Propane paperwork

The E2 regulation was amended in 2011 and 33 substances were added, for a total of the 215 substances currently listed. A proposed amendment will add another 49 substances for a total of 264 substances. The following information relative to the EC E2 regulation is presented to hopefully clarify what is required under Section 200 of the Canadian Environmental Protection Act (CEPA) and published in Part II of the Canada Gazette on Dec. 21, 2011.

When determining if one’s propane installation is regulated by the Environmental Emergency Regulations, it is important to understand the math behind propane storage tank capacities: 4.5 metric tonnes equals 2,345 U.S. gallons or 8,876 litres.

Level 1 threshold
This level applies to propane installations where the total storage capacity is 4.5 metric tonnes or greater, where the single largest storage container is less than 4.5 metric tonnes. For example, an installation having two 2,000-gallon storage tanks manifolded together. The combined capacity is over the 4.5 metric tonnes threshold, with the single largest storage container being 2,000 gallons, which is less than 4.5 metric tonnes in capacity.

The company or individual having “charge, management and/or control of propane” at such an installation is required to register the site with Environment Canada using a Schedule 2 Notice Regarding the Identification of Substance and Place. It is not required, but Environment Canada strongly recommends development of an EC E2 Emergency Response and Preparedness Plan (ERPP) for the installation.

Level 2 threshold
Now we are talking about propane installations where the total storage capacity is 4.5 metric tonnes or greater, where the single largest storage container is 4.5 metric tonnes or greater. For example, an installation with one 1,000-gallon storage tank and one 5,000-gallon storage tank on site. The combined capacity is over the 4.5 metric tonnes threshold, with the single largest container being 5,000 gallons, which is greater than 4.5 metric tonnes in capacity.

The company or individual in charge of the propane at this facility is required to register the site with EC using a Schedule 2 notice and prepare an E2 ERPP, as above. In addition, they must submit a Schedule 4 Report Regarding the Preparation of an Environmental Emergency Plan and a Schedule 5 Notice of the Implementation and Testing of an Environmental Emergency Plan.

Once the above requirements have been met, they are by no means complete. There is a requirement for annual verification of the information and an ERPP testing component.

For further information on Environment Canada’s E2 regulation and the implementation guidelines, you can visit ec.gc.ca or contact Environment Canada’s regional environmental emergencies coordinator at 1-800-668-6767.

About the author – Gord Ellis of Ellis Management Group in Burlington, Ont., has over 35 years of Canadian propane industry experience. He has held senior sales and marketing management positions within the industry and has sat on the board of directors of the former Ontario Propane Association (OPA) and Propane Gas Association of Canada (PGAC). He was recently re-elected to a second term on the board of directors of the CRA Ontario.