and air toxics, which apply to the refinery as a whole, rather than to individual sources at the refinery; and • Are “performance-based” rather than “prescriptive”, i.e., they would not dictate the technology refineries must use in order to achieve the required reductions.

Implementation of the National Framework was expected to lead to substantial reductions, as high as 50% of some parameters at some facilities. Alberta implemented the framework through reference in each refinery approval.

Prill Towers

Prill towers were used both in the fertilizer sector and the sulphur handling sector. The heated liquid compound would be sprayed at the top of a tower counter-current to a cooling stream of air. As the chemical cooled and solidified, it formed small “prills” which were a granular solid, which was then sold or marketed as the final product. This technology was evidently used in other jurisdictions, one being Poland and was generally thought of as non-polluting. However, it was observed that for kilometers around such operations fine sulphur dust was leading to soil acidification. The Air Monitoring Directive required soil monitoring around operations which could be sources of sulphur dusting.

Common Industrial Equipment

Commercial and industrial heaters and boilers are significant sources of NOx emissions. Emission minimization required the use of low-NOx burners, but it was never clear what constituted low-NOx burners. Through the CCME NOx/VOC Management Plan a working group on industrial heaters and boilers were formed with Randy Dobko being the Department representative. Guideline development focused on setting NOx levels reflective of the first generation of low-NOx burners for this type of

138 Canadian Council of Ministers of the Environment (2004) National Framework for Petroleum Refinery Emission Reductions. Environment Canada, EPS 9/AP/2, 32 pp + 5 appendices

common equipment. The CCME guideline was issued in 1998,139 and immediately implemented in Alberta. Source Monitoring

Point source emissions can be measured in two ways: manual stack surveys and continuous emission monitoring. Manual stack surveys are short duration tests in which effluent gas samples are collected by inserting a probe into the stack. If emissions are large, then continuous emission monitoring instruments are permanently installed on the stack. Visible emissions can be measured by trained observers or photographic techniques. Fugitive emissions are releases of gases or aerosols from pressurized equipment due to leaks in valves, pipe connections, seals and other fittings. Various remote sensing techniques can be used to identify and/or quantify such emissions. Mobile emissions are measured by drawing exhaust samples through instruments to determine concentrations.

Stack Surveys

Source or stack surveys were conducted throughout the province starting in 1967, with sour gas plants being a major industry sector but also including fertilizer plants and smaller industries. Primary parameters monitored were SO2, NOx and particulates. In the 1970s a dedicated stack sampling team was established and the scope expanded to include sources such as asphalt plants, brick manufacturing, recycled oil acid contact plants, and oil seeds plants. When the ERCB took over environmental responsibility for the oil and gas industry, they also took over the responsibility for stack sampling. For efficiency the ERCB went to a system of witnessing or auditing third party surveys. The Department also adopted the audit system but retained a dedicated stack sampling team in order to maintain and develop its own technical expertise. Spot checks continued and standards or codes for stack sampling were developed. An important initial issue was also the provision for safe and properly located stack sampling ports and platforms, which were incorporated into approvals and codes.

The 1969 guidance document had included information on how to perform stack surveys. In 1976 a separate stack sampling code was published.140 In 1988 methods for measuring total reduced sulphur compounds from pulp and paper operations were published and in 1991, methods for measuring total reduced sulphur compounds from sour gas plants.141 In 1995, an amended code was issued to include newer, more advanced technological methods.142 This code specified how to measure emissions of air pollutants from stationary sources in Alberta, as required for determining compliance with the terms and conditions of an Approval under EPEA.

139 CCME (1998) National Emission Guideline for Commercial/Industrial Boilers and Heaters. Prepared by the N306 Multistakeholders Working Group and Steering Committee. Canadian Council of Ministers of the Environment, Winnipeg, March 1998, PN 1286, 32 pp.

140 Industrial Waste Management Branch (1976) Source Sampling Code: Reference Methods for Source Sampling and Analysis of Particulates, Sulphur Oxides and Oxides of Nitrogen. Publication SSC-1/76, Standards and Approvals Division, Alberta Environment 141 (a) Pollution Control Division (1988) Measurement of stack emissions for total reduced sulphur compounds from pulp and paper operations, Alberta Environment, December 1988; (b) Environmental Protection Services (1991) Reference Method for Source Testing: Measurement of Emissions of Total Reduced Sulphur Compounds from Sour Gas Plants, Alberta Environment , June 1991, 35 pp. 142 Environmental Regulatory Service (1995) Alberta Stack Sampling Code. Alberta Environmental Protection, 406 pp

For many years the Air Pollution Control Section of the Department of Health and the Air Quality Control Branch of the Department of Environment also operated a government stack sampling program to gather independent data on industrial emissions and check the numbers produced by industry self- monitoring. Figure 11 shows a stack survey in progress. This was a summer program, typically pairing a staff engineer with a student hired under the provincial government Student Temporary Employment Program (STEP). In the early 1970s two permanent stack sampling crews were hired when Albert Poulette, Ryan Leavitt, Al Montpellier and Kent Lukinuk joined the Air Quality Control Branch. Students also assisted in inspecting asphalt producing plants around the province since many complaints were received about the black smoke released by such operations. One summer, students were used in a campaign to locate any illegal incinerators operating in backyards or commercial areas of the cities.143

Figure 11. Stack survey in progress (May 1977)

Continuous Emission Monitoring Systems (CEMS)

Large sources were also required to monitor their emissions continuously with instruments permanently mounted on the stack. Draft guidelines for continuous emission monitoring of sulphur dioxide were published in 1986, and performance specifications for a Continuous Emission Monitoring System (CEMS)

143 Lack, JC (2015) personal communication

were published in 1991. A draft Continuous Emissions Monitoring System Code was released for discussion in 1994 and a final code published in 1998.144

Alberta has always been a leader within Canada in the use of continuous emission monitoring for significant emission point sources, starting in the 1970’s. The first examples of CEMS were gas chromatographs used in the sour gas (sulphur recovery) industry. Eventually as CEMS technology evolved with the advent of newer extractive system technology, companies based in Alberta became world class leaders in systems specific to sour gas processing. At this time, there were a number of attempts to develop a “made in Alberta” CEMS requirement with only limited success. Additionally, other industries were being required to install CEMS and USEPA requirements were usually used as the basis of the technical requirements. In 1997/1998, a multistakeholder technical group was put together and chaired by Larry Begoray to develop an Alberta CEMS Code. One of the unique aspects of the Code was that it allowed for other in-situ optical systems rather than the typical extractive system as long as the laid out performance specifications could be met.

Visible Emissions Monitoring

Visible emissions were initially estimated by human observers using the Ringelmann Chart as noted in the Public Health regulations. The Ringelmann Smoke Chart was developed by Professor Maximilian Ringelmann of Paris. Ringelmann, born in 1861, was professor of agricultural engineering at l'Institute National Agronomique and Director de la Station d'Essais de Machines in Paris in 1888. The Ringelmann system is a scheme whereby graduated shades of gray, varying by five equal steps between white and black, may be accurately reproduced by means of a rectangular grid of black lines of definite width and spacing on a white background.145 The chart printed and distributed by the Department of the Environment in the 1970s is shown in Figure 12.

Figure 12. Alberta Environment visible emissions chart

144 (a) Alberta Environment and Energy Resources Conservation Board (1986) Guidelines for sulphur dioxide continuous emission monitoring systems, draft September 1986; (b) Alberta Environment (1991) Continuous Emission Monitoring System (CEMS) Performance Specifications, January 1991; (c) Standards and Approvals Division (1994) Draft Continuous Emissions Monitoring System (CEMS) Code, Alberta Environment, June 1994; (d) Alberta Environmental Protection (1998) Continuous Emission Monitoring System (CEMS) Code. Alberta Environmental Protection , Environmental Service, May 1998, 48 pp 145 US Bureau of Mines (1967) Ringelmann Smoke Chart (Revision of IC 7718) United States Department of Interior, information circular 8333, May 1967

This method of estimation turned out to be insufficiently robust for legal enforcement. Consequently, a formal training program was developed for observers to determine opacity using a calibrated smoke generator.146 The program was operated in partnership with Mount Royal College, but eventually was discontinued owing to low usage.

Fugitive Emissions Monitoring

By 1985, Licences contained fugitive emission clauses asking operators to develop a fugitive emission control program to address leakages from valves, flanges, sampling connections, pumps, pipes and compressors. The ERCB also investigated complaints related to such emissions from oil and gas operations and sometimes used mobile monitoring or stationary monitoring trailers to track the sources. A CCME Fugitives Emission Code, developed through an initiative under the NOx/VOC Management Plan was referenced after 1993. The ERCB, in Directive 060, regarded the migration of H2S and VOC emissions off-lease as unsatisfactory and in 2007 the Canadian Association of Petroleum Producers published a best management practice to assist its members in compliance.147

Mobile Emissions Monitoring

While source testing on industrial point sources has a regulatory focus, emission testing on mobile sources was aimed at driver education and awareness. For a number of years, vehicle emission test clinics were held in Edmonton, Calgary, Red Deer and Lethbridge (Figure 13). These were very popular; people waited in long lineups to have their cars and trucks tested. Part of the appeal may have been the “free” tune-up of carburetor settings that test vehicles received as part of the clinic operations.

146 Industrial Waste Branch (1977) A Manual for Training and Certification of Observers and Evaluation of Visible Emissions, Standards and Approvals Division, Alberta Environment, Publication VEE-2/77 147 (a) Witthoeft, Frank (1985) Regulatory perspective of fugitive emissions. Presented at Canadian Prairie and Northern Section, Air Pollution Control Association, Fifth Annual Meeting, June 5, 1985, Calgary; (b) Melnychyn, Lonnie (1985) ERCB viewpoint of fugitive emissions, Presented at Canadian Prairie and Northern Section, Air Pollution Control Association, Fifth Annual Meeting, June 5, 1985, Calgary; (c) CCME (1993) Environmental Code of Practice for the Measurement and Control of VOC Emissions from Equipment Leaks, Canadian Council of Ministers of the Environment, October, 1993, Winnipeg, 44 pp; (d) CAPP (2007) Management of Fugitive Emissions at Upstream Oil and Gas Facilities, Best Management Practice, Canadian Association of Petroleum Producers, Calgary, January 2007, 51 pp.

Figure 13. Vehicle emission testing Emissions Inventories

An emission inventory is a comprehensive listing, by source, of air pollutant emissions associated with a specific geographic area for a specific time interval. Emission inventories have a variety of uses: tracking progress towards emission targets, determining compliance with emission regulations, setting the baseline for policy planning, identifying general emission patterns and trends, developing control strategies and new regulations, serving as the basis for permitting, predicting pollutant concentrations from dispersion models, and providing input for human health risk assessment and the siting or ambient air quality monitors.

Urban Inventories

Likely the earliest urban inventories for Alberta were produced by the Department of Health in 1964 for the calendar year 1963.148 Questionnaires were sent to 210 specific emission sources in the Edmonton area and to 1644 emission sources in the Calgary area. The numbers were based on engineering estimates and emission factors, taken largely from a 1960 County of Los Angeles technical report.149 There were 10 pollutant types in the inventory, and both bottom-up and top-down methods were used to make the estimates. A simple box model was used to predict ground level concentrations of some of the pollutants.

148 (a) Rolston, JJ (1964) A Study of Air Pollution Sources and their Significance in Edmonton, Alberta. Department of Public Health, Division of Sanitary Engineering; (b) Rolston, JJ (1964) A Study of Air Pollution Sources and their Significance in Calgary, Alberta. Department of Public Health, Division of Sanitary Engineering 149 Slubik, D (1996) Emission inventories of sulphur dioxide, nitrogen oxides, and ammonia in Alberta 1963 to 1995: a review. In: Proceedings of the Acidifying Emissions Symposium, April 15-17, 1996, Red Deer, Alberta, Clean Air Strategic Alliance, Edmonton, 28 pp

The 1971 emissions in the two cities were inventoried as part of the urban model development project.150 The reports provided quantities of sulphur dioxide, carbon monoxide, oxides of nitrogen, hydrocarbons, and particulates with seasonal and geographic distributions, and evaluated control methods at the time. Sources included all industrial sources, transportation sources, fuel combustion for process and space heating, and a miscellaneous category, which included sources such as incinerators, dry cleaners, and service stations. Methods included: questionnaires mailed to operators of the major industrial sources, reviews of permit data, calculations from stack surveys, and U.S. EPA emission factors.

An emissions forecast was made using an estimated population increase to increase emissions proportionately from natural gas combustion and gasoline marketing. Vehicle registrations were increased by the same proportion but emissions were adjusted to account for new emission control technologies. For industrial expansion, an arbitrary annual increase was applied.

These inventories were updated in 1975 and 1982 using vehicle data supplied by the two cities: traffic counts from Edmonton and vehicle models for Calgary.151 A detailed procedures manual accompanied the 1982 inventory152 as the work was labor intensive and generally done by summer students or seasonal workers under the supervision of Peter Truch. A database was also part of the 1982 inventory, and was used in providing input to urban air dispersion models. The preparation of this inventory required the equivalent of 5 person years of work. The report showed that the transportation sector contributed most to total emissions, with the major industrial sources contributing significantly to SO2 totals for the Edmonton area.153

Point Source Inventories

The first province-wide inventory was published in 1973, providing estimates of the 1971 emissions of the five most important air pollutants from industrial sources, fuel combustion in stationary sources, transportation, solid waste disposal and miscellaneous sources. Over half of the total emission mass was due to carbon monoxide and another one-fifth was sulphur oxides. Nearly 90% of the carbon monoxide was from the transportation sector while over 95% of the sulphur emissions were from stationary fuel combustion (utilities and power).154

150 (a) Earl, GO and PA Beauchemin Jr (1973) Inventory of air pollution sources and emissions in the city of Edmonton, 1971. Prepared for Alberta Environment by Western Research and Development, Calgary; (b) Earl, GO and PA Beauchemin Jr (1973) Inventory of air pollution sources and emissions in the city of Calgary, 1971. Prepared for Alberta Environment by Western Research and Development, Calgary; (c) Western Research and Development Ltd (1973) Sources and Emissions Inventory for the Cities of Edmonton and Calgary—preparation and results, 1971. Alberta Environment, Edmonton 151 (a) Alberta Environment (1975) Inventory of air pollution sources and emissions in the city of Edmonton, 1973. Pollution Control Division, Air Quality Control Branch; (b) Alberta Environment (1975) Inventory of air pollution sources and emissions in the city of Calgary, 1973. Pollution Control Division, Air Quality Control Branch (c) Truch, P and W MacDonald (1985) Inventory of Air Pollution Sources and Emissions in the Cities of Edmonton and Calgary, 1982. PNWIS-APCA 1985 Annual Meeting, Calgary, Alberta, 1985 152 Truch, P (1984) Sources and Emissions Inventory Procedure Manual. Alberta Environment, internal document (unpublished) 153 Slubik, D (1996) Emission inventories of sulphur dioxide, nitrogen oxides, and ammonia in Alberta 1963 to 1995: a review. In: Proceedings of the Acidifying Emissions Symposium, April 15-17, 1996, Red Deer, Alberta, Clean Air Strategic Alliance, Edmonton, 28 pp 154 Standards and Approvals Division (1973) An Inventory of Air Pollutant Emissions in the Province of Alberta - 1971. Environmental Protection Services, Alberta Environment, February 1973, 11 pp

Annual SO2 emissions were compiled and published by Alberta Environment in three reports for the periods 1974-1978, 1977-1981 and 1981-1985.155 The sectors and facilities that were inventoried included (in order of decreasing emissions) gas processing plants (flaring and extraction), oil sands plants, coal fired power plants, sour oil batteries, petroleum refineries, pulp and paper manufacturing, fertilizer manufacturing, heavy oil recovery plants, a coke calcining plant, and a chemical plant. For the gas processing industry, emissions were taken from monthly report summaries submitted to Alberta Environment. These were cross checked with Energy Resource Conservation Board (ERCB) sulphur balance reports. Data on sour oil batteries was obtained from the ERCB. Emissions from all other sectors were compiled from monthly and annual reports submitted to Alberta Environment by the facility operators.

Emissions were also forecast during this period of regular emissions compilation. A 1982 publication for the period 1980-2000 used two growth scenarios: (1) a high demand for natural gas, vehicle ownership and use, and a year 2000 population of 3.8 million people; (2) less optimistic conditions with population growth to 3.0 million. The two forecast scenarios were further divided by assuming present, best practicable, and best available control technologies. This forecast in began in 1980 with estimated SO2 emissions of about 600 kilotonnes and ended with estimated emissions for the year 2000 ranging from 140 to 750 kilotonnes.156

A second forecast was published in 1990 for the period 1983-2005.157 Actual emission numbers were available for 1983 to 1988; the forecast was partially based on improvements in sulphur recovery that were mandated in the ERCB. In 1983, about 500 kilotonnes of SO2 were reported; the forecast for 2002 was 635 kilotonnes.

158 A number of inventories of NOx emissions were also compiled over the time period as for SO2. The inventory reports provided tabular summaries of NOx emissions for three major categories: industrial processes, transportation, and fuel combustion. Each of these categories was further divided into various sectors. Most of the industrial emissions numbers were calculated from stack surveys and operational time, or production data and emission factors. In the natural gas processing sector, emissions of NOx were determined from ERCB fuel use statistics and EPA emission factors. Emissions from transportation were determined using Environment Canada methods. For the fuel use category, provincial and Statistics Canada consumption data and EPA emission factors were used. The Alberta Forest Service supplied the forest fire statistics for amount of timber burnt, and EPA emission factors were used to determine the NOx emissions.

155 (a) Sandhu, HS, editor. (1979) Industrial Sulphur Emissions for Alberta 1974-78. Alberta Environment, Research Secretariat, 1979; (b) Air Quality Control Branch (1982) Industrial Sulphur Emissions for Alberta 1977-81. Pollution Control Division, Alberta Environment; (c) Air Emissions Branch (1988) Industrial Sulphur Dioxide Emissions Inventory for Alberta 1981- 85., Standards and Approval Division, Environmental Protection Services, Alberta Environment 156 Research Management Division (1982) Alberta Sulphur Dioxide Emissions Forecast 1980-2000. Alberta Environment, RMD Report 82/16, 1982 157 Energy Resources Conservation Board (1990) Sulphur Emissions Forecast for Alberta 1983-2005. Prepared by the ERCB Gas Department for Alberta Energy and Alberta Environment, 1990. 158 (a) Peters, RR, and HS Sandhu (1980) Nitrogen Oxides Emissions for Alberta 1976 to 1979. Research Management Division, Alberta Environment, RMD-80/3; (b) Air Quality Control Branch (1984) Nitrogen Oxides Emissions for Alberta 1978-82. Pollution Control Division, Alberta Environment; (c) Air Quality Control Branch (1988) Nitrogen Oxides Emissions for Alberta 1981-85. Pollution Control Division, Alberta Environment; (d) Air Emissions Branch (1990) Nitrogen Oxides Emissions for Alberta 1987. Standards and Approvals Division, Alberta Environment.

159 Two NOx emission forecasts were also prepared. The 1980 to 2000 NOx forecast methodology was similar to that used in the SO2 forecast with two growth scenarios and present, best practicable, and best available control technologies. This forecast began with estimated NOx emissions of about 350 kilotonnes and for the year 2000 estimated emissions ranged from 150 to 660 kilotonnes. For the 1988 to 2005 forecast, an econometric model was used to develop one forecast scenario of aggregate energy end use. For 1988, an end use inventory was compiled for the energy production, industrial, transportation, residential and commercial sectors. All emissions were calculated from energy consumption and appropriate emission factors. Alberta's total NOx emissions were forecast to grow from 448 kilotonnes in 1988 to 535 kilotonnes by 2000.

Under the government-industry Acid Deposition Research Program an inventory was compiled to assist in the investigation of the possible effects of acidifying emissions. The four reports160 highlighted the importance of air quality predictions in finding solutions to air quality problems and in evaluating the potential impacts of proposed sources. This inventory differed from the provincial inventories in that it was specifically designed for use with dispersion modelling. It had significantly more detail on the spatial and temporal distribution of sources and emissions, and of emission characteristics (stack height, gas exit velocity, and gas exit temperature). The sources in this inventory included natural gas processing facilities, oil refineries, oil sands and heavy oil recovery facilities, fertilizer and chemical plants, power generation plants, pulp and paper plants, cement plants, sour oil batteries (emitting more than 0.2 tonnes/day of sulphur dioxide), industrial engines (power output greater than 100 kW), urban centres, and major portions of high traffic highways in the province. A limited NOx source sampling program was also done as part of this project. It yielded significantly different emission factors for compressor engines than were currently in use. The inventory included 565 sources of SO2 and 4025 sources of NOx. The large number of sources was due to the inclusion of sour oil batteries and compressor engines as point sources rather than area sources.

For the SO2 inventory, detailed stack design information and stack emission data were gathered from the Standards and Approvals Division of Alberta Environment, with some data obtained through correspondence with the individual operators. The ERCB provided the data on the sour oil batteries. For the NOx inventory, licence applications made to Alberta Environment were reviewed to provide most of the stack information. The ERCB was contacted for information on smaller NOx sources and on oil batteries. Data from gas utility companies was used to provide emissions from the fuel used for heating and industrial processes within the urban centres. From an earlier study, a ratio between space heating emissions and vehicle emissions in the urban areas was determined. Using the same ratio, and with emissions for space heating calculated in this study, emissions for vehicles were determined for 1984.

159 (a) Colley, DG, RW Poon, MJ Zelensky, and L Zanzotto (1983) Alberta Oxides of Nitrogen Emissions Forecast 1980 to 2000. Prepared for the Alberta Environment, Research Management Division by Western Research, Division of Bow Valley Resources Ltd. RMD Report 83/26; (b) Energy Resources Conservation Board (1990) Energy Related Nitrogen Oxide Emissions in Alberta 1988-2005. Prepared for Alberta Energy and Alberta Environment 160 (a) Picard, DJ, and Colley, DG, and Boyd, DH (1987) Overview of the Emission Data: Emission Inventory of Sulphur Oxides and Nitrogen Oxides in Alberta. Prepared for the Acid Deposition Research Program by Western Research, Division of Bow Valley Resource Services Ltd., Calgary, Alberta, Canada; (b) Picard, DJ, and Colley, DG, and Boyd, DH (1987) Design of the Emission Inventory: Emission Inventory of Sulphur Oxides and Nitrogen Oxides in Alberta. Prepared for the Acid Deposition Research Program by Western Research; (c) Picard, DJ, and Colley, DG, and Boyd, DH (1987) Emission Data Base: Emission Inventory of Sulphur Oxides and Nitrogen Oxides in Alberta. Prepared for the Acid Deposition Research Program by Western Research; (d) Picard, DJ, and Colley, DG, and Boyd, DH (1987) Results of the Emission Source Surveys: Emission Inventory of Sulphur Oxides and Nitrogen Oxides in Alberta. Prepared for the Acid Deposition Research Program by Western Research.

NOx emissions along the major highways were determined from average daily vehicle volumes (Alberta Transportation) and emission factors (Environment Canada).

For the 1984 calendar year, it was found that the petroleum industry was by far the major source of emissions, accounting for 38% of NOx emissions and 82% of SO2 emissions. Also found to be important were electric power plants for NOx and SO2, vehicle emissions along the major highways for NOx and urban centres for NOx. Because of the greater industrialization in the southern half of the province (south of latitude 54), 72% of the NOx and SO2 emissions occurred within that region. The inventory also pointed out that the 10 largest emitters of SO2 accounted for 61% of the total emissions, and that the 10 largest emitters of NOx accounted for 39% of total emissions.

Inventory Data Management

In the late 1990s, the department considered an update to the Air Monitoring Directive so that it could move from a paper-based industry reporting system to an electronic reporting system. Rather than develop customized software, a search was undertaken for existing systems that might serve the purpose. In 2000 a detailed evaluation was made of the Regional Air Pollutant Inventory Development System (RAPIDS) used by the Great Lakes Commission as a common emission inventory system for member agencies. RAPIDS was found to be complex to use, and did not satisfy industry’s need to streamline their emission information reporting process. It also needed to link with other department systems.161 Because industry was already reporting to the federal National Pollutant Release Inventory (NPRI), the department worked with Environment Canada to develop the NPRI reporting system to serve both purposes. Summaries of NPRI reported emissions for 500+ Alberta sources are occasionally published.162 A summary of emissions trends and projections from a variety of sources was prepared for the CASA Clean Air Strategy Project Team.163 The department also continued to search for a suitable in- house data management tool and in 2008 acquired a version of Lakes Environmental Emissions View™ Customizable GIS-Based Emissions Inventory System to manage its emissions data.

The department’s emissions inventory program has waxed and waned over the years. The peak was during the urban inventory updates of the late 1970s and early 1980s when up to 5 FTEs were devoted for a few years. Generally only one FTE has been assigned; at times there were zero resources assigned. When the Lakes software was purchased, 2 FTEs were available, but more were needed to make full use of the system. The sporadic nature of program support and absence of a database led to production of various inventory reports, sometimes as part of a research projects, sometimes as part of a planning exercise. The PM and Ozone Management Framework and other air quality planning needs have intensified the need for thorough and accurate emission inventories.

Summary of Sources and Emissions

The Department of Public Heath issued the first source performance guidance in 1965, for solid waste incinerators and for the petroleum/petrochemical sector. These were augmented over the years with

161 LGS Group inc (2000) RAPIDS Evaluation Project Report. Science and Technology Branch, Environmental Sciences Division Alberta Environment, March 2000, 32 pp 162 Evaluation and Reporting Section (2006) Alberta Environment Summary Report on 2004 NPRI Air Emissions. Environmental Monitoring and Evaluation Branch, Environmental Assurance, Alberta Environment, 83 pp 163 Air Policy Branch (2008) Alberta Air Emissions Trends and Projections. Environmental Assurance. Alberta Environment, 20 pp

standards for different industries and commercial enterprises and by 1990 there were guidelines for 10 types of industrial operations. Sulphur Recovery Guidelines issued jointly with the Energy Resources Conservation Board have been updated at various intervals and have been a central feature of air pollution management in the province. These standards were used to determine the emission limits in a permit. In the absence of Alberta standards, an approvals engineer drew upon technology information and standards elsewhere to create suitable emissions limits for the industry.

Stack emission surveys were conducted by departmental staff and required of industry as a licence condition. Continuous emission monitoring for large sources was required once suitable instrumentation became available with a dedicated Code being published in 1998. Visible emissions was measured by human observers initially using the Ringelmann chart and later by certified readers trained with a calibrated smoke generator. By 1985 industrial operators were being asked to develop control programs for non-stack (fugitive) emissions. Subsequently fugitive emission codes were published by the Canadian Council of Ministers of the Environment and by the Canadian Association of Petroleum Producers.

The first sources and emissions inventories were prepared by the Department of Public Health in 1964 for the Cities of Edmonton and Calgary. The first province-wide inventory was developed by the Standards and Approvals Division of Alberta Environment in 1973. Sulphur dioxide emissions were compiled by the Research Secretariat in 1979, Pollution Control Division in 1982, and Standards and Approvals Division in 1988. Forecasts of future emissions were published by Research Management Division in 1982 and the Energy Resources Conservation Board in 1990. Oxides of nitrogen emissions were inventoried first by Research Management Division in 1980 and then by Pollution Control Division in 1984, 1988, and 1990. Forecasts were published by Research Management Division in 1983 and the Energy Resources Conservation Board in 1990. Extensive detailed inventories of sulphur oxides and nitrogen oxides were also compiled in 1987 for the joint industry-government Acid Deposition Research Program. The first urban inventories for modelling purposes were published in 1973 and updated in 1975 and 1982. Inventory preparation was a very labour intensive process until suitable computer hardware and software became available. In 2000, the department did a detailed evaluation of a potential system for Alberta, however it was not until 2008 that suitable software was identified and acquired.

Ambient Monitoring and Reporting

Ambient monitoring consists of continuous or periodic measurements over long periods to meet long term objectives, define trends, check on compliance or study the relationship between air quality and environmental health. Measurements refer to the determination of the concentrations of an atmospheric pollutant present in the air at a given time or of the amounts found in a receptor.

The Pollution Control Section of the Division of Sanitary Engineering, Department of Public Health first started monitoring for total sulphation around gas plants in 1959 and for dustfall in the Coleman area in 1960. The first sour gas monitoring trailers were acquired in 1961 and by 1963 there were three such units in the province.164

Fixed Station Networks

Alberta started its urban air quality monitoring program in the 1960s and by 1965 there were measurements of particulates (with high volume samplers), oxidants, oxides of nitrogen and coefficient of haze. The number of stations and parameters continued to grow and by 1973 the urban networks consisted of a number of hi-vol samplers for suspended particulate matter, exposure stations for total sulphation and dustfall, smoke monitors and continuous monitors for oxides of nitrogen, ozone and hydrocarbons in Edmonton (Figure 14) and Calgary (Figure 15).

The National Air Pollution Surveillance (NAPS) Network was established in 1969 as a joint project of the federal and provincial governments to monitor and assess the quality of ambient (outdoor) air in the populated regions of Canada. The federal government provided the equipment for the stations which were operated by the provinces and the data submitted to the NAPS database. Alberta established six such continuous monitoring stations, three each in Edmonton and Calgary, to represent residential, industrial and downtown areas. These were supplemented with networks of exposure cylinders for sulphur dioxide, hydrogen sulphide and dust fall. By 1976 the monitoring networks had changed dramatically.165 Figure 16 shows the 1976 Edmonton monitoring network and Figure 17, the Calgary network. These networks operated for the next thirty years with equipment upgrades as newer technology became available.

164 Personal communication with John Torneby, February 2015 165 (a) Alberta Environment (1976) Air Monitoring Report City of Edmonton (b) Alberta Environment (1976) Air Monitoring Report City of Calgary

Figure 14. Air monitoring in Edmonton 1973

Figure 15. Air monitoring in Calgary 1973

Figure 16. Edmonton air monitoring 1976

Figure 17. Calgary Air Monitoring 1976

The air intakes were located above street level (3.5-12 m) so that the influence of local sources (such as a passing bus) would be minimized and the site would provide a measurement that would be representative of a larger area in the vicinity. The basic parameters measured continuously were: oxides of nitrogen (NOx), nitric oxide (NO), nitrogen dioxide (NO2), ozone (O3), total hydrocarbons (THC), reactive hydrocarbons (RHC), carbon monoxide (CO), sulphur dioxide (SO2), total suspended particulates (TSP), smoke (COH) and wind (no wind was measured at the downtown stations because of tall buildings that disrupt the airflow). The objectives of the monitoring program were stated as twofold: (1) to provide data for the assessment of existing air quality; and (2) to establish long-term trends in air quality.166 Guidelines for monitoring station set-up were established through the cooperative federal- provincial program.

Smoke and dust were measured by a tape sampler, drawing air through a filter tape for an hour and then measuring light transmittance to yield the coefficient of haze (Figure 18). A similar tape sampler was used for hydrogen sulphide until alternative technology was developed. The early tape samplers used a bellows to pull air through the tape, making a distinctive sound that earned them the nickname “groaning Gertie”.167

Figure 18. Tape sampler used for smoke and dust in coefficient of haze units

The stations measured suspended particulate matter (0.1 to 10 µm diameter) using high-volume samplers giving 24-h values every six days. The hi-vol samples were also analyzed for benzo (alpha) pyrene and lead content. For the settling of large particles (> 10 µm diameter) dustfall cylinders (Figure 19 left) were set out for 30 days. Exposure cylinders for total sulphation rate (reaction with all sulphur compounds in the air) and hydrogen sulphide were housed in a louvered shelter, colloquially called a “birdcage” (Figure 19 right).

166 Air Quality Control Branch (1981) Air Monitoring Report City of Edmonton (City of Calgary), Pollution Control Division, Environmental Protection Service, Alberta Environment. 167 Personal communication with John Torneby, January 2015.

Figure 19. Dustfall station (left) and louvered shelter for the exposure cylinders (right), 1970s

Don Kupina (Figure 20) and Ed Boyko, both long term employees, operated the Edmonton network with one other technologist.

Figure 20. Don Kupina, senior monitoring technologist in Edmonton (1996 photo)

The Air Quality Control Branch maintained an office and staff in Calgary to operate the monitoring network and deal with air quality issues. One engineer, Phil Ullman, and three technologists comprised the staffing. Dave Bensler (Figure 21) was a long-term operator of the Calgary network.

Figure 21. Dave Bensler checking charts in Calgary continuous ambient monitoring station

In support of the monitoring network, a service shop was established in 1973. The first two technical personnel were hired and later that year, Ray Brassard joined as a noise technician. By the end of 1973 the department realized more support was needed on the air pollution side , so his efforts were redirected The technical support group started out in the basement of the Milner Building, but at the end of the year moved to unofficial space borrowed from Public Affairs on 142 Street and 117 Avenue. In the fall of 1975 an Environment shop was officially established on 120 Street and 112 Avenue. In July 1976 Harry Benders joined the group. In 1978, Ray Brassard (Figure 22) became the shop supervisor and hired George Bayard. The shop installed the first data acquisition system from a computer with home-grown software in 1979-89. A commercial data acquisition system (SUMX) was purchased and installed in 1985. It operated until about 2000 when it was replaced by another commercial system from the Environmental Systems Corporation. Around 1992 the shop moved to the McIntyre Building at 49 Avenue and 89 Street. Shop staff conducted audits of air monitoring stations operated by industry and by airshed associations. They also maintained and operated the Department’s iconic mobile air monitoring laboratory.

Figure 22. Ray Brassard at work in the electronics shop (1983 photo)

Fort McMurray also had an urban monitoring station established as part of the Alberta Oil Sands Environmental Research Program.

Precipitation chemistry monitoring as the measure of “acid rain” began in Alberta in 1985 with six stations: Beaverlodge, Whitecourt, Edmonton, Calgary, Red Deer, and Suffield. Environment Canada also established five CANSAP (Canadian Network for Sampling Precipitation) stations in Alberta: Fort McMurray, Edson, Coronation, Rocky Mountain House and Lethbridge. Ultimately Environment Canada‘s monitoring was reduced to a single station at Esther co-located with a provincial soil plot.

By 1994 the ambient air quality monitoring network consisted of 11 continuous monitoring stations (giving hourly averages), 8 intermittent stations (giving daily averages) and over 250 static (monthly and trimonthly averages), 12 integrated (weekly) wet deposition stations and 1 integrated (weekly) dry deposition station (Figure 23). The objectives of the government monitoring program were now fivefold: (1) to provide data for the assessment of existing air quality relative to air quality guidelines; (2) inform the public on the status of air quality; (3) monitor air quality in representative urban environments to document human exposure to air pollution; (4) report long-term trends in air quality;

75 and (5) to undertake monitoring in special problem areas. Industry operated another 165 continuous, 73 intermittent and 1610 static monitoring stations in the vicinity of their operations as required by their licenses.168

Figure 23. Static and precipitation monitoring in Alberta 1994

168 Myrick, RH and RP Angle (1996) Monitoring of Acidifying Substances in Alberta. Proceedings of the Acidifying Emissions Symposium, April 15-17, 1996, Red Deer, Alberta, Clean Air Strategic Alliance, Edmonton

Air Quality Surveys

The Department of Health operated a number of “sour gas” trailers that measured air quality at selected locations in the vicinity of sour gas plants. Before the advent of data loggers and microcomputers, the data were manually punched into Hollerith cards for processing by a mainframe computer. A keypunch machine and instructions were provided to the operators. The punch card accompanying the instructions is shown in Figure 24.

Figure 24. Punch card for sour gas air monitoring data, late 1960s

Alberta Environment continued to operate these units, particularly in the Whitecourt area where Wayne Buck was a long term operator and the Red Deer area where Luke Stang was a long term operator (Figure 25). The sour gas trailers focused on SO2 and H2S and were generally located in response to resident’s complaints or in areas where the maximum ground level concentration was anticipated. In response to the need for more mobile monitoring, in conjunction with the technical support shop, portable generators and continuous H2S and SO2 monitors were placed on the back of the trucks and the operators were then able to locate their units downwind of an emission source. The data was then used very effectively in confronting the source operators and getting them to address emission problems and implement effective controls. This system was effective in areas such as oil and gas fields or battery locations but also in some urban industrial areas.

Surveys were also conducted in different parts of Edmonton and Calgary and in smaller centres. One of portable units is shown in Figure 26 and some of the resulting reports, in Figure 27. Scores of air quality surveys were conducted over the years in response to many different types of concerns. For example, from May 1982 to May 1983, measurements were made near the Moose Mountain Ice Caves in Kananaskis Country to assess the potential risk to tourists from natural leakage of hydrogen sulphide from nearby springs.169

169 Air Quality control Branch (1985) An Assessment of the Ambient Air Quality in the Moose Mountain Area of Kananaskis Country, Alberta Based on a Survey Conducted May 18, 1982 to May 31, 1983. Pollution Control Division, Alberta Environment, May 1985, 13 pp

Figure 25. Wayne Buck (left), Whitecourt Office, circa 1985; Luke Stang (right), Red Deer Office, 1973

Figure 26. Portable air monitoring unit of the 1980s

Figure 27. Examples of air quality survey reports

In order to collect some data on regional background concentrations, some monitoring was done at a farm near Kavanagh, Alberta, just south of Edmonton. In rural air upwind of the city, ozone levels were expected to be quite low. Surprisingly, the levels turned out to be elevated. Short-term air quality surveys conducted by the portable trailers in the regions had also collected ozone data. Putting this data together with data from the three long-term stations operating in the oil sands area under AOSERP revealed that Alberta had elevated background ozone concentrations with monthly means ranging from 16 to 56 ppb depending on topography and season.170 Annual averages exceeded the Canadian maximum desirable and acceptable levels all of the time and the daily averages a very large percentage of the time. Ultimately, Alberta removed the annual and daily air quality objective for ozone. Federal scientists were not convinced of high background ozone until they began collecting ozone data at the remote Fraserdale station in northern Ontario. When the results were published, Finnish scientists revealed similar findings, but had been reluctant to publish their results as they went against established wisdom of the time. A follow-up study contrasted urban and rural ozone concentrations.171

The Acid Deposition Research Program also reported a mean annual value of 43 ppb at the Fortress Mountain Station,172 slightly higher than the 37 ppb reported for the Birch Mountain station in the oil sands. In 1998 the enhancement of photochemical air pollution by forest fires was documented.173 The state of knowledge about ozone in Alberta was summarized by Harby Sandhu in support of the Alberta’s contribution to the development of Canada-Wide Standards and implementation thereof.174 Ozone has continued to be of interest, prompting Shell Canada to host an Ozone Forum in 1999.175 Similar data evaluations were done for particulate matter176 and for volatile organic compounds.177

In recognition of evolving air quality monitoring technology, a TAGA 3000 monitoring unit was brought into Alberta in 1981 and deployed in the area of creosoting industry as well as the oil sands plants. The quadrupole mass spec detector was capable of detecting substances at very low levels, but this raised another issue of how to determine which substance and at what level was significant. In order to assist in the interpretation and carry out some follow-up, Mel Strosher of the University of Calgary was retained. Although not leading to conclusive results, the testing of leading edge technology was important in assessing its value and applicability to Alberta.

In 1981, Alberta Environment purchased from the United States a self-contained, self-powered, completely mobile air monitoring laboratory that could be instrumented in various ways. Mounted in a pre-owned GM Transmode front wheel drive Recreational Vehicle (RV), the unit included a navigation

170 Angle, RP and HS Sandhu (1986) Rural ozone concentrations in Alberta, Canada. Atmospheric Environment 20: 1221-1228 171 Angle, RP and HS Sandhu (1989) Urban and rural ozone concentrations in Alberta, Canada. Atmospheric Environment 23: 215-221 172 Peak, Eric and BD Fong (1990) Ozone concentrations at a remote mountain site and at two regional locations in southwestern Alberta. Atmospheric Environment 24A: 475-480 173 Cheng, L, KM McDonald, RP Angle, and HS Sandhu (1998) Forest fire enhanced photochemical air pollution: a case study. Atmospheric Environment 32:673-681 174 Sandhu, HS (1999) Ground-level ozone in Alberta. Prepared for Science and Technology Branch, Alberta Environmental Protection, 66 pp + appendices 175 Shell Canada (1999) Ozone Experts Forum, June 10-11, 1999. Shell Canada Centre, Calgary 176 (a) Sandhu, HS (1998) Ambient particulate matter in Alberta. Prepared for Science and Technology Branch, Alberta Environmental Protection; (b) Cheng, L, HS Sandhu, RP Angle and RH Myrick (1998) Characteristics of inhalable particulate matter in Alberta Cities. Atmospheric Environment 22: 3855-3844; (c) Cheng, L, HS Sandhu, RP Angle, KM McDonald and RH Myrick (2000) Rural particulate matter in Alberta, Canada. Atmospheric Environment 34:3365-3372 177 Cheng, L, L Fu, RP Angle and HS Sandhu (1997) Seasonal variations of volatile organic compounds in Edmonton, Alberta. Atmospheric Environment 31:239-246

system to record position relative to an origin (this was before the advent of modern Geographical Positioning Systems). The delivery of the Air Quality Measurement Laboratory (AQML) was delayed by Canadian Customs because of import rules around “pre-owned” vehicles. The need for SO2 and H2S monitoring during the 1982 Lodgepole sour gas well blowout prompted the federal government to release the vehicle from impound. The unit is shown in Figure 28. Harry Benders (Figure 29) was one of the first operators of the unit. The AQML was replaced in 1997 by the Mobile Air Monitoring Laboratory (MAML) shown in Figure 30.

Figure 28. The Air Quality Measurement Laboratory (AQML) went into service in 1982

Figure 29. Harry Benders reviewing AQML data (1984 photo)

Figure 30. Mobile Air Monitoring Laboratory (MAML), 1997

Different measurement methods were always examined, some were tested, and a few were adopted. In 1977 the Barringer Correlation Spectrometer (COSPEC) was evaluated for remote sensing of nitrogen dioxide.178 In 1979 a staff member’s research for a Master’s degree found that wind speed and the grade of lead dioxide used in preparing exposure cylinders had a large influence on the amounts of sulphur compounds absorbed.179 In the early 1980s methods for measuring dry deposition were explored.180 The use of absorbents and mass spectrometer gas chromatography was examined in 1982.181 Monitoring for vinyl chloride monomer was developed by 1986 in partnership with the Alberta Environmental Centre, Vegreville.182 A gas chromatograph with a flame photometric detector was evaluated for use in measuring hydrogen sulphide, sulphur dioxide, carbonyl sulphide, carbon disulphide, methylmercaptan and ethylmercaptan.183 In 1981, a portable double mass spectrometer (TAGA 3000) was brought to the province for measuring trace amounts of air contaminants.184 Department staff watched with great interest in 2004 when the Petroleum Technology Alliance Canada (PTAC) brought in from the United Kingdom a Differential Absorption Light Detection and Ranging (DIAL) system for field testing as a measurement tool for sulphur dioxide from test flares and for fugitive

178 Klemm, RF (1977) Final report on nitrogen dioxide studies for Alberta Environment. Prepared by Alberta Research Council for Alberta Environment, June 1977, 13 pp. 179 Singh, Charanjit (1979) Experimental evaluation of variables affecting the lead dioxide method for monitoring of sulfur dioxide. M.Sc. thesis, Dept. of Chemical Engineering, University of Alberta, Fall 1979, 136 pp. 180 (a) Promet Environmental Group and Concord Scientific Corporation (1980) Analysis of techniques for measuring the dry deposition of SO2. Pollution Control Division, Alberta Environment, Oct 1980, 87 pp; (b) Wright, RG, CS Davis (1983) A system for the measurement of sulphur dioxide concentration gradients. Air Quality Control Branch, Alberta Environment, Feb 18, 1983; (c) Chadder, DS, WA Murray, RD Brymer and AH Jamal (1984) Improved measurement system for SO2 dry deposition rates. Pollution Control Division, Alberta Environment, March 1984, 49 pp. 181 Strosher, MT (1982) Trace organic compounds in the atmosphere near industrial developments. Prep for Alberta Environment by Kananaskis Centre for Environmental Research, University of Calgary, Feb 16, 1982, 53 pp. 182 Lau, Yan K, William S Macdonald, and Henry L Bertram (1986) Monitoring of vinyl chloride in ambient air. Presented at CPANS/APCA meeting: Atmospheric Organics: An Emerging Issue”, Edmonton, A June 4, 1986, 17 pp 183 Lau, Yan K (1989) Measurement of sulphur gases in ambient air. Environmental Monitoring and Assessment 13:69-74 184 Sciex (1981) Air Quality Surveys in Alberta Using the TAGA 3000 Mobile Laboratory. Air Quality Control Branch, Alberta Environment, 70 pp

emissions from gas plants.185 City-wide odour surveys were conducted in Edmonton and Calgary in 1973186 and various means of measuring odour were investigated.

Air Quality Reporting

The urban monitoring data were compiled and published regularly in annual monitoring reports (Figure 31). The data and trends were also published by Environment Canada in annual NAPS reports and occasional trend studies.

Figure 31. Examples of urban air monitoring reports

In order to make air monitoring results more meaningful to the average person, Jerry Lack and Al Schulz (Figure 32) developed an index187 using the four measured pollutants most relevant to Calgary and Edmonton. The index took the form of a power law:

1.3 1.2 Alberta Air Quality Index = [Ox) + [NOx] + [CO/2} + {10 COH]

where the concentration of oxidants (as ozone) and oxides of nitrogen were in units of parts per hundred million (pphm) and the concentration of carbon monoxide was in parts per million (ppm). The

185 Chambers, Allan (2003) Well Test Flare Plume Monitoring Phase II: DIAL testing in Alberta. Prepared by the Alberta Research Council for the Canadian Association of Petroleum Producers, December 2003, 79 pp 186 (a) Gramms, Lorne C (1973) A study of the impact of odors on the City of Calgary, January 1973. Prepared for Dept of Environment by Strong, Lamb & Nelson Limited; (b) Stanley Associates Engineering Ltd (1973) Survey and assessment of atmospheric odor in the Edmonton area, February 1973. Prepared for Dept of Environment by Stanley Associates Engineering Ltd Consulting Engineers and Planners 187 Lack, JC and AR Schulz (1973) Alberta’s Experience with the development and distribution of an air quality index. Presented at the Air Pollution Control Association Pacific Northwest International Section Annual Meeting, November 30, 1973, Seattle, WA. 21 pp

exponents were assigned on the basis that each pollutant would contribution an equal amount when concentrations were at the hourly limits (8 pphm, 15 pphm, 30 ppm and 0.9 respectively). An arbitrary scale provided descriptors: 0-25 clean air, 26-50 light air pollution, 51-75 moderate air pollution, 76-100 heavy air pollution, 100+ severe air pollution. The index was released to the media through a telephone taped-message recorded at 08:00 and 13:00, but issued every hour if the value exceeded 25. The media response to the index was very different in Edmonton and Calgary. In Edmonton, there was considerable criticism about spatial representativeness, low, unexciting levels and lack of correlation with visible conditions. In Calgary there was greater acceptance for a variety of possible reasons. A University of Calgary professor reviewed the strengths and weaknesses in 1973 and made several recommendations for improvement.188 By 1974 sulphur dioxide was added to the index and the terms 189 for NOx and CO adjusted somewhat.

Al Schulz, P.Eng., started as an air pollution control engineer in May 1968. During his early years, he introduced the concept of the Air Monitoring Directive, which has been updated numerous times since and has been central to the Ministry’s quality assurance program for data collection and reporting. He directed monitoring efforts during the Lodgepole sour gas well blowout in 1982 and represented the department during the subsequent Energy Resources Conservation Board Inquiry. As Director of Pollution Control Division after the Environmental Law Enforcement Review, Al established the first enforcement policy for the department and also served as a Member of the International Air Quality Advisory Board, International Joint Commission. In June 1993, Al became Assistant Deputy Minister, Environmental Regulatory Service, Alberta Environmental Protection, a position he held until his retirement in 1997.

Figure 32. Al Schulz (1986 photo) made many contributions to air quality management.

In 1980 the Federal-Provincial Committee on Air Pollution has developed a Canadian Index of the Quality of the Air (IQUA)190 based on the three-level National Ambient Air Quality Objectives. The IQUA replaced the Alberta Index and was used with a few modifications for the next thirty years. In 2003 the dust and smoke component was replaced with a fine particulate matter measurement.

After the passage of the Canadian Environmental Protection Act, the federal government lost interest in updating the national ambient air quality objectives. For communicating air quality, they decided to abandon the IQUA, which was based on those air quality objectives, and move instead to an Air Quality Health Index (AQHI) based on statistical correlations between three pollutants (ozone, nitrogen dioxide and fine particulate matter) and hospital admissions. Alberta in 2011 was the last province to adopt the

188 Tollefson, Eric L (1973) A review of the Alberta Combined Air quality index. prepared for Alberta Environment by Dept of Chemical Engineering, University of Calgary, March 31, 1973 189 Lack, JC (1974) The Alberta Air Quality Index. Presented at the Air Pollution Control Association Joint Meeting of the Ontario and Quebec Sections, October 6-7, 1974, Ottawa, Ontario. 9 pp. 190 Federal-Provincial Committee on Air Pollution (1980) Guidelines for a short-term air quality index. Environment Canada

AQHI because modifications were required to account for rapidly changing air quality and to include additional pollutants.

Data Quality Assurance

In order to ensure that appropriate, quality controlled information was collected from industry, the Department of Environment set out monitoring and reporting requirements through air monitoring directives (AMDs) and operated a Quality Assurance Program. The need for a data quality assurance guide became apparent after an unsuccessful prosecution of an oil sands operator for exceeding ambient standards. The quality assurance program comprised:

• inspection and approval of the monitoring site and instrumentation, • regular review of data submitted for irregularities (initially by abatement engineers and later by technologists in the monitoring and reporting group), • random calibration or staff witnessing of calibration of monitoring instruments by the operator, • occasional inspection of the charts from monitors to confirm the results reported, • occasional monitoring with Alberta Environment’s monitoring trailers for comparison, and • sample interchange between labs for exposure measurements.

The first Air Monitoring Directives were issued for the sour gas industry in 1972 and 1973, then consolidated in 1974 (AMD- 74-1). The sour gas AMD was updated in 1976 (AMD -76-1), revised in 1980 (AMD- 80-2) and consolidated with the rest of the petroleum industry in 1981 (AMD- 81-1). AMD-77-1 was issued for the power generating industry, AMD 77-2 for the wood products industry, AMD -78-1 for the oil industry, AMD- 79-1 for the fertilizer Industry, AMD-79-4 for the cement manufacturing Industry and AMD-80-1 for pulp & paper Industry. AMD -79-3 provided a format for source emissions survey report s.191 In 1989 a consolidated Air Monitoring Directive replaced all of these.192 The Directives outlined the required monitoring and reporting procedures, provided instructions for sampler-site selection and documentation, listed required instrument specifications, specified calibration procedures and addressed data presentation. For the natural gas industry some monitoring requirements were outlined in ERCB Information Letters (e.g. IL-OG-72 -20 Environmental Monitoring Program and IL-79-2 Revised Environmental Monitoring Requirements for Plants Processing Sour Gas).193

One of the challenges of the early 1970s was deciding on the method of determining and counting contraventions of ½-h, 1-h and 24-h maximum levels. In principle, the time periods should be moving averages since receptors would respond to any 30 minute, 60 minute or 24 hour Interval. In practice, however, this became quite difficult to track. The 1976 AMD settled the issue in favor of using clock- hours and calendar-days.

191 (a) AMD-74-1 Consolidated Air Monitoring Directive, 34 pp; (b) AMD-76-1, 17 pp + 4 appx; (c) AMD-77-1 Power Generating Industry, 25 pp + 8 appx; (d) AMD-77-2 Wood Products Industry, 7 pp + 3 appx; (e) AMD-79-1 Fertilizer Industry, 36 pp + 7 appx; (f) AMD-79-3 Source Emissions Survey Report Format, 13 pp + 3 appx; (g) AMD-79-4 Cement Manufacturing Industry, 12 pp + 6 appx; AMD-81-1 Oil and Gas Industry, 36 pp + 10 appx 192 Environmental Protections Services (1989) Air Monitoring Directive: Monitoring and Reporting Procedures for Industry. Alberta Environment, June 1989, 349 pp 193 Environment Council of Alberta (1985) Alberta’s Clean Air Act: Conclusions and Recommendations of the Review of the Clean Air Act. Staff report prepared by Mary Gordon and Brian Free. Environment Council of Alberta, March 1985.

The department also had its own quality assurance program, developed by Yan Lau, and general guidance on monitoring network design by Steve Sakiyama.194 The instrument service shop also served as a calibrations laboratory and provided station audits for the government network, for industry compliance monitoring and later for airshed monitoring. Environment Canada provided station audits for its NAPS stations. Plans for Monitoring

The first published air monitoring plan was prepared by the Air Pollution Control Section of the Division of Environmental Health Services, Department of Health in 1970.195 It proposed air monitoring on a limited scale in all communities with a population in excess of 10,000. The numbers of stations are summarized in Table 7. These were to be located in four general parts of the centres – residential, downtown, industrial and high density.

Table 7. The Air Monitoring Plan of 1970

Pollutant Population Population Population Population Population 10,000-25,000 25,000-50,000 50,000- 100,000- >500,000 (Camrose, (Lethbridge, 100,000 500,000 Grande Prairie, Medicine Hat, (Calgary, Sherwood Red Deer) Edmonton) Park, St. Albert) Dust fall 3 4 6 10 15 Total 3 4 6 8 10 sulphation Smoke 1 2 4 8 10 Oxides of 1 2 3 4 nitrogen Ozone 1 2 3 4 Carbon 1 2 3 4 monoxide Sulphur 1 1 dioxide Total 1 1 hydrocarbons

The plan also contained staffing and equipment requirements to deliver the proposed program over the next three years. With the formation of the Department of Environment in 1971, the plans for Edmonton and Calgary were realized and exceeded by 1976. Smaller centres were served by the

194 (a) Lau, Yan K (1988) Quality Assurance (QA) for an ambient air monitoring network. Presented at CPANS/APCA 1099 Annual Meeting, Calgary, Alberta, May 16-176, 1988; (b) Sakiyama, SK (1989) Monitoring Network Design. Standards and Approvals Division, 11 pp; (c) Sakiyama, SK (1988) Monitoring network Design for the Syncrude/Suncor Oil Sands Plants-Preliminary Considerations, 28 pp 195 Air Pollution Control Section (1970) Air Pollution in Alberta. Environmental Health Services Division, Department of Health, 14 May 1970

portable air monitoring trailers until the 1990s when many of them did get continuous monitoring stations often as part of an airshed monitoring plan.

The East Edmonton refinery row area was an early concentration of industry, and a number of companies held licences requiring ambient air monitoring. To avoid duplication, Alberta Environment in 1982 allowed the Strathcona Industrial Association to monitor on behalf of its 11 members with a six station network. This first “zone monitoring system” is still operational and is now associated with the Capital Region Airshed. With the Department’s encouragement, similar networks were established in the Ft. McMurray area between Suncor and Syncrude. Since these networks were operated with increasing independence, they started to enhance data credibility.

The 1991 Clean Air Strategy for Alberta identified local air quality issues and problems as a priority and hence a goal to “develop and implement a zone approach to managing air quality within specific airsheds.” Moving toward implementation of this recommendation a Working Group explored the establishment, function, operation and common needs of Zone Air Quality Management Systems. After the Clean Air Strategic Alliance (CASA) was formed in 1994, one of their first tasks was the production of zone management guidelines to help stakeholders who wanted to set up a zone in their area. This document provided the foundation for the subsequent formation of airsheds in Alberta.196 By 2010 there were nine airsheds operating in Alberta, eight collecting monitoring data, and one planning for air quality management in the Capital Region.197

The West Central Airshed, the first of the nine Alberta airsheds, was formed in parallel with the development of the CASA guidelines and there was considerable interplay between the two groups. Amoco Canada was a key industry advocate of the zonal approach in the belief that a network operated by an airshed association would be less expensive and would assume responsibility for quality assurance/quality control which had posed some problems for them in the past.

Shortly after the Clean Air Strategic Alliance was formally established, the importance of having credible, reliable information on ambient air quality and its relationship with human and ecosystem health was recognized. A strategic plan for air quality monitoring in Alberta was developed in 1995. By this time industry ambient air monitoring was required at 256 plants in Alberta, comprising 158 continuous, 1507 static, and 72 intermittent monitoring sites. Provincial government air monitoring activities198 included 11 continuous (hourly) stations, 8 intermittent (daily) sites, 12 wet deposition (weekly) sites, one dry deposition (weekly) site, one mobile monitoring unit, and over 250 static (monthly and trimonthly) sites.

The federal government monitored wet and dry deposition and visibility at one site. The strategic plan called for approximately 35 sites to gather the ambient air quality data related to human health effects and three sites to gather data on transboundary transport, flux and visibility. Two mobile monitoring

196 (a) Advisory Group (1991) Clean Air Strategy for Alberta Report to Ministers. Clean Air Strategic Alliance, Edmonton; (b) Working Group (1993) Zone Air Quality Management: Report of Working Group G-1, Clean Air Strategy for Alberta. Clean Air Strategic Alliance, Edmonton; (c)CASA (1995) Air Quality Management Guidelines. Clean Air Strategic Alliance, Edmonton; (d) CASA (2004) Airshed Zones Guidelines. Clean Air Strategic Alliance, Edmonton 197 Angle, RP (2013) Alberta Airshed Planning. In: Chapter 17, Taylor E, McMillan A (eds) Air Quality Management: Canadian Perspectives on a Global Issue. Springer, Dordrecht, 340-342; (b) Angle, RP (2010) Mechanisms for the Alignment of Air Quality Planning, Alberta Environment, July 2010, 64pp 198 Myrick, RH and RP Angle (1996) Monitoring of acidifying substances in Alberta. Proceedings of the Acidifying Emissions Symposium, April 15-17, Red Deer, Alberta, Clean Air Strategic Alliance, Edmonton

units were recommended for use around the province. Ecological effects monitoring was proposed for all six ecoregions of Alberta, with a minimum of two sites in each ecoregion.

An implementation design for a cooperative network was completed in 1997 and in May 1998 an Operations Steering Committee was established to provide overall direction, track progress and make budgetary decisions regarding the network. The Alberta ambient air quality monitoring system had stations operated by Alberta Environment, Environment Canada, the Strathcona Industrial Association, and ultimately eight Airshed Associations. Data were collected and archived in a centralized data management system, the CASA Data Warehouse, which is accessible to stakeholders and the general public.199 Implementation was hampered by reorganization and direction shifts within Alberta Environment.

John Torneby (Figure 33) was the long term supervisor of technical operations for the province and played a key role in supporting the development of the strategic plan and taking the first steps toward implementation.

John Torneby joined the Sanitary Engineering Division in 1965 as a sour gas trailer operator. He moved to Calgary in 1969 to oversee the setup and operation of air monitoring equipment, often at health unit offices. In 1974 he returned to Edmonton as the technical supervisor for provincial air monitoring operations, and in the winter of 1974 coordinated elements of the joint air pollution field study in Edmonton. John was instrumental in the department’s acquisition of the mobile Air Quality Measurement Laboratory in 1981 and its replacement in 1997. After the formation of the Clean Air Strategic Alliance (CASA) and until his retirement in 1998, John was active in establishing a number of airsheds in the province and in the development and initial implementation of the first multi- stakeholder provincial air monitoring strategy.

Figure 33. John Torneby, supervisor of provincial air monitoring activities (1996 photo)

By the late 2000s the extent, pace and expectations of ambient air monitoring in Alberta had changed significantly:

• Increased levels of industrial activity along with increased population; • More rapid than expected formation of airshed zones, with an associated increase in ambient monitoring by the zones; • Implementation of several CASA frameworks that have created a need for specific types of monitoring and data (Particulate Matter and Ozone Management Framework, Acid Deposition Management Framework, Emissions Management Framework for the Electricity Sector); • Improved technologies for monitoring and for collecting and managing data; and • New air monitoring guidelines.

199 (a) Ambient Air Quality Monitoring Project Team and Ecological Effects Monitoring Working Group (1995) A Strategic Plan for Air Quality Monitoring in Alberta . Clean Air Strategic Alliance, November 24, 1995, 29 pp; (b) Alberta Ambient Monitoring Implementation Design Team (1997) Report to the CASA Board, December 4, 1997, Clean Air Strategic Alliance

A new CASA project team was formed update the strategic plan, and in 2009 the team delivered a new plan containing:

(1) A Framework for air monitoring with a long-term vision, principles, goals and objectives; (2) Responsibilities for various agencies and organizations in maintaining the monitoring network as well as performance measurement ; (3) A Network Design with seven monitoring sub-programs: a) Population-based, b) Ecosystem-based , c) Ozone Monitoring, d) Boundary Transport, e) Background, f) Pattern Recognition, and g) Industry Compliance; (4) A Funding System with funding principles, a funding formula and an example of how to calculate the funding contribution based on emissions; (5) A Data and Information Management System focusing on developing strategies to actively and reliably provide information to Albertans; and (6) An Implementation Plan that recommends the order and priority for implementation.200

Summary of Ambient Air Quality Monitoring

Alberta started its urban air quality monitoring program in the 1960s and by 1965 there were measurements of particulates, oxidants, oxides of nitrogen and coefficient of haze. The number of stations and parameters continued to grow and by 1973 the urban networks consisted of a number of hi-vol samplers for suspended particulate matter, exposure stations for total sulphation and dustfall, smoke monitors and continuous monitors for oxides of nitrogen, ozone and hydrocarbons in Edmonton and Calgary. The National Air Pollution Surveillance (NAPS) Network was established in 1969 as a joint project of the federal and provincial governments, with the federal government providing equipment for the stations and the provinces operating the stations and submitting the data. Alberta established six continuous monitoring stations, three each in Edmonton and Calgary, to represent residential, industrial and downtown areas. These were supplemented with networks of exposure cylinders for sulphur dioxide, hydrogen sulphide and dust fall. By 1976 the monitoring networks had settled into the basic configuration they would keep for the next thirty years. Equipment was upgraded as newer technology became available.

The Department of Health operated a number of “sour gas” trailers that measured SO2 and H2S concentrations in the vicinity of sour gas plants often in response to resident’s complaints. For greater mobility portable generators and continuous monitors were placed on the back of the trucks. In 1981, Alberta Environment purchased from the United States a self-contained, self-powered, completely mobile air quality monitoring laboratory (AQML) that could be instrumented in various ways. Mounted in a GM Transmode front wheel drive recreational vehicle, the unit included a navigation system to record position relative to an origin. In 1997 the vehicle was replaced. More comprehensively equipped

200 AMSP Project Team (2009) 2009 Ambient Air Monitoring Strategy for Alberta : Report to the CASA Board , September 2009, Clean Air Strategic Alliance

trailers were used to monitor air quality in smaller centres and to undertake various types of investigations.

The urban monitoring data were compiled and published regularly in annual monitoring reports, while survey data were published some months after a survey was completed. To make the complex urban air quality data more understandable to the general public, in the early 1970s an air quality index was developed to combine (using a power law) the four major city pollutants into a single number with an associated descriptor. In 1980 this was replaced with the federal-provincial Index of the Quality of the Air (IQUA) which, with slight modifications, was used for the next thirty years.

Data quality assurance for industry self-monitoring was addressed through quasi-regulatory Air Monitoring Directives. The first air monitoring directive was issued for the sour gas industry in 1972, and a number of revisions followed. Air monitoring directives were also issued for the power generating industry, the wood industry, the oil industry, the fertilizer industry, the cement manufacturing industry and the pulp & paper industry. These were consolidated into one document in 1989. The department’s instrument service shop assumed a role in calibrations and station audits and an internal data quality assurance program was put in place.

The first published air monitoring plan was prepared by the Air Pollution Control Section of the Division of Environmental Health Services, Department of Health in 1970. The Strathcona Industrial Associations established the first zone monitoring system in 1982. The 1991 Clean Air Strategy for Alberta led to the adoption of a zone monitoring approach culminating in eight monitoring airsheds throughout the province. In 1995, recognizing the importance of having reliable ambient air quality information, CASA developed a strategic plan for air quality monitoring in Alberta, followed by an implementation plan in 1997. Owing to changed circumstances, a new strategic plan for air monitoring was produced in 2009.

Ambient Air Quality Objectives

An ambient air quality objective (AQO) is a numerical level of concentration or deposition that provides protection for human health and the environment. They are used for permitting, planning and communication.

While it is not clear when the first ambient air quality objectives may have been proposed, the 1969 Air Pollution Control at Gas Processing and Sulfur Recovery Plants specified acceptable pollutant concentrations at ground-level for sulphur dioxide, hydrogen sulphide and sulphur trioxide. In 1973 an amended Clean Air (Maximum Levels) Regulation set out maximum permissible concentrations for seven air contaminants; sulphur dioxide, hydrogen sulphide, carbon monoxide, oxides of nitrogen, total oxidants , suspended particulates and dustfall. Most of the Alberta numbers were drawn from the federal National Ambient Air Quality Objectives maximum desirable level.

In 1969 the federal Department of National Health and Welfare had formed an ad hoc Federal-Provincial Committee on Air Pollution. A subcommittee of senior officials was struck in 1970 to develop national ambient air quality objectives. The committee was formalized under the Canadian Clean Air Act of 1971. The committee articulated a three-level framework for ambient air quality objectives: 1. The maximum desirable level is the long-term goal for air quality and provides a basis for an anti-degradation policy for unpolluted parts of the country and for the continuing development of pollution control technology. It provides guidance for land-use planners and technology developers. At lower levels, there is in essence “no effect” on any receptor. Persuasion and financial incentives would be the principal methods used to attain this objective. 2. The maximum acceptable level is intended to provide adequate protection against effects on soil, water, vegetation, materials, animals, visibility, and personal comfort and well-being. It represents the realistic objective today for all parts of Canada. When this level is exceeded, control action by a regulatory agency is indicated. 3. The maximum tolerable level denotes time-based concentrations of air contaminants beyond which, owing to a diminishing margin of safety, appropriate action is required without delay to protect the health of the general population.201

The method for developing air quality objectives proceeded in three steps: (1) scientific review: the relevant published literature was identified and then panels of experts systematically and critically reviewed the information to compile a report on what was known about the adverse effects of pollutants at various concentrations . The resulting documents were known as air quality criteria, or guides; (2) Air Quality Objective selection: from the scientific knowledge summary, senior government officials developed the levels that would become the basis for air management; (3) implementation: regulators detailed the administrative steps necessary to achieve and maintain the Objectives. Many of the later criteria documents were compiled by the National Research Council’s Associate Committee on Scientific Criteria for Environmental Quality.

In 1988, the Canadian Environmental Protection Act (CEPA) subsumed the Clean Air Act into broader legislation aimed at the overall management of toxic substances. Risk assessments were internalized

201 (a) Federal-Provincial Advisory Committee on Air Pollution (1976) Criteria for National Air Quality Objectives: Sulphur Dioxide, Suspended Particulates, Carbon monoxide, Oxidants (Ozone) and Nitrogen Dioxide. Fisheries and Environment Canada, Ottawa; (b) Working Group on Air Quality Objectives and Guidelines (1994) National Ambient Air Quality Objectives for Carbon Monoxide: Desirable, Acceptable & Tolerable Levels. Environment Canada and Health Canada, Toronto and Ottawa

within Environment Canada and Health Canada. In 1992 the CEPA National Advisory Committee formed a new federal-provincial working group on air quality objectives and guidelines. The CEPA working group, operating with limited resources, first reviewed the AQO for carbon monoxide, proposed a somewhat different two-level framework, recommended a reference level for hydrogen fluoride and completed risk assessments for ozone and particulate matter. These were used by the Canadian Council of Ministers of Environment in the development of the Canada-Wide Standards. The Working Group was terminated in 2000.202

Alberta adopted the “desirable” level for particulates, carbon monoxide, oxides of nitrogen (annual average) and sulphur dioxide. Alberta adopted the “acceptable” level for oxides of nitrogen (1-h and 24- h) and oxidants as ozone. The intent was never to set provincial ambient objectives less stringent than the federal objectives.203 For many years Serge Dobko was chairman of the Federal-Provincial Subcommittee on Air Quality Objectives. After the restructuring under CEPA, little progress was made in expanding the number of objectives or updating the original objectives.

After the passage of the Alberta Environmental Protection and Enhancement Act in 1992, bearing in mind the recommendations of the environmental law enforcement review of 1988, ambient objectives (maximum permissible concentrations) were removed when the Clean Air (Maximum Levels) Regulation was rolled into the Substance Release Regulation. Instead they were published in a 1994 pamphlet as interim air quality guidelines until a formal procedure could be worked out for updating and expanding them. That same year a Standards and Guidelines Branch was formed to develop ambient environmental objectives for all media. An environmental chemist, Long Fu, and an environmental biologist, Kenneth Foster, were recruited to conduct the scientific work in support of ambient air quality guidelines, as they were now being called in deference to the Environmental Law Enforcement review.

In 1997, the first formal set of ambient air quality guidelines were published under the Environmental Protection and Enhancement Act.204 They included numbers from three sources: (1) maximum permissible concentrations from the Clean Air (Maximum Levels) Regulation, (2) ambient objectives stated in source standards documents, and (3) indicator values for total sulphation and hydrogen sulphide exposure used in Air Monitoring Directives.

Growth in the petrochemical industry resulted in large ethylene production plants being built in rural areas. Farmers in the vicinity of these petrochemical plants were concerned that ethylene releases might have adverse effects on crops. In the absence of an Alberta ambient air quality objective, Ontario’s objectives had been used for reviewing applications and issuing approvals. After a comprehensive literature review, Alberta issued an interim guideline in 1997, to be finalized after a joint industry-government research project had been completed. The final guideline was adopted in 2000.205

202 Angle R (2014) Ambient Air Quality Objectives. Chapter 14 In: Taylor E, McMillan A (eds) Air Quality Management: Canadian Perspectives on a Global Issue. Springer, Dordrecht, 289-301 203 Lack (2006) personal communication with Jennifer Martin 204 Environmental Assessment Division (1997) Alberta Ambient Air Quality guidelines. Fact Sheet. Environmental Protection and Enhancement Act. Alberta Environmental Protection, January 1997. 3 pp 205 (a) Foster, Kenneth R (1998) Ambient air quality guideline development in Alberta. In: Emerging Air Issues for the 21st Century: The Need for Multidisciplinary Management: Proceedings of an International Specialty Conference Jointly Sponsored by the Air & Waste Management Association, the Association of Professional Engineers, Geologists and Geophysicists of Alberta, and the Alberta Society of Professional Biologists, Allan H. Legge &, Linda L. Jones (eds) September 22-24, 1997, Calgary, Alberta; (b) Standards and Guidelines Branch (1997) Ethylene (Interim Guidelines). Alberta Environmental Protection pub. no. T/379, Edmonton, 1997, 71 pp. (c) Environmental Sciences Division (2000) Program Policy No. ES-99-PP5, Alberta Environment

As part of an acid deposition management strategy led by Jerry Lack, Alberta Environment examined the feasibility of implementing a critical loading for acidic deposition.206 In 1995 as part of a Clean Air Strategic Alliance review of Alberta’s sulphur dioxide management program, a CASA project team was struck to confirm the approach and recommend critical load values. The recommended framework and values were adopted by a formal Alberta Environment policy in 1999.207

The Canadian Council of Ministers of the Environment under the Canada-wide Accord on Environmental Harmonization undertook an extensive standards development process with broad stakeholder participation and numerous studies. George Murphy and Long Fu devoted many hours to the process on behalf of Alberta Environment. In June 2000 the Canada Wide Standards for Particulate Matter (PM) and Ozone were published. These new national ambient air quality objectives committed governments to reduce PM and ground-level ozone through jurisdiction-specific air quality management plans. Alberta Environment asked the Clean Air Strategic Alliance to assemble a multi-stakeholder team to design an implementation plan for Alberta.208 The PM and Ozone Management Framework set out four action levels that represented a continuum of analysis and management activities based on measured ambient concentrations in the province: (a) Baseline monitoring and data gathering; (b) Surveillance; (c) Management plans; and (d) Mandatory plans to reduce below the CWS. This tiered structure was reminiscent of the Acid Deposition Management Framework.

At the department’s request, the same CASA Project Team also recommended a general process for AQO development in Alberta as shown in Figure 34. In October 2000 the department worked with CASA to hold the first priority setting workshop. A three year work plan for the creation and adoption of new ambient guidelines and the review of some existing guidelines followed in 2001.209 The second workshop was held in 2004, also coordinated by CASA with an organizing committee to oversee the process210 and a second three-year plan was published.211 The third workshop was held in 2009.212

As work progressed, it became clear that there was a distinction between guidelines and objectives, the latter having a stronger role in the management system than the former. To be consistent with the terminology in EPEA, the environmental science-derived numbers were to be called “air quality objectives” while numbers developed as empirical indicators would be called “guidelines.” Both are used for reporting. Objectives are used to determine adequacy of industrial facility design, to establish

206 (a) Task Group on Acid Deposition (1988) Review and Assessment of Acid Deposition Management Strategy for Alberta. Alberta Environment, October 1988, 13 pp + appendices; (b) Alberta Environment (1990) A review of approaches for setting acidic deposition limits in Alberta. 64 pp 207 (a) Cheng, Lawrence, Karen McDonald, Dave Fox and Randy Angle (1997) Total Potential Acid Input in Alberta. Prepared for the Target Loading Subgroup, SO2 Management Project Team, Clean Air Strategic Alliance, May 1997, 24pp; (b) Target Loading Subgroup (1999) Application of Critical, Target and Monitoring Loads for the Evaluation and Management of Acid Deposition, Clean Air Strategic Alliance and Alberta Environment, November 1999, 67 pp. (c) Environmental Sciences Division (1999) Program Policy No. ES-99-PP4. Alberta Environment. 208 Particulate Matter and Ozone Project Team (2003) Particulate Matter and Ozone Management Framework. Clean Air Strategic Alliance, September 2003. 54 pp + appendices 209 Air and Water Branch (2001) Alberta Ambient Air Quality Guidelines Work Plan. Science and Standards Division, Alberta Environment, April 2001, 20 pp 210 Priority Setting Workshop Organizing Committee (2005) Priority Setting Workshop Final Report of the Organizing Committee. Clean Air Strategic Alliance, March 2005, 19 pp + Priority Setting Workshop 2004 Proceedings. 11 pp 211 Environmental Policy Branch (2005) Alberta Ambient Air Quality Objectives Work Plan 2005-2008. Alberta Environment, February 15, 2005. 9 pp. 212 Priority Setting Workshop Organizing Committee (2010) Priority Setting Workshop Final Report of the Organizing Committee. Clean Air Strategic Alliance, March 2010. 12 pp

stack heights and release conditions, and to assess compliance and facility performance. Guidelines are used for airshed planning and management, general performance and assessing local concerns.213 Additional guidance on the use of the numbers was first published in 2009.214 By 2010 Alberta had developed objectives for 46 substances.

Figure 34. The stakeholder-recommended process for AQO development

213 Air Policy Branch (2010) Alberta Ambient Air Quality Objectives and Guidelines Fact Sheet. Alberta Environment. December 2010, 5 pp 214 Air Policy Section (2009) Using Ambient Air Quality Objectives in Industrial Dispersion Modeling and individual Industrial Site Monitoring. Alberta Environment. March 2009, 10 pp

While this new process worked quite well and was reasonably fast in comparison to many objective- setting processes used elsewhere, there were staff concerns that it might not meet all of the department’s need. If a new industry entered the province or an existing industry began emitting different substances, preparing the conditions of an Approval would require at least an interim ambient air quality objective. Consequently, a quick method for producing such numbers was established in 2005.215

Summary of Ambient Air Quality Objectives

The Department of Health published the first ambient objectives for sulphur compounds in 1969. Alberta based subsequent ambient objectives on the work of the federal-provincial committee on air pollution, generally adopting the maximum desirable level, the most stringent of the three-tier National Ambient Air Quality Objectives. After the federal Clean Air Act was subsumed into the Canadian Environmental Protection Act in 1988, little progress was made in developing national objectives for additional substances.

Alberta’s ambient air quality objectives were removed from regulations in 1992 when the Substance Release Regulation under the Environmental Protection and Enhancement Act replaced the Clean Air (Maximum Levels) Regulation under the old Clean Air Act. In 1997 a set of ambient air quality guidelines were published restating the numbers in the old regulation and adding numbers that had appeared in source standards documents and air monitoring directives. Concerns about ethylene releases from large petrochemical plants in central Alberta led to a government-industry research program on potential crop effects culminating in a guideline for ethylene in 2000. Concerns about acidic deposition were addressed by a project team of the Clean Air Strategic Alliance with a recommendation for a target loading adopted by the department in 1999.

In 2000 Alberta Environment initiated a process for the development and review of ambient air quality objectives as recommended by the Clean Air Strategic Alliance with participation by industry, government and public interest groups. Substances for which objectives may be required were prioritized at a multi-stakeholder workshop held every 3-5 years. Then three-year work plans were developed and implemented. A distinction has been made between objectives and guidelines and guidance provided on the use of these numbers in air quality management. By 2010 the department had enlarged its set of air quality objectives to encompass 46 substances. A fast track protocol was also developed should interim objectives be needed for industrial permitting.

215 Cheng, Lawrence (2005) Fast track ambient air quality objectives setting protocol. Science and Standards Branch, Alberta Environment. April 20, 2005. 3 pp

Dispersion Modelling

An atmospheric dispersion model (also known as an air quality simulation model) is a numerical technique or methodology based upon physical principles for estimating pollutant concentrations in space and time as a function of the emission distribution and the attendant meteorological and geophysical conditions. Dispersion modelling is the application of mathematical methods to provide a cause-effect link between the sources of air pollution and measured ambient air quality. Such models have a variety of uses in air quality management, some of which are: trend analysis, temporal and spatial patterns, contributions of different sources, worst case estimation, locating “hot spots”, monitoring network design, control planning, emission release requirements, stack height calculations, and determination of compliance with ambient objectives.

Point Source Modelling

Plume dispersion modelling to calculate ground-level concentrations from stacks, began in Alberta in 1964 with application of the Sutton equation with the Lowry modification to determine the maximum ½-h downwind ground-level concentration. Plume rise was calculated by the Bosanqet-Carey-Halton formula.216 In December 1964 Eugene Kupchanko produced a FORTRAN Program known as SH505 for the calculation of maximum ground level concentrations from elevated sources for the cases of strong inversion and neutral atmosphere (adiabatic lapse rate). In June 1965 a program for calculating maximum ground-level concentrations from flares using Sutton-Lowry was made available as SH508.

In August 1965 a FORTRAN program for stack calculations at any distance using the Pasquill method became available as SH510. In April 1968 a program by Phil Ullman used the Pasquill method for the calculating downwind concentrations from a flare, SH507. The computer code was included in the 1969 document Air Pollution Control at Gas Processing and Sulfur Recovery Plants.

After the Department of Environment was formed the two Air Quality Branches jointly hired the department’s first air scientist in 1973, a dispersion meteorologist named Randy Angle (Figure 35). Stenson217 noted that this may have come as a response to a private sector initiative the previous year when a large environmental consulting company had hired western Canada’s first diffusion meteorologist, Dr. Douglas Leahey.

216 Gosline, CA, LL Falk and EN Helmers (1956) Evaluation of Weather Effects. Chapter 6 in Air Pollution Handbook edited by Paul L Magill, Francis R Holden, and Charles Ackley. McGraw-Hill Book Company 217 Stenson, F (2000) The Last Stack: Entrepreneurism and the Environment. CETAC-WEST, Calgary, Alberta

Randy Angle joined Alberta Environment in 1973 as a dispersion meteorologist responsible for air quality modelling, meteorological measurements and related atmospheric science activities. In 1994 he became the Head of the Air Issues and Monitoring Branch and thereafter held various management positions, retiring in 2009 as Leader of the Air Policy Unit. He drafted the first modelling guideline, co-authored a book on plume dispersion, published 14 papers in peer-reviewed journals, authored more than 52 other publications, and gave dozens of presentations air quality management. He initiated Alberta’s ambient air quality objective setting process, oversaw the development of numerous internal and external policies, assisted in the formation of the Clean Air Strategic Alliance, and participated in numerous CASA projects. He also served on a number of federal-provincial committees and as a provincial representative on two international committees.

Figure 35. Randy Angle, Alberta Environment’s first dispersion meteorologist (1999 photo)

The use of the Sutton-Lowry programs was discontinued and the Department continued to distribute the two Pasquill programs on punch cards (Hollerith cards). A minor coding error was detected and corrected in 1973. In 1978 updated models for calculating maximum ground-level concentrations from stacks and flares were introduced, called respectively STACKS and FLARES. These models used a pragmatic “Alberta standard site” assuming plume trapping by an elevated inversion at the worst possible height, immediate plume rise using the Briggs formula, plume spreads for rough terrain from Smith and Pasquill, winds speeds ranging between 1 and 20 m/s, and terrain influence on both plume height and vertical spread. The user could input emission parameters for up to 20 stacks and specify up to 50 distances with terrain elevations along a straight line. If the stacks were not tall enough to reduce ground-level concentrations below the ambient objective, the program calculated the required height. The FLARE program computed plume rise from the low heat values of flare fuel gases and hydrogen sulphide.

In addition a general plume model called PLUMES was introduced to calculate concentrations for any specified stability, roughness type, mixing type, temperature gradient, mixing height, averaging time, wind speed, wind direction and chosen height above ground for up to 50 stacks and specified ranges of downwind and crosswind distances. The FORTRAN IV codes and description of the theory appeared in the first modelling guideline, the cover of which is shown in Figure 36.218

218 Standards and Approvals Division (1978) Guidelines for Plume Dispersion Calculations. Alberta Environment, Environmental Protection Services. August 1978

Figure 36. Cover of First Modelling Guideline

The effects of elevated terrain were a topic of much debate in the early years of modelling plume dispersion. Proposals included: deduct the terrain height from the plume height, ignore the terrain but increase the vertical spread, deduct half the terrain height, reduce the plume height by a factor of 2. The models introduced in the guideline represented terrain as semi-circular cylinders and applied potential flow theory to calculate the height of the plume streamline above the hill. Enhanced plume spread was estimated as equal to the streamtube contraction.

Standards & Approvals Division conducted an external review of the modelling program in 1984219 and received 18 recommendations concerned with model packages, user friendliness, parameter consistency, flexible screening models, user warnings, operational improvements, post processing of outputs, use of onsite meteorological data and adopting MESOPLUME for downwind distances beyond 100 km. This provided direction for subsequent dispersion modelling activities for the next decade. The

219 Davies, M (1984) Air quality model review. Submitted to Standards and Approvals Division, Alberta Environment. September 1984, 60 pp

modelling of stack aerodynamic downwash was investigated220 as were means of modelling odours caused by short-term concentration fluctuations.221

For some time there was concern about the oxides of nitrogen from compressor stations. The low stacks in comparison to building heights meant plume downwash and coupled with an assumption of full conversion to nitrogen dioxide led to high concentrations and concern because of potential effects. 222 In 1977 Alberta Environment undertook a short field study which showed that the ratio of NO2/NOx rose quickly from the in-stack value of 0.03 to a value after one minute of travel of 0.2, about half the predicted value from a chemical model without diffusion. The chemical model predicted the maximum conversion would occur after about 4 minutes, so Alberta Environment adopted a working assumption that 40% of the emitted NOx would be in the form of NO2 at the point of maximum ground-level concentration. Avoiding downwash by making stacks at least 2.5 times the peak building height and assuming 40% conversion was embodied in a draft ERCB Informational Letter. Industry members of the Alberta Petroleum Industry Government Environmental Committee (APIGEC) were concerned about loss of efficiency with higher stacks, cost of modifications, inability to use heat economizers, and technical problems with manifolding for maximum plume rise.

A research effort was mounted under APIGEC’s Steering Committee on Acid Gases in the Environment (SCAGE). Under ERCB IL-80-30 compressors not in compliance were given the option of collecting monitoring data near the facility to determine whether retrofit was really required. By 1984 there were 134 station months of data at 11 stations. Neither of two models identified in the literature were able to predict the maximum concentration reliability although the ratios were predicted correctly. To resolve the problem, Alberta Environment proposed to apply an empirical conversion ratio (from the monitoring data) to a plume model with an EPA advanced method for handling diffusion around obstacles. Steve Sakiyama produced the model SEEC (Search for Extreme Ensemble Concentrations) which looped through all possible meteorological conditions to find the maximum concentration.223

The advent of the personal computer was a major factor in moving toward more user-oriented models. In 1988 five models for personal computers (STACKS2, PLUMES2, SEEC, SULDEP3, ADEPT) , developed by Steve Sakiyama and a part-time graduate student from the University of Alberta , were released with complete documentation contained in a binder shown in Figure 37.224 PLUMES2 determined short- term, downwind concentrations under a variety of user-specified meteorological conditions from single or multiple point source emissions. STACKS2 determined short-term, overall maximum ground level concentration under adverse conditions for hilly and flat terrain. SULDEP3 was used for estimating long term (seasonal) average concentrations and depositions of sulphur within 100 km from a point source. ADEPT (Alberta Deposition model with Terrain) was a version of SULDEP with multiple point sources in

220 Davies, MJE, DD. Krismanson and RD Rowe (1985) A field investigation of stack aerodynamic downwash. prep for Standards &Approvals Division by Monenco Consultants Limited and University of Calgary, 16 August 1985 221 Sakiyama, SK and RP Angle (1985). Calculating the impacts of fugitive hydrogen sulphide emissions. Proceeding, Fifth annual Technical Meeting, Canadian Prairie and Northern Section, air pollution control association, Theme: Fugitive and Uncontrolled Emissions, Marlborough Inn, Calgary, June 5, 1985 222 Angle, RP, HS Sandhu, and WJ Schnitzler (1979) Observed and predicted values of NO2/NOx in the exhaust plume from a compressor installation. APCA Journal 29: 253-255 223 (a) Angle RP, CS Liu and K Godard (1987) Regulating oxides of nitrogen from compressor stations. Presented at CPANS/APCA Technical Meeting: New Directions in Air Quality Standards. February 10, 1987, Calgary; (b) Sakiyama SK, P Freeman and RP Angle (1988) A dispersion model for use in the design of compressor station stacks. CPANS Technical Meeting: Fingerprinting. Air Pollution Control Association, Canadian Prairie and Northern Section, May 16-17, 1988, Calgary 224 Alberta Environment, Environmental Protection Services (1988) User’s manual for Alberta environment dispersion models. Standards and Approvals Division, Air Quality Branch

complex terrain. The SEEC (Search for Extreme Ensemble Concentration) model determined the highest concentrations that could occur from a wide range of possible meteorological conditions and source/building orientations.

Figure 37. User’s Manual for Alberta Environment Dispersion Models

A second modelling guideline was drafted in 1987 and published in 1989.225 This guideline provided an overview of model types, model limitations, and factors in choosing models, for various applications. It also gave guidance on using models for stack design, air quality impact assessment and monitoring program design. Input data requirements and expected model performance were described. In an effort to control costs and improve service, model distribution and support was identified by the government as a candidate for privatization. Around 1990 a private contractor took over production and distribution of the floppy discs and manuals, charging users a fee for the service.

Modelling was a rapidly developing field requiring increasing manpower and budgets. It was decided to terminate model development in favor of simply applying the models of the U.S. Environmental Protection Agency under a set of standardized procedures for Alberta. A new modelling guideline,

225 (a) Environmental Protection Services (1987) Guidelines for Atmospheric Dispersion Modelling in Alberta, November 1987, 70 pp; (b) Standards and Approvals Division (1989) Guidelines for Atmospheric Dispersion Modelling in Alberta, February, 1989, 87 pp.

drafted in 1994 and formalized in 1996, suggested which EPA models were appropriate and how they were to be used.226

In January 1998, a month after the release of the latest draft of the Air Quality Model Guidelines,227 a one-day workshop was held at which stakeholders were invited to provide feedback on the guidelines. The outcome of this workshop was a task group to determine whether or not to adopt the United States Environmental Protection Agency’s (EPAs) model, ISC3, and whether or not to modify it to incorporate the 0.55 correction factor that was part of the current model SEEC.228 This correction factor arises when the 3-minute Pasquill plume spreads are used to calculated 60-minute averages. A comparison between the ISC3 and 0.55 ISC3 models was conducted to determine which model should be incorporated into the modelling guideline. The results of the study showed the unadjusted ISC3 model was the favorable model.229 Ahmed Idriss prepared model guidelines issued in 1999, 2000, and 2003.230 In 2003, guidance was provided for emergency/process upset flaring management.231 As models grew more sophisticated, they required more input data. For data sparse regions of the province, the Fifth Generation NCAR/Penn State Mesoscale Model version 3.5 (MM5) was used to generate meteorological files for Alberta locations, the use of which is addressed in the 2009 model guideline.232

Area Source Modelling

Alberta Environment also commissioned the development of an urban air pollution model for the cities of Edmonton and Calgary to help manage air pollution which had become quite visible (Figure 38). Water vapor was also of concern because low temperature fog formation caused problems for traffic movement during winter months. Verification of the models occurred in two stages: first using existing air quality data from the three monitoring stations in each city, and second, using a short-term data set collected during a field study.

226 (a) Alberta Environmental Protection (1994) draft Air Quality Model Guidelines, December 1994; (b) Air Emissions Branch (1996) Air Quality Model Guidelines. Air and Water Approvals Division, Environmental Regulatory Services, September 1996. 227 Air Emissions Branch (1997) Air Quality Model Guidelines. Air and Water Approvals Division, Regulatory Services, 13 pp. 228 Model Modification Task Group (1999) Dispersion modeling modification task group recommendation report for the Alberta air quality guidelines. Prepared for Alberta Environmental Protection 229 Alberta Environmental Protection, Environmental Sciences Division, Science and Technology Branch (1999) Model performance evaluation of the US EPA industrial source complex (ISC) and the 0.55 adjusted model. April 1999. 230 (a) Environmental Sciences Division (2000) Interim Air Quality Model Guidelines: Draft for Public Consultation, Environmental Service, June 2000, 37 pp; (b) Environmental Sciences Division (2000) Air Quality Model Guideline, Environmental Service, October 2000, 44 pp (c) Idriss, A (2003) Air Quality Model guidelines. Science and Technology Branch, Environmental Sciences Division, Environmental Service, revised March 2003, 34 pp 231 Idriss, A (2003) Emergency/process upset flaring management: modeling guidance. Science and Standards Branch, Alberta Environment, March 2003. 232 Idriss, A and F Spurrell (2009) Air Quality Model Guideline. Climate Change, Air and Land Policy Branch, Alberta Environment, May 2009

100

Figure 38. High air pollution days in Edmonton (left) and Calgary (right)

The Edmonton study was carried out jointly by Alberta Environment, Environment Canada and the contractor, Western Research and Development.233 The field study was conducted in November and December of 1974 using an instrumented helicopter, two additional monitoring trailers, two minisondes for upper air data, and wind data from three airports, and two instrumented towers. The Department of Health had instrumented the CBC tower near Sherwood Park and the Edmonton Telephone Tower in the west end.234

The Calgary field study was conducted jointly by Alberta Environment and Western Research and Development in February and March of 1975 using an instrumented helicopter, one additional monitoring trailer operated by the contractor, airport wind data, wind and temperature from the instrumented tower near Bonnybrook and pilot balloon releases from Prince’s Island.235

In order to apply the models, urban area source emissions needed to be estimated. Point sources were not considered as most would have contributed little to concentrations in the city under adverse weather conditions. NOx, CO and heat emissions were estimated from data about space heating, water heating, and vehicle activity. In Edmonton, where low temperature fog was an issue, water vapour emissions were estimated for space heating, water heating, vehicles, industrial cooling towers and open water on the river.236 The covers of the reports on the modelling work are shown in Figure 39.

233 Angle, RP and JE Torneby (1975) The coordination of a joint air pollution field study in Edmonton, Alberta. 1975 Annual Meeting of PNWIS-APCA, Vancouver, B.C. November 19-21, 1975. 234 (a) Western Research and Development Ltd (1976) Application of an air column trajectory pollution model to the city of Edmonton. Prepared for Alberta Department of the Environment. January 1976, 2 volumes; (b) Leahey, DM (1975) An application of a simple advective pollution model to the City of Edmonton. Atmospheric Environment 9: 817-823 235 Western Research and Development Ltd (1976) Application of air column trajectory pollution model to the city of Calgary. Prepared form Alberta Department of the Environment, January 1976, 2 volumes. 236 Western Research and Development (1973) Sources and Emissions Inventory for the Cities of Edmonton and Calgary: preparation and results, 1971. Prepared for Alberta Department of the Environment, Edmonton

101

Figure 39. Urban air pollution model reports

The models were applied to answer a number of planning questions: how would air quality be affected by staggering hours of work to smooth out the rush hour traffic, reduce the number of cars on the road, change the age of the fleet, alter major arteries, and what would be the impact of urban growth.237 One of the most notable applications of the urban models was in assessing the impacts of a proposed ring road (now the Anthony Henday Drive) on air quality in Edmonton. Maintaining the emissions inventory needed to run these models proved to be very challenging. Eventually insufficient resources were available and use of the models ceased in the mid-1980s.

The observation of relatively high ozone concentrations in rural Alberta locations coupled with increasing oil and gas development in 1988 prompted a modelling investigation of potential ozone formation from the emissions in the Lindburgh heavy oil development area. The California Air Resources Board photochemical model, SMOG, was used to estimate ozone concentrations for various growth scenarios and emission profiles.238 Ozone production was shown to increase steadily with potential exceedance of the ozone ambient air quality objective. As one means of management, the work suggested an ambient air quality objective for reactive hydrocarbons in the range 0.20-0.24 ppm. However, given the highly variable nature of hydrocarbon emissions, such an objective would lack broad applicability. Application of the model to the Edmonton region, showed no indication of a future ozone problem.

237 Choukalos, Mitchell (1977) Effects of the Proposed Ring road on Edmonton Air Quality, Air Quality Control Branch, unpublished draft, November 1977. 238 Brennand, Michael (1988) Results of Applying the SMOG model to Edmonton and the Lindburgh Heavy Oil area. Air Quality Control Branch unpublished report, 29 July 1988, 20 pp.

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After Alberta signed the Canada-Wide Standard for Particulate Matter (PM) and Ozone in 2000 and the Clean Air Strategic Alliance developed the PM and Ozone Management Framework, there was again interest in photochemical modelling. In November 2006, the ozone “Planning Trigger” of the Framework had been exceeded at several airsheds in Alberta. To develop management plans requires that detailed photochemical modelling be carried out. Alberta Environment (AENV) held a workshop to discuss issues surrounding photochemical modelling in Alberta and obtain input from stakeholders.239 Thereafter David Lyder undertook to set up and operate the USEPA CMAQ (Community Multi-scale Air Quality Model).

Deposition Modelling

Another area of concern to the Department, as identified at the Environment Conservation Authority (ECA) hearings, was the deposition of sulphur around sour gas plants. Early work had suggested maximum sulphur deposition rates downwind of a sour gas plant could be as large as 2 kg/ha/month and that about 25% of the sulphur emissions wold be deposited within 100 km. Under the Alberta Oil Sands Environmental Program (AOSERP) Environment Canada scientists in 1977, using a modified USEPA model, estimated maximum dry deposition around the Suncor oil sands plant to be about 16 kg/ha/year. Both of these models used constant deposition velocities.

To improve estimates, Alberta Environment commissioned the development of a sulphur deposition model (SULDEP) where deposition velocity was a function of atmospheric stability and wet deposition was incorporated through equilibrium scavenging theory.240 The cover of the report is shown in Figure 40. Wet deposition near the source was found to be about one-tenth that of dry and maximum total deposition was less than 6 kg/ha/year. The wet/dry ratio was very different from that of eastern Canada, but perhaps not surprising given the much drier climate. In 1984 the model was further improved (SULDEP2) by incorporating surface roughness, wind speed variation with height, and limited mixing meteorology. Deposition maximums for a medium size gas plant were found to be somewhat further downwind with values around 11 kg/ha/year and about 24% of the emissions being deposited within 100 km.241 In 1998 refinements saw the release of SULDEP3 and a sulphur deposition model with terrain adjustments (ADEPT).

239 Alberta Environment (2009) Alberta Environment Photochemical Modelling Workshop, 12 June 2009, TransAlta Theatre, Calgary, Alberta. prepared by: Randolph Angle, 28 July 2009, 18 pp (unpublished) 240 Western Research and Development (1978) Derivation of first order estimates of Sulphur Deposition in the region of representative point sources. Prepared for Alberta Environment, Nov 13, 1978 241 Peake E, RP Angle and HS Sandhu (1986) Atmospheric Measurement, monitoring and modelling of acid forming emissions. Proceedings of the second Symposium/Workshop on Acid Forming Emission in Alberta and their Ecological Effects, Calgary, May 12-15, 1986. Alberta Environment

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Figure 40. Cover of Deposition Model Report

For medium range (100-1000 km) transport of sulphur emissions it is necessary to include chemical transformations. Early modelling in 1982 with a long-range transport model suggested peak deposition from the oil sands area to be about 4 kg/ha/year with the wet component contributing 40%. Of the wet deposition, 10% was due to sulphates and occurred in the summer. About 25% of the sulphur emissions were deposited within 200 km, 50% within 500 km and 75% within 1000 km.

From the 1960s acid rain was a growing concern in eastern Canada.242 The potential for such problems to occur in western Canada prompted the formation of the Western and Northern Canada Long Range Transport of Air Pollutants program in 1980.243 In 1985 a Mesoscale Modelling Task Group reviewed more than 100 candidate models and recommended a Lagrangian and Eulerian model for each of four applications: urban photochemical, mesoscale deposition, advanced complex and statistical.244

242 McMillan, Ann and G. Foley (2013) A History of Air Quality Management. Chapter 2 in Air Quality Management: Canadian Perspectives on a Global Issue, Eric Taylor and Ann McMillan, eds, Springer 243 Concord Environmental Corporation and ESSA Environmental and Social Systems Analysts Ltd (1992) 10-year review and assessment of the western and northern Canada long-range transport of atmospheric pollutants (WNC-LRTAP) Program. Prepared for BC Ministry of Environment on behalf of the Technical Committee of the WNC-LRTAP Program, July 1992 244 Western Mesoscale Modelling Task Group (1985) A Review of Mesoscale Modelling for Application to Western Canada. Western Canada LRTAP Technical Committee, December 1985, 29 pp

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Subsequently, Alberta Environment, working with the Alberta Research Council, chose to implement the USEPA model RELMAP (Regional Lagrangian Model of Air Pollution) because it operated with a small amount of input data, had short data processing and computation times, and low computer costs. It was modified to include a simple chemical mechanism for sulphur and nitrogen and became RELAD.245 This model was used to make concentration and deposition estimates for all of Alberta and for at least one airshed.246 Its characteristics were well documented247 and it became integral to the acid deposition management framework for Alberta developed by CASA.

Sour Gas Modelling

The sour gas processing industry was the impetus for much of Alberta’s air quality management activity in the formative years. A different aspect of sour gas revealed itself on October 2, 1973 when an oil well containing hydrogen sulphide gas blew out near New Norway and forced the evacuation of 800 people. The subsequent investigation and public inquiry set in motion a series of actions to reduce the likelihood of a blowout and the potential consequences should one occur. A number of risk assessments were produced and some sour gas facilities were relocated. The ERCB imposed additional safety requirement on sour gas systems: addition of automatic shutdown valves, increased corrosion protection, monitoring for pipe integrity, clear marking of public crossings and the preparation of emergency procedures plans. Planning regulations were also introduced to create a minimum separation distance between sour gas facilities and residential developments. An account of these developments can be found in the 1982 risk monograph by University of Toronto Institute for Environmental Studies.248 With the assistance of John Whittaker and David Wilson of the Mechanical Engineering Department, University of Alberta, a pipeline risk model was programmed by Mitch Choukalos of the Air Quality Control Branch and risks estimated by Whittaker for a variety of situations.249

245 (a) Cheng, L, RP Angle, E Peake, and HS Sandhu (1995) Effective Acidity modelling to establish acidic deposition objectives and manage emissions. Atmospheric Environment 29: 383-392; (b) Cheng, L, RP Angle and HS Sandhu (1996) Mesoscale effective acidity modelling in acidifying emissions management: Western and northern Canada perspective. Recent Res. Dev. In Atmospheric Sci, 1 (1996) 1-14 246 (a) Cheng, Lawrence and Randy P Angle (1993) Annual Variation of Acidic Loading and Representative Meteorology for Acid Deposition Management, prepared by Alberta Research Council and Standards & Approvals Division, AEP for the Acid Deposition Program, Alberta Ministry of Environmental Protection, November 1993, 50 pp+13 appendices; (b) Cheng, Lawrence (1994) Concentration and Deposition of Anthropogenic Pollutants in Alberta. Prepared by the Alberta Research Council for Alberta Environmental Protection, March 1994, 34 pp + appendix; (c) Cheng, Lawrence (1994) Concentration and Deposition of Anthropogenic Pollutants in Alberta (Summary Report) . Prepared by the Alberta Research Council for Alberta Environmental Protection, April 1994, 10 pp; (d) Cheng, Lawrence (1994) Concentration, Deposition and Transboundary Transport of Anthropogenic Pollutants in the Proposed West Central Regional Airshed. Prepared by Alberta Research Council for the Technical Working Group on Monitoring Design, West Central Regional Airshed Monitoring Program, Alberta Environmental Protection 247 (a) Cheng, L and RP Angle (1996) Model-calculated interannual variability of concentration, deposition and transboundary transport of anthropogenic sulphur and nitrogen in Alberta. Atmospheric Environment 30: 4021-4030; (b) McDonald, Karen M, Lawrence Cheng, Marvin P Olson and Randy P Angle (1996) A comparison of box and plume model calculations for sulphur deposition and flux in Alberta, Canada, Atmospheric Environment 30: 2969-2980 248 Angle, RP (1982) Sour gas facilities: a case study of a public risk in Alberta. In: Living with Risk: Environmental Risk Management in Canada. Institute for Environmental Studies, University of Toronto, IES monograph #3 ,September 1982 249 (a) Choukalos, Mitchell (1980) A Computer Model of the Risks from Gas Pipeline Ruptures. Air Quality Control Branch, Alberta Environment December 1980, 43 pp; (b) Whittaker, JD (1980) Public Safety Aspects of Sour Gas Facilities. Prepared by JD Whittaker for Air Quality Control Branch, January 1980; (c) Whittaker, JD, RP Angle, DJ Wilson, and MG Choukalos (1982) Risk-based zoning for toxic-gas pipelines. Risk Analysis 2: 163-169; (d) Whittaker, JD (1982) Risk evaluation of a sour gas pipeline system. INFOR 20: 40-51;

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One of the controversies during this period concerned the methods of calculating the downwind concentrations and determining the hazard zones for pipelines. Different models gave vastly different results. The Alberta Government Industry Environmental Committee concluded from model sensitivity tests that the key uncertainties were around plume rise and pipeline blowdown rate. A series of pipe burst experiments were carried out and suitable models chosen or developed. Ultimately reliable models became available for the transient release, sonic jet expansion, plume rise, puff dispersion, building effects, concentration fluctuations, and gas lethality.

The foothills on eastern slopes of the Rocky Mountains provided two important resources – outdoor recreation and sour gas. Conflicts were inevitable. In 1982 a resource company proposed to build a pipeline from its existing wells down a narrow valley and across a second valley, threatening recreational development planned for the Moose Mountain area of Kananaskis Country. To address atmospheric dispersion in these unique terrain conditions, a tracer study was undertaken to document the actual behavior of a gas release and site-tune a dispersion model. A version of the dispersion model IMPACT (Integrated Model for Plumes and Atmospherics in Complex Terrain) performed much better than a standard Gaussian plume model since valley meteorology greatly enhances dispersion.250

In October 1982, the worst sour gas blowout in Canadian history occurred near the hamlet of Lodgepole in the Drayton Valley area. This was a much larger sour gas blowout than one that occurred in the same area in December 1977. On some days, the rotten-egg odour of hydrogen sulphide could be smelled in Saskatchewan and Manitoba. An unprecedented amount of air quality monitoring took place during this period. At the beginning of the blowout, preliminary information suggested that the hydrogen sulphide flow rate was about 0.5 m3/s. However, back-calculations from early monitoring results using Alberta Environment’s PLUMES model suggested a flow rate an order of magnitude higher.251 The Lodgepole Blowout Inquiry Panel concluded that the flow rate was probably 4 m3/s. The well contained 28 percent hydrogen sulphide and spewed gas for 23 of the 67 days it was out of control.

In January 1986 the ERCB began a study to develop an improved computer model for evaluating toxic gas hazards. In June 1987 a consultant, Concord Scientific, delivered the model GASCON for predicting sour gas release rates from well blowouts and pipeline ruptures and the plume rise, initial dilution and atmospheric dispersion of the accidental release gas clouds. At a public meeting in June 1987, Dr. Keith Hage, representing the residents of northeast Calgary expressed concerns about the validity of the model under very low wind speed stable atmospheres. Could low turbulence result in a plume of undiluted gas and high exposure to residents? In response, the ERCB undertook and comprehensive Field Measurement Program at a test site near Kathryn, Alberta not far from Calgary.252 In October 1990, the ERCB released GASCON2 which used more realistic assumptions for plume rise, averaging time and vertical spread.253

The Alberta Energy and Utilities Board (EUB) formed an Advisory Committee (Committee) on Public Safety and Sour Gas in January 2000 to review the regulatory system for sour gas as it relates to public

250 Sakiyama, SK and RP Angle (1988) Modelling-tracer study for risk assessment of a proposed sour gas facility. Environmental Monitoring and Assessment 10-2 (1988): 133-146. 251 Angle, RP (1987) Alberta’s experience with the accidental release of hydrogen sulphide in the petroleum industry. Presented at : Workshop on Air Quality Response to Accidental Releases of Hazardous Substances. Atmospheric Environment Service, Environment Canada, Downsview, Ontario, 4-6 February 1987 252 Holizki, LD, MJE Davies, and T Howard (1991) Modelling and field measurement of atmospheric dispersion for a well blowout or pipeline rupture. Paper 91-86.3. Air and Waste Management Association Annual Meeting, 20 pp 253 ERCB (1992) Field Measurement Program, Volume 9, Review of GASCON2 (version 2.1) January 1992 Public Release.

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health and safety. The Advisory Committee includes representation from all major stakeholders, including Alberta Environment’s David Spink, Director of Environmental Sciences Division. Among its 87 recommendations were three pertaining to models,254 the intent of which was to establish and maintain standardized methods for dispersion modelling and risk analysis. Implementation of the recommendations was completed in 2007 and for the modelling recommendations, the EUB reported:255

A new computer software program called EUBH2S was developed to calculate emergency planning zones (EPZs) using a state-of-the-art dispersion modelling technique. This software will be the base requirement in Directive 071 for calculating EPZs. The EUBH2S software will also have the ability to calculate the distance to H2S and SO2 mandatory evacuation levels required under Directive 071.

Dispersion Meteorology

In 1966 Environmental Health Services Division of the Department of Health identified a need to measure winds and temperatures at different heights in Edmonton and Calgary in response to growing concern about smoke levels and reduced visibility in low temperature fog. A contractor mounted temperature sensors on the CN Tower building at three levels, but building effects made the installation unsuitable for accurate measurements. The contractor also erected a 92 m tower near the Bonnybrook Bridge in Calgary with sensors at four levels.256 Data from mid-1967 to mid-1971 were published in the Meteorological Tower Bulletin. Although there were technical problems, some conclusions were drawn about inversion frequencies and wind profiles.

In 1974 the Atmospheric Environment Service of Environment Canada instrumented the CBC and Edmonton Telephone Towers in Edmonton and re-instrumented the Calgary Bonnybrook Tower as part of the Canadian Meteorological Tower Network. The Federal government terminated the tower network in 1978. Alberta Environment then took over operation of the Edmonton CBC Tower and the Calgary Bonnybrook Towers until 1980 when maintenance problems forced the closure of both towers. The Bonnybrook Tower was re-instrumented but shortly thereafter was accidently knocked down by a heavy equipment operator.257 A data summary has been published.258

For dispersion calculations, the most accessible long term measurements are those made by the Canadian Weather Service in support of weather forecasting. From upper air soundings made twice a day it was possible to define meteorological air pollution potential in terms of mixing height, mean transport winds, and their product, the ventilation coefficient; however, stagnation charts produced by

254 Provincial Advisory Committee on Public Safety and Sour Gas. (2000) Findings and Recommendations Final Report. December 2000. Energy and Utilities Board, Calgary 53 pp. 255 Alberta Energy and Utilities Board (2007) Public Safety and Sour Gas Final Report. March 2007, EUB, Calgary, 82 pp. 256 Geoscience Research Associates Limited (1970, 1969, 1968) Investigation of Air Pollution in Calgary and Edmonton, Reports to Department of Health for fiscal years April 1, 1969 to March 3, 1970; April 1, 1968 to March 31, 1969; April1, 1967 to March 31, 1968. 257 Angle, RP (1983) Urban air pollution meteorology in Alberta Environment. Presented at Urban Air Quality Workshop, sponsored by Research Management Division, Alberta Environment, Edmonton, Alberta, October 17-18, 1983 258 Choukalos, M (1985) Summary of Data from Tall Meteorological Towers in Calgary and Edmonton. Alberta Environment, Pollution Control Division, Air Quality Control Branch, March 1985.

107 the Weather Service showed little relationship to urban air quality levels.259 For plume dispersion modelling, the frequency of stability classes could be derived from surface winds and cloud cover using the USEPA STAR program.

Models perform best when high quality input data are available, such as that collected during the urban model field study. In 1977 a meteorological station specifically designed to support air quality models was established west of Ellerslie, just outside of Edmonton to develop a climatology of wind, temperature stratification and turbulence. The installation included monostatic acoustic radar, balloon- borne minisonde tracked by optical theodolite, bivane, two levels of sensitive cup anemometers and vanes, temperature gradient on a short tower, an albedometer, a net radiometer and a fluxatron in addition to the more standard measurements of pressure, temperature, humidity and precipitation.260 Joe Godin (Figure 41) operated the station until its closure at the end of 1985 and equipment was redeployed elsewhere, including in support of the Calgary Winter Olympics in 1988. The data from 1978 to 1985 were analyzed and published by several different scientists.261 In 1986 much of the equipment was relocated and used to produce a similar dataset for the Fort Saskatchewan Regional Industrial Association.262

Figure 41. Joe Godin tracking a minisonde at the Ellerslie Meteorological station (1983 photo)

259 (a) Angle, RP (1974) Pollution Potential in Alberta Cities. Air Quality Control Branch (unpublished, November, 1974, 7 pp; (b) Angle, RP (1975) The Utility of Stagnation Area Charts, Air Quality Control Branch (unpublished), February 1975, 8 pp 260 (a) Angle, RP and JU Godin (1979) A meteorological station for air quality management. Presented at the 1979 Annual Meeting of the PNWIS-APCA, Edmonton, November 7-9, 1979; (b) Angle, RP and JU Godin (1982) Toward an atmospheric boundary layer climatology for central Alberta. Proceedings of the Technical and Business Sessions of the 6th Annual General Meeting of the Alberta Climatological Association, 25 February 1982 261 (a) Leahey DM ad MC Hansen. (1985) Doppler acoustic radar observations of wind in the Ellerslie region of Alberta. Prepared for Alberta Environment by Western Research. RMD Report 85/31, 77 pp. (b) Sakiyama, S and J Wong (1987) Summary of data from the Ellerslie meteorological station, 1978-1985. Alberta Environment, Pollution Control Division, Air Quality Control Branch, October 1987. (c) Sakiyama, SK, RH Myrick, RP Angle and HS Sandhu (1991) Mixing Heights and Inversions from Minisonde Ascents at Edmonton/Ellerslie. Alberta Environment, November 1991, 57 pp.(d) Angle, RP, M Brennand and HS Sandhu (1992) Surface albedo measurements at 53° N Latitude. Atmospheric Environment 26A: 1545-1547 (d) Myrick, RH, SK Sakiyama, RP Angle and HS Sandhu. (1994) Seasonal mixing heights and inversions at Edmonton, Alberta. Atmospheric Environment 28: 723-729 262 Concord Environmental Corporation (1993) Summary of Surface and Upper Air data from the FSRIA Fort Saskatchewan Meteorological Station 1989-1992. Environmental Quality Monitoring Branch in conjunction with Fort Saskatchewan Regional Industrial Association, February 1993.

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During the Moose Mountain field study a number of vertical and horizontal wind and temperature profiles were measured in order to determine: (a) the depth and strength of valley drainage flows, (b) relative frequencies of thermally driven and synoptically controlled wind regimes, (c) depth and strength of inversions and mixing layers with their frequencies of occurrence, and (d) correlations between intensive study data and long-term climatological data. The characterizations were summarized in a report and paper.263

Environmental assessments by industry and a variety of research programs generated a considerable amount of knowledge that was summarized in the 1991 book Plume Dispersion in Alberta,264 the cover of which is shown in Figure 42.

263 (a) Angle, RP and P Gourlay (1983) Dispersion Climatology of the Moose Mountain Area. Alberta Environment, February 1983. 58 pp. (b) Papirnik, P, RP Angle, and SK Sakiyama (1987) Diurnal variation of valley flows in the Alberta foothills. Alberta Environment, September 1987, 13 pp. 264 Angle, RP and SK Sakiyama (1991) Plume Dispersion in Alberta. Standards and Approvals Division, Alberta Environment, December 1991.

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Figure 42. Cover of book summarizing knowledge of dispersion meteorology in Alberta up to 1990

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Summary of Dispersion Modelling and Meteorology

Point source modelling was started in the Department of Health in 1964 using the Sutton-Lowry diffusion equation with Bosanqet-Carey-Halton plume rise formula. By 1968 the Pasquill method was being used for calculating ground-level concentrations from stack and flares. The new Department of Environment replaced the computer programs with updated formulations and published a guideline in 1978. A suitable method for handling elevated terrain was investigated and introduced. For dispersion from compressor stations, an empirical conversion ratio for NO2/NOx from monitoring data was applied to a plume model able to handle diffusion around obstacles. The models were converted for use on minicomputers in 1989 and distributed by a private firm for several years. Support and ongoing development grew unsustainable and in 1994 Alberta Environment adopted the models of the US Environmental Protection Agency with guidelines for their use.

Urban air quality models were developed in the early 1970s and verified using existing monitoring data and short-term field studies using monitoring trailers and an instrumented helicopter. These models were then used to answer questions about the impacts on air quality of scenarios such as ring roads and staggered work hours. In 1988 a photochemical model was applied to estimate ozone concentrations for various growth scenarios and emission profiles. The model suggested that and AQO for reactive hydrocarbons would be one method of controlling ozone formation for potential problem areas.

To address the acid deposition issue, in 1978 Alberta Environment commissioned the development of a point source sulphur deposition model with the dry deposition velocity a function of atmospheric stability and wet deposition incorporated through equilibrium scavenging . Wet deposition near the source was found to be about one-tenth that of dry, very different from that of eastern Canada. After a mesoscale model review by the Western and Northern Canada LRTAP Program, Alberta pursued the use of a Lagrangian model modified to include a simple chemical conversion mechanism. This became the foundation of the Alberta acid deposition management framework.

After a sour gas well blew out in 1973, considerable emphasis was placed on calculating expected concentrations downwind of such releases and delineating separation and planning distances. A pipeline risk model was programmed but much uncertainty remained. A series of pipe burst experiments were conducted by APIGEC and a tracer study was undertaken by the department in valley terrain. The massive 1982 Lodgepole sour gas well blowout prompted the ERCB to commission the development of an advanced model for evaluating toxic gas hazards, the first version of which was delivered in 1987. A comprehensive field test of the model under adverse atmospheric conditions subsequently took place near Calgary, and a revised model released in 1990.

In 1966 the Department of Health commissioned the instrumentation of two tall towers, one each in Edmonton and Calgary for measurement of wind and temperature at several levels. In 1974 Environment Canada instrumented two communications towers in Edmonton, and the department’s tower in Calgary, but terminated the cross-Canada tower network in 1978. The department continued operating one tower in each city until 1980. To gather more diffusion-specific meteorological data, Alberta Environment operated a specialized station near Ellerslie from 1977 to 1985. Knowledge about plume dispersion in Alberta up to 1990 was summarized in a book published by Alberta Environment.

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Science, Research and Technology

Science, Research and Technology provide the information needed to operate the components of the air management system, fill knowledge gaps, explore new opportunities, and make improvements to the system. In Alberta, as in many of the jurisdictions creating environmental agencies in the 1970s, there was recognition of the need to develop the scientific knowledge that would support decision-making in this new field of endeavor. The industries subject to regulation also realized the need to fund environmental research related to their operations and corporate interests.

A considerable amount of this early environmental research was never published in the mainstream scientific literature. Some was held confidential; much resides in the environmental assessment documents filed with various regulatory agencies in support of proposed industrial developments. This immense body of “grey literature” created some novel challenges not encountered in other types of research. Because so much of the work was case-specific, it was difficult to generalize. The identification of problems to be addressed was as diverse as the funding organizations themselves.

In the spring of 1971 The Alberta Environmental Research Trust (AERT) was created to provide a mechanism for “the expansion of applied and fundamental research and development relative to environment improvement.” The trust operated as a granting agency, providing funds to applicants meeting its criteria. In its 24 years of operation, the AERT disbursed over $5 million in funds, generally to small projects which were unable to obtain funding from other, more targeted sources of research funding.

In 1973, two years after the creation of Alberta Environment, a Research Secretariat was established under the leadership of Dr. Stuart Smith to assume responsibility for environmental research activities as outlined in Section 8 of the Department of Environment Act: compile, study and assess information; carry out research projects; conduct a continuing review of research; promote the co-ordination of research; enter into an agreement with respect to research, make grants for carrying out research. A 1976 brochure265 outlined:

• Role of Alberta Environment in research o Research policy and priorities o Relationship with other jurisdiction • Role of the Research Secretariat o Environment research definition and scope of research funding o Structure and functions of the Research Secretariat o Relationship to other agencies and the Alberta Environmental Research Trust o Staff activities and the administration of research projects o Alberta Environment Library.

The Secretariat was structured around four research systems: terrestrial environment, aquatic environment, atmospheric environment and human environment. Dr. Harby Sandhu (Figure 43), who had earlier started Alberta’s first study of potential photochemical pollution,266 was hired as the chief

265 Research Secretariat (1976) Environmental Research. Alberta Environment, June 1976 266 (a) Sandhu, HS (1975) A study of photochemical air pollutants in the urban airsheds of Edmonton and Calgary. Alberta Environment, Research Secretariat, Staff Report No. 1, October 1975, 155 pp (b) Sandhu, HS (1976) Oxidant levels in Alberta

112 scientist for the atmospheric system. Several follow-up studies were completed.267 The need to understand atmospheric chemical reactions also led to a study of the conversion of sulphur dioxide to sulphuric acid.268

One of the first challenges in this new field of environmental research was to define what it actually encompassed. Environmental funding agencies were receiving applications from workers in almost every recognized field of knowledge from mathematics to social sciences. After considering the problem and reviewing literature, Harby proposed the definition that was used by Alberta Environment thereafter:

Environmental research is scientific activity undertaken with the primary aim of maintaining, restoring or improving the environment, or for predicting changes in the environment. Investigation can be conceptual, experimental or developmental in nature or may pertain to man-made or natural environmental systems.269

Dr. Harby Sandhu joined the department in 1974 and served until 1999. He was skilled at anticipating issues and establishing programs proactively to address them. He valued science in the service of man and strove throughout his career to link academic research to real world policy decisions. He authored many scientific papers and policy reports, initiated and managed dozens of research projects, and worked to develop the Western and Northern Canada LRTAP program and the Alberta Petroleum Industry Government Environmental Committee (APIGEC) Acid Deposition Research Program. Harby participated in numerous federal-provincial committees, the start-up of the Clean Air Strategy for Alberta and the founding of the Clean Air Strategic Alliance. Harby was the champion of the “bridge scientist” whose role was to link scientific knowledge to policy development, as for example, in creating the Air Research User’s Group.

Figure 43. Dr. Harby Sandhu, chief scientist for the air research program (1986 photo)

airsheds. Presented at the international conference on photochemical oxidant pollution and its control, Sept 12-19, 1976 in Raleigh, North Carolina 267 (a) Bottenheim, JW and OP Strausz (1979) The effect of a polluting source on the air quality downwind of pristine northern areas. Atmospheric Environment 13: 1085-1089; (b) Bottenheim, JW and OP Strausz Gas-phase chemistry of clean air at 55° N latitude. Environmental Science and Technology 14: 709-718; (c) Peake, E and HS Sandhu (1983) The formation of ozone and peroxyacetyl nitrate (PAN) in the urban atmospheres of Alberta. Canadian Journal of Chemistry 61: 927-935; (d) Peake, E (1983) Peroxyacetyl nitrate in the Calgary atmosphere, final report. Research Management Division, Alberta Environment, Report 83/24; (e) Peake, E, MH Maclean, PF Lester and HS Sandhu (1988) PAN in the atmosphere of Edmonton, Alberta, Canada. Atmospheric Environment 22: 973-979; (f) Gladstone, KP, H Niki, PB Shepson, JW Bottenheim, HI Schiff and HS Sandhu (1991) Photochemical oxidant concentrations in two Canadian prairie cities: model evaluation. Atmospheric Environment 25B: 243-254 268 Bottenheim, JW and OP Strauss (1978) Computer Modelling on Polluted Atmospheres and the Conversion of Atmospheric sulfur dioxide to sulfuric acid. Prepared by the Department of Chemistry, University of Alberta for the Research Secretariat, Alberta Environment, June 1978, 144 pp 269 Sandhu, HS (1977) A definition of environmental research. Environmental Management 1: 483-489

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Some of the early atmospheric studies were concerned with the effects of Calgary’s chinook winds on air quality270 and with modelling air pollution in the Edmonton’s river valley.271 An urban air quality workshop was hosted in 1983, and urban air quality research needs were summarized in 1985.272 A follow-up study recommended that California’s Urban Airshed Model be adopted for use in Alberta cities.273 The chemical composition of air pollution around Alberta was a recurring theme.274 Bio- monitoring of air pollution and the effects of air pollution on the environment were also topics of interest.275 A complete list of publications from Research Management Division was published in 1985.276

During its existence the Research Secretariat (and later the Research Management Division) funded a large number of air research projects, some examples being:277

• Fiscal year 1981/1982 o Peroxyacetyl Nitrate in the Calgary atmosphere o Sulphur isotope abundances in the environment and their relation to long-term sour gas flaring near Valleyview, Alberta. o airshed management modelling systems for the AOSERP area phase III o air quality data acquisition in the AOSERP area o oil sands extraction, upgrading and emission technology review • Fiscal year 1982/83 o Alberta nitrogen oxides emission forecast 1980 to 2000 o Alberta Sulphur dioxide emissions forecast 1980 to 2000

270 (a) Western Research and Development Ltd (1977) A preliminary study of the effects of the Chinook on the air pollutant levels in Calgary. Prep for Research Secretariat, Alberta Environment, March 1977, 46 pp; (b Mathews, T and RB Hicks (1978) A study of the stability of the atmospheric boundary layer as revealed by an acoustic sounder and its relation to pollution levels in Calgary. Prepared for Research Secretariat by Department of Physics, University of Calgary, 87 pp. 271 (a) Hage, KD and P Hopps. (1982) A new air pollution model for Edmonton. Part 1. Prep for Research Management Division by Department of Geography, University of Alberta, 37 pp, RMD Report 82/14; (b) Hage, KD and P Hopps (1982) A new air pollution model for Edmonton. Part 2. Additional carbon monoxide measurements in the North Saskatchewan River valley in Edmonton. Prep for Research Management Division by Department of Geography, University of Alberta, 26 pp, RMD Report 82/10. 272 (a) Research Management Division (1983) Urban Air Quality Workshop; Oct 17-18, 1983. Research Management Division, Alberta Environment, (b) Jandali and B. Hrebenyk (1985) Urban air quality research needs in Alberta: a literature review and synthesis of available information. Alberta Environment, Research Management Division, 188 pp 273 Reid, N.W. and D.R. Rooney (1987) Selection and application of an urban air quality model for Alberta. prep for Research Management Division, Alberta Environment by Concord Scientific Corporation RMD Report L-106, 109 pp 274 (a) Klemm, RF and JML Gray 1982. a study of the chemical composition of particulate matter and aerosols over Edmonton. Prepared for RMD by ARC Report RD 82/9 125 pp; (b) Strosher M.T. (1984) A qualitative survey of organic compounds in source and ambient air from industrial areas in Alberta. prep for Alberta Environment by Kananaskis Centre for Environmental Research, University of Calgary, January 1984; (c) Peake, Eric and Karen Black (1975) Carcinogenic hydrocarbons as pollutants in the atmosphere of the city of Calgary. Submitted by the Environmental Sciences Centre (Kananaskis), University of Calgary to the Alberta Environmental Trust Fund, July 1975. AERT no. 93. 275 (a) Case, J.W. (1982). Biomonitoring of Air Pollution in Alberta with lichens and mosses. Report to Alberta Environment, Research Management Division, 166 pp; (b) Legge, Allan H, Eduard M van Zinderen Bakker Jr, Eric Peake and Dennis C. Lindsay (1980) The oxides of nitrogen and their interactions in the environment: a review. Final report to Research Secretariat, Alberta Environment and Canadian Petroleum Association, Feb 1980.by Kananaskis Centre for Environmental Research, University of Calgary 169 pp. 276 Research Management Division (1985) Research Management Division Publications. January 1985, Research management Division, Alberta Environment, Alberta Environment, 7 pp 277 (a) Research Management Division (1982) Research Management Division Annual Report for the fiscal year 1981/82, RMD report 82/11; (b) Research Management Division (1983) Research Management Division Annual Report for the Fiscal Year 1982/83, RMD report 83/11.

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o effects of aerial pollutant emissions on soil and vegetation processes o review of the technology available for the control of atmospheric emissions from oil sands plants o ambient air quality: AOSERP data.

The potential for extensive development of the oil sands in Northeastern Alberta was recognized in the early 1970s as Syncrude was gearing up to begin operations. Negotiation between the Government of Alberta and the Government of Canada resulted in the 1975 creation of the Alberta Oil Sands Environmental Research Program (AOSERP). It was originally intended to run for 10 years with an annual budget of $4 million, organized on a discipline basis with 8 technical research committees. The unwieldiness of managing a research program with so many committees and over 50 members led to a revised agreement in 1977 and a simpler four-system structure with hired program managers. William (Bill) Hume was seconded from the Atmospheric Environment Service of Environment Canada to manage the air system. Air system research within AOSERP included: (1) investigation of the processes involved in plume dispersion, chemical transformation and deposition of airborne pollutants, (2) gathering data on temperature, wind, precipitation and air quality, as a baseline for predictions that would be used in air quality management, and (3) development of a model to predict levels of air pollution resulting from oil sands processing plants.278 Model requirements were articulated and a frequency distribution model, FREDIS, was delivered in 1981.279

As a result of growing conflicts between provincial and federal scientists, the federal government withdrew from AOSERP at the end of 1978/1979 fiscal year. The province funded the program at a reduced level to an early completion in 1980. The provincial component was merged with the Research Secretariat to form a Research Management Division. The combined group adopted the four-system approach and was organized into four teams. By 1981/82, the Air Team comprised: Dr. Harby Sandhu, Senior Research Manager, Bruce Thomson, Assistant Research Manager (seconded from Atmospheric Environment Service, Environment Canada) and Bonnie Magill, Research Assistant. Subsequently a number of cross-cutting research programs were introduced to allow for an interdisciplinary approach.

In the 1970s the driving force for the environmental research was the need to produce environmental impact statements. The Secretariat’s Director enumerated the essential features of EIA research in order to avoid polarisation of judgements and the creation of adversary positions: (1) include social needs and benefits, (2) make timely recommendations based on estimates derived partly from real data and partly from professional judgement, (3) eliminate barriers to systematic analysis of data posed by organizational boundaries, (4) encourage new and innovative application of traditional disciplines. Dr. Smith also identified two major factors that would maximize the benefits of environmental research: (1)

278 Smith, SB (1981) Alberta Oil Sands Environmental Research Program 1975-1980: Summary Report. November 1981, AOSERP Report 118, 170 pp 279 (a) Angle, RP (1979) Air quality modelling and user needs. Prepared for the Alberta Oil Sands Environmental Research Program by Air Quality Control Branch, Alberta Environment. AOSERP Report 74, 34 pp; (b) Davison, DS and RB Lantz (1980) Review of requirements for air quality simulation models. Prepared for the Alberta Oil Sands Environmental Research Program by INTERA Environmental Consultants Ltd. AOSERP Report 104, 86pp; (c) Davison, DS, ED Leavitt, RR McKenna, RC Rudolf, and MJE Davies (1981) Airshed Management System for the Alberta Oil Sands, Volume 1: A Gaussian Frequency Distribution Model, 149 pp (d) Davison, DS, MC Hansen, RC Rudolph, and MJE Davies (1981) Airshed Management System for the Alberta Oil Sands, Volume II: Meteorological Data. 89 pp (f) Davison, DS, MJE Davies, RC Rudolph and MC Hansen (1981) Airshed Management System for the Alberta Oil Sands, volume III: Verification and Sensitivity Studies, 125 pp. Prepared by INTERA Environmental Consultants Ltd and Western Research and Development Ltd for Research management Division, Alberta Environment, Edmonton. March 1981.

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proximity of research to the principal users, and (2) involvement of both industry and government in cooperative programs, preferably on a shared-cost basis.280

The first example of a co-operative industry-government EIA-inspired research venture in Alberta was the West Whitecourt Environmental Study.281 In 1973 a group of companies processing sour gas came together to assess the effects of sulphur dioxide emissions on forest areas in west-central Alberta. The Alberta government joined the study and the open dialogue that started and the mutual appreciation of the problems that resulted set the tone for future joint initiatives.

In 1979 APIGEC sponsored a sour gas workshop to review information about potential environmental effects emerging from the West Whitecourt Study, AOSERP and the Western and Northern Canada Acid Deposition Program. A Steering Committee on Acid Gases in the Environment (SCAGE) was created to develop a coordinated research program on the consequences of acidic deposition in Alberta. Over 40 experts were recruited from Alberta industry, government and universities for three technical subcommittees who ultimately recommended the formation of an Alberta Government/Industry Acid Deposition Research Program (ADRP). The program, including both biophysical and human health282 components, began in 1983 and was completed in 1986.283 The results of the biophysical component were published as book in 1990.284

Partnerships with neighbouring Canadian jurisdictions were also established. In 1980, the Western and Northern Canada Long Range Transport of Atmospheric Pollutants Program (WNC-LRTAP) was established jointly between the provinces of British Columbia, Alberta, Saskatchewan, Manitoba, and the federal Government of Canada.285 In 1982 the Government of the Northwest Territories joined as a participant. The program had six objectives all related to research: to collect data on baseline conditions, to evaluate the effects of industrial development on the environment, to establish research and monitoring priorities, to co-ordinate research, to publish relevant scientific information, to translate research results into operational practices. Three-year programs were initiated in 1981, 1984 and 1988 each with a set of research and monitoring priorities.286 Annual Reports were published from 1981 summarizing each agency’s activities and projects as well as joint endeavours between two or more agencies. In parallel with Alberta’s own acid deposition management, the partnership explored the use of critical and target loadings.287

280 Smith, SB (1978) Philosophy, technology and politics of environmental impact assessment. Chemistry in Canada, February 1978: 13-17 281 Legge, AH, DR Jaques, HR Krouse, EC Rhodes, HU Schellhase, J Mayo, AP Hartgerink, PF Lester, RG Amundson and RB Walker (1978) Sulphur gas emissions in the boreal forest: The West Whitecourt case study, Final Report submitted to the Whitecourt Environmental Study Group. October 1978 615 pp; Executive Summary published in Water, Air and Soil Pollution 15: 77-85 282 Spitzer, WO (1986) The Southwestern Alberta Medical Diagnostic Review. Supported by a grant from Alberta Community and Occupational Health, administered by the Alberta Government-Industry Acid Deposition Research Program, 3 volumes, June 1986 283 Sandhu, HS, AH Legge, and RR Wallace (1991) Design, management, and key accomplishment of a coordinated environmental research program on acidic deposition. Environmental Management 15: 497-506 284 Legge, AH and S V Krupa (1990) Acidic Deposition: Sulphur and Nitrogen Oxides. Lewis Publishers, 659 pp 285 Sandhu, HS and RG Wilson (1987) Management strategy for acidic deposition in Western and Northern Canada. Environmental Management 11: 637-640 286 Concord Environmental Corporation and ESSA Environmental and Social Systems Analysts Ltd. (1992) 10-year Review and Assessment of the Western and Northern Canada Long Range Transport of Atmospheric Pollutants (WNC-LRTAP) Program. Prepared for the B.C. Ministry of Environment, Lands and Parks on behalf of the Technical Committee of the WNC-LRTAP Program. July 1992. Vancouver, BC 287 Angle, RP and HS Sandhu (1992) Application of acid deposition critical or target loads to limit source emissions in sensitive areas. Paper IU-29.07, 9th World Clean Air Congress and Exhibition, Montreal, Canada, August 30-September 4, 1992, 7 pp

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In 1981 the Alberta Environmental Centre opened in Vegreville, Alberta. The Centre worked on behalf of four provincial government departments - Environment, Labour, Health, and Agriculture. Nirmal Das and Henry Bertram of the Air Analysis and Research Group provided analytical services for the air monitoring program, published methods manuals for use by other laboratories,288 and worked on methods development.289

The 1982 Lodgepole Blowout led to several studies of the health effects of hydrogen sulphide. Bob Rogers, who had earlier compiled a bibliography of relevant work,290 completed a review291 in 1988 on behalf of an Ad Hoc Committee on H2S Toxicity with a view to establishing evacuation guidelines in the event of an uncontrolled release of H2S. In 2002 Alberta Health and Wellness commissioned Don Davies of CanTox to review the health effects associated with short term exposure to low levels of hydrogen sulphide.292 A companion review of knowledge gaps was published by Alberta Environment in 2003.293 In 2006 with assistance from CanTox, Alberta Health and Wellness produced a review of the health effects associated with short-term exposure to low levels of sulphur dioxide.294 Community exposure and health effects have been assessed for a range of air pollutants in various settings by Alberta Health and Wellness in a series of studies.295

In 1988 the department underwent a major reorganization; the research management function was eliminated and all responsibility for research was transferred to the Centre. In support of the department’s air management activities, the Centre briefly undertook an acid deposition research program. In 1996 the Centre was moved out of the department and into the Alberta Research Council. To ensure that the department was able to get its own research and analytical work done, funds were removed from the Centre’s budget and retained by the department for contract work. As a transition, the department guaranteed contracts to the Centre for a period of three years. Thereafter the department was free to choose whatever research performer it desired.

Initially the retained funds were targeted to two research priorities: air quality, which had been largely neglected since 1988, and sustainable forestry. Oversight for all of the funds was vested with a

288 (a) Air Analysis and Research Group (1987) Methods Manual for the Analysis of Atmospheric Pollutants. Alberta Environmental Centre, Vegreville, Alberta; (b) Air Analysis Branch (1993) Methods manual for chemical analysis of atmospheric pollutants, Air and Water Research Program, Physical and Engineering Sciences Division, Alberta Environmental Centre, May 1993. 289 Bertram, Henry L, C Bruce Cristensen, Violet I Hannak and Nirmal C Das (1988) Developments in passive monitoring of ambient sulphur dioxide. CPANS Technical Meeting: Fingerprinting. Air Pollution Control Association Canadian Prairie and Northern Section, Calgary, May 16-17, 1988, 13 pp 290 RE Rogers and WR Trost (1976) Hydrogen sulphide: a bibliography of its health effects, formation, distribution and control. Environment Conservation Authority Staff Report 291 Ad Hoc Committee on H2S Toxicity (1988) Report on H2S Toxicity. Alberta Community and Occupational Health, August 29, 1988. 292 Davies, DB and SE Haggerty (2002) Health Effects Associated With Short-Term Exposure To Low Levels of Hydrogen Sulphide (H2S): A Technical Review. Prepared for Alberta Health and Wellness, July 2002, 78 pp 293 Roth, SH and VM Goodwin (2003) Health Effects of Hydrogen Sulphide: Knowledge Gaps. Prepared for Alberta Environment, 237 pp 294 Health Strategies Division (2006) Health Effects Associated with Short-term Exposure to Low Levels of Sulphur Dioxide (SO2) - A Technical Review. Alberta Health and Wellness, 243 pp 295 Alberta Health and Wellness (a) The Alberta Oil Sands Community Exposure and Health Effects Assessment Program: Summary Report, June 2000, 74 pp; (b) The Grande Prairie Community Exposure and Health Effects Assessment Program: Final Report, March 2002, 152 pp +appendices; (c) The Fort Saskatchewan and Area Community Exposure and Health Effects Assessment : Final Report, June 2003, 159 pp + appendices; (d) The Wabamun and Area Community Exposure and Health Effects Assessment : Final Report, August 2006, 205 pp

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Research Needs and Priorities Committee, comprising the Directors of the Divisions who would be using the research. Two Research Users Groups were struck to develop the programs in these two priority areas. Dr. Harby Sandhu was chair of the Air Research Users Group until his retirement, and then Randy Angle became the chair until the research program was terminated in 2004. The groups consisted of staff scientists and engineers who would be applying the results to line decision-making. Project selection criteria were developed and responsibilities of department project co-ordinators delineated. The department also developed rolling three-year Research Business Plans that set out functional themes. The air research themes are summarized in Table 8. In 2005 all funding for environmental research was redirected to other environmental management priorities.

Table 8. Research themes under the Air Research Users Group

Years Air Research Themes 1997-1999 • anthropogenic sources • natural sources • effects on crops 2000-2002 • emissions characterization • monitoring methods • ambient guidelines, • cross-cutting (issues management) 2003-2004 • improving monitoring methods • understanding source contributions

One of the most significant projects was a multi-year study of the potential effects of ethylene on Alberta crop yield and growth. In partnership with Alberta’s petrochemical industry, the project was launched in 1997 and completed in 2001. Alberta Environment’s Dr. Ken Foster provided scientific advice and George Murphy served on the Management Committee. The work was carried out by a team of Alberta Research Council Scientists at Vegreville under the leadership of Dr. Xioamei Li.296 The results were used to finalize an air quality objective for ethylene.

The two principles of proximity and stakeholder involvement imply that communication is an intrinsic part of environmental research. Every few years the research management group organized and hosted a symposium/workshop to create a dialogue between researchers and managers.297 Researchers shared

296 (a) Alberta’s Ethylene Crop Research Project (2002) Fact Sheet-Research Results, January 2002; (b) Archambault D and X Li, (1999) Report I. Design and Performance of ARC's ethylene exposure system, and Report II. The effects of ethaphon on barley, wheat, oats, field peas and canola: A screening test for the determination of ethylene sensitivity. Alberta Research Council (c)Archambault D and X Li (2001) Report III. Response of barley, field pea, canola and tree seedlings to ethylene exposure. Alberta Research Council 297 (a) Hocking, Drake and David Reiter, editors (1973) Proceedings of a Workshop on Sulphur Gas Research in Alberta. Northern Forest Research Centre, Edmonton, December 1973, Information Report NOR-X-72;(b) MacDonald, WR and HS Sandhu (1975) Proceedings of Alberta Sulphur Gas Research Workshop II. Held at Environmental Sciences Centre, Kananaskis, Alberta, January 16-17, 1975, Queens’ printer, Edmonton; (c) Sandhu and M Nyborg, editors (1977) Proceedings of Alberta Sulphur Gas Research Workshop III, held at the University of Alberta, Edmonton, Nov 17-18, 1977, Research Secretariat, Alberta Environment: (d) Sandhu, HS, JR Clements, and BL Magill, organizers (1982) Proceedings Acid Forming Emissions in Alberta and their Ecological Effects, held at the Westin Hotel, Edmonton, March 9-12, 1982, cosponsored by Alberta Department of Environment, Canadian Petroleum Association, and Oil Sands Environmental Study Group, 648 pp; (e) Sandhu, HS, AH Legge, JI Pringle and S Vance, editors (1987) Acid forming emission in Alberta and their ecological effects: 2nd Symposium/Workshop

118 their findings and together with the environmental managers, and developed recommendations for future work. The covers of the proceedings are shown in Figure 44. Academics from Alberta’s universities made many contributions over the years.298

Figure 44. Covers of symposium/workshop proceedings

Such organized exchanges ceased when the Research Management Division was eliminated. There was a gap of several years until the Clean Air Strategic Alliance began to organize science symposia on selected topics of interest to government, industry and environmental groups: climate change in 1995, acidifying emission in 1996, air quality and health in 2002, and nitrogen in 2006.

Proceedings. Research Management Division, Alberta Department of Environment and Kananaskis Centre for Environmental Research, University of Calgary. Held at Palliser Hotel, 1986 May 12-15, Calgary, 478 pp 298 For example, (a) Bonnet, PA, Drake Hocking and EE Daniel (1970) Air Pollution in Edmonton. Air Pollution Group of the Interdisciplinary Committee for Environmental Quality, University of Alberta; (b) Longley, Richmond W. (1972) Diffusion of Pollutants over Edmonton, AB; (c) Tollefson, Eric L (1972) Sources of air pollutants and future trends in air quality standards. presented at the Canadian Natural Gas Processors Association (CNGPA) second quarterly meeting, Chateau Lacombe Edmonton, June 9, 1972; (d) Benjamin, SF ( 1975) The fate of SO2 from sour gas plants. University of Calgary Interdisciplinary Sulphur Research Group (UNISUL) group 4, September 1975. 33 pp. funded by National Research Council

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In July, 1978, the major sour gas producers in Alberta submitted a proposal to the Production Subcommittee of the Alberta Petroleum Industry-Government Environmental Committee (APIGEC) for a field verification program of H2S isopleth prediction techniques. APIGEC agreed to undertake the project and approved funding for: (1) a computer sensitivity analysis of the variables and (2) a full-scale field program to observe the source configuration of gaseous emissions resulting from a pipeline rupture. The field data were used to evaluate the validity of the assumptions used in calculating hazardous areas resulting from uncontrolled releases of sour natural gas.299 The department supplemented this work with a series of studies by David Wilson at the Mechanical Engineering Department, University of Alberta.300 APIGEC also sponsored studies on the chemistry and diffusion of emissions from compressor stations.301

Flares in the petroleum industry had long been a concern. In order to calculate the dispersion of sulphur dioxide from a flare, certain assumptions had to be made. It was known from theoretical and laboratory tests that a large fraction of the heat released from the combustion of flare gases was lost to radiation and not available to provide buoyant rise to the effluent. Model for the plume rise from a flare generally assumed a 25% loss. To test this assumption under real world conditions, Research Management Division commissioned field studies which showed that losses up to 40% were possible if black smoke was present.302 The topic continued to receive attention and a review of work was commissioned by the Science and Technology Branch in 2000.303

The efficiency of flaring for the conversion of hydrogen sulphide to sulphur dioxide was also an issue of concern. Research Management Division commissioned a preliminary study published in 1985.304 In 1990 a Government Industry Consultative Committee on Flaring was formed by Environment Canada,

299 (a) Alberta Petroleum Industry-Government Environmental Committee (1978) H2S Isopleth Prediction, Phase I: Model Sensitivity Study. APIGEC December 1978, 20 pp +figures and tables; (b) Alberta Petroleum Industry-Government Environmental Committee (1979) Hydrogen Sulphide Isopleth Prediction Phase II: Pipe Burst Study, April 1979, 45 pp + 7 appendices; (b) Knox, HW, LD Atwell, RP Angle, RW Willoughby, JP Dielwart (1979) Field verification of assumptions for modelling sour gas pipeline ruptures and well blowouts. Paper 79-6.2 PNWIS-APCA, Edmonton 197917 pp 300 (a) Wilson, DJ (1979) The release and dispersion of gas from pipeline ruptures. Prepared by Department of Mechanical Engineering, University of Alberta for Pollution Control Division, Alberta Environment, 91 pp; (b) Wilson DJ (1981) Expansion and Plume Rise of Gas Jets from High Pressure Pipeline Ruptures. Prepared by Department of Mechanical Engineering, university of Alberta for Pollution Control Division, Alberta Environment, April 1981, 61 pp;(c) Wilson, DJ (1082) Predicting Risk of Exposure to Peak Concentrations I Fluctuating Plumes. Prepared by Department of Mechanical Engineering, University of Alberta for Pollution Control Division, Alberta Environment, December 1982, 90 pp; (d) Wilson, DJ and BW Simms (1985) Exposure time effects on concentration fluctuations in plumes. Prepared by Department of Mechanical Engineering, University of Alberta for Pollution Control Division, Alberta Environment, 160 pp; (e) Wilson, DJ (1986) Plume Dynamics and Concentration Fluctuation in Gas Emissions. Prepared by Department of Mechanical Engineering, university of Alberta for Pollution Control Division, Alberta Environment, April 1986, 99 pp 301 (a) Vet, RJ, NW Reid, E Alp, and SJ Diehl (1982) Compressor exhaust chemistry and wake diffusion. Prepared by Concord Scientific Corporation for Alberta Petroleum Industry Government Environmental Committee, April 1982, 205 pp (b) Zelensky, MJ (1983) NOx Control Technology for Compressor Engines in Alberta. Prepared by Western Research for Alberta Petroleum Industry Government Environmental Committee, 76 pp 2 appendices 302 (a) Leahey, D M (1979). ‘A Preliminary Study Into The Relationships Between Thermal Radiation And Plume Rise’,: Alberta Environment, Research Management Division, May 1979, 33 pp; (b) Davies, MJE and DM Leahey (1981) Field study of plume rise and thermal radiation from sour gas flares. Alberta Environment and ERCB, 92 pp 303 (a) Leahey, DM and MJE Davies (1984) Observations of plume rise from sour gas flares. Atmospheric Environment 18: 917- 922; (b) Guigard, Selma E, Warren B Kindzierski, and Nicola Harper (2000) Heat Radiation from Flares. Prepared by Department of Civil and Environmental Engineering, University of Alberta for Science and Technology Branch, Alberta Environment, May 2000, 48 pp + appendices 304 Leahey, DM, HG Paskall, MB Schroeder and MJ Zelensky (1985) A Preliminary Study of the Chemical Composition and Combustion Efficiency of a Sour Gas Flare, Alberta Environment, Research Management Division, RMD Report 85/30, 93 pp

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Alberta Energy and Utilities Board, the Canadian Association of Petroleum Producers (CAPP), the Alberta Research Council, Alberta Environmental Protection and the University of Calgary. An extensive research program was developed consisting of laboratory studies, pilot-scale studies. The controversial results were published in 1996.305 Lab and pilot studies showed efficiencies in excess of 98%; however field studies showed by efficiencies could drop to 82% or even lower depending on fuel characteristics, particularly liquid content. Through the Petroleum Technology Alliance Canada, industry and government have continued to support work on flare efficiency and flare technology. The Air Research Users Group also commissioned some analysis of ambient levels of PAH and VOC in the vicinity of flare stacks.306 The PTAC Air Research Planning Committee has become the main facilitator of applied research on air emissions in the upstream oil and gas sector, with Lawrence Cheng and Randy Dobko representing the interests of Alberta Environment.

To address long-debated questions about possible relationships between animal health and exposure to emissions from oil and gas field facilities, Alberta Cabinet Minister Dr. Steve West initiated the largest and most comprehensive study of its kind in North America involving a sample size of approximately 33,000 cattle in 205 herds. The geography and scope of the Study area were much larger than previous studies, involving much of Western Canada. The total cost of the study was $17 million dollars over six- years. The Government of Alberta, through Alberta Environment, provided the majority of funding – over $14 million – towards the Study, with additional funding support from British Columbia, Manitoba, Saskatchewan, Alberta Cattle Commission, Canada-Alberta Beef Industry Development Fund, B.C. Oil and Gas Commission, Canadian Association of Petroleum Producers (CAPP) and Environment Canada. The Western Interprovincial Scientific Studies Association (WISSA) was established in February 2001 as a non-profit corporation to manage the study supported by a Science Advisory Panel composed of eleven internationally renowned scientists with collective expertise in environmental and reproductive epidemiology, animal and human health and toxicology. The study was conducted by the Western College of Veterinary Medicine (Saskatoon, Saskatchewan). The final report was released in May 2006.307

305 Strosher, M (1996) Investigations of Flare Gas Emissions in Alberta: Final Report to Environment Canada, Energy and Utilities Board, and Canadian Association of Petroleum Producers, Alberta Research Council, November 1996, 117 pp + appendix 306 Kumar, Yogesh (2000) Ambient air levels of polyaromatic hydrocarbons and volatile organic and organosulfur compounds in the vicinity of selected gas plant flare stacks, Alberta Research Council, Vegreville, March 2000. 119 pp. 307 Western Interprovincial Scientific Studies Association (2006) Western Canada Study of Animal Effects Associated with Exposure to Emissions from Oil and Natural Gas Field Facilities. 4 volumes. Technical Summary 47 pp, Research Appendices, An Interpretive Overview by the Science Advisory Panel, 15 pp and What About the Cattle (Highlights), Western Interprovincial Scientific Studies Association, Calgary

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Summary of Science, Research and Technology

When the environment emerged as a priority in the 1970s, research was an important component. The Department invested in a Research Secretariat to fund and coordinate research. The Secretariat was structured around four research systems: terrestrial environment, aquatic environment, atmospheric environment and human environment. The Research Secretariat supported a wide variety of projects on ozone formation, the conversion of sulphur dioxide to sulphuric acid, flaring, the effects of chinook winds on Calgary’s air quality, river valley dispersion, chemical composition of air pollution and biomonitoring.

In 1975 the federal and provincial government’s created the Alberta Oil Sands Environmental Research Program (AOSERP) to address potential environmental effects of development in northeastern Alberta. After the withdrawal of the federal government in 1978, the provincial components were merged with the Research Secretariat to for the new Research Management Division. AOSERP was supported to an early completion in 1985. The Research Management Division continued to fund and coordinate research in the province.

Partnerships with industry were cultivated and a large Acid Deposition Research Program was launched in 1983 and completed in 1986. A partnership with other western provinces/territories and the federal government, The Western and Northern Canada Long Range Transport of Air Pollution Program, started in 1980 and operated for ten years, adding greatly to knowledge of acid deposition in the West.

In 1988 Research Management Division was eliminated. Aside from the loss of research funding, there was no longer support for scientific workshops and symposia which were the main venue for the exchange of research information among academics, industry and government. The Alberta Environmental Centre Vegreville supported a small acid deposition research program for a few years. In 1996, the Alberta Environmental Centre was moved to join the Alberta Research Council. The department retained some of the research budget which was managed by a number of research user groups until 2005. The Air Research Users Group supported projects on natural and man-made sources, effects on crops, emission characterization, monitoring methods, ambient guidelines, and source contributions.

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Conclusion

Complaints about blowing dust from coal mines prompted the provincial government in 1945 to include in the Public Health Act a general provision for the investigation of air pollution complaints. Subsequent amendments provided increasing authority for the creation of air pollution regulations and building various components of the air management system. When the Department of Environment was created in 1971 the basic infrastructure was in place. Air quality was given some focus with the passage of the Clean Air Act. The Department of Environment subsequently added to the regulations, expanded the permitting regime and developed quasi-regulatory instruments. The Energy Resources Conservation Board was a powerful ally in addressing air pollution issues related to the Oil and Gas Industry.

In 1969 the Air Pollution Control Section of the Department of Health articulated a two-pronged approach to air quality management in Alberta: (1) control of pollutants at the source, and (2) dilution of the residual to levels harmless to receptors. By 1980 a number of operating principles had been added, including: use of best practicable technology for emission control, joint government-industry setting of emission standards, industry self-monitoring and reporting of emissions and resulting air quality with government checking data quality, and considering multiple sources in meeting ambient air quality objectives. As public interest in environment matters grew, consultation processes evolved to include environmental groups, citizens at large, and sometimes academics and health groups. The Clean Air Strategy for Alberta brought a multi-stakeholder approach to problem solving and air quality planning.

In the Department of Health, the central components of air quality management all resided in one section. When the Department of Environment was formed, air quality management was split between two different units, one responsible for developing rules and issuing permits, and the other, for monitoring and abatement. In 1988 enforcement was strengthened and monitoring moved to a third area of the department in a major realignment. Thereafter reorganization became a frequent occurrence as the department responded to various political, financial and administrative factors.

Alberta Environment worked closely with the federal government and the other provinces in the federal-provincial committees set up under the federal Clean Air Act. Alberta Environment has also been an active participant in the air initiatives of the Canadian Council of Ministers of the Environment. Acid rain concerns from oil sands emissions led to a western Canada LRTAP program and to an agreement with Saskatchewan

The Department of Public Heath issued the first source performance guidance in 1965. These were augmented by Alberta Environment and by 1990 there were guidelines for 10 types of industrial operations. Sulphur Recovery Guidelines issued jointly with the Energy Resources Conservation Board have been a central feature of air pollution management in the province.

Stack emission surveys were conducted by departmental staff and required of industry as a licence condition. Continuous emission monitoring for large sources was required once suitable instrumentation became available. Initially visible emissions was measured by human observers using the Ringelmann chart and later by certified readers trained with a calibrated smoke generator. By 1985 industrial operators were being asked to develop control programs for fugitive emissions

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The Department of Health started an urban air quality monitoring program in the 1960s. The number of stations and parameters continued to grow and by 1973 Alberta Environment had established six continuous monitoring stations, three each in Edmonton and Calgary, to represent residential, industrial and downtown areas. These were supplemented with networks of exposure cylinders and by 1976 the monitoring networks had settled into the basic configuration they would keep for the next thirty years.

The Department of Health operated a number of “sour gas” trailers that measured SO2 and H2S concentrations in the vicinity of sour gas plants. In 1981, Alberta Environment obtained its first self- contained, self-powered, completely mobile air quality monitoring laboratory (AQML). Comprehensively equipped trailers were used to monitor air quality in smaller centres and to undertake various types of investigations.

The urban monitoring data were compiled and published regularly in annual monitoring reports, while survey data were published some months after a survey was completed. To make the complex urban air quality data more understandable to the general public, an air quality index was developed in the early 1970s and used until it was replaced in 1980 by the federal-provincial Index of the Quality of the Air (IQUA) which, with slight modifications, was used for the next thirty years.

Data quality assurance for industry self-monitoring was addressed through quasi-regulatory Air Monitoring Directives, the first of which was issued for the sour gas industry in 1972. In subsequent years, air monitoring directives were issued for other industries and then consolidated in 1989.

The first published air monitoring plan was prepared by the Department of Health in 1970. The 1991 Clean Air Strategy for Alberta led to the adoption of a zone monitoring approach culminating in eight monitoring airsheds throughout the province. In 1995, recognizing the importance of having reliable ambient air quality information, CASA developed a strategic plan for air quality monitoring in Alberta and updated it in 2009.

The Department of Health published the first ambient objectives for sulphur compounds in 1969. Alberta based subsequent ambient objectives on the work of the federal-provincial committee on air pollution, generally adopting the maximum desirable level, the most stringent of the three-tier National Ambient Air Quality Objectives. In 2000 Alberta Environment initiated its own process for the development and review of ambient air quality objectives with participation by industry, government and public interest groups. By 2010 the department had enlarged its set of air quality objectives to encompass 46 substances.

Point source dispersion modelling was started in the Department of Health in 1964. The new Department of Environment replaced the computer programs with updated formulations and published the first guideline in 1978. The models were converted for use on minicomputers in 1989. In 1994 Alberta Environment adopted the models of the US Environmental Protection Agency and issued guidance on their use. Urban air quality models were developed in the early 1970s and verified using existing monitoring data and short-term field studies. In 1988 a photochemical model was applied to estimate ozone concentrations for various growth scenarios and emission profiles. To address the acid deposition issue, in 1978 a point source sulphur deposition model was developed. In 1994 a larger scale model with simple chemistry was developed and applied for acid deposition management.

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from 1977 to 1985. Knowledge about plume dispersion in Alberta up to 1990 was summarized in a book published by Alberta Environment.

The Department’s Research Secretariat funded and coordinated research, supporting a wide variety of air quality projects. After the federal government withdrew from Alberta Oil Sands Environmental Research Program (AOSERP) in 1978, the provincial components were merged with the Research Secretariat to form the new Research Management Division. Partnerships with industry were cultivated and a large Acid Deposition Research Program was launched in 1983 and completed in 1986. A partnership with other governments, The Western and Northern Canada Long Range Transport of Air Pollution Program, started in 1980 and operated for ten years, adding greatly to knowledge of acid deposition in the West. In 1988 Research Management Division was eliminated. A small research budget was managed by a number of research user groups until 2005.

Air management in Alberta has changed substantially over more than six decades. Starting rather modestly as complaint resolution in the Department of Health, it grew to a multi-component system in the Department of Environment. Nearly 200 individuals have contributed directly to air quality management in the Alberta public service during the first 65 years, not counting the integrated approvals staff in the regions or the staff of the Energy Resources Conservation Board. The foundations of the air quality management system were laid by the Department of Health in the late 1960s and the Department of the Environment in the 1970s. Many factors, external and internal, large and small, have shaped the components of the Alberta’s air management system over its first 65 years.

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Appendix A. Chronology of Significant Events in Alberta Air Quality Management

AENV = Alberta Environment = Alberta Department of Environment, for a time known as Alberta Environmental Protection (AEP) ERCB = Energy Resources Conservation Board, for a time known as Energy and Utilities Board (EUB) IL = Informational Letter ECA = Environment Conservation Authority or Environment Council of Alberta APIGEC = Alberta Petroleum Industry Government Environmental Committee

Year Event 1907 • Public Health Act 1919 • Department of Public Health Act 1938 • Petroleum and Natural Gas Conservation Board (forerunner of ERCB) created 1945 • Public Health Act amended to allow for air quality complaints to be evaluated and corrected 1946 • Public Health Act amended to address blowing dust from piles of coal and slag 1955 • Public Health Act amended to include pollution prevention and regulation of industrial discharges to the atmosphere 1957 • British American Oil Company (BA) started operating a sour gas processing plant near Pincher Creek 1958 • Serge Dobko hired as the first air pollution engineer in the Division of Sanitary Engineering, Department of Public Health 1961 • Regulations for the Control of Air Pollution (AR262/61) stated limits for smoke, odor, and toxic/noxious materials and required Board of Health approvals for new industry 1962 • Public Health Act amended to extend authority to pipelines 1964 • First dispersion model calculated maximum ground level concentration and distance at which it occurs using Sutton-Lowry method (programmed by E. Kupchanko) • First emissions inventory, A Study of Air Pollution Sources and their Significance in Edmonton, Alberta and A Study of Air Pollution Sources and their Significance in Calgary, Alberta 1965 • Publication of Air pollution control in disposal of solid refuse through the utilization of proper incinerators or other methods in the Edmonton Metropolitan area and Air pollution control in the petroleum and petrochemical industries in the Edmonton metropolitan area • Stack dispersion model using Pasquill method (by E. Kupchanko) • Flare dispersion model using material balance and Sutton-Lowry method (Kupchanko) • John Torneby joined Division of Sanitary Engineering , Department of Public Health 1966 • Alberta Regulation 276/666 (amended AR262/61) introduced a particulate emission standard and a method of measurement • Jerry Lack joined the Division of Sanitary Engineering, Department of Public Health • A contractor put meteorological instrumentation on towers in Edmonton and Calgary 1967 • Alberta Regulation 231/67 amended AR 262/61 to include pulp and paper products • plume overlap principle applied to Great Canadian Oil Sands (GCOS) Company allowing only one third of the ambient air quality objective • Alberta Department of Public Health became the Department of Health; Division of Sanitary Engineering became Environmental Health Services Division

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1968 • Alberta Regulation 261/68 required incinerators to meet standards set out in a technical document Incinerator Standards for the Province of Alberta • Flare dispersion model using Pasquill method (by P.M. Ullman) • Al Schulz joined the Air Pollution Control Section, Environmental Health Services, Department of Health 1969 • Air Pollution Control at Gas Processing and Sulfur Recovery Plants set out major policies that became the foundation of the air quality management program in Alberta • National Air Pollution Surveillance (NAPS) Network established to assess the ambient air quality in urban areas throughout Canada 1970 • Environment Conservation Act established the Environment Conservation Authority to conduct a continuing review of policies and programs make recommendations and hold public hearings • ERCB information letter IL-70-11 (March 4) communicated the ERCB’s assumption of further responsibilities with respect to pollution and environmental control related to drilling and production operations in the oil and gas industry • ERCB information letter IL-70-33 (July 24) outlined responsibilities of the Department of Health and the ERCB with respect to environmental control at natural gas processing plants • First published plans for air monitoring in Alberta 1971 • Department of the Environment Act enumerated Minister’s responsibilities • Clean Air Act empowered Environment Minister to make regulations and specified authority of Director of Standards & Approvals and Director of Pollution Control • Energy Resources Conservation Act created the Energy Resources Conservation Board (ERCB) with a mandate that now included control of pollution • The Alberta Environmental Research Trust Act established a corporation for provincial expansion of applied and fundamental research relative to environmental improvement • Clean Air Regulations (AR 299/71) specified information to be submitted to Director for approval of an industrial plant • Air Contaminant (Maximum Levels) Regulation (AR 303/71) set out visible emission methods, particulate emission standards , and general requirements • ERCB Informational Letter 71-29 Sulphur Recovery Requirements for Gas Processing Operations 1972 • ECA published Environmental effects of the operation of sulphur extraction gas plants in Alberta: Report and Recommendations from extensive public hearings • AENV issued first approval (72-AP-082) to Anderson Exploration, Dunvegan, a sweet gas plant, on September 7 • Standards & Approvals Division published Gas Processing Plant Standards: Air pollution control and emission standards for new and existing plants. December 21 • ERCB IL-OG-72 -20 Environmental Monitoring Program for sour gas plants • The Alberta Air Quality Index became operational in Edmonton and Calgary • The Alberta Petroleum Industry/Government Environment Committee (APIGEC) formed • Tar Sands Processing Plants Standards: Air Pollution Control and Emission Standards for New and Existing Plants published 1973 • Clean Air Regulations (AR 33/73) separated approvals into construction permits, operating licences and amendments • Clean Air (General) Regulations (AR 34/73) listed responsibilities for the Director of

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Pollution Control and the Director of Standards and Approvals • Clean Air (Maximum Levels) Regulation (AR 10/73) added maximum permissible concentrations in the ambient air • Alberta Government/Industry Sour Gas Environmental Committee created • First emissions inventories for urban modelling: Inventory of air pollution sources and emissions in the city of Edmonton, 1971 and Inventory of air pollution sources and emissions in the city of Calgary, 1971 • Air monitoring service shop established in Edmonton • Randy Angle was hired as the department’s air pollution meteorologist • Research Secretariat established • First sour gas well blowout to garner widespread public attention (New Norway) 1974 • Stop Order Appeal Regulations (AR 9/74 granted the right to appeal a Ministerial stop order to the Environmental Conservation Authority • Natural Gas Processing Plant Delegation Regulations (AR 88/74) assigned the powers of the Director of Pollution Control to the ERCB for natural gas processing plants • Thermal Electric Power Plant Delegation Regulations (AR 89/74) assigned the powers of the Director of Pollution Control to the ERCB for thermal electrical power plants • ERCB Informational letter IL-OG-74-5 Sulphur Recovery and Sulphur Dioxide Emissions at Gas Processing Plants Guidelines • AMD-74-1 Consolidated Air Monitoring Directive • Edmonton urban model verification field study • Environment Canada instrumented two towers in Edmonton, and re-instrumented the AENV tower in Calgary • First Emission Control Order served on Tollestrup Construction • Harby Sandhu joined the Research Secretariat • A Report by the Alberta Industry-Government Sour Gas Environmental Committee on Guidelines for Urban Development in Relation to the Sour Gas Industry 1975 • Clean Air (Maximum Levels) Regulations (AR 218/75 ) replaced Regulation 10/73 to provide greater clarity with additional definitions and more specific wording • Clean Air (General ) Regulations (AR 216/75) expanded the 1973 Regulation and included the prohibition of certain releases and definition of restricted burning areas around Edmonton and Calgary • Calgary urban model verification field study • The Alberta Oil Sands Environmental Research Program (AOSERP) created as a partnership between AENV and Environment Canada 1976 • Guidelines for Limiting Contaminant Emissions to the Atmosphere from Fertilizer Plants and Related Industries in Alberta • Source Sampling Code: Reference Methods for Source Sampling and Analysis of Particulates, Sulphur Oxides and Oxides of Nitrogen • Air Monitoring Directive, AMD-76-1 Sour Gas Industry (superceded AMD-74-1). • Urban model reports: Application of an air column trajectory pollution model to the city of Edmonton and Application of an air column trajectory pollution model to the city of Calgary • ERCB Informational Letter IL-OG-76-24 Stack Exit Temperature for Acid Gas Incinerators Associated with Gas Processing Plants 1977 • Alberta Regulation 224/77 established a program for the certification of visible emission

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readers with reference to a department publication A Manual for Training and Certification of Observers and Evaluation of Visible Emissions • Alberta Regulation 334/77 applied emission standards for stationary asphalt plants to portable asphalt plants • Guidelines for the Location of Stationary Bulk Ammonia Storage Facilities • Environmental Control Guidelines for Asphalt Paving Plants • The Environment Council Act narrowed the scope of the former Authority to inquiries or public hearings specifically requested by the government • AMD-77-1 Power Generating Industry, and AMD-77-2 Wood Products Industry • Ellerslie air pollution meteorological station began collecting data • Sour gas well blowout in Drayton Valley area 1978 • Alberta Regulation 167/78 introduced emission standards for secondary lead smelters and referenced The Alberta Stack Sampling Code • The Index of the quality of air (IQUA) was developed by a federal-provincial committee • First modelling guidelines: Guidelines for Plume Dispersion Calculations introducing three computer programs replacing the Dept of Health programs • Air Monitoring Directive, AMD-78-2, Petroleum Refining Industry • First operational sulphur deposition model: Derivation of first order estimates of Sulphur Deposition in the region of representative point sources • Environment Canada discontinued the meteorological tower network • APIGEC publication: H2S Isopleth Prediction, Phase I: Model Sensitivity Study. 1979 • Alberta Regulation 319/79 introduced source performance standards for vinyl chloride and polyvinyl chloride plants and revised the maximum permissible concentration for oxidants, given Alberta’s high background levels • AMD-79-1 Fertilizer Industry • AMD-79-3 Source Emissions Survey Report Format • AMD-79-4 Cement Manufacturing Industry • ERCB IL-79-22 Revised Environmental Monitoring Requirements for Plants Processing Sour Gas • ERCB IL-79-16 Revised Incinerator Stack Exit Temperature Criteria for Plants Processing Sour Gas • Environment Canada withdrew from AOSERP • APIGEC publication Hydrogen Sulphide Isopleth Prediction Phase II: Pipe Burst Study, April 1979 1980 • Alberta Regulation 215/80 exempted portable incinerators from the General Regulations • AMD-80-2 (superceding AMD-76-1) Reporting and Air Quality Monitoring Requirements for the Sour Gas Industry. • ERCB (and AENV) IL 80-24 Sulphur Recovery Guidelines, Gas Processing Operations. • The Western and Northern Canada Long-Range Transport of Air Pollution (WNC-LRTAP) program initiated • Federal-Provincial Committee on Air Pollution developed a Canadian Index of the Quality of the Air (IQUA) which replaced the Alberta Index • Research Management Division formed from the combination of the Research Secretariat and the provincial components of the Alberta Oil Sands Environmental Research Program (AOSERP)

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1981 • Amendment to the Alberta Environmental Research Trust Act added “development” to the research support mission • Air Quality Measurement Laboratory (AQML) purchased 1982 • Alberta Regulation 342/82 removed restricted burning areas from the General Regulations • ERCB publication: Sour Gas Processing in Alberta: A Review of Evidence Presented at Recent ERCB Hearing Respecting the Impacts and Surveillance of Sour Gas Plants • ECA publication: Environmental Standards: A Comparative Study of Canadian Standards, Standard Setting Processes and Enforcement. • Lodgepole sour gas well blowout occurred from October 17 to December 23 • AQML and other mobile monitoring used to monitor ambient concentrations during Lodgepole sour gas well blowout • APIGEC publication: Compressor exhaust chemistry and wake diffusion 1983 • Guidelines for Design and Operation of Refuse Incinerators in Alberta • amendment to the Clean Air Act to clarify the availability of industry monitoring information to the public • APIGEC’s Acid Deposition Research Program (ADRP) began • APIGEC publication: NOx Control Technology for Compressor Engines in Alberta 1984 • Alberta Regulation 40/84 removed the half-hour maximum permissible concentrations for sulphur dioxide and hydrogen sulphide • Alberta Regulation 407/84 added hazardous waste facilities to those requiring permits and licenses • Release of Monitoring Information Order (AR 403/84) provided an application form for the release of information • Emission Guidelines for Fossil Fuel Fired Thermal Power Generating Plants in Alberta • Air quality model review with recommendations on how the modelling program should proceed 1985 • ECA publication: Alberta’s Clean Air Act: Conclusions and Recommendations of the Review of the Clean Air Act. • ADRP emissions inventory and air quality monitoring stations inventory 1986 • Alberta Regulation 24/86 exempted small sweet gas plants from approvals • ERCB IL 86-2 concerning the exemption of sweet gas processing plants from applying for permits and licenses under the Clean Air Act • ERCB publication: A trace element emission study at selected sour gas plant incinerator stacks in the province of Alberta. • Ellerslie air pollution meteorological station decommissioned • APIGEC’s Acid Deposition Research Program (ADRP) ended • The Southwestern Alberta Medical Diagnostic Review completed 1987 • Uncontrolled release of ammonia from a Calgary fertilizer plant impacted a number of people • ERCB received GASCON, a model for evaluating sour gas hazards • ADRP emissions inventory publications summarized in: Overview of the Emission Data: Emission Inventory of Sulphur Oxides and Nitrogen Oxides in Alberta 1988 • An Action Plan for Environmental Law Enforcement in Alberta • ERCB IL 88-5 Application for Approval of Natural Gas-Driven Compressors • ERCB IL 99-13 Sulphur Recovery Guidelines for Sour Gas Plants in Alberta

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• User’s manual for Alberta environment dispersion models provided five models for personal computers: • AENV’s mission changed from “balance environmental preservation against resource development” to “achieve the protection, improvement, and wise use of Alberta’s environment now and in the future” • The California SMOG model was applied to Edmonton and the Lindburg heavy oil area • Research Management Division eliminated • Measurement of Stack Emissions for Total Reduced Sulphur Compounds from Pulp and Paper Operations 1989 • Air Monitoring Directive: Monitoring and Reporting Procedures for Industry • Guidelines for Atmospheric Dispersion Modelling in Alberta published after public review of the draft 1987 guidelines 1990 • Clean Air Strategy for Alberta, a broadly based, public consultation process on energy and air quality • ERCB received GASCON2, updated after conducting a field verification program 1991 • Reference Method for Source Testing: Measurement of Emissions of Total Reduced Sulphur Compounds from Sour Gas Plants • Plume Dispersion in Alberta • WNC-LRTAP ended 1992 • The Environmental Protection and Enhancement Act • Alberta Environment became the Alberta Department of Environmental Protection with added responsibilities for forests, fish and wildlife, parks, public lands and protected areas 1993 • Substance Release Regulation (AR 124/1993) • The Ozone Depleting Substances Regulation (AR 125/1993) • Release Reporting Regulation (AR 117/93) • The Comprehensive Air Management Framework for Canada created the National Air Issues Coordinating Mechanism • Dept of Environmental Protection regionalized all services into six regions 1994 • Clean Air Strategic Alliance (CASA) formed after Clean Air Strategy for Alberta recommendations accepted by the Government of Alberta. • Environmental Quality Monitoring Branch was dissolved and air monitoring moved to the new Air Issues and Monitoring Branch • First operational Regional Lagrangian Acid Deposition model (RELAD) developed for AENV by the Alberta Research Council 1995 • Environmental Statutes Repeal Act eliminated the Alberta Environmental Research Trust and the Environment Conservation Authority • Alberta Energy and Utilities Board (EUB) created by merging the Energy Resources and Conservation Board (ERCB) and the Public Utilities Board (PUB) • Alberta Stack Sampling Code (revised version of the 1976 Alberta Environment Stack Sampling Code) • CASA strategic plan for air quality monitoring in Alberta • First zone air quality group, West Central Airshed • Air Quality Model Guidelines finalized from a 1994 draft replacing AENV models with USEPA models and standardized procedures for application 1996 • Management of industrial sulphur dioxide and nitrogen oxides emissions in Alberta –

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description of the existing system. • Wood Buffalo airshed formed in Fort McMurray area • Alberta Environmental Centre transferred to Alberta Research Council; some research funds retained by AENV and managed by Users Groups 1997 • ERCB Informational Letter 97-04 Emissions from Glycol Dehydrators-Benzene • Mobile Air Monitory Laboratory (MAML) replaced AQML • CASA implementation plan for cooperative air quality monitoring network • Parkland airshed formed in Rocky Mountain House area • Fort airshed formed in Fort Saskatchewan area 1998 • Air Quality Criteria for Sour Gas Processing Industry: A Summary • Air Toxics Management Program in Alberta • Continuous Emission Monitoring System (CEMS) code • Standards & Approvals Division became the Environmental Sciences Division under David Spink; air quality subsumed into Industrial Program Development Branch and Science and Technology Branch with monitoring in the Environmental Assessment Division 1999 • The Department of Environmental Protection reverted back to the Department of the Environment, shedding the extra responsibilities from the 1992 merger • EUB Guide 60: Upstream Petroleum Industry Flaring Guide. • Provincial Policy ES-99-PP4, Application of critical, target, and monitoring loads for the evaluation and management of acid deposition • Provincial Policy ES-99-PP5, Ambient air quality guidelines for ethylene. • Peace airshed formed in the Peace River-Grande Prairie area 2000 • Ozone-depleting Substances and Halocarbons Regulation (AR 181/2000) • Lakeland airshed formed in Cold Lake-Bonneville area 2001 • Interim Directive ID 2001-3 Sulphur Recovery Guidelines for the Province of Alberta, updated the guidelines after a stakeholder review process • Environmental Sciences Division became the Science and Standards Division under Bill Macdonald with an Air Quality Branch under Randy Angle • Alberta’s joint industry-government ethylene crop research project completed; results used to finalize air quality objective for ethylene 2002 • AENV organizational unit titles were downgraded: Service to Division, Division to Branch, Branch to Section, Section to Group 2003 • AENV replaced the dust and smoke component of IQUA with a fine particulate matter component and renamed the index the air quality index (AQI) • Emergency/process upset flaring management: modeling guidance • Palliser airshed formed in Medicine Hat area 2004 • The Ozone Depleting Substances and Halocarbons Regulation further amended (AR132/2004) • Air quality again disappeared as Environmental Policy Branch replaced Science and Standards with Sections for Policy Integration, Systems Development and Science & Innovation • All research programs and Users Groups were terminated 2005 • Alberta Emission Standards for Electricity generation and Alberta air emission guidelines for Electricity Generation. • The National Air Issues Coordinating Committee on non-climate change air issues (NAICC- A) disbanded on March 31

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• Calgary airshed formed in Calgary area 2006 • Emission Trading Regulation (AR 33/2006) • Mercury Emissions from Coal-Fired Power Plants Regulation (AR 34/2006) • EUB Directive 060. Upstream Petroleum Industry Flaring, Incinerating, and Venting. November 16, 2006. • Capital airshed formed in Edmonton area • WISSA publication: interprovincial Western Canada Study of Animal Effects Associated with Exposure to Emissions from Oil and Natural Gas Field Facilities with results of massive 6-year study

2007 • Interim Emission Guidelines for Oxides of Nitrogen (NOx) for New Boilers, Heaters and Turbines using Gaseous Fuels for the Oil Sands Region in the Regional Municipality of Wood Buffalo North of Fort McMurray based on a Review of Best Available Technology Economically Achievable (BATEA) • Environmental Policy Branch restructured into a number of media-specific policy business units reporting directly to the ADM 2008 • Air Management Strategy for Alberta Environment • Air Policy Business Unit subsumed into the Climate Change, Air and Land Policy Branch 2009 • Air Management in Alberta gave a full description of the Alberta industrial and regional air management systems • CASA developed a new ambient air monitoring strategy for Alberta 2010 • Canadian Council of Ministers of the Environment publication Comprehensive Air Management System: A Proposed Framework to Improve Air Quality Management

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Appendix B. Individuals Who Worked in Air Quality Management

(From an original list compiled by John Torneby and Serge Dobko circa 1995, with additions by Randy Dobko and the author)

Name Work Areas Abdalgawad, Emad source standards Aitken, Lena air technologist support Albert, Marilyn station operations—Edmonton; industry data report review Aldi, Rick stack sampling Allerie, Norm station operations Alseth, Brian stack sampling Anderson, Debbie office Angle, Randy dispersion meteorology & modelling; air issues & monitoring branch; air science & standards branch; air policy leader Angotti, Ralph trailer operations Armitage, Patricia assistant deputy minister’s office Asquin, Dave data analysis & reporting; computing support Ayers, Jamie ambient objectives Bannerjee, Amit source standards Barrett, Randall air issues; regional planning; regional management Bates, Laurie air data analysis student intern Bayard, George electronics shop; mobile monitoring Beaty, Bob air standards and approvals Begoray, Larry air quality control; standards & guidelines; pollution prevention Benders, Harry electronics shop; mobile monitoring; station auditing Bensler, Dave trailer operations; station operations--Calgary Berring, Herb trailer operations; station operations Berry, Dene investigations branch head Bertram, Henry air analysis laboratory, Vegreville Bioletti, Rob emissions inventory Blair, Laura ambient objectives development Blower, Lloyd research Bodie, Grant trailer operations (Health Dept) Bohay, Dwight stack sampling Bollo-Kamara, Arthur chemical investigations Boyko, Ed trailer operations; station operations--Edmonton Brassard, Ray noise monitoring; electronics shop; station auditing Brennand, Michael research; computer modelling Breckenridge, Will electronics shop Briggs, Bob pollution control director Buck, Wayne trailer operations--Whitecourt Bushey, Vern station operations--Fort McMurray (AOSERP) Byrne, Christine air data analysis student intern Calder, Bill environmental relations; environmental strategies

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Chan, Casey regional approvals; policy development Cheng, Lawrence air issues; deposition modelling; policy development Childs, Frank trailer operations Chodak, Marilyn network support Chomlak, Kerra air data analysis student intern Choukalos, Mitchell computer programming Clayton, Andrew ambient data analysis Coxen, Jeff electronics shop Crumb, Dan air standards and approvals Crumb, Kevin air standards and approvals Das, Nirmal air analysis laboratory, Vegreville Davies, Chris electronics shop Dean (Pico), Connie office Defir, John standards & approvals director DeRossi, Pablo computers Dobko, Randy special projects; stack sampling; source standards; air policy Dobko, Serge air pollution section (Health Dept); air standards & approvals branch head Duchesneau, Yvette office support El-Ali, Labib ambient objectives Eliuk, Murray station operations--Edmonton Feschuk, Gerald air quality control Ferguson, Bob pollution control (Health Dept) Fletcher, Leanne office support Flett, Jillian compliance branch head; environmental strategies Flipsen, Peter station operations—Fort McMurray (AOSERP) Foster, Ken ambient objectives Freeman, Phil dispersion model coding Fu, Long ambient objectives; science & technology Glasere, V laboratory (Health Dept) Godin, Joe meteorological measurements Gregory, Marshall stack sampling Gupta, Krishna gas chromatography Hackett, Jim air quality control Hamre, Anne ambient data reporting Hansen, Kurt air standards & approvals Hartman, Caroline acid deposition Hartt, Doris air standards & approvals Hartwell, Phil trailer operations, pollution control (Health Dept) Hennessey, Christine office support Hogge, Harvey environmental health services director (Health Dept); standards & approvals director Hudson, Jackie station operations--Calgary Huang, Robert industrial wastes Hui, Ernie summer stack sampling; environmental assurance assistant deputy minister

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Idriss, Ahmed dispersion modelling; source standards Jacobs, Joan ambient data reporting Jaferi, Jafir air standards and approvals Jardine, Ron trailer operations Johnson, Les air standards and approvals Kastelen, Bill pollution control (Health Dept) Kemp, Rob air standards & approvals Kemper, Bryan environmental quality monitoring branch head; standards & guidelines branch head Keenan, Terry pollution control (Health Dept) Keys, George meteorological measurements Kish, Dorothy report data entry Knapp, John environmental assurance assistant deputy minister Knudson, Wayne trailer operations Kortch, Bill pollution control laboratory manager Kostler, Joe air standards and approvals Krishmanswami, G.K pollution control (Health Dept) Kryviak, Lawrence trailer operations Kupchanko, Eugene pollution control (Health Dept); environmental protection assistant deputy minister Kupina, Don station operations--Edmonton Lack, Jerry air pollution control (Health Dept); air quality control branch; standards & approvals director; chemicals assessment & management director Lau, Yan data quality assurance Law, Emery trailer operations, pollution control (Health Dept) Lee, Rick air quality control Leete, John parts and supplies Lehman, Shelley complaint line Leszcynski, Yolanta air quality control Levitt, Ryan stack sampling Liu, Chow Seng air standards and approvals Livingstone, Scott air quality control Lockhart, Lynn office support Lotz, Frank air quality control Lukinuk, Kent stack sampling; station operations--Edmonton Lyder, David dispersion modelling Macdonald, Bill air quality control; air emissions branch head; science & standards director Magill, Bonnie research Manji, Shahin industry report review Marsh, Chris electronics shop Martindale, Steve air quality control McGuiness, Liz industry report review McKinnon, Stu station operations--Fort McMurray (AOSERP) Megley, Collen station operations

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Munkholm, Gordon air quality control Murphy, George standards & guidelines; pollution prevention Montpellier, AI stack sampling; investigations Mueller, Bettina approvals; monitoring, air policy development Myrick, Bob research management; data analysis & reporting; air policy evaluation Olson, Eric air standards & approvals technologist support Onuczko, Dave air quality control; investigations Papirnik, Patty research Parrell, Crystal ambient data analysis Parsons, Shannon stack sampling Peck, Gurdon trailer operations, pollution control (Health Dept); technical support--Calgary Phaneuf, Rick air quality control Pilger, Kevin station operations--Fort McMurray Popoff, Craig summer asphalt plant inspections Poulette, Albert stack sampling; investigations Powell, Fred trailer operations; air standards & approvals technologist support Priest, Kristin CEMS code implementation Primus, Carl environmental protection assistant deputy minister Redden, Faye data management Redman, Joan office support Ricci, Matilda regional approvals; air policy development (Matty) Richards, Alwyn asphalt plant inspection Rolston, Jim pollution control (Health Dept) Ross, Janine station operations--Edmonton; air policy evaluation Sandhu, Harby research; strategy Sakiyama, Steve dispersion modelling Schneider, Darlene office support Schnitzler, Bill air quality control Schulte, Fred environmental assessment director; pollution control director Schulz, AI stack sampling; air quality control, pollution control director, environmental regulatory assistant deputy minister Schutte, Alex dispersion modelling Shannon, David stack sampling Shaw, Terry network support--Edmonton Shelly, Neil air standards and approvals Simons, Caroline air quality control Singh, Charanjit air quality control Singh, Kem regional approvals Slubik, Dave dispersion modelling; emissions inventory Smith, Ken environmental protection assistant deputy minister Smith, Stuart research management director Snider, Craig station operations--Fort McMurray (AOSERP)

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Spackman, Tim station operations--Calgary Spink, David environmental sciences director Spruit, Nick trailer operations; station operations--Calgary Stang, Luke trailer operations, pollution control (Health Dept); trailer operations- red deer (environment) Stetson, Ross laboratory (Health Dept); stack sampling; air standards & approvals Stiles, Karen office support Stokes, Dennis standards & guidelines; air science Strosher, Mark air quality control; alberta oil sands environmental research program (AOSERP) Swabey, Darcy stack sampling Tapics, Tara ambient objectives student intern Torneby, John trailer operations, pollution control (Health Dept); station operations--Calgary; technical services manager Truch, Peter data analysis and reporting; emissions inventory Tupper, Doug environmental service assistant deputy minister Ullman, Phil air pollution control (Health Dept); air quality control- Calgary Valupadas, Prasad regional approvals; science & technology Vest, Richard stack sampling Vigfusson, Dianne office support Volo, Gary station operations--Calgary Wallace, Dave electronics shop Walten, George electronics shop Warren, Bob stack sampling Watson, Peter environmental assurance assistant deputy minister Witthoeft, Frank air standards & approvals Wong, Doug air standards & approvals Yee, Bev environmental assurance assistance deputy minister; environmental relations assistant deputy minister Young, Vic air standards & approvals

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Appendix C. Photographs of Some of the People Listed in Appendix B

Begoray, Larry (1982) Barrett, Randall (1998) Air Quality Control Bertram, Henry Air Issues Air Analysis Laboratory

Briggs, Bob (1984) Cheng, Lawrence (1998) Pollution Control Crumb, Dan Air Issues Director Approvals

Defir, John (1984) Eliuk, Murray (1996) Standards & Approvals Dobko, Randy (1998) Station Operations Director Approvals

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Foster, Ken (2000) Fu, Long (1998) Ambient Objectives Ambient Objectives Kemp, Rob (1998) Approvals

Kemper, Bryan (2000) Kupchanko, Eugene Environmental Quality Leszcynski, Yolanta (1979) Environmental Monitoring (1986) Protection Assistant Air Quality Control Deputy Minister

Macdonald, Bill (1997) Martindale, Steve Air Emissions Leavitt, Ryan (1982) (1983) Stack Sampling Air Quality Control

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Myrick, Bob (1998) Data Analysis & Montpellier, Al (1983) Murphy, George (1998) Reporting Stack Sampling Standards & Guidelines

Poulette, Albert (1982) Powell, Fred (1999) Redman, Joan (1998) Air Quality Control Trailer Operations Office Support

Ross, Janine (1979) Schnitzler, Bill (1977) Station Operations Singh, Charanjit (1979) Air Quality Control Air Quality Control

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Stokes, Dennis (1998) Slubik, David (1993) Spink, David (1999) Standards & Guidelines Dispersion Modelling Environmental Sciences Director

Wong, Doug (1996) Approvals

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Appendix D. Summary of Findings and Recommendations of the Environment Conservation Authority Sour Gas Hearings (1972)

People and the Gas Plants

…because the sulphurous gases do smell and do have toxic properties, the attractive and desirable natural setting of farmers and ranchers…may have become less desirable surroundings. To the extent that this has been so there has been an undue burden and disadvantage to some individuals. …common to all those who have suffered…is a sense of unending and profound frustration. They have not been able to get anyone to believe that they actually have a problem, that they actually are smelling bad smells, suffering from the toxic effects of the gases to which they are exposed, and losing many of the values and delights of the life they had had in their scenic settings…The public opinion survey showed that 66% of those interviewed in the general Alberta sample wanted stricter air pollution standards for the sulphur plants and this figure rose to 83% for those living within 10 miles of a gas plant.

Recommendations • That the fact be accepted that the emanations from sour gas wells and from sulphur extraction gas plants have properties than can be often inimical…to the health and well-being of men and other living species, and that the complains of individuals…be taken seriously. • That personnel in industry be encourage to be attentive to the relevant complaints of citizens in the vicinities of sulphur extraction gas plants. • That employees in departments and agencies of government be particularly enjoined to adopt the attitude that the complaints of citizens in the vicinities of sulphur extraction gas plants can have validity and that all reasonable steps be taken to assist the citizen in establishing and proving his complaint. • That personnel in industry and in government agencies develop and maintain close liaison with individuals who reside in potential problem areas.

Legal Implications

…citizens are at a distinct disadvantage in proving the cause of debilitation of health or property to the satisfaction of the courts. The technical aspects of environmental investigations require expertise and finances beyond the capability of most private citizens, and legislation is lacking which provides the public with either investigative or monetary assistance. …There have been a number of court case involving environmental damage claims against sulphur extraction gas plants, including substantial out- of-court settlements…Such legal confrontations are not conducive to a complete disclosure of facts and information; nor are they likely to result in solutions for the benefit of the general populace…Nevertheless, if the rights of individuals are to be adequately protected there must be meaningful legal recourse on matters of environmental pollution.

Recommendations • That government undertake a comprehensive assessment of the legal and financial constraints on citizens involved in court actions relating to environmental pollution; • That consideration be given to changing the legal code on the basis of the above assessment and an evaluation of the effectiveness of legislation in other provinces and countries;

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• That environmental impact statements that take into account health and other effects on individuals be required of industry before new sulphur extraction gas plants or major alternations to existing ones are approved.

Ambient Air Quality

Sulphurous gases have affected living system in Alberta.

Recommendation • That ambient air quality be maintained at a level which, as far as possible, is consistent with lack of direct effects on humans, or on plants or animals, ...and that regular review of standards reflect improvements in knowledge of short-and long-term effects and improvements in technology be carried out.

Meteorological and Terrain Effects

Much discussion centred on the reliability of the application of standard formulae under radically differing conditions of temperature, wind velocity, turbulence, or to other factors which could affect plume integrity.

Recommendations • That the validity of the formulae currently used to calculate the dispersal of stack effluents be re- examined under actual condition …in Alberta, and that use be made when appropriate, of the recently developed computational models for the dispersion of gases in unique environments; • That the design and location of sour gas treatment plants take into account known or suspected anomalies in meteorological conditions; • That due regard be paid to the extreme variability in weather patterns to be expected annually at any location in Alberta; • That suspected or documented cases of fumigation by stack effluents should result in expanded monitoring programs; • That whenever possible new plants should be located where problems of terrain and meteorology do not present undue hazards to society.

Soil – Effect of Gaseous Effluent

No data appear to exist which give detailed accounts of the possible effects of sulphurous gases on soils.

Recommendations • That a soil survey be designed to catalogue the soil types and sulphur status of soils in the vicinity of sulphur recovery plants; • That any change in soil sulphur content be carefully monitored as a safeguard against excessive buildup.

Soil – Sulphur Dust

Evidence is available that sulphur dust in the vicinity of sulphur recovery plants may be present in such amounts that soil in the area may be rendered sterile.

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Recommendations • That every precaution be taken ensure that soils are not impaired by sulphur dust spread; • That soils in the vicinity of sulphur recovery facilities be routinely monitored for acidity as well as for sulphur content as an operating requirement of the sour gas industry; • That where soil has been adversely affected by sulphur deposition, suitable reclamation procedures be adopted.

Corrosion

A number of farmers and other residents of the areas surrounding the sulphur extraction gas plants related experiences of severe corrosion damage to their equipment…fence wire…agricultural implements, electrical switchgear, and the exterior paint on their houses and farm buildings.

Recommendation • That studies be undertaken by sulphur extraction gas plants to determine corrosive effects of their gaseous emissions.

Monitoring and Control – Stacks and Flares

To monitor the concentrations of sulphur gases near gas treatment plants is a complex problem. Exposure cylinders have been used to monitor ambient concentrations of hydrogen sulphide and of sulphur dioxide…Sulphur dust-fall monitors are also used…in the immediate vicinity of sulphur stockpiles. Trailers that contain air monitoring devices are a more recent introduction… they are equipped to provide continuous measurement of ambient air constituents at any given spot. Although they can be moved from place to place, the trailers require a power source for their operation, and at about $15,000 each, are relatively costly.

Recommendations • That measurements of ground level concentrations of sulphur gas from sour gas plants be designed in such a manner as to be directly co-related with plant practices and weather conditions; • That effects of ground level concentrations be related to immediate effects, as noticed by people, as well as to longer term effects on vegetation and animals; • That information be gathered…not only for normal plants operations but also for plant upsets.

Monitoring and Control – Ambient or Ground Level Controls

It is suggested that two points are self-evident: (1) Control of sulphur dioxide concentration as it leaves the gas plants can be most practically and effectively done by measurement and control of the sulphur dioxide concentration in the incinerator stack. (2) Determination of the environmental effects of the operation of sulphur extraction gas plants…can be determined by the reactions of animals and green plants themselves, and by monitoring the air.

Recommendations • That…concentrations of gases be monitored both at the point of emission...and at suitable points at ground level outside the plant; • That permissible concentrations for sulphur dioxide be set in the stack and at ground level;

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• That addition appropriately detailed calculation be employed to relate the permissible stack concentrations to the permissible ground level concentrations in areas where meteorology and terrain present particular problems. • That both ambient air quality standards and stack emissions concentration standards be reviewed regularly; • That...dilution methods which involve the burning of extra quantities of sweet gas be de- emphasized; • That …biological sensors as well as chemical and mechanical sensors should be employed. • That monitoring programs…be designed in such a fashion that comparisons can be made on a statistically supportable basis; • That monitoring stations for ground level concentrations should ...record…on a continuous basis; • That all plants be required to upgrade their in-plant, on-site and off-site monitoring systems to the level of the best available in the industry at any given time; • That government should provide a sufficient number of qualified field inspectors; • That inspectors should make their inspections at irregular intervals and give no advance notice; • That where more than one gas plant has to be located within a given area, adequate spacing be provided in order to avoid the additive effect of their effluents.

Field Flaring

When sour gas is fed to the flare the odour of hydrogen sulphide can often be detected in the area. This is an indication that the hydrogen sulphide has not been completely burnt while passing through the flare. As well, flares have been known to be extinguished under certain conditions and …to discharge uncombusted sour gas to the atmosphere.

Recommendations • Further unitization …be encouraged in order to keep the number of flare stacks to a minimum; • That the technology of flame lighting and maintaining the flame in flare stacks be improved to prevent flame burnout; • That reliable automatic re-ignition systems be a requirement of all stack systems; • That improvements be made in the design of flare stacks in order to achieve improved combustion efficiency under all operating conditions; • That improved surveillance methods be instituted for flare stacks operating at …remote locations so that abnormalities can be promptly detected; • That adequate, all-weather access …be installed to provide quick access for maintenance personnel and equipment.

Living Systems

Of the several topics discussed at the public hearings, the one which received the most attention was the interaction between gas plant emissions and living systems.

Recommendations • That a comprehensive survey be made by government in representative districts as determined by climate, terrain and geography over the area of potential impact of existing or of proposed sour gas plants; • That …environmental surveys of the same area be repeated about once every five years;

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• That the comparative environmental surveys…be used as a component in decisions leading to site selection.

Living Systems – Human Health

No serious attention seems to have been paid to the long-term effects of low-level exposure, to possible synergistic effects that may occur when several pollutants are present, to the sensitization of individuals or to the special sensitivities that different individuals, age groups or sexes might display.

Recommendations • That medical research…devote some attention to typical unique health problems indigenous to the Province; • That clinical records and evidence as the health history of individuals exposed to these conditions be gathered and studied; • That professionals in the human health field be encouraged to share their knowledge and experience on matters of environmental health for the public benefit. • That a well-balanced research program which looks at the human elements as affected sour gas plants be undertaken; • That the investigative team carrying out this human health and semi-sociological research project be gathered from outside industry and government personnel; • That prior to sulphur extraction plant construction and operation, a thorough investigation of the human situation be carried out.

Living Systems – Health of Animals

If pollutants affect the productivity of domestic animals, then this may be viewed not only as a direct effect on the animal but as an economic disbenefit to the farmer. …Wild animals, like domestic species, are sensitive to many effluents from gas plants and changes in their behavior and population density may be related to pollution levels.

Recommendations • That comprehensive research programs into the effects on animal health and productivity of the operation of sulphur extraction gas plants be undertaken; • That company and government monitoring procedures include a periodic check on the status of indigenous wildlife species; • That local residents be encouraged to report any noticeable effects on domestic and wildlife species in the area of sulphur extraction gas plants.

Living Systems – Vegetation

Because of their ubiquitousness, growing plants offer the best opportunity as indicator species for pollution.

Recommendations • That industry and government cooperate to develop a bioassay monitoring system; • That regular vegetation damage surveys be conducted;

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• That maps showing the relative degrees of damage to vegetation be prepared and used as guidelines for the placement of mobile monitoring facilities.

Living Systems – Crops

A true understanding, however, of the relationship between emissions from gas plants and the quantity and quality of agricultural crops will require comprehensive field studies.

Recommendations • That government and industry undertake comprehensive studies on the effects of sulphurous emissions on agricultural crops commonly grown in Alberta; • That studies be initiative to determine if there are nutritional differences in crops related to emissions from sulphur extraction gas plants.

Living Systems – Trees and Forests

There are a number of sulphur extraction gas plants in Alberta which are located in forested areas of the Province. Although there may be less direct effects on humans… there is no reason to assume that the total environmental impact is any less than for agricultural areas.

Recommendations • That monitoring systems for gas plant effluents in forested areas of the Province be comprehensive and well organized even though the human population may be meagre.

Living Systems – Selenium Deficiency Diseases

Many farmers and some veterinarians in western Alberta attribute the rise in the incidence of White Muscle Disease to emissions from sour gas plants. …The repression of selenium uptake by sulphur is apparently well known.

Recommendations • That studies be undertaken to determine the radial distribution of sulphur emissions form sour gas plants and their effects on the productivity of vegetation, including an analysis of the selenium content; • That veterinarians be required to report the details of all cases of White Muscle Disease or other selenium deficiency diseases to the Department of Agriculture so that proper statistics on incidence and distribution can be accumulated. • That studies be undertaken to determine the selenium concentrations and sulphur/selenium ratios in soils…; • That a study be made of the effect that sulphur dioxide and hydrogen sulphide absorbed from the air through the leaves might have on the selenium content of cereal and forge crops.

Living Systems – Research Requirements

A mechanism is needed to ensure adequate examination of research requirements concerning the environmental effects of sulphur gas plants.

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Recommendations • That research programs be funded by a means which will ensure a continuing flow of information to industry and Government alike. • That environmental research into sulphur gas problems receive funding from industry, from Government at the federal and provincial levels, and from the Alberta Environmental Research Trust; • That all gas plant environmental research papers be placed in the library of the Alberta Department of the Environment; • That continuing discussions be held between the Government and Industry, through the Alberta Industry-Government Sour Gas Environmental Committee.

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Appendix E. Summary of Recommendations from the Environmental Law Enforcement Review Panel (1988)

Standard Setting • Establish a policy to set, review and evaluate environmental standards; • Consideration be given to establishing new standards for compounds which are of concern in Alberta, but for which no standards currently exist; • Issue an annual or biannual State of the Environment Report.

Ambient Air Quality Standards • Because of the problems associated with having unenforceable ambient standards specified in regulations… Part 1 of the Clean Air (Maximum Levels) Regulations be repealed…replaced by a comprehensive set of objectives...contained in a policy which would be developed with input from experts and interested parties and be open for public review; • Air quality objectives be published by Alberta Environment and the performance against these objectives should be publicized; • Licences continue to require major sources of air contaminants to monitor ambient air quality; • Times periods for source emission compliance be compatible with the objective to be attained.

Licensing Procedures • Applications for new and renewed licenses…be made known to the public through a notice in the newspaper; • Senior legal counsel from the Attorney General’s office conduct a review and provide assistance prior to the issuance of all licenses; • A summary of the terms of the license be published in a local paper with full terms available to any member of the public without charge; • Legislation to allow a licensee or the Minister to open up the terms of a license at any time for renegotiation if it is in the public interest to do so. • All licenses be subject to renewal, although the renewal term may vary up to a maximum of ten years; • A license appeal process be established…and a new appeal body be established to hear all appeals of licenses issued.

License Requirements • Each license have maximum emission limits based on emissions levels that could give rise to an immediate danger to human health, life, property or the environment; • Each license contain performance limits based on past performance in the industry, available technology and established standards for that industry; • Upon submission of an application for a license-to-operate, an applicant be required to include a declaration regarding the start-up sequence and/or the timing of start-up of the pollution control equipment for the facility…each applicant…to conduct a worst case assessment for upset situations including a comprehensive response plan; • Each applicant be required to carry out a risk assessment for emergency events which could result in the maximum emission limits being exceeded; • After issuing a permit-to-construct…the Department have the option of issuing a short term, interim license-to-operate for the commissioning period;

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• [start-up and shut-down] waiver clauses be removed and licensees be required to meet the maximum emission limits at all times.

Monitoring Compliance • Consideration be given to making more use of the single measurements to analyze a situation without requiring further monitoring where it is not warranted; • Back-up monitoring, accuracy and service requirements be established [where source monitoring equipment is also a control device]; • Requirements for regional and site specific ambient air monitoring be proportional to the amount and type of air emissions and account for the potential environmental and health effects within affected airsheds; • The unit of measurement stated in the license and the unit of measurement supplied by monitoring equipment should be compatible.

Administrative Responses to Non-Compliance • Develop a formal enforcement policy; • The enforcement policy include detailed criteria for enforcement response giving a clear direction to enforcement officers; • A manual be developed to assist enforcement officers in the practical interpretation of the enforcement policy; • Directives be used only to require that information be submitted. Control orders and stop orders should be used to require that certain action is taken; • Consideration be given to amending the legislation to allow for a new type of order to “suspend” operations…consideration be given to including a general offense provincial in the Clean Air Act similar to section 17 of the Clean Water Act. This would allow for enforcement action against unregulated operations which are a source of pollution; • Adopt [a proposed] enforcement model;

Environmental Enforcement Unit • The mandate of the Pollution Control Division be limited to carrying out enforcement action. All monitoring, abatement and licensing activities should be assigned outside the Pollution Control Division. • The restructured Pollution Control Division consists of two Branches, an Investigation Branch and an Enforcement Branch. Investigative Branch staff have a strong technical background and receive training in collecting legal samples and other investigative skills. Staff of the Enforcement Branch have a strong background in enforcement operations and legal and court proceedings. • [Standards and Approvals Division] in additional to their mandate to issue permits and set source standards…should be responsible for training operators, reviewing ambient monitoring,…reviewing source emission monitoring reports, and referring possible contraventions to the restructured Pollution Control Division for further investigations and potential enforcement action. • The Director of [Pollution Control] Division have...all the necessary technical and scientific analysis to support enforcement operations. This will necessitate a dedication of laboratory services provided by the Alberta Environmental Centre at Vegreville. • Investigation Branch…conduct a comprehensive quality assurance program to ensure that monitoring equipment is properly calibrated and that data submitted by operators is accurate useable for enforcement purposes.

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• An annual report be published which outlines all environmental enforcement actions that have been initiated, the status of these action, the success of the actions and a summary of the record of compliance with the order.

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Appendix F. Organizational Structures and People

Political Leaders

Time Period Minister Department Name Premier 1945-1957 Wallace Warren Cross Public Health Ernest Manning 1957-1967 Joseph Donovan Ross Public Health Ernest Manning 1967-1969 Joseph Donovan Ross Health Ernest Manning/Harry Strom 1969-1971 James Douglas Henderson Health Harry Strom 1971 James Douglas Henderson Environment Harry Strom 1971–1975 William John Yurko Environment Peter Lougheed 1975–1979 David John Russell Environment Peter Lougheed 1979–1982 John W. Cookson Environment Peter Lougheed 1982–1986 Frederick Deryl Bradley Environment Peter Lougheed/Don Getty 1986–1988 Kenneth R. Kowalski Environment Don Getty 1988–1989 Ian Wilson Carlyle Reid Environment Don Getty 1989–1992 Ralph Phillip Klein Environment Don Getty 1992–1994 Brian J. Evans Environmental Protection Ralph Klein 1994–1999 Tyrone O. Lund Environmental Protection Ralph Klein 1999–2000 Gary G. Mar Environment Ralph Klein 2000–2001 Halvar C. Jonson Environment Ralph Klein 2001–2004 Lorne James Taylor Environment Ralph Klein 2004-2006 Guy Boutilier Environment Ralph Klein 2006-2011 Rob Renner Environment Ed Stelmach

Department Executive

Time Period Assistant Deputy Ministers with primary Air Deputy Minister Responsibility 1945-1952 Sanitary Engineering and Sanitation Malcolm R. Bow Division, Department of Public Health 1952-1961 Sanitary Engineering and Sanitation Ashbury Somerville Division, Department of Public Health 1961-1967 Sanitary Engineering and Sanitation Malcolm G. McCallum Division, Department of Public Health 1967-1970 Environmental Health Division, Department of Health Patrick Blair Rose 1971-1983 Eugene Kupchanko, Environmental Protection Services Erwin E. Ballantyne (1971-1975) 1984-1986 Carl L. Primus, Environmental Protection Services Walter Solodzuk (1975- 1987) 1987-1991 Ken R. Smith, Environmental Protection Services Vance A. MacNichol (1987-1992) 1992-1997 Alfred R. Schulz, Environmental Regulatory Services Peter G. Melnychuk

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(1992-1997) 1997-2000 Doug Tupper, Environmental Service Jim Nichols (1997-1999) 2001-2004 Peter Watson, Environmental Assurance Division C. Douglas Radke (1999- 2001); Roger F. Palmer (2001-2002); Ronald J. Hicks (2002-2004) 2005-2006 Bev Yee, Environmental Assurance Division C. Peter Watson (2005- 2008 2006-2008 John Knapp, Environmental Assurance Division C. Peter Watson (2005- 2008) 2008-2010 Ernie Hui, Environmental Assurance Division Jim Ellis

Unit Managers (incomplete after 1998)

Time Period Organizational Unit Heads Directors 1964-1967 Serge Dobko, Pollution Control Section Harvey Hogge, Division of Sanitary Engineering 1967-1971 Serge Dobko, Air Pollution Control Section Harvey Hogge, Division of Environmental Health Services 1971-1988 Serge Dobko, Air Branch, Standards and Harvey Hogge/John Defir, Standards Approvals Division and Approvals Division

Jerry Lack, Air Quality Control Branch, Pollution Bob Briggs, Pollution Control Control Division Division

Dr. Harby Sandhu, Air Team, Research Dr. Stuart Smith/Dr. William Secretariat/Research Management Division McDonald /Dr. Percy Sims, Research Management Division 1988-1994 Bill Macdonald, Air Emissions Branch, Standards Jerry Lack, Standards and Approvals and Approvals Division Division

Bryan Kemper, Environmental Quality Monitoring Fred Schulte, Environmental Branch, Environmental Assessment Division Assessment Division

Dr. Percy Sims, Standards Development Branch, Environmental Assessment Division 1994-1998 Bill Macdonald/Joe Kostler, Air Emissions Branch, David Spink, Air and Water Standards and Approvals Division Approvals Division

Randy Angle, Air Issues and Monitoring Branch, Jerry Lack, Chemicals Assessment Chemicals Assessment and Management Division and Management Division

Bryan Kemper/George Murphy, Environmental Bob Stone, Environmental Criteria Branch/Standards & Guidelines Branch Assessment Division

Dene Berry, Investigations Branch, Pollution Fred Schulte, Pollution Control

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Control Division Division

Jillian Flett, Compliance Branch, Pollution Control Division 1998-2001 Randy Angle, Science and Technology Branch, David Spink, Environmental Sciences Environmental Sciences Division Division

Walter Ceroici, Industrial Program Development Fred Schulte, Enforcement and Branch, Environmental Sciences Division Monitoring Division

Bob Stone, Monitoring Programs Branch, Enforcement and Monitoring Division 2001-2002 Randy Angle, Air Branch, Science and Standards Bill Macdonald, Science and Division Standards Division

Bob Stone, Monitoring Branch, Enforcement and Fred Schulte, Enforcement and Monitoring Division Monitoring Division 2002-2005 Randy Angle, Air Section, Science and Standards Bill Macdonald/Keith Leggat, Science Branch and Standards Branch

John Taggart, Evaluation and Reporting Section, Bob Stone, Environmental Environmental Monitoring and Evaluation Branch Monitoring and Evaluation Branch

David Graham, Air Monitoring Section Albert Poulette, Regional Services 2005-2007 Randy Angle, Systems Development Section, Keith Leggat, Environmental Policy Environmental Policy Branch Branch

Shannon Flint, Policy Integration Section, Environmental Policy Branch

Walter Ceroici, Science and Innovation Section, Environmental Policy Branch Bob Stone, Environmental John Taggart, Evaluation and Reporting Section, Monitoring and Evaluation Branch Environmental Monitoring and Evaluation Branch

Albert Poulette, Regional Services 2007-2008 Randy Angle, Air Policy Business Unit, Direct report to ADM, Environmental Assurance Division Environmental Assurance Division

John Taggert, Evaluation and Reporting Section, Bob Stone, Environmental Environmental Monitoring and Evaluation Branch Monitoring and Evaluation Branch

Hubert Howe, Monitoring Programs 2009-2010 Hamid Namsechi, Air Policy Section Keith Leggat, Climate Change, Air and Land Policy Branch

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Tom Dickson, Monitoring Programs Bob Stone, Environmental Monitoring and Evaluation Branch

Unit staff (incomplete)

Time Organizational Unit Air Staff Period 1964-1967 Pollution Control Section, Division Engineers: R.H. Ferguson, E.E. Kupchanko, D.T. of Sanitary Engineering Keenan, W.A. Kastelen, Jerry Lack (from 1966) Lab Technicians: Gurdon Peck, Emery Law, Grant Bodie, Phil Hartwell, John Torneby (from 1965) Pollution Control Laboratory: W. Kortch, Ross Stetson, V. Glasere, John Leete 1967-1971 Air Pollution Control Section, Engineers: Eugene Kupchanko , Bill Kastelen, Jerry Division of Environmental Health Lack, Al Schulz (from 1968) , G.K. Krishmanswami, Services Phil Ullman Technicians: John Torneby, Gurdon Peck, , Grant Bodie, Phil Hartwell, 1971-1988 Air Branch, Standards and Bob Beaty, Frank Witthoeft, Chow-Seng Liu, Les Approvals Division Johnston, Vic Young, Jafir Jaferi, Gordon Munkholm, Fred Powell Air Quality Control Branch, Admin: Joan Redman Pollution Control Division IT Support: Faye Redden Engineering: Al Schulz (Manager), Mark Strosher , William (Bill) Macdonald, Bill Schnitzler, Charanjit Singh, Larry Begoray, Yolanta Leszcynskii, Dave Onuczko, Steve Martindale, Phil Ullman (Calgary), Randy Dobko Technical: Gurdon Peck/John Torneby (Manager) Edmonton: Ed Boyko, Don Kupina , Kent Lukinuk, Fred Powell, Marilyn Chodak (Albert) Calgary: John Torneby/Gurdon Peck, Dave Bensler, Tim Spackman, Nick Spruitt Fort McMurray: Kevin Pilger, Craig Snider, Vern Bushey, Stewart McKinnon Whitecourt: Wayne Buck Red Deer: Luke Stang Stack surveys: Albert Poulette, Al Montpellier, Ryan Leavitt, Dwight Bohay Shop: Chris Davies, Ron Jardine, Ray Brassard, Jeff Coxen, Harry Benders, George Bayard, Chris Marsh Science: Randy Angle (Manager), Yan Lau, Steve Sakiyama, Joe Godin, Mitchell Choukalos Reporting: Joan Jacob, Dave Asquin Air Team, Research /Research Dr. Harby Sandhu (Manager), Bonnie Magill, Patti Management Division Papirnik, Bob Myrick 1988-1994 Air Emissions Branch, Standards Engineering: Bob Beaty, Frank Witthoeft, Chow-Seng

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and Approvals Division Liu, Neil Shelley, Dan Crumb, Kevin Crumb, Joe Kostler, Fred Powell, Randy Dobko, Larry Begoray Dispersion: Randy Angle (Manager), Steve Sakiyama/Dave Slubik, Phil Freeman, Michael Brennand Air Quality Assessment Section, John Torneby (Manager) , Ed Boyko, Don Kupina, Joe Environmental Quality Monitoring Godin, Stewart McKinnon, Janine Ross, Bob Myrick Branch, Environmental Assessment Shop: Ray Brassard, George Bayard, Harry Benders, Division Will Breckenridge Standards Development Branch, Serge Dobko , George Murphy Environmental Assessment Division 1994-1998 Air Emissions Branch, Standards Chow-Seng Liu, Les Johnson, Vic Young, Randy and Approvals Division Dobko, Kem Singh, Fred Powell, Doug Wong

Air Issues and Monitoring Branch, Admin: Lynn Lockhart Chemicals Assessment and Issues: Randall Barrett, Lawrence Cheng Management Division Network Operations: John Torneby (Manager), Don Kupina, Murray Eliuk, Ed Boyko, Janine Ross, Dave Bensler Reporting: Bob Myrick Shop: Ray Brassard, George Bayard, Harry Benders Standards & Guidelines Branch Larry Begoray, Long Fu, Dennis Stokes, Ken Foster 1998-2001 Science and Technology Branch, Admin : Lynn Lockhart Environmental Sciences Division Air: Dennis Stokes (Manager), Lawrence Cheng, Raymond Wong, Alex Schutte/Ahmed Idriss, Long Fu, Laura Blair Pollution Prevention: George Murphy (Manager), Larry Begoray

Industrial Program Development Randy Dobko, Prasad Valupadas Branch, Environmental Sciences Division

Monitoring Programs, Enforcement Network Operations: Murray Eliuk, Ed Boyko, and Monitoring Division Janine Ross, Dave Bensler Shop: Ray Brassard , George Bayard, Harry Benders Reporting: Bob Myrick 2001-2002 Air and Water Branch, Science and Admin: Lynn Lockhart Standards Division Raymond Wong, Ahmed Idriss, Long Fu, Larry Begoray, Lawrence Cheng, Randy Dobko, Laura Blair Air Evaluation, Evaluation and Bob Myrick (Manager), Chow-Seng Liu, Dave Slubik, Reporting Branch, Environmental Rob White, Janine Ross Monitoring and Evaluation Division Regional Services Murray Eliuk, Ed Boyko, Dave Bensler, Ray Brassard , George Bayard, Harry Benders, Chris Marsh, Warren Grimes 2002-2005 Air Section, Science and Standards Lynn Lockhart, Raymond Wong, Ahmed Idriss, Long

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Branch Fu, Larry Begoray, Lawrence Cheng, Randy Dobko, Laura Blair, Robyn Kuhn Air Evaluation, Evaluation and Bob Myrick (Manager), Crystal Parrell, Dave Slubik, Reporting Section, Environmental Jason Hawirko, Rob White, Bettina Mueller, Richard Monitoring and Evaluation Branch Melick, Andrew Clayton, Janine Ross Air Monitoring/Regional Services Murray Eliuk, Ed Boyko, Dave Bensler, Ray Brassard, George Bayard, Harry Benders, Warren Grimes 2005-2007 Systems Development Section, Raymond Stemp, Raymond Wong Environmental Policy Branch

Policy Integration Section, Long Fu, Larry Begoray, Prasad Valupadas Environmental Policy Branch

Science and Innovation Section, Randy Dobko, Lawrence Cheng, Laura Blair Environmental Policy Branch

Air Evaluation, Evaluation and Bob Myrick (Manager), Crystal Parrell, Dave Slubik, Reporting Section, Environmental Jason Hawirko, Rob White, Bettina Mueller, Richard Monitoring and Evaluation Branch Melick, Andrew Clayton, Janine Ross, Rob Bioletti Regional Services Murray Eliuk, Harry Benders, George Bayard, Al Clark, Warren Grimes 2007-2008 Air Policy Business Unit, Policy Development: Bettina Mueller (Manager), Environmental Assurance Division Randy Dobko, Rob Bioletti, Casey Chan/ Matilda Ricci, Lawrence Cheng, Raymond Wong, Laura Blair Policy Evaluation: Bob Myrick (Manager), Janine Ross, David Lyder, Andrew Clayton, Crystal Parrell, Richard Melick Monitoring Programs; Monitoring, Murray Eliuk, Harry Benders, George Bayard, Al Reporting and Innovation Branch Clark, Shelley Morris, Warren Grimes 2009-2010 Air Policy Section; Climate Change, Policy Development: Bettina Mueller (Manager), Air and Land Policy Branch Randy Dobko, Rob Bioletti, Casey Chan/ Matilda Ricci, Lawrence Cheng, Raymond Wong, Laura Blair Policy Evaluation: Bob Myrick (Manager), Janine Ross, David Lyder, Andrew Clayton, Crystal Parrell, Richard Melick Monitoring Programs; Monitoring, George Bayard, Shelley Morris, Al Clark, Warren Reporting and Innovation Branch Grimes

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Appendix G. Environment Department Logos

Department of Health

Early 1970s

Late 1970s and 1980s

Alberta’s 75th Anniversary (1980)

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Combined Departments (1992-1999)

Lorne Taylor Years (2001-2004)

Alberta Centennial (2005)

2006-2010

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Year Index

1945 ...... i, 3, 17, 122, 125, 152 1946 ...... 1, 3, 125 1947 ...... 1 1952 ...... v, 1, 152 1955 ...... 4, 125 1956 ...... 52, 95 1957 ...... 16, 19, 125, 152 1958 ...... 19, 38, 125 1959 ...... 43, 68 1960 ...... 38, 62, 68 1961 ...... 4, 20, 68, 125, 152 1962 ...... 5, 125 1963 ...... 62, 63, 68 1964 ...... 20, 62, 67, 95, 110, 122, 123, 125, 153, 155 1965 ...... 48, 66, 68, 88, 95, 122, 125, 155 1966 ...... 5, 6, 20, 38, 48, 107, 110, 123, 125, 155 1967 ...... 6, 38, 54, 58, 60, 107, 125, 152, 153, 155 1968 ...... 6, 95, 107, 110, 126, 155 1969 ...... 20, 38, 43, 46, 49, 58, 68, 88, 90, 94, 95, 107, 122, 123, 126, 152 1970 ...... 15, 17, 43, 50, 60, 85, 89, 90, 107, 118, 123, 126, 152 1971 ...... 6, 7, 10, 11, 16, 17, 18, 38, 43, 44, 49, 50, 51, 63, 85, 90, 101, 107, 111, 122, 126, 152, 153, 155 1972 ...... 1, 7, 15, 22, 23, 35, 39, 46, 54, 84, 89, 118, 123, 126, 142 1973 .. 10, 11, 12, 33, 35, 50, 63, 67, 68, 69, 70, 75, 78, 82, 83, 84, 88, 90, 95, 96, 101, 105, 110, 111, 115, 117, 122, 123, 126, 127 1974 ...... 13, 33, 43, 44, 50, 64, 83, 84, 101, 107, 110, 127 1975 ...... 11, 12, 63, 67, 75, 101, 107, 111, 113, 114, 117, 118, 121, 127, 152 1976 ...... 8, 49, 50, 55, 58, 64, 68, 71, 72, 75, 84, 85, 88, 90, 101, 111, 116, 123, 127, 130 1977 ...... 12, 15, 49, 59, 61, 64, 81, 98, 102, 103, 108, 110, 112, 113, 114, 117, 124, 127 1978 ...... 12, 30, 54, 64, 75, 96, 103, 107, 108, 110, 112, 113, 114, 115, 119, 121, 123, 124, 128 1979 ...... 12, 13, 30, 33, 64, 67, 75, 81, 98, 108, 112, 114, 115, 119, 128, 152 1980 ...... 11, 22, 30, 39, 45, 46, 50, 64, 65, 67, 81, 83, 84, 89, 104, 105, 107, 110, 113, 114, 115, 121, 122, 123, 124, 128, 158 1981 ...... 16, 39, 52, 64, 73, 79, 81, 84, 88, 113, 114, 115, 116, 119, 123, 129 1982 ...... 11, 15, 17, 19, 30, 33, 39, 52, 54, 63, 64, 67, 77, 80, 81, 86, 89, 104, 105, 106, 108, 113, 115, 116, 117, 119, 129, 152 1983 ...... 9, 17, 49, 64, 65, 67, 75, 77, 81, 107, 108, 109, 112, 113, 115, 119, 121, 124, 129, 152 1984 ...... 9, 11, 13, 49, 52, 54, 63, 64, 65, 66, 67, 80, 81, 97, 98, 103, 113, 115, 119, 129, 152 1985 ...... 9, 11, 13, 33, 35, 40, 45, 46, 61, 63, 64, 67, 75, 77, 78, 84, 98, 104, 107, 108, 110, 113, 119, 121, 122, 124, 129 1986 ...... 11, 17, 35, 59, 60, 79, 81, 83, 103, 106, 108, 112, 115, 118, 119, 121, 124, 129, 152 1987 ...... 25, 29, 30, 64, 65, 67, 98, 99, 106, 108, 109, 110, 113, 115, 116, 117, 129, 130, 152 1988 ... 29, 30, 33, 35, 39, 42, 44, 46, 49, 50, 51, 58, 64, 65, 67, 85, 90, 91, 92, 94, 98, 102, 106, 108, 110, 112, 115, 116, 121, 122, 123, 124, 129, 149, 152, 153, 155 1989 ...... 79, 81, 84, 85, 89, 99, 108, 110, 123, 130, 152 1990 ...... 23, 35, 37, 39, 40, 44, 45, 48, 49, 64, 65, 67, 79, 92, 99, 106, 109, 110, 115, 119, 122, 124, 130 1991 ...... 36, 37, 45, 53, 58, 60, 86, 89, 106, 108, 109, 112, 115, 123, 130, 152 1992 ...... 13, 30, 35, 36, 40, 52, 75, 91, 94, 104, 106, 108, 115, 130, 131, 152, 159 1993 ...... 13, 14, 32, 40, 42, 45, 61, 86, 105, 108, 116, 130 1994 ...... 16, 35, 37, 39, 41, 46, 48, 60, 75, 76, 86, 90, 91, 100, 105, 108, 110, 123, 130, 152, 153, 155, 156 1995 ...... 16, 32, 36, 37, 58, 62, 63, 86, 87, 89, 92, 105, 118, 123, 130, 133 1996 ...... 26, 27, 32, 34, 37, 46, 50, 62, 63, 74, 76, 86, 87, 100, 105, 116, 118, 120, 121, 130 1997 ...... 35, 37, 60, 79, 80, 81, 87, 88, 89, 91, 92, 94, 100, 117, 131, 152, 153 1998 ...... 23, 27, 37, 41, 45, 46, 47, 56, 58, 60, 67, 79, 87, 91, 100, 103, 131, 153, 154, 156 1999 ...... 37, 40, 45, 50, 79, 92, 94, 96, 100, 117, 131, 152, 153, 159 2000 ...... vi, 13, 14, 19, 30, 34, 37, 44, 45, 47, 50, 52, 64, 65, 66, 67, 75, 79, 91, 92, 94, 95, 100, 103, 106, 107, 113, 116, 117, 119, 120, 123, 131, 152, 153 2001 ...... 34, 35, 36, 37, 41, 45, 50, 52, 57, 92, 117, 120, 131, 152, 153, 154, 156, 159 2002 ...... 29, 37, 41, 45, 48, 55, 64, 116, 117, 118, 131, 153, 154, 156 2003 ...... 33, 37, 82, 83, 92, 100, 116, 117, 131 2004 ...... 1, 14, 31, 37, 42, 57, 66, 81, 86, 92, 117, 131, 152, 153, 159

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2005 ...... vi, 29, 31, 32, 48, 64, 65, 92, 94, 117, 121, 124, 131, 153, 154, 156, 157, 159 2006 ...... vi, 4, 14, 17, 37, 48, 66, 91, 103, 116, 118, 120, 132, 152, 153, 159 2007 ...... 42, 48, 55, 61, 107, 132, 154, 157 2008 ...... 27, 29, 42, 46, 66, 67, 92, 132, 153, 154, 157 2009 ...... 28, 31, 37, 88, 89, 92, 93, 100, 103, 123, 132, 154, 157 2010 ...... i, 38, 42, 86, 92, 93, 94, 123, 132, 153, 154, 157, 159

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