A summary of the recommendations, and the status and lead agency for each are outlined below.
Recommendation 17: Establish an air-quality task force to oversee implementation of the recommendations in the report.
The Fort McKay Air Quality and Odours Advisory Committee was established in December 2016. The committee is chaired by the AER, Alberta Health, and the Fort McKay First Nation and Métis community, and includes representatives from AEP, Environment and Climate Change Canada, and industry.
Recommendation 8: Clarify who is accountable for supporting the complaint response and notification when ambient air monitoring identifies ground-level concentration exceedances, and ensure that this is captured in the odour response protocol described in recommendation 4.
The Wood Buffalo Environmental Association (WBEA) has been confirmed as the agency responsible for reporting ground-level concentrations that exceed the Alberta Ambient Air Quality Objectives (AAAQO). WBEA has been responsible for reporting exceedances in the past, but this has now been formalized with a contract.
Recommendation 1: Monitor ambient air quality for acute concentrations of H2S and SO2 for emergency response in the Fort McKay community. Monitoring should be done by AEP and be funded by industry, and acute thresholds for H2S and SO2 concentrations should be approved by Alberta Health in discussion with Fort McKay.
The air monitoring station was installed in Fort McKay and began monitoring air quality in July. The air monitoring station has been named the Waskōw ohci Pimâtisiwin station. This name was chosen by a member of Fort McKay and means “air of life.” Trigger levels for acute concentrations of H2S and SO2 have also been established. When concentrations exceed the trigger levels, the Fort McKay community will receive advance notice that air quality will be impacted. This will provide time to prepare for an emergency response if needed. The next step will involve developing trigger levels for additional contaminants that may have an acute health impact. This work is being led by Alberta Health and is expected to start in November 2017.
Recommendation 3: Share oil sands operators’ emergency response plans (ERPs)—or relevant sections—with the community of Fort McKay through a regulatory mechanism.
A risk analysis of the impacts operators in the area could have on Fort McKay has been completed. This will help identify which parts of operator ERPs should be shared with the community. A subcommittee was established in August and the first meeting will be held in the fall.
Recommendation 4: Develop an odour response protocol that is specific to the Fort McKay community and consistent with the odour management policy of the GoA.
A draft odour response protocol has been developed and will be tested in the fall. The protocol will help improve response to odour complaints, provide more transparency about the actions taken to address complaints, and identify the source of the odours. It will also create a process to ensure that findings from investigations into odour events are shared with industry and the complainant.
Recommendation 5: Develop a checklist of operating conditions that an operator is to complete when an odour complaint is received by the AER and the operator is contacted by the AER.
A draft checklist has been developed and will be tested in the fall with the draft odour response protocol developed for recommendation 4. The checklist will be used as part of the protocol. Once the protocol and checklist are finalized, an implementation plan will be developed by the AER and industry.
Recommendation 7: Provide all parties with access to real-time air monitoring data collected by Environment and Climate Change Canada in the Fort McKay community.
A data-sharing agreement is being reviewed by the AER and the GoA. The agreement will allow the AER, AEP, and Alberta Health to access air monitoring data from the Oski-ôtin research station in Fort McKay. This information will help improve the odour complaint response and investigation.
Lead: Environment and Climate Change Canada
Recommendation 9: Assess fixed- and fugitive-emission sources, focusing on the parameters in the air quality focal parameter list (section 6.6.4 of the report) and on polycyclic aromatic hydrocarbons in order to develop a roadmap for a systematic process for examining the dominant emission sources of the parameters in the focal parameter list.
A subcommittee was established in April, and work has begun to implement this recommendation.
Recommendation 10: Conduct a targeted examination of emissions control based on the findings from recommendation 9, and implement the controls through a multiyear continuous improvement program.
A subcommittee was established in April, and work has begun to implement this recommendation. This recommendation is to be fully implemented in 2018 once work on recommendation 9 has been completed.
Recommendation 13: Assess the health implications on the Fort McKay community based on the ambient monitoring results, specifically the parameters in the air quality and odorant focal parameter lists (section 6.6.4 of the report) that were in concentrations greater than standards, limits, objectives, and thresholds. The assessment must consider limitations in the data, how applicable the thresholds are to human health, and what it means to the community when parameters are exceeded.
Alberta Health is working with Fort McKay to determine the scope of the work required to implement this recommendation. Alberta Health and Fort McKay met for the first time in May with further scoping of this recommendation planned for the fall.
Lead: Alberta Health
The following recommendations are expected to be implemented starting 2018 because they depend on the implementation of other recommendations.
Recommendation 2: Provide policy guidance on the appropriateness of odour thresholds for emergency response purposes in the community of Fort McKay.
Recommendation 6: Provide policy guidance on the use and application of odour thresholds in the Fort McKay community, and clarify how the AER uses environmental protection orders under the Environmental Protection and Enhancement Act (EPEA)to address offensive odours.
Recommendation 11: Consider odours generated by project activities when modelling air dispersion for EPEA applications and environmental impact assessments, and review the Air Quality Model Guideline to improve the consistency, among operators, of air dispersion modelling for odours.
Recommendation 12: Review reporting requirements for oil sands EPEA approvals in order to improve the consistency of monthly and annual reporting, units of measurements, and quality assurance and quality control; to include additional parameters with AAAQOs; and to consider transparency and public access to the industry reports.
Recommendation 14: Establish an integrated, consistent approach to air quality monitoring from source (industry emissions) to fenceline (Mildred Lake – AMS02, Mannix – AMS05, Lower Camp – AMS11) to ambient monitoring stations (AMS01 and Oski-ôtin). Changes to monitoring should consider contaminants on the air quality focal parameter list (section 6.6.4). Consider polycyclic aromatic hydrocarbons in future monitoring plans.
Recommendation 15: Improve the consistency in monitoring H2S and total reduced sulphur, including examining individual sulphur compounds under the oil sands’ ambient air monitoring network.
Recommendation 16: Develop and apply ambient air quality policy for parameters that do not have AAAQOs in the areas of odour, ecology, and human health.