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Environmental Performance Agreement (EPA) with Dow Chemical Canada Inc.
To implement a management strategy for 1,2-dichloroethane (DCE) to minimize emissions at the Fort Saskatchewan, Alberta, production facility and the North Vancouver, British Columbia, distribution facility.
Between Environment Canada and Dow Chemical Canada Inc. (Five-year agreement from October 26, 2001 to October 26, 2006).
In 1994, DCE, also known as ethylene dichloride (EDC), was declared toxic under the Canadian Environmental Protection Act (CEPA) and listed on Schedule 1 of the Act. As a "Track 2" substance under the Toxic Substances Management Policy, DCE requires management throughout its life cycle to prevent or minimize its release into the environment.
In Canada, DCE is used primarily to make vinyl chloride monomer, which is transformed into polyvinyl chloride (PVC) and used in a number of important products like pipes and plastics. DCE is a volatile substance that evaporates about four times faster than water. As a result, most DCE releases are to the air, during manufacturing and storage. For more background information related to DCE, visit: http://www.ec.gc.ca/TOXICS/EN/detail.cfm?par_substanceID=22∥_actn=s1.
In Canada, Dow Chemical is the only producer and a major user of DCE. Dow manufactures DCE in Fort Saskatchewan, Alberta and ships it by rail to its West Coast Distribution Centre in North Vancouver, B.C. for export.
Dow took steps to reduce its emissions of DCE voluntarily between 1989 and 2001, as a member of Responsible Care® under the Canadian Chemical Producers' Association and under Environment Canada's Accelerated Reduction and Elimination of Toxics (ARET) program. Dow had also developed plans outlining procedures for and responses to potential DCE spills or emergencies. When Environment Canada negotiated the 2001 EPA with Dow Chemical, it took this track record into account.
- The development of an environmental management plan for DCE:
Dow committed to preparing, within one year of the date of signing (October 26, 2001), an environmental management plan for DCE. The plan would include emission reduction targets for DCE, an ambient air monitoring program, an environmental emergency plan listing the hazards and preparedness and response measures appropriate for DCE, as well as an audit of results.
- To have the environmental management plan and its targets approved by Environment Canada:
DOW submitted its plan to Environment Canada in 2002. Environment Canada reviewed and accepted Dow's plan, which included the following:
- Scheduled ambient air monitoring in 2002, 2004 and 2006, and audits and facility management reviews in 2004 and 2007 to assess progress.
- Five year, verifiable reductions in DCE emissions (from the 2001 base year) at each facility:
- Fort Saskatchewan: an overall reduction in DCE emissions of 6 003 kg (about 6 tonnes or 48%) by the end of 2006; and
- North Vancouver: an overall reduction in DCE emissions of 1 265 kg (about 49%) by the end of 2006.
- Emission Reductions Achieved:
- Fugitive emissions (leaks from valves, pipes, connectors, etc.) accounted for most DCE emissions from both facilities. As a result, Dow's environmental management plan stepped up their program to identify, monitor, repair and develop procedures and staff training to prevent and reduce DCE leaks. Dow initiated several engineering projects, made capital investments, replaced equipment and implemented numerous improvements to wastewater handling and storage tanks, for example, repainting their storage tanks white in order to reduce heat related to fugitive emissions in summer. Importantly, Dow also developed and improved methodologies to better measure DCE releases to the environment. The tables below summarize the reductions achieved in emissions of DCE at Dow's Fort Saskatchewan and North Vancouver facilities:
Dow reductions in DCE emissions at Fort Saskatchewan
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Targets: Annual total emissions (kg) (as indicated in Dow management plan) |
Actual total emissions (kg) (reported to NPRI) |
Actual percentage (total kg) reduced from 2001 baseline (NPRI) |
| 2001 (base year) |
12 565 |
11 748 |
- |
| 2002 |
10 405 |
6 515 |
44 (5223) |
| 2003 |
9 655 |
8 170 |
30 (3578) |
| 2004 |
8 905 |
7 791 |
34 (3957) |
| 2005 |
7 455 |
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| 2006 target |
6 562 |
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Dow reductions in DCE emissions at North Vancouver
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Targets: Annual total emissions (kg) (as indicated in Dow management plan) |
Actual total emissions (kg) (reported to NPRI) |
Actual percentage (total kg) reduced from 2001 baseline (NPRI) |
| 2001 (base year) |
2 586 |
2 319 |
- |
| 2002 |
- |
1 160 |
50 (1159) |
| 2003 |
- |
924 |
60 (1395) |
| 2004 |
- |
1 066 |
54 (1253) |
| 2005 |
- |
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| 2006 target |
1 321 |
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Sources: National Pollution Release Inventory (NPRI) on-site releases (actual total emissions-note that 2004 reported data are not yet reviewed) and Dow Management Plan (2002) (targets).
- Further information about emissions at these facilities can be obtained on the NPRI online data search website, by following the links under "Substance-based search" and selecting chemicals or under "Location-based search" and selecting a province, territory, or postal code.
- Ambient air monitoring program:
- As scheduled, Dow implemented its ambient air monitoring program in 2002, collecting 22 ambient air quality (24-hour duration) samples at the fence line on each plant site. Results from these samples show values ranging from non-detectable levels up to 2.87 parts per billion (ppb) at the Fort Saskatchewan facility and from 0.19 to 36.76 ppb at the North Vancouver facility.
- Environment Canada, Health Canada and Dow agreed that additional monitoring take place, beyond the requirements of the EPA, in order to obtain more information related to DCE levels in ambient air. As a result, in 2004, a year-long ambient air quality monitoring program was initiated. Sample collection is ongoing and the results will be examined. More information about the monitoring program for Fort Saskatchewan is available on the Fort Air Partnership website at: http://www.fortair.org/whats_new.php.
- Audit and management review of findings
- In fall 2004, a third-party auditor chosen by Dow and approved by Environment Canada completed the first of two scheduled audits for the EPA. The purpose of the audit was to verify that representations made by Dow concerning DCE emissions are soundly based and that the projects and activities have been successfully implemented. Environment Canada, Alberta Environment and the Dow Fort Saskatchewan Community Advisory Panel also participated as observers.
- The auditor concluded that: "In general, the representations made by Dow as to presentation and communications of information relating to the Dow NPRI reports and the EMP [environmental management plan] for the EDC [DCE] EPA are correct and factual, and are free of material misstatement. Overall, the progress, as described in Dow's presentations, was good and well intentioned with continuous improvement in mind."
Next steps for this EPA
- Emission reductions: Dow will continue to implement the aggressive emission reductions outlined in its environmental management plan.
- Ambient air monitoring: Monitoring at the fence line of each facility will also occur in winter 2005 and summer 2006.
- Audit and management review of findings: A second audit is scheduled for 2007, in order to verify emission reductions and the company's compliance with other aspects of Dow's environmental management plan. Dow management will review the findings of the auditor and make decisions with respect to follow-up actions and continuous improvement objectives.
Senior Toxic Substances Officer
Tel: (780) 951-8731
Fax: (780) 495-2758
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