Response from West Coast Olefins

Editor's note: On Sept. 6, The Citizen posted a series of questions from the Too Close 2 Home group about the proposed petrochemical plant in Prince George and we invited Ken James, the president and CEO of West Coast Olefins, to respond. The following is his reply:

We will not have any polyethylene plants on our site. This project involves:

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One natural gas liquids recovery plant - the fractionation portion of that plant will be located on the West Coast Olefins site.

One ethylene plant that will produce ethylene from the ethane recovered in the above fractionation plant - this will also be located on our site.

One polyethylene plant that will be developed by a third party and will not be located on our site.

I have met with Marie Hay on two separate occasions (Aug. 7 and Aug. 22) and with other members of PACHA. I informed her that West Coast Olefins were just about to enter into the formal regulatory process. Much of the information she is requesting will be provided to the BC Environmental Assessment Office (EAO) once they have issued their Section 11 order. The process leading to the Section 11 Order includes:

EAO develops a draft order under section 11 of the Act that specifies the scope of the project and the assessment.

Order also sets out the procedures and methods of the EA.

EAO sends the draft order to Aboriginal groups for review and considers comments that are received.

EAO provides a letter responding to any comments provided on the draft Section 11 order.

EAO issues the Section 11 order.

Hopefully the responses below to this latest questionnaire will help clarify the points that the Too Close 2 Home group have raised.

Refining/manufacturing

1. Which main chemicals will be used in the proposed refining/manufacturing process?

Dimethyl disulfide (DMDS) (used for passivation of furnaces, small amounts)

Acid (used for regeneration of demin treatment)

Amine

Caustic soda

Specific amounts of these chemicals will be determined during detailed engineering phase.

2. How will these chemicals be transported to the site?

By truck and mainly rail.

3. What type of onsite storage facilities will be used and what safeguards are associated with such storage facilities?

Industry standard storage vessels, such as spheres or bullets. Primary and secondary containment strategies.

4. What precautions will be in place to protect the chemicals and processes associated with the plant from contaminating the land, rivers, and groundwater?

No underground piping or hydrocarbon (HC) tanks, this will reduce the potential for underground leaks.

Secondary containment procedures.

Tertiary containment procedures (site contained stormwater systems, which control, capture, test and release any collected stormwater).

5. How will solid/liquid waste products be handled? What percentage of these is expected to stay in the local area?

Will generate very few liquid/solid wastes. Those which are produced will be captured, contained and shipped of site to the appropriate and accepted location for disposal. See the project description for a detailed list of liquid/solid wastes and the proposed management and mitigation techniques.

Have not completed a survey of available waste disposal facilities in B.C., but Swan Hills Waste Treatment Facility in Alberta is often used for Albertan projects and is close enough to be considered an option for waste disposal for WCOL Project.

6. Will the plant's tailing ponds be completely covered over and will this prevent associated toxic fugitive air emissions?

There are no tailings ponds in NGL recovery or ethylene plants. These are typical of mining projects.

7. How high will the plant's flare stacks be, and how much of the time will flaring take place? Which times of day and week will flaring be conducted (times; frequency)? How long are the sessions expected to last?

Flare stacks are typically in the range of 150 feet. The height will be determined by proximity to other buildings and radiant temperature relative to ground level.

The Nova E2 ethylene plant where I worked from 1989 to 1994 only flared during startup and shut down. There were no scheduled outages. The plant typically had less than one unplanned outage per year. From experience with Nova, the flare will usually last less than 10 hours during startup. Startup and shutdown flaring typically occur every three to five years during periodic planned turnarounds that are scheduled to ensure the integrity of the plant and associated equipment.

The flare system is a key safety system. It permits the safe release of compressed hydrocarbon during a serious upset or emergency. It is not intended as an incineration device as was often the case with older plants.

8. When flaring does take place with either planned or unplanned shutdowns at the plant, how much of an additional air emission load is to be anticipated during such times?

Modern flares are designed to have a combustion efficiency of close to 100 per cent. This means 100 per cent combustion to hydrocarbons to CO2 and water vapour.

Specific volumes will be reported within the Environmental Assessment (EA) Application, however we must receive Section 11 Order first and then complete sufficient engineering to make this determination.

9. What is the anticipated production capacity of the ethane extraction plant, and which products and markets will it most closely be affiliated with? Is the plant's maximum capacity one megatonne?

The plant will process between 1.5-2 billion standard cubic feet of natural gas in Enbridge's Westcoast Energy Pipeline and recover approximately 65,000 barrels per day of ethane, 26,000 barrels per day of propane, 9,000 barrels per day of butane and 2,000 barrels per day of condensate.

The NGL recovery plant will produce ethane which will feed the ethylene plant. Byproducts from the NGL recovery plant are propane, butane and C5+ condensate.

The ethylene plant will produce ethylene, which will feed the ethylene derivatives plant. Byproducts from the ethylene plant are mixed C3 (which consists of mainly of propylene (86 per cent) and propane (11 per cent), mixed C4 (which consists mainly of butadiene (45 per cent) and pyrolysis gas (consists of aromatics and heavy HC). These byproducts will be sold to third parties for further refinement to more valuable products.

The third-party ethylene derivative plant will produce polyethylene pellets.

10. West Coast Olefins Ltd. has publicly suggested that up to three plastic plants can be accommodated on the 300-acre site to utilize the ethylene produced by the ethane plant. What are the expected emissions into the PG airshed in terms of expected increases in truck, rail and car traffic with all the proposed facilities at the proposed site location in Willow Cale, through all phases including construction through to ongoing operation? What impacts are you anticipating with increased road and rail traffic, and what measures will you take to mitigate those potential impacts?

The WCOL development will involve three separate plants. West Coast Olefins in only developing two of the three plants. The NGL recovery plant, and the ethylene plant. The NGL separation plant and the ethylene plant will be on the Willow Cale site. The NGL extraction plant will be on a site located in close proximity to the preexisting Westcoast Energy Pipeline. The ethylene derivitive plant, most likely polyethylene, will not be located on the Willow Cale site. It will be located on a separate site and will be owned by a third-party partner. No plastic plants will be built on the 300-acre site. WCOL does not make plastics. A third-party will make the polyethylene pellets. This has been clarified several times.

All emissions will be reported through the EA application process.

We will be primarily shipping by rail from the B.C. Industrial Park to Prince Rupert. The advantage of Prince George is that this rail routing will ensure there is minimal disruption to local traffic as the rail runs under Highway 97 at the south entry to Prince George, under Highway 16 at the east entry and then along First avenue then under River Road and the two Nechako River bridges. All switching will occur on the BCR Site, a benefit of the proposed location. Other locations that have been suggested, such as Hart North, would require major rail development and increase rail traffic greatly.

11. If the main product is plastic pellets and the majority of those will be shipped to Asia, how many rail cars are going to be needed to transport the pellets to Asia through Prince Rupert? Will this put an additional strain on rail, rail companies, and/or communities with rail lines? If so, how will the company work to mitigate associated negative impacts?

The ethylene derivative plant will likely be producing plastics. This facility will be owned by a third party. We have had numerous discussions with potential third parties but have not concluded an agreement with a specific third party as this point.

The third party will be required to provide this information when they go through their own separate regulatory processes.

12. How much extra rail line is going to have to be built by CN in order to connect with and serve your site?

We will build our own rail system on our property adjacent to the CN rail line. The West Coast Olefins property has approximately one mile of frontage on the CN rail line to Vancouver.

These details will be developed with CN and included within the EA application/

The polyethylene producer will be responsible for their own rail requirements.

13. As the current CN rail capacity to Prince Rupert is already at maximum capacity, will CN be building more railways to Prince Rupert to accommodate the extra rail car traffic?

This information is incorrect. Following discussions with CN, there is a preference to route through Prince Rupert as it has the most available capacity. From Prince George, we have the option to route through Prince Rupert, Vancouver and Kitimat.

14. Will this increase in rail traffic bring westerly passenger rail traffic to a halt? Can you provide evidence to reassure community members that rail capacity can be augmented without increased conflict or risk?

No, it will not bring passenger rail traffic to a halt. In fact, should the WCOL Project not go ahead, there are other projects in the works that will produce these same products in Alberta and these products will still route through Prince George.

15. It is our understanding that the Port of Prince Rupert is also currently operating at maximum capacity. Is the port capable and prepared to accommodate and service all the extra tanker traffic, unloading, storage, and loading of one mega tonne of ethylene product?

Again, that is incorrect information. It was CN that suggested Prince Rupert as their preferred export destination.

16. How will you mitigate fugitive plastic pellet and dust losses around Prince Rupert and the harbour area, bearing in mind the welfare of the marine animals that live there?

It is the responsibility of the third-party producer to address all questions regarding polyethylene pellet production and related activities. West Coast Olefins is not authorized to speak on their behalf.

Process

1. Will this proposed plant be built with flexible process production lines? What considerations have been given to planning upgrades to more environmentally sustainable production methods and process?

No, only hard piping will be used, no hoses.

The advantage of building a new plant is that we have the option to implement state of the art technologies, processes and methods. New plants are significantly different to those built 40 years ago. For example, the first Joffree Plant, started in 1979, used 50 per cent more energy (and therefore produced 50 per cent more emissions) to produce ethylene than the plant built in the early 2000s. We have the advantage of implementing further advancements that have been developed over the past 20 years.

2. Where exactly will the raw supply for the ethylene production come from and how is it going to be transported to the new facility? Many residents have expressed concerns that your facility will require another pipeline to be built to supply it with the raw materials. Due to the recent pipeline explosion last fall near Shelley, B.C. and subsequent voluntary (and mandatory) reduction in use of natural gas throughout the province, most British Columbians are now aware that the Enbridge pipeline is still only permitted to run at 85 per cent of its capacity and is responsible to supplying much of the central and southern interior's natural gas for both commercial and residential customers. How do you plan to address these concerns?

Raw material for the NGL extraction site will be supplied via Enbridge's existing Westcoast Energy Pipeline, which delivers natural gas to customers in BC, Washington, Oregon and California and has been operating for more than 60 years.We will only require a short pipeline from the pipeline to our BCR site to transfer recovered natural liquids for processing. This transfer line will not impact operation of the Enbridge pipeline.

Our job is not to manage this pipeline.

Water and Air Quality

1. Please provide quantitative estimates of expected VOCs, especially Benzene,1,2-Butadiene, and formaldehyde, as well as the tonnage per annum of fine particle emissions during all phases of the proposed development and its ongoing operation.

VOCs: Volatile Organic Contaminates are those organic emissions that will vaporize at atmospheric conditions. Modern plants are designed to minimize VOC emissions by eliminating atmospheric vents on tanks and other process equipment, implementation of vapour recovery systems and routing waste streams for safe incineration. Dry gas seals and flanges are designed to minimize leaks to the atmosphere.

Benzene: There has been a lot of misleading information being circulated regarding benzene emissions. In my first meeting with Hay, she initially quoted that the Joffre site emitted 35 tonnes/year of benzene and then restated the same information during the Open House an hour later. This is incorrect. Two days later, she wrote a letter to The Citizen and revised these number down to state that "Red Deer also emits five tonnes of benzene, which has no safe lower limit in the air shed." The 2017 Facility and Substance Information Report for the Nova Chemicals Corporation (Joffre) Site that Hay often refers to states that the Benzene emission is 3.5 tonnes/year, not 35 or five. In addition, the Joffre site has three times the ethylene capacity of the plant we are contemplating and two of the three plants use 40-year-old technology. The site also has two very large polyethylene plants and a linear alpha olefins plant on the same site. The Project WCOL is proposing is one-third of the ethylene capacity and will be using much newer technology and processes.

Hay's assertion is that there is "no safe lower limit in the air shed" is incorrect. I want to make it clear that West Coast Olefins is not condoning benzene emissions, acknowledge that it is a known carcinogen and will take extensive measures to minimize exposure and releases. However, it is important that we consider information in a real context.

The data below is the estimated emissions in kilotonnes adapted from Benzene Emissions Inventory for Canada (1990-2010), illustrates where chemicals fit relative to other large emitters of benzene (note that the numbers are in thousands of tonnes per year).

1995

Transportation - 31

Natural gas dehydrators - 8.7

Steel - 1.2

Petroleum distribution - 0.5

Petroleum refining - 0.4

Chemicals - 0.4

Residential wood -11

Miscellaneous combustion - 4.7

Prescribed burning - 0.5

Forest fires - 58

2000

Transportation - 22

Natural gas dehydrators - 4

Steel - 0.4

Petroleum distribution - 0.5

Petroleum refining - 0.2

Chemicals - 0.1

Residential wood - 11

Miscellaneous combustion - 4.8

Prescribed burning - 0.4

Forest fires - 27

2010

Transportation - 15

Natural gas dehydrators - 3.6

Steel - 0.1

Petroleum distribution - n/a

Petroleum refining - 0.2

Chemicals - 0.1

Residential wood - 12

Miscellaneous combustion - 5.5

Prescribed burning - 0.4

Forest fires - 27

As can be seen, the petrochemical industry has one of the lowest benzene emissions, with forest fires emitting 270 times more benzene in 2010, and residential wood (burning of wood pellets within the home, for example), emitting 120 times more benzene in 2010. If the Red Deer emissions are pro-rated down to reflect a single point, our plant, as Hay would project, then our emissions would .001 kilotonnes to the table or 0.0016 per cent of total benzene emissions.

The greatest exposure that most people will encounter is when fueling your car. The maximum benzene content for gasoline is specified as one per cent. About half of the exposure to benzene in the United States results from smoking tobacco or from exposure to tobacco smoke. Benzene is a byproduct of the combustion of tobacco in cigarettes. The average smoker (32 cigarettes per day) takes in about 1.8 milligrams (mg) of benzene per day. This amount is about 10 times the average daily intake of benzene by non-smokers.

Butadiene: I believe the reference should be 1,3-Butadiene? 1,3-Butadiene will be produced in our Mixed C4 by-product and is an important input synthetic rubber production.

Formaldehyde: This chemical is not produced in our plant.

Fine particle emssions: As has been mentioned to Hay multiple times, the NGL recovery and ethylene plants will not produce particulate emissions as we do not have solid products. Our fuel gas is a mixture of methane and hydrogen making it the cleaned fuel of any industrial plant.

At this stage of engineering development, we do not have accurate and detailed quantities for the emissions being referenced but will need to do so to get through the regulatory process. B.C. has a very stringent Environmental Assessment processes and the public should place some trust that these regulatory bodies will execute their duty and ensure there is adequate consultation with the public.

2. Do you have wind maps to suggest where the emissions from this facility will travel - how far, how frequently, and how long can we expect to experience emissions in each area of the city? What degree of accuracy is associated with these maps? Which areas will be most affected and how will you mitigate these effects?

This information is publicly available through Environment Canada and these will be used when we have air dispersion modeling done by a third party.

Mitigation techniques, where applicable, will be reported throughout the application process.

3. Please provide planned procedures and technologies that will be used to address the VOC emissions mentioned.

Some procedures and techniques to address VOC emissions include, but are not limited to: closed HC systems, no intentional or unintentional atmospheric venting (like past processes commonly did. This is the purpose of the flare, to safely vent and burn HC inventory/purge during plant upsets or during startup or shutdown procedures), vapour recovery systems, elimination of underground piping and HC tanks, design and monitoring of flanges on piping and equipment, seals and packing on valves and rotating equipment to minimize leakage of process fluids (fugitive emissions).

4. Please include the estimated carbon emissions from transporting product and wastes to and from the site, storage, delivery, etc.

The carbon emissions associated with our project is a very good story. Extracting natural gas liquids from the Enbridge pipeline will make it a much cleaner fuel when it is burned by downstream users where virtually all of the gas is burned as fuel in home heating, refineries and power plants. Cleaning up this large hydrocarbon fuel source by removing the heavy components (ethane, propane, butane and condensate) reduces carbon emissions that more than offsets the direct carbon emissions from our facilities. In addition, producing polyethylene in Canada from ethane and selling it into the Asia market will displace Chinese production where polyethylene is produced from coal but with 15 times the carbon emissions.

Figure 1 compares greenhouse gas (GHG) emitted (combustion sources) from the NGL recovery plant and ethylene plant with the direct reductions achieved from the cleaner combustion associated with the return of lean gas into the Westcoast Pipeline and the beneift of displacing high emissions production in China. The 8+Mt/a reduction in GHG emissions is a significant portion of the total 60+ Mt/a that B.C. emits annually.

Quantities for carbon emissions associated with transport of products and waste will be developed during detailed engineering, but these numbers will be minor compared to those referenced above.

5. How many millions of plastic pellets and how much plastic dust will be lost into the environment per annum, both as inevitable and accidental fugitive plastic losses during all phases of production, storage, transport and delivery. What efforts will be taken to reduce such losses?

As previously stated, this information will be provided by the third-party polyethylene producer.

6. How will you mitigate emissions, spills, or chemical explosions at your facility? What risks exist for adjacent facilities, Haggith Creek, and the Fraser River should a spill, explosion, or fire occur at your facility? What strategies will you have in place to ensure further contamination does not occur following a fire? What is your response strategy to minimize impacts while ensuring worker safety?

See answer to question 4 in the refining/manufacturing section.

Emergency response plans will be developed before the plant starts up. As the hazards are so unique, the standard practice in modern petrochemical plants is to train their personnel in emergency response as they best understand hazards and appropriate responses.

7. How will you protect the salmon and sturgeon living in the Fraser River, from both accidental and inevitable plastics losses into the river?

Third-party partner will be responsible for addressing all concerns regarding the production of plastics and the associated activities. However, we would be very surprised if this third-party locates the plastic loading close to the Fraser River.

8. What emissions standards are currently in place for the newest facilities in the world, and exactly how do you plan to meet or exceed these?

This is a very broad answer, but many of the methods are referenced in the responses provided in this document.

I have worked on all the ethylene plants in Canada. Our team will be working from good benchmarks and have very good knowledge of the improvements that have been made (previously discussed improvements from the Joffre plants).

B.C.'s regulatory regime is one of the most stringent in the world and we will need to ensure that we are using the best available proven technology if we hope to obtain regulatory approval for our project.

9. How do these contemporary plant emission standards (see previous question) compare to what you intend to build in the bowl of Prince George on Willow Cale Road? How does the proposed plant for Prince George compare with the Joffre plant in Red Deer (that you have publicly referenced)?

See answer to question one within the water and air quality section for comparison with Joffre Plant.

Furthermore, all of the people we have talked to don't consider the south end of Willow Cale Road, where our plant will be located, as within the Bowl area. It is within the Prince George airshed, but not within the Bowl. The site location is on the southeastern boundary of the city within the BCR Industrial Site.

10. Would the chief operating officers of this company want this facility in their backyard? In their children's airshed?

Both the CEO and COO have worked daily within an ethylene plant and would have no concerns working there on a long term basis.

I have worked in ethylene plants in Russia, China, and the United States Gulf Coast (USGC), but would not go back as readily as I would in any of the ethylene plants operating in Canada. I am very proud of Canadian standards for the petrochemical Industry and they have been demonstrated leaders with programs such as Responsible Care.

Site selection

1. Why have you chosen this site for your proposed facility? How did this site win out over alternative sites?

The criteria that was used in site selection by WCOL includes the following considerations: reasonable commute for workers; utilization of previously developed industrial land; close proximity to critical infrastructure (road, rail, Westcoast Energy Pipeline); and local community capable of supporting the long-term operating and maintenance needs of our project.

The Pas Lumber Site was the first site considered and was identified by the provincial government as an abandoned industrial site that might be suitable for our project. Considerations for not selecting this site included: disturbance of a large block of undeveloped land that would have to be disturbed to make this site suitable; the lack of existing infrastructure such as water and railway; and the lengthy commute from Prince George that would pose the single most significant hazard to our workers and local residents using this highway.

The former North Central Plywood (Canfor) site was the second site considered and was located within the BCR Industrial Park. The main attraction was the existence of all critical infrastructure our plant required and the fact that we would be utilizing land that had previously been used as a large industrial plant site. However, this site was not chosen for the following reasons due to the close proximity to College Heights, approximately 0.95 km away from the closest house in College Heights.

Hart North site: In our first meeting with Hay and other PACHA members on Aug. 7, Hay questioned why we had not selected the Hart North site, that was recommended in the Prince George Area Industrial Land Profile study that was published in May 2008. West Coast Olefins stated that we were not aware of the report, at which point Hay gave us a hard copy. An hour later, during our open house, Hay made a public accusation that we had not considered the Hart North site option or even read the copy of the study she had given us, despite knowing in the hour that had passed since our earlier meeting with her and PACHA, we were preparing and presenting at our open house to present our project to the general public. Prior to our next meeting with Hay and PACHA member on Aug. 22, West Coast did review the document, only to realize that it is not a real option at all. We had visions of an existing industrial park that was zoned and approved for industrial development. In fact, this "industrial park" is piece of Crown land athat lies 30 km north of the City boundaries. It has not been transferred to any proponent that intends to develop it as an industrial park. For this to be considered a valid option, significant time, effort and money would be required to achieve the following: a proponent would need to be identified to develop this site, which we assume would be the Regional District (the land lies outside of the city, and therefore, Prince George representatives would have no jurisdiction over rezoning, or transferring land titles); an application would need to be made to transfer title from the Crown; and First Nations title rights and impact on treaty and Aboriginal rights would need to be addressed as the Hart North site is located in the traditional lands identified in the McLeod Lake Indian Band treaty and overlapping claims with Lheidli T'enneh First Nation. Achieving all of these milestones will take several years, and there are several risks that this outcome will actually never be realized. How can West Coast Olefins consider this as a real site option when nobody has taken any steps to develop it, despite the fact that 11 years have passed since the 2008 report was issued? Despite being made aware of this fact, Hay continues to suggest that Hart North is the site we should be using.

2. What meteorological data did you use in determining the best site for your petrochemical plant?

What does this question have to do with site selection? See previous question for site selection criteria.

3. How did proximity to residential neighbourhoods and schools, as well as the ALR designation for the land upon which the site is proposed, factor into your site selection?

There has been a lot of incorrect information circulating regarding the proximity of our site to Lower College Heights. In our first meeting with Hay and PACHA, she stated that the site was 800 metres from Lower College Heights and she restated this in our open house later that same day. Later, in her letter to the Prince George Citizen, Hay modified her assertion that the Willow Cale site is two kilometres from Lower College Heights but this information is also incorrect. The distance between the proposed location of the ethylene plant, and the nearest house within College Heights is 3.65 km. The proposed WCOL Site is located on the southeast boundary of the City of Prince George.

Between the community of College Heights and the WCOL Site is the Fraser River, Chemtrade West, multiple fabricators within the BCR Industrial Site, the Pacific BioEnergy Plant and the CN rail line. We are located within the industrial area of Prince George. We do not border any schools, we are approximately 4 km from the nearest school and we are 3.65 km away from the nearest residential neighborhoods.

Parts of the fringes of the property are designated as ALR, however the location in the BCR site makes it impractical for agricultural purposes. We have talked to the city and they do not foresee insurmountable issues in having this land redesignated.

4. How does this kind of project fit in with the global need to reduce the proliferation of plastics?

Our project has nothing to do with proliferation. The overall WCOL development will create product that the market is demanding. The reality is the Chinese market has developed a coal to methanol to olefins industry which has 15 times the emissions as a plant which uses ethane as its feed. If the world is going to have plastic, it is important to supply it in the most efficient way possible.

Alternatively, the Frontier Project plans to export liquids, that would otherwise be used by WCOL to Alberta and create jobs there. Is this the preferred outcome?

5. Both Sarnia, Ont. and the Louisiana Gulf Coast which have big petrochemical ethane cracking plants are referred to as "Cancer Alleys." What convincing evidence can you offer that in 10-15 years Prince George will not also be referred to as "Cancer Alley?"

This information is incorrect. Prior to the last five years, Sarnia and the U.S. Gulf Coast have not been ethane-based producers, most using naphtha (liquid HC) as feedstock. These plants produce more by-products and many were built 40-70 years ago. The rapid development of shale gas in the past ten years has provided the ethane feedstock that is being used in plants that have recently been built or converted to ethane feedstock. None of the environmental standards, let alone measuring tools, existed when these older plants were designed and built. We believe the solution is to replace aging infrastructure as quickly as possible and that is the best way to improve the environment and still provide the necessary commodities of today's lifestyle.

Human health

1. How do you plan to respond to well documented long-term human health impacts and concerns associated with similar existing facilities elsewhere in the world?

See answer to previous question. The best thing is to replace with more efficient plants.

2. Can you provide evidence that your proposed facility will not cause long-term negative human health, environmental, and air quality impacts both on site and in the greater community?

I don't think there is an answer we could provide that would satisfy you on this. See answers to previous questions.

3. How will you protect workers in your facility from exposure to toxic heavy metals like lead and mercury, arsenic and cadmium? How will you seek to prevent worker nanoparticle dust ingestion/integration, exposure to toxic chemicals and gas emissions?

None of these heavy metals are present within NGL Recovery, ethylene production or polyethylene production. These are present in mining processes and have nothing to do with our process.

All operators and onsite personnel will be provided with adequate personal protective equipment (PPE) and training before they work on the WCOL site(s).

4. How do you plan to monitor levels of exposure for your workers regarding inhalation of nanoparticles, chemicals and gas emissions? If exposure, acute, and/or long term health impacts are reported, how will you work to address these in terms of reducing harm to workers and improving the health and safety of the plant?

All new workers will be undertake full medical to serve as a baseline for all future testing.

All workers will be equipped with monitor badges and adequate PPE.

Industry accepted safety practices and regulatory bodies, such as Occupational Health and Safety and Worksafe BC will address these issues.

5. The City of Prince George is a signatory to the Blue Dot campaign. As a Blue Dot community, our city council has committed to protecting residents' rights to a clean environment. This includes the right to breathe healthy air. What data can you supply residents to assure them that the proposed plant will not compromise this?

See previous questions for answers to air emissions. As has been stated multiple times, the NGL recovery plant and ethylene plant will emit no particulate matter, closed systems will be implemented to reduce the possibility of atmospheric leaks and will be using cleanest burning fuel, to name a few.

Environmental assessment & community engagement

1. Do you have deadline dates for the Provincial Environmental Assessment Process and can you share those with our group?

One of the first steps in the regulatory process is to determine whether a project is reviewable as defined in Section 10 the BC Environmental Assessment Act. Once that determination is made, the Environmental Assessment Office will issue a Section 10 with its decision. West Coast Olefins is in the process of trying to secure its Section 10 order.

Assuming that the determination is that an environmental assessment certificate is required for the project and the proponent may not proceed with the project without an assessment, the Environment Assessment will determine the specific assessment scope, procedures and methods required in the proponents environmental assessment, as defined under Section 11 of the act. The EAO will issue these instructions as a Section 11 Order. West Coast Olefins is hoping that occurs later this year

The timing for the actual assessment activities will depend on what is specified in the Section 11 order.

2. Will the proposed plant be subject to regulation under the Oil and Gas Activities Act as amended by Bill 23- 2015?

The regulator will guide WCOL through the applicable legislation and regulations.

3. Please provide dates, times, and locatios for the next public information session/s you will be offering in our community.

The public consultation requirements will be defined in our Section 11 order when we receive it.

Ken James

President and CEO

West Coast Olefins

Calgary

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