the elemental
sulphur management
framework
FOR THE INDUSTRIAL HEARTLAND
Vision
World-class
elemental sulphur
management in the
Industrial Heartland
that sustainably
supports the
environment,
and social and
economic aspects
of development.
contents
4 Acknowledgements
5 Executive Summary
7
7
7
7
Introduction
Mandate
What is Elemental Sulphur?
What Need is there for an Elemental Sulphur Management Framework?
8 Background
9 Consultation and Review Process
11
11
11
11
12
12
Elemental Sulphur Management Framework
Vision
Desired Outcomes
Principles
Boundary
Elemental Sulphur
13
14
15
16
17
Framework Strategies
Strategy 1
Strategy 2
Strategy 3
Strategy 4
18 Next Steps
19 Appendix 1:
Definitions
22 Appendix 2:
Regulatory and Non-regulatory Measures in Alberta
26 Appendix 3:
Map of the Industrial Heartland
3
acknowledgements
Elemental Sulphur Working Group
Lisa Sadownik – Chair, Alberta Environment
Doug Bertsch – North West Upgrading Inc.
Steve Bolger – Total E&P Canada
Claude Chamberland – Shell Canada Ltd.
Nick Corcoran – Kinder Morgan Inc.
Mike Droppo – Kinder Morgan Inc.
Locke Girvan – Strathcona County
Andrea Hiba Brack - Natural Resources Conservation Board
Mike Knoff – Agrium
Robert Mann – HAZCO
Dennis Maschmeyer – Lamont County
Dennis McCartney – Lamont County
Chris Micek – Agrium
Jennifer Nisbet – Sherritt Metals
John Percic – Petro-Canada
Don Roberts – International Commodities Export Company
of Canada Limited Global
Neil Shelly – Alberta Industrial Heartland Association
Secretariat
Scott Beeby – Alberta Energy
Michelle Camilleri – Alberta Environment
Richard Chabaylo – Alberta Environment
JoLynn Ho – Alberta Environment
Tim Jantzie – Alberta Environment
Chris Lavin – Facilitator, Sierra Systems
Nancy Mackenzie – Principal Writer
Julie Norwig – Alberta Environment
Jim Spangelo – Energy Resources Conservation Board
Tracy Wadson – Alberta Energy
4
executive summary
The Government of Alberta is moving toward an approach for land and
resource management that promotes long-term sustainability and improved
quality of life for Albertans. Alberta’s Land-use Framework divides the
province into seven regions and identifies the need for regional plans in
each. These regional plans will include strategies to reduce the footprint
of human activities; manage the impacts of development on land, water,
and air; and establish information, monitoring, and knowledge systems.
A cumulative effects management approach will be used in the regional
plans to manage the combined impact of human activity on the environment.
The Honourable Rob Renner, Minister of Environment, announced on
October 2, 2007 that a cumulative effects management approach would
be applied to Alberta’s Industrial Heartland area. The Industrial Heartland
is a sub-region of the North Saskatchewan Region and also falls within the
boundaries of the Capital Region Growth Management Plan. It is a unique
area zoned for industrial use by the municipalities of Sturgeon, Strathcona,
Lamont, and Fort Saskatchewan in their Joint Area Structure Plan, and
adjacent areas in the Capital Region. Many of the existing and potential
future industrial operators in the Industrial Heartland manage elemental
sulphur as consumers, handlers, or producers.
Elemental sulphur is both a by-product of oil and gas processing, and a
valuable commodity on the world market. Although the current economic
downturn has resulted in delays to some activities planned for the Industrial
Heartland, specifically a number of bitumen upgrading projects, it is
anticipated that development will proceed when the economy improves.
As a result, there will be a corresponding need to manage sulphur.
When businesses choose not to send sulphur to market, the by-product
is typically stored on-site. The projected increase in sulphur production,
an unpredictable future sulphur market, and the uncertain economic viability
of transporting the by-product to market, are the driving needs for this
Elemental Sulphur Management Framework for the Industrial Heartland.
The Elemental Sulphur Working Group, comprised of representatives from
government, municipalities, and industry, worked together to create Phase I
of a management framework that would provide “World-class elemental
sulphur management in the Industrial Heartland that sustainably supports
the environment, and social and economic aspects of development.”
5
This Framework sets out a vision, outcomes, and principles, and presents
four Phase I strategies to improve the management of elemental sulphur in
the Industrial Heartland now and in the future:
1
Increase knowledge and understanding regarding concerns and impacts
(positive and negative) associated with the storage and handling of
elemental sulphur in the Industrial Heartland.
2
Require facility operators to pursue elemental sulphur management
measures that reduce or avoid the need for long-term elemental sulphur
storage in the Industrial Heartland.
3
Manage the handling and storage of elemental sulphur in the Industrial
Heartland to reduce the potential for adverse effects.
4
Revisit the Elemental Sulphur Management Framework for the
Industrial Heartland to evaluate performance and adjust as needed.
Phase II for the Framework will be the implementation of the
recommendations identified under each of these strategies.
6
introduction
MANDATE
Cumulative effects management recognizes that watersheds, airsheds,
and landscapes have a finite carrying capacity and that the current system
of managing effects on a project-by-project basis may not be sufficient to
ensure that the environment is not over-allocated.
On October 2, 2007, the Honourable Rob Renner, Minister of Environment,
announced a new cumulative effects management approach and the
decision to apply this approach to the Industrial Heartland. Cumulative
impacts to water and air are being addressed through management
frameworks for these media in the Industrial Heartland area. The Minister
also announced the need to examine sulphur management.
A Working Group was formed on November 3, 2008 to advise Alberta
Environment on the design and implementation of a framework to
manage elemental sulphur in the Industrial Heartland, and help minimize
the risk to human health and the environment. This framework will be part
of land stewardship actions being developed for the Industrial Heartland.
By describing a context for future elemental sulphur management in the
Industrial Heartland, this document represents the completion of Phase I.
Addressing the recommendations described in this document will occur
during Phase II: Framework Implementation.
WHAT IS ELEMENTAL SULPHUR?
In Canada, by-product elemental sulphur is produced when sour gas is
processed, and when bitumen is upgraded to synthetic crude oil. Sulphur is
removed from gas and refined petroleum products to reduce sulphur
dioxide emissions that occur when these products are used as fuel. Sulphur
is also an input to some industrial processes. The main commercial use of
the by-product is to produce sulphuric acid for use in fertilizer production
and other industrial applications. It is understood that the intent is to
describe elemental sulphur whenever sulphur is referred to in this report.
WHAT NEED IS THERE FOR AN ELEMENTAL SULPHUR
MANAGEMENT FRAMEWORK?
Sulphur is both a by-product and an important commodity on the world
market; hence, it must be managed rather than treated as a waste product.
Potential adverse effects associated with sulphur management are currently
mitigated through a combination of industry best practices and regulatory
requirements applied on a facility-specific basis.
If the extent of industrial development proposed for the Industrial Heartland
proceeds, it is anticipated that there will be a large volume of elemental
sulphur to manage in the region. The Elemental Sulphur Management
Framework describes the context and approach for elemental sulphur
management in the Industrial Heartland in the future. It is based on a
desired regional end result or outcome that balances the interests of
residents, industry, and the government.
7
background
Alberta’s Industrial Heartland is a highly industrialized area located to the
northeast of Edmonton. It is home to a variety of industrial operations and is
expected to grow significantly in the future, specifically due to a number of
bitumen upgrading operations proposed for the area. Although some of the
facilities proposed for the area have been put on hold, it is anticipated that
development may proceed in the future, bringing with it an increased
volume of sulphur to be managed in the Industrial Heartland.
Currently there are both sulphur consuming and producing facilities in the
Industrial Heartland. While there is no long-term storage of sulphur in the
Industrial Heartland, small volumes are held in liquid (molten) form in tanks
and pits at production and consumption facilities prior to processing, or rail
or truck transportation. In addition, there are applications before Alberta
Environment that include plans to handle and store both blocked and
formed solid elemental sulphur in the short-term.
Solid sulphur is typically stored on-site when producers can not send it to
market either due to choice (discretionary) or circumstances beyond their
control, such as a transportation disruption (emergency). While emergency
storage is expected to be for shorter timeframes (i.e., until the event that
led to the storage is over), the choice to store sulphur can lead to long-term
storage depending on how a facility operator views their business with
respect to sulphur. A business may wait until the market is favourable in
terms of demand and price, recognizing that Alberta is at a competitive
disadvantage due to overland and ocean freight costs.
The current regulatory regime manages proposals for facilities involving
sulphur management on a case-by-case basis. There are a number of
regulators with different jurisdictions over sulphur management in Alberta.
Municipalities determine where industrial development can occur via zoning.
The Energy Resources Conservation Board addresses energy projects and
the Natural Resources Conservation Board addresses non-energy projects.
The Boards will determine whether a project is in the public’s best interest.
Alberta Environment decides whether or not environmental approval should
be granted and the conditions for construction, operation, and reclamation
that would go with this approval. (See Appendix 2 for more information.)
The large volume of sulphur that would accompany future upgrading
projects requires that a proactive sulphur management approach be
developed that is regional, comprehensive, integrated, and forward-thinking
in nature. The approach will support future decisions about individual
facilities by providing certainty, consistency, and public-assurance about
expectations for elemental sulphur management in the Industrial Heartland.
8
consultation and review process
A Working Group was established on November 3rd, 2008. Participants
included industry, municipalities, and regulators. Invitations were extended
to environmental non-government organizations; however, the invitations
were declined.
In a series of workshops from November 2008 to March 2009, the Working
Group met to review presentations and discuss current sulphur management
practices in Alberta, and the need for action now and in the future. The Working
Group discussed the mandate and the form that an elemental sulphur
management framework might take, developed Terms of Reference, and a
framework outline.
In keeping with a cumulative effects management approach for the Industrial
Heartland, the group identified a vision, desired outcomes for sulphur
management in the Industrial Heartland, and principles to guide their work.
Information about existing regulatory requirements and guidance was
presented to the Working Group, and is attached in Appendix 2. Other
presentations addressed the sulphur forming processes, trade flows, and the
work being done by Alberta Sulphur Research Limited (an industry-funded
research group affiliated with the University of Calgary). Through these various
presentations it became apparent that sulphur management is a complex and
dynamic issue and that the resulting framework would need to strike a fine
balance between the needs of the various stakeholders. This would be no easy
task because the public requires assurance that regulators are taking a firm
and consistent approach, while industry requires flexibility to deal with sulphur
as both a marketable commodity and by-product in an ever-changing market.
Discussions to determine the best approach to take for sulphur management
in the Industrial Heartland focused on scenario analyses, which became the
foundation of the Framework. Scenarios analyzed were:
• Solid blocked elemental sulphur stored and handled
in the Industrial Heartland.
• Solid formed elemental sulphur stored, handled, and transported
in the Industrial Heartland.
• Molten elemental sulphur stored, handled, and transported
in the Industrial Heartland.
The scenario analyses served to:
• identify potential issues with the storage, handling, and transport
of elemental sulphur
• determine existing mitigation measures, best management practices,
and regulatory requirements
• identify parameters for consideration, gaps, and potential solutions.
9
Potential issues associated with sulphur management included in the
analyses were groundwater and surface water contamination, soil
acidification, emergency incidences, odours, aesthetics, and dusting.
The analyses identified the following.
• Key issues of concern for working group members representing residents
in the vicinity of the Industrial Heartland included emergency incidences,
odours, aesthetics, and siting of sulphur management facilities.
• Potential issues related to sulphur management can largely be mitigated
using best industry practices.
• There does not appear to be a common understanding among
stakeholders about potential issues.
• Additional science based information about environmental outcomes
related to sulphur management is required.
• There is not clear, consistent, and easily accessible guidance from
regulators about expectations for sulphur management in the
Industrial Heartland.
Resulting from the analyses were four Framework strategies that form
the core of the Elemental Sulphur Management Framework, Phase I.
These strategies will be used to guide the work of implementing a
cumulative effects management approach for elemental sulphur in
the Industrial Heartland. Implementation will commence with Phase II
of the Framework.
10
elemental sulphur management framework
VISION
World-class elemental sulphur management in the Industrial Heartland
that sustainably supports the environment, and social and economic aspects
of development.
DESIRED OUTCOMES
• Management of elemental sulphur is part of an integrated cumulative
effects management system in the Industrial Heartland.
• Effects and risks to humans and the environment are minimized.
> The quality of life for people who live and work in the vicinity of the
Industrial Heartland area continues to be safe and healthy.
• The Industrial Heartland area continues to be an attractive place to add
value to Alberta’s resource development.
> Elemental sulphur production is acknowledged as a necessary component
of value-added resource development in Industrial Heartland.
• Alberta is recognized as a world-class leader in the management of
elemental sulphur.
> The approach used to develop the Elemental Sulphur Management
Framework for the Industrial Heartland will help to facilitate
the development of elemental sulphur management frameworks
across the province.
> The public has confidence in how elemental sulphur is being managed
in the Industrial Heartland area.
PRINCIPLES
• Provides certainty for current and future industrial projects.
• Sets objectives in support of meeting desired outcomes with the intent
of minimizing the environmental impacts and the footprint of elemental
sulphur storage, handling, and transportation.
• Provides for an adaptive management approach.
• Respects the required environmental outcomes and the diversity
of decisions that may be made, while considering social and
economic implications.
• Recognizes elemental sulphur as a commodity that is subject
to fluctuations in the global market.
• Respects decision-making authorities and processes that currently exist.
• Provides for a timely, fair, and equal application of the Framework.
• Strives to manage the environment rather than managing individual
industrial projects.
11
BOUNDARY
The Alberta Industrial Heartland Association boundary (see Appendix 3
for map) was adopted as the Elemental Sulphur Management Framework
Boundary because:
• it is consistent with the area of focus proposed for other land stewardship
activities in the Industrial Heartland
• the boundary includes the existing and proposed upgraders, which are
the primary sources of elemental sulphur in the region.
DEFINITION
Industrial Heartland is a 470-square kilometre area just northeast of
Edmonton. Industrial Heartland refers to the total land zoned by the
municipalities of Sturgeon, Strathcona, Lamont, and Fort Saskatchewan in
their Joint Area Structure Plan (ASP), and adjacent areas in the Capital
Region.
ELEMENTAL SULPHUR
Elemental sulphur was defined as that which is:
• produced in the region
• consumed in the region from local sources or imported
(to be consumed, stored, and/ or processed)
• exported from the region
• in transit (truck to rail; truck to forming or storage; rail to forming
or storage; in pipelines)
• stored in the region as molten, solid formed, and solid blocked.
Further definitions are provided in Appendix 1.
12
framework strategies
The framework recognizes increasing production at oil sands upgraders
(existing, proposed, and future) as a major driver for defining a regional
approach for sulphur management in the Industrial Heartland.
Uncertainty around when anticipated development will actually proceed
makes it important to clarify expectations and upcoming actions in advance.
Having this clarification will provide regulatory certainty as new projects
come forward and move through economic evaluation, project design,
application, regulatory review, approval, and decision-making processes.
The four strategies that follow set out a course of action for long-term
elemental sulphur management in the Industrial Heartland. When
implemented they will:
• improve the knowledge base and collective understanding of elemental
sulphur management impacts
• proactively address sulphur management in the Industrial Heartland,
including how applications for solid (formed and blocked) sulphur storage
will be considered
• establish expectations for how sulphur handling and storage should
be approached
• enable continued learning and adaptive management.
Strategy 1: Increase knowledge and understanding regarding concerns
and impacts (positive and negative) associated with the storage and
handling of elemental sulphur in the Industrial Heartland.
Strategy 2: Require facility operators to pursue elemental sulphur
management measures that reduce or avoid the need for long-term
elemental sulphur storage in the Industrial Heartland.
Strategy 3: Manage the handling and storage of elemental sulphur in the
Industrial Heartland to reduce the potential for adverse effects.
Strategy 4: Revisit the Elemental Sulphur Management Framework to
evaluate performance and adjust as needed.
The strategies flow from one to the next and are intended to be considered
as a whole. Implementation of strategies 1, 2, and 3 could be either
consecutive or sequential. Information gathered and assessed through
strategies 1 through 3 will provide the foundation for the implementation
of the last strategy. Together, these four strategies complete Phase I
of the Management Framework by providing the context for future
sulphur management in the Industrial Heartland. Phase II: Framework
Implementation involves the work of addressing the recommendations
described below for each strategy.
13
STRATEGY 1
Increase knowledge and understanding regarding concerns and impacts
(positive and negative) associated with the storage and handling of
elemental sulphur in the Industrial Heartland.
Background
• There is not a common understanding of the potential impacts
of sulphur management in the Industrial Heartland from the perspective
of environmental outcomes.
• Residents living in the vicinity of the Industrial Heartland have concerns
related to sulphur management that have not been addressed.
Considerations
• A common understanding of concerns and potential adverse effects
associated with sulphur management will assist industry and regulators
in making more informed and timely decisions in the Industrial Heartland.
• It is important that the Elemental Sulphur Management Framework be
aligned with regional objectives for air, water and land being developed
for the Industrial Heartland.
Recommendations
• Develop a monitoring and reporting program for environmental outcomes
to demonstrate that sulphur management activities in the Industrial
Heartland are well managed and not resulting in adverse effects. This may
include, at a minimum, the following.
> Selection of indicators for air, water, and soil (e.g., sulphate and pH)
and identification of science based objectives.
> Consideration of both regional and fence-line monitoring.
• Develop a program to consult with local residents and other
stakeholders on sulphur management in the Industrial Heartland in order
to do the following.
> Identify concerns.
> Assess positive and negative impacts (environmental, social
and economic).
> Increase knowledge and understanding.
• Examine the regulatory process for consistency of public involvement
and identify appropriate regulatory requirements for future sulphur
management activities.
14
STRATEGY 2
Require facility operators to pursue elemental sulphur management
measures that reduce or avoid the need for long-term elemental sulphur
storage in the Industrial Heartland.
Background
• Sulphur producing and consuming facilities in the Industrial Heartland may
require the ability to store solid sulphur.
• There are no approvals to date for solid sulphur storage in the Industrial
Heartland; however, there are applications for solid sulphur storage under
review.
Considerations
• As future industrial development proceeds, the volume of sulphur to be
managed will increase, resulting in either the need for long-term storage
or alternatives.
• In comparison with other areas of the province that produce, handle,
and transport elemental sulphur, the Industrial Heartland is well-situated
geographically to move sulphur to market with respect to:
> proximity to market
> transportation infrastructure
> competitive cost.
• There are sulphur management alternatives outside of the
Industrial Heartland.
Recommendations
• Develop guidelines for regulatory applications related to solid sulphur
storage which include, at a minimum, the following.
> Description of storage required including form, amount, location,
and duration.
> Rationale for storage requirements and alternatives explored.
> Discussion of potential adverse impacts, mitigation, and contingencies.
• Develop associated evaluation tools for regulators to use when reviewing
sulphur handling and storage applications.
15
STRATEGY 3
Manage the handling and storage of elemental sulphur in the Industrial
Heartland to reduce the potential for adverse effects.
Background
• Industrial facilities rely primarily on industry best practices and internal
standards to guide how they handle and store elemental sulphur.
• There is limited guidance from regulators on sulphur handling and
storage, which could result in inconsistency across facilities and a lack
of clarity regarding expectations.
• There is a lack of information available to the public regarding industry
best practices and expectations for sulphur management.
Considerations
• Regulatory applications involving sulphur management in the Industrial
Heartland are expected to increase should industrial development in
the area proceed as anticipated.
• Industry requires regulatory certainty with respect to expectations
for sulphur management in the Industrial Heartland.
• Potential adverse effects relating to sulphur management must be
managed consistently and correctly.
• Information and understanding regarding sulphur management
expectations in the Industrial Heartland should be easily accessible.
Recommendations
• Include information requirements in application guidelines for sulphur
management facilities and associated regulator evaluation tools
(Strategy 2) which consider, at a minimum, the following:
> siting
> mitigation including containment, dust control, odour control etc.
> operation
> emergency response.
• Identify a degassing requirement for sulphur that is handled and
stored in the Industrial Heartland, and consider the need for other
quality specifications.
16
STRATEGY 4
Revisit the Elemental Sulphur Management Framework to evaluate
performance and adjust as needed.
Background
• Elemental sulphur management is a dynamic and complex issue
influenced by a variety of factors, including sulphur prices and demand,
transportation availability and cost, forming and handling availability,
production levels, regulatory requirements, and individual operators’
business considerations.
• The economic situation has changed considerably since the October 2007
announcement about addressing sulphur management for the Industrial
Heartland. A large portion of industrial development planned at that time
has since been put on hold.
Considerations
• With an improvement in the economy, it is anticipated that industrial
development would again proceed.
• Future studies and monitoring will improve our understanding about
concerns and potential adverse effects related to elemental sulphur
management in the Industrial Heartland.
• The elemental sulphur situation in the Industrial Heartland will continue
to change over time creating the need to re-visit the effectiveness and
continued applicability of the Elemental Sulphur Management Framework.
Recommendations
• Revisit the Elemental Sulphur Management Framework when the
economic situation improves, and proposed development proceeds,
to assess its applicability and effectiveness, and make improvements,
if needed. Criteria for consideration upon revisiting will include,
at a minimum, the following.
> Learnings from the implementation of Strategies 1, 2, and 3.
> The situation in the Industrial Heartland at the time with respect
to amount of industrial development and related elemental sulphur
management needs.
17
next steps
Delivery of The Elemental Sulphur Management Framework for the
Industrial Heartland to Alberta’s Minister of the Environment marks the
end of Phase I work to establish a context for future elemental sulphur
management in the Industrial Heartland.
Upon acceptance of framework recommendations from the Minister,
the following next steps are proposed as part of Phase II: Framework
Implementation.
• Convene a multi-stakeholder group to act as an Industrial Heartland
Sulphur Management Framework Implementation Team.
• The Implementation Team is to do the following.
> Review Phase I recommendations and confirm understanding of intent.
> Identify priorities for implementation and strike subgroups as needed
to support specific tasks.
> Develop a work plan for implementation of the recommendations
including roles and responsibilities, tasks, and timing.
> Begin work on tasks to deliver Framework recommendations.
18
appendix 1
DEFINITIONS
Some of these definitions come from the Land Use Framework.
Carrying Capacity
The ability of a watershed, airshed, and/or landscape to sustain activities and
development before it shows unacceptable signs of stress or degradation.
Cumulative Effects
The combined effects of past, present, and reasonably foreseeable land-use
activities, over time, on the environment.
Cumulative effects management determines the capacity of the environment and
ecosystem to support the effects of all activities, and identifies thresholds for the
air, land, water, and biodiversity.
A cumulative effects management system (CEMS) is an integral part of the
Land-use Framework. The CEMS manages for the environment rather than managing
in a project-by-project way and is focused on the desired environmental outcomes.
Degassing
The process of removing hydrogen sulphide (H2S) from molten sulphur.
Discretionary Sulphur Storage
Occurs when the decision to store sulphur is made in the absence of economic
incidences (i.e., for strategic or economic purposes).
Elemental Sulphur Dust
Elemental sulphur dust is created when solid elemental sulphur breaks down
to form fine particles. The elemental sulphur dust may be dispersed into the air
where it eventually settles onto the surrounding environment.
Elemental Sulphur Odours
Elemental sulphur odours occur when hydrogen sulphide (H2S) and sulphur
dioxide (SO2) are released from elemental sulphur into the environment.
Elemental sulphur odours are most noticeable during the handling of molten
sulphur, including the pouring and re-melting of a sulphur block. Effective degassing
minimizes odours.
Emergency Incidencies
Fire, spills, train derailment, rail strikes, and temporary sulphur market disruptions.
Emergency Sulphur Storage
Occurs when there is an emergency incidence that impedes the removal of
storage from the site in order to allow a producer to continue production.
19
Environmental Outcomes
Environmental outcomes are environmental end states defining the specific
conditions or functions of the environment.
Framework
A framework is an underlying set of ideas, principles, agreements, or rules that
provide the basis or outline for something intended to be more fully developed
at a later date.
Groundwater
Water held in soil or rock, below the water table, is known as groundwater.
Groundwater moves through permeable layers of rock known as aquifers.
Industrial Development
In the context of land use, this term means natural resource development
activities like exploration, harvesting, and extraction of natural resources.
It can also mean, in a municipal planning/zoning context, the use, infrastructure,
and activities associated with production (e.g., manufacturing, fabricating,
warehousing, processing, refining, or assembly).
Industrial Heartland
Industrial Heartland is a 470-square kilometre area just northeast of Edmonton.
Industrial Heartland refers to the total land zoned by the municipalities of
Sturgeon, Strathcona, Lamont, and Fort Saskatchewan in their Joint Area
Structure Plan (ASP), and adjacent areas in the Capital Region.
Primary Sulphur Handling Facility
Any location, structure, or equipment which is associated directly with and
proximal to a sulphur production facility and which handles, stores, forms, remelts,
or loads sulphur.
Reclaiming or Remediating a Sulphur Block
The process of melting a sulphur block to produce molten sulphur.
Secondary Sulphur Handling Facility
Any location, structure, or equipment which receives sulphur from a sulphur
production facility or from a primary sulphur handling facility for the purposes
of handling, storing, forming, remelting, or loading sulphur and is located a
significant distance from the facility from which it receives its sulphur or operates
by virtue of an approval independent of the sulphur production facility.
20
Stored
Elemental sulphur held on-site regardless of time or containment structure.
Sulphur Fires
If ignited by spark or flame, sulphur will burn in air resulting in sulphur dioxide
fumes. Sulphur dust suspended in air can be ignited by flame, static electricity,
or spark.
Sulphur Handling
The forming, pouring, re-melting, or movement of elemental sulphur on-site.
Sulphur Production Facility
Any facility producing molten elemental sulphur as part of their process.
Surface Water
Water that occurs in rivers, streams, lakes, dugouts, and other fresh water sources
is described as surface water.
Stewardship
An ethic whereby citizens, industry, communities, and governments work together
to responsibly care for and manage Alberta’s natural resources and environment.
Strategy
A series of actions for obtaining a specific goal or result.
Sustainable Development
Development that meets the needs of the present without compromising the
ability of future generations to meet their needs.
Sustainability
Relates to understanding the interconnections and continuity of economic,
environmental, and social aspects of human society and the non-human
environment.
Systems Approach
An approach to integration that recognizes the interdependence and interaction
of parts of a system. It views systems in a holistic manner.
Transported
Elemental sulphur moved off-site.
21
appendix 2
SULPHUR MANAGEMENT –
REGULATORY AND NON-REGULATORY MEASURES
IN ALBERTA
Sulphur is regulated in Alberta by a number of agencies. These include
Alberta Environment (AE), the Energy Resources Conservation Board
(ERCB), the Natural Resource Conservation Board (NRCB), Alberta Energy,
and the appropriate municipality. Each regulatory agency plays a part in
managing different aspects of the sulphur industry.
The following are some of the policies, guidelines, and directives relating
to the storage, handling, transportation, and disposal of sulphur or sulphur
wastes. Agency and industry responsibilities are also outlined.
Alberta Environment
Activities Designation Regulation (Alberta Regulation 276/2003)
The Activities Designation Regulation (Alberta Regulation 276/2003) under
the Environmental Protection and Enhancement Act (EPEA) requires an
approval for the construction, operation, and reclamation of a sulphur
storage facility and sulphur manufacturing or processing plant. An EPEA
approval may also be required for sulphur producers and primary sulphur
handling facilities, such as, upgraders or sour gas plants.
The EPEA approval addresses the environmental aspects related to sulphur
operations. These include air, surface water, wastewater, groundwater, soil,
and waste. Any amendments and changes to an activity might be subject
to the approval process.
Environmental Impact Assessment (EIA)
The requirement for an EIA for various sulphur projects can be mandatory,
exempt, or determined at the discretion of the Director under the Act.
The Director’s decision to require an EIA for a project is based on the size
and nature of the issues involved. The Director can request information from
the public, industry, and other government agencies to help decide whether
or not an EIA is necessary.
Guidelines for the Remediation and Disposal of Sulphur
Contaminated Solid Wastes (May 1996)
These guidelines were developed by Alberta Environment to assist waste
generators, landfill operators, and others handling sulphur contaminated
wastes to do so in an environmentally acceptable manner.
22
Alberta Energy
Oil Sands Royalty Guidelines (1997) – Updated November 2006
The Alberta Oil Sands Royalty Guidelines provide a general understanding
of the principles used to establish oil sands royalty legislation. They explain
the administrative policies used by the Department of Energy in interpreting
this legislation. They also explain the business rules and operating procedures
used when royalty-related legislation is applied.
Alberta Natural Gas Royalty Guidelines (2006)
These Guidelines are provided to give an understanding of the general
application and principles for determining Alberta’s Crown royalty share
of gas and gas products, such as sulphur, produced from lands subject to
a Crown lease agreement.
Application of the Regulation in specific situations may vary, and
implementation and practice of the Regulation may change without
amending the Guidelines. This manual interprets the relevant energy
legislation (statutes and regulations), and communicates policy decisions
made, based on the legislation.
Energy Resources Conservation Board
ERCB General Bulletin 92-4 (March 10, 1992)
and IL 84-11 (October 29, 1984)
The purpose of these documents is to provide the policy and requirements
for sulphur storage in Alberta and thereby assist operators of sulphurproducing facilities with decisions regarding whether or not, where, and
how they store produced sulphur. The bulletin does not contain any new
requirements, but brings the information to the attention of industry.
Storage Requirements for the Upstream Petroleum Industry
(December 2001)
Directive 55 contains the ERCB storage requirements for the upstream oil
and gas industry. It outlines the requirements for storage systems including
specifications for liners. While it does not apply to sulphur storage, it does
apply to the storage of waste material including sulphur contaminated soil.
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Joint Regulations
Information Letter IL 96-7: ERCB/AEP Memorandum of
Understanding on the Regulation of Oil Sands Developments
(April 18, 1996)
The Memorandum of Understanding outlines the coordinated regulatory
approval process that will be followed for major oil sands projects that
require approvals under both the Oil Sands Conservation Act and the
Environmental Protection and Enhancement Act. The memorandum states
that Alberta Environment is responsible for ensuring that the storage of
these materials does not result in significant environmental impacts, while
the Energy Resources and Conservation Board is responsible for ensuring
sulphur is stored so that future recovery is maximized. Furthermore the
ERCB has the primary decision-making authority regarding whether a project
is in the public interest (having regard for social, economic, and environmental
effects of a project).
Municipalities
Strathcona County Municipal Development Plan (May 22, 2007)
The Municipal Development Plan provides comprehensive long-term
(approximately a 20 year horizon) land use policy framework within which
present and projected growth and development may take place.
Strathcona County Land Use Bylaw (July 10, 2001)
This Land Use Bylaw regulates the use, conservation, and development
of land, habitat, buildings, and signs in pursuit of the objectives of
Strathcona County’s statutory plans. These objectives are to maintain
and enhance the quality of life by providing opportunities to attain individual
and community aspirations; to conserve and enhance the environmental
quality in Strathcona County; and to foster planned, efficient, economical,
and beneficial development that provides a diversity of choice, lifestyle,
and environment.
Lamont County Municipal Development Plan (Bylaw 74/07)
The Municipal Development Plan provides policies to give the opportunity
for both industrial and residential development to occur while at the same
time conserving the agricultural base of the county. Such planned growth
will ensure that future generations will have a desirable place to live and work.
Lamont County Land Use Bylaw 675/07
The Land Use Bylaw is to regulate and control the use and development
of land and buildings within the municipality to achieve the orderly and
economic development of land.
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Natural Resources Conservation Board (NRCB)
Natural Resources Conservation Board Act (1990)
The purpose of the Natural Resources Conservation Board Act is to provide an
impartial process to review the province’s non-energy projects that will or may
affect the natural resources of Alberta in order to determine whether, in the
Board’s opinion, the projects are in the public interest. Reviews generally involve
the active participation of community residents, interest groups, government
departments and municipal authorities, in addition to applicants. Approvals under
the Natural Resources Conservation Board Act must be authorized by the Alberta
cabinet and are in addition to licenses, permits or approvals required by other
acts, regulations, or by-laws.
Other
Potential Short and Long-term Sulphur Storage Options in Alberta –
Final Report AMEC Earth & Environmental, (November 2004)
The report was prepared by AMEC under the direction of a committee with
members from Alberta Environment, Alberta Energy and Resources Conservation
Board, Alberta Sulphur Producers, and industry. The report provides technical
advice and discusses the advantages and disadvantages of various sulphur
storage options.
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appendix 3
MAP OF THE INDUSTRIAL HEARTLAND
26
This framework
sets out a vision,
outcomes, and
principles to improve
the management of
elemental sulphur
now and in the future.
For more information, or to
order additional copies, contact:
Alberta Environment
Information Centre
Main Floor, 9820 - 106 Street
Edmonton, AB T5K 2J6
Toll-free: Dial 310-0000
and the phone number
Telephone: 780-427-2700
www.environment.alberta.ca
This document is printed on chlorine-free paper
made from 100 per cent post-consumer fibre.
In choosing this paper, Alberta Environment saved
11,734 litres of water, prevented 307 kilograms of
greenhouse gas emissions, conserved 7 trees and
diverted 156 kilograms of waste from Alberta landfills.
The paper was produced using wind power, which
prevented 159 kilograms of air emissions and saved
the use of 24 cubic metres of natural gas.
ISBN No. 978-0-7785-8557-2