Starting in July 2006, regional air quality monitoring stations near our oil sands base plant began recording more frequent incidents of higher-than-normal concentrations of sulphurous compounds. While no adverse health or environmental impacts occurred from these emissions, an increase in the frequency of exceedances the Alberta Ambient Air Quality Objective for hydrogen sulphide (H2S) and total reduced sulphur (TRS) compounds was measured at these stations.

Any detection that exceeds the Alberta Ambient Air Quality Objectives is known as a ground level concentration (GLC) exceedance. Working with regulators, Suncor established an emissions management task force to investigate these exceedances and to develop an action plan. The team, in conjunction with research institutions and a number of specialized consultants from North America and Europe began investigating potential contributors to the H2S/TRS exceedances and identifying possible process and equipment improvements to address the issue.

In December 2007, Alberta Environment issued an Environmental Protection Order (EPO) related to the GLC exceedances. The EPO set out several steps Suncor had to execute to reduce the frequency of GLC exceedances and meet the terms of the order.

Suncor's investigation task force determined the GLC exceedances were due to two main sources: emissions resulting from the transfer of mature fine tailings (MFT) from Suncor's original tailings pond during reclamation, and operational issues at our base plant. The emissions from MFT transfer were successfully mitigated by modifying the deposition into the destination tailings ponds.

One of the key operational issues had to do with the operation of the upgrader's Vapour Recovery Unit (VRU), which uses a special catalyst to remove sulphurous compounds in vapours from our South Tank Farm and Naphtha Recovery Unit. After in-depth analysis of the VRU operation, significant improvements were made to operational and maintenance practices, including predictive modeling of catalyst consumption to enable catalyst changeout prior to emissions breakthrough. Suncor is also fast-tracking the replacement of the VRU with improved technology. This capital project is currently expected to be completed in Q3 2010.

Suncor also optimized operation of the Naphtha Recovery Unit (NRU), which is part of our secondary extraction process. This resulted in a significant decrease in total reduced sulphur compounds in the final tails stream discharged to the tailings ponds.

The causes of the GLC exceedances reported in 2006 and 2007 have been identified and virtually eliminated. Other GLC exceedances occurred in 2008, which were largely attributable to flaring events. A task force was formed and it has made significant progress in mitigating those exceedances. Suncor continues to investigate and implement strategies and measures to minimize our sulphurous compounds emissions to the environment.

Suncor received notices of enforcement in September 2007 from both Alberta Environment (AEnv) and the Alberta Energy Resources Conservation Board (ERCB) related to regulatory deficiencies in the design, construction and operation of the Firebag in situ facility.

In relation to the AEnv enforcement order (received on September 21, 2007) non-compliances were noted in the areas of vent emissions sources that lacked required pollution abatement equipment, and in ambient air odour impacts. A formal regulatory investigation was subsequently initiated by AEnv.

In relation to the ERCB enforcement action (received on September 24, 2007) regulatory shortfalls were noted in the areas of flaring, venting and H2S emissions in contravention with ERCB regulatory requirements. This enforcement action resulted in the issuance of significant production, venting, flaring and emissions caps equivalent to May 2007 performance results. 

ERCB production restrictions were eventually lifted in July 2008.

Several air emissions treatment projects have since been completed or are underway to address these shortfalls and a comprehensive air emission and ambient air monitoring program continues in and around the site.

After the regulatory investigation concluded, the Province of Alberta charged Suncor with two counts under the Environmental Protection and Enhancement Act. The charges related to the failure to construct facilities at Firebag as described in our original operating approval and failure to provide required follow-up information, subsequent to a 2005 inspection at the facility.

On April 2, 2009, Suncor pled guilty to the two counts and incurred a $675,000 fine. Creative sentencing submitted by the Crown and Suncor directed $315,000 of the total fine to the University of Calgary’s Regulatory Compliance Project, which helps promote research and public education. Another $75,000 was directed to the Keyano College Endowment Fund to support the Environmental and Conservation and Sciences Program.

Firebag began operations in December 2003. Suncor’s original design included Vapour Recovery Units (VRUs) on all process water tanks at Firebag. The design plans were later amended to exclude VRUs on produced water tanks after experience at our Burnt Lake pilot project suggested they weren’t necessary. This change was not reflected in the regulatory application, which is taken as a commitment of what the company will build.

The Crown has acknowledged that the issue arose out of a miscommunication within Suncor. We weren’t aware of the discrepancy between the application and the design plan. When we became aware, we notified regulators.

Since the discovery of the contraventions, Suncor has spent about $175 million on equipment to bring the facility into compliance. Site-wide hydrogen sulphide emissions have been reduced by more than 99 percent. We expect to spend a total of $500 million on a variety of emissions control equipment for current and future Firebag stages.

This incident should have never happened. We fell short of the expectations of regulators—and ourselves. There was a failure in management oversight, for which we take full responsibility. We have strengthened our project controls and environment, health and safety (EHS) management systems to prevent it from occurring again.

On April 2, 2009, Suncor pled guilty to one count related to exceeding approved discharge limits of wastewater to the Athabasca River. A subcontractor who operated water treatment facilities at two of Suncor's residential camps, pled guilty at the same time to reporting misleading or incorrect information and allowing discharges that at times exceeded the water quality limits in the operating approval. Although Suncor was not directly involved in the operation of the wastewater plant or the camp facilities, we were the owner of the camp.

Suncor learned of the potential reporting issues in the fall of 2007 and cooperated fully in the subsequent investigation. Suncor also worked with the company that operates the camps to ensure appropriate actions were taken. The contractor who managed the plant operations was dismissed and a new subcontractor was engaged to manage the two treatment plants. Stakeholders were informed of the issue in October 2007 and in follow-up conversations.

The Crown acknowledged the discharges had no impact on Athabasaca River water quality. Following our guilty plea, Suncor received a $175,000 fine. Creative sentencing submitted by the Crown and Suncor directed the fine to the Alberta Waste and Waste Water Operators Association, a registered non-profit organization. The association will use the funds to update operator training course materials, finance a new water and wastewater operator scholarship and subsidize operator training courses and seminars.

Suncor is committed to being a responsible operator and we recognize the importance of protecting the quality of water in the Athabasca River. While we are grateful the discharges did no harm to the environment or human health, the fact remains we did not meet the standards set by the Province of Alberta. We are committed to working with regulators, contractors and all stakeholders to ensure this does not occur again.

The following incidents occurred in 2005 and 2006, with fines paid in 2007 and 2008.

Incident 1. In early 2005, insulation was being removed at the Sarnia refinery under the information that it was asbestos free. However, the insulation did contain asbestos and three contract workers were exposed.

In May 2007, a settlement was reached with the Ontario Ministry of Labour for a fine of approximately $156,000 ($125,000 plus 25 percent victim surcharge) on two charges under the Occupational Health and Safety Act (OH&SA): failing to report in writing, and failing to use a pressurized respirator.

The contractor, Tornado Insulation, was also fined for $50,000 on one charge under the OH&SA.

Incident 2. On July 27, 2006, the Sarnia refinery reported a leak of acid vapour, which occurred during routine maintenance on an alkylation unit.

Suncor emergency crews responded immediately to evacuate personnel from the affected area. The leak was contained and there was no off-site impact or risk to the surrounding community.

Affected workers received treatment at on-site facilities at the refinery and were taken to local hospitals for observation.

The alkylation unit stabilizes raw gasoline stock and converts some components to high octane blending stock. The unit uses hydrofluoric acid as a catalyst in this process.

Suncor pled guilty on March 31, 2008 to one charge under the OH&SA for failure to take every reasonable precaution when draining the hydrofluoric acid from pump 1-9 P04A for the protection of a worker. Suncor was fined $94,000 ($75,000 plus 25 percent victim surcharge) for this incident.

Incident 3. On August 22, 2006, the Sarnia refinery was evacuated when vapour containing amine and hydrogen sulphide (H2S) was released from the sulphur recovery unit. The incident occurred during project Genesis construction, when routing of amine material drain to a sump resulted in amine and H2S release through disconnected sump pump piping.

Work in the area was halted and all workers were evacuated from the affected area. Two contractors received first aid treatment on site at the refinery. An additional nine workers who were in the vicinity also reported to Suncor's medical centre as a precaution.

As part of the response to the incident, Suncor triggered a Code 8 alarm with the Chemical Valley Emergency Coordinating Organization (CVECO). This code is used to report a noticeable disturbance, or a potential problem, which could cause concern or inquiry by parties external to a CVECO member's site.

Suncor pled guilty on March 31, 2008 to one charge under the OH&SA for failure to lock out equipment that may endanger a worker. Suncor was fined $156,000 ($125,000 plus 25 percent victim surcharge) for this incident.

In-depth investigations of all three incidents took place at the refinery. The findings of the investigations were shared with the refinery leadership and employees, and were followed by thorough refinery process reviews and capture of lessons learned.