GENERAL BULLETIN GB 99-10

20 May 1999

REVIEW OF SULPHUR RECOVERY GUIDELINES

This is to advise all operators that the Alberta Energy and Utilities Board (EUB) intends to conduct a review of certain elements of the provincial sulphur recovery guidelines described in EUB Information Letter (IL) 88-13, Sulphur Recovery Guidelines for Sour Gas Plants in Alberta . This review will update and clarify Board policy regarding:

• sulphur recovery requirements for grandfathered sour gas plants,
• the application of the sulphur recovery guidelines to other facilities, and
• small gas plant proliferation guidelines.

IL 88-13 established revised sulphur recovery guidelines for new and/or expanding sour gas processing facilities. Existing sour gas plants were not required, however, to meet the revised sulphur recovery guidelines. This decision was made on the basis of the perceived environmental benefits relative to the associated costs and the anticipated life expectancy of many of the existing plants.

Currently, over 30 operating sulphur recovery plants (1998 data) remain grandfathered. As well, approximately 30 smaller gas plants have grandfathered approvals to flare acid gas containing more than one tonne per day (t/d) of sulphur. Increasing sour gas activity and age of the plants has resulted in questions from the public regarding whether the policy established in 1988 continues to be appropriate. The EUB concurs that such a review is now timely.

IL 88-13 also does not formally address non sour gas facilities such as production batteries, refineries and heavy oil upgraders. However, the sulphur recovery guidelines established in IL 88-13 are routinely used as a reference for these types of facilities. In order to provide additional clarity to the energy industry, the EUB intends to examine how the current sulphur recovery guidelines should in the future potentially be applied to these facilities.

Another issue the EUB will consider in the review is the potential risk of proliferation of new small gas plants emitting less than one t/d of sulphur. Such plants are not currently required to remove sulphur and the number of these plants relative to larger new sour gas plants has been increasing. Large numbers of such plants within a specific area could have significant cumulative sulphur emissions, effectively negating the sulphur emissions targets of IL 88-13.

In carrying out the review, the EUB intends, in consultation with Alberta Environmental Protection (AEP), to develop an initial working draft of the review findings. The working draft will then be made available to industry and other stakeholders for their examination and input. The EUB, and AEP, will consider stakeholder input for incorporation into the final review report and any associated recommendations submitted to the Board.

Attached for background information is a listing of current grandfathered plants in Alberta. Also attached are listings of non-grandfathered sour gas plants with an approved sulphur inlet greater than 1 t/d, other low emission non-grandfathered sulphur recovery processes, and acid gas injection plants. If you have any questions regarding the review, please contact Mr. Kim Eastlick, EUB Environment, Safety and Technical Services Group at (403) 297-4325.

<signed by >

Brian Bietz, Ph.D.
Board Member

Attachments

List of grandfathered plants and non-grandfathered plants (in Excel format)
- Excel 97 version
- Excel 5.0 version