Ontario CA

Soon, Ontario Regulation 88/22 Will Require Sulphur Dioxide Monitoring

May 9, 2023

By: Peter Pakalnis

Do you know what’s special about January 1, 2024? 

That’s the day Ontario Regulation 88/22 will require petroleum facilities to install Continuous Emission Monitoring Systems (CEMS) for sulfur dioxide (SO2). 

Historically, refineries in Ontario, Canada haven’t operated compliance-grade CEMS on many of the sources. The regulation will soon require monitoring because there was no government call to do so previously. But the tides are turning.

How we got here

Ontario Regulation 88/22 was introduced as part of an effort to reduce SO2 emissions. The sector-specific regulation affects five petroleum facilities in Ontario and places emission restrictions on flares, catalytic cracking units, sulfur reduction units, and certain combustion devices. Operators are now required to install CEMS on these sources to determine SO2 emissions.

As part of the regulation, Continuous Monitoring Plans (CMPs) were submitted to the Ministry of Environment, Conservation and Parks (MECP). These plans described the equipment types in detail and the means of ensuring accurate data collection and representation. Some of the requirements state that the equipment meets the installation and performance specifications of Environment Canada EPS 1/PG/7. 

So, for many facilities that have never had to operate CEMS per their CMP, this new requirement will bring about drastic change. For some monitors, there will be daily, quarterly, semi-annual, and annual checks on the CEMS as required in Environment Canada EPS 1/PG/7. This blog covers some of the actions you’ll need to take to ensure your CEMS is compliant.

What’s currently happening

Affected facility operators are spending their 2023 installing the CEMS required to meet the target installation date of January 1, 2024. If they’re not already, they’ll also need to ensure the CEMS is operational no later than July 1, 2024.

What this means for you

As a CEMS owner, you’ll have to ensure that the equipment is running properly and generating valid data at all times.  Prior to using the CEMS for data, there may be a requirement for CEMS certification for the equipment as per your CMP. Once the equipment is up and running, it may require calibration checks, relative accuracy test audits (RATA), bias tests, and a robust preventative maintenance plan.

What you should do now

As a facility ensure, that you understand the requirements to operate your CEMS as per a compliance analyzer as written in the facility CMP.  January 1, 2024, is not that far away, so it would be best to be prepared and make sure that the equipment is ready to generate valid data.

How we can help

If you require assistance with your CEMS certification or daily, quarterly, semi-annual, or annual RATA/bias checks contact Montrose Environmental Group Ltd.  For three of the five refineries in Ontario, we are local to the Sarnia area.  We have extensive experience in CEM certifications and conducting tests for the performance specifications in EPS 1/PG/7. And our team includes field specialists with extensive experience in the petrochemical and petroleum sector and can fully support your continuous monitoring system compliance requirements. 

Contact us if you require any assistance for ensuring that your CEMS are generating valid data! We have the experience and capabilities to ensure your CEMS initiative is a success.

Peter Pakalnis
Principal, Emissions Testing
Peter Pakalnis is an Operations Manager in Eastern Canada for Montrose Environmental Group Limited (Montrose). He has over 30 years of experience in the emissions testing field and currently specializes in assisting with CEMS testing programs for numerous industries. He has worked for Montrose since 2020 and LEHDER Environmental Services Limited prior to that. He is well versed in the emissions testing field in both wet method testing and CEMS / FTIR-related work. He has also taught emission testing courses at local colleges, industrial facilities, and for government personnel. He is an active member of the Source Evaluation Society (on QSTI Committee and former director SES) and outside of work is a Zone Chairman for the Lions Club and Treasurer for the Ontario Hazelnut Association. Peter has a Diploma in Environmental Technology from Fanshawe College in London, Ontario.

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