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I r :/ 1/f 1<1/ I/

R VIEWOF

NVIRONMENTAL
PROTCTION
ACTIVITIES
FOR1973

PROPRIETARY
TO
IMPERIAL
OILAND
AFFILIATES

IMPERIAL
OILLIMITED
TORONTO,
ONTARIO

628 . 5
134

  15:2

 

I

19 7 3 ENVIRONMENTAL PROTECTI ON REVIEW
AND COORDINATION ACTIV ITIES

CONTENTS

I.

!.!:.,.')'
PERSPECTIVE

1.
2.
3.

4.

5.

II.

'}

4

PERFORMANCE AND PROBLEMS OF OPERATING FUNCTIONS

1.
2.

3.
4.
III.

Global
Organization
International
Conventions
U.S.
Overview
Regulation,
Status
Canada Overview
Regulation,
Status
Public
Attitude

Policy
and Objectives
Accomplishments
(1) Exploration
and Production
(2)
Logistics
(3) Transportation
(4} Marketing
(5) Esso Chemical
(6) Building
Products
(7) Business
Development
(8) Oil Spill
Incident
Report
Major
Problems
Remaining
Plans

7
7
7
7
8
8
6
8
8
9
9

10

COORDINATION DEPARTMENT ACTIVITIES

1.
2.

3.

4.

s.
6.

coordination
- Environmental
Quality
Committee
Audit,
Manpower,
Expenditures
and Budgets
service
to Executive
and Departments
Industry
Activities
(1)
PACE
(2) CPA and APOA
Government
Relations
public
Relations

12
13
13
14
14

15
16
17

Nr).

 -

I

-

197 3 ENVIRONMEN'T'/\
f, J>HO'l'Jo:<''1'I ON
AND COORDTN/\'f'ION
SEC'l'TON

/\(''I'

I' 1,;vf J•;w

IV f'I' I J,;f;

r

PERS PEC'I' rvr,:
1.

Global

Organization

The Unit ed Nations
Conf r nc
on 1-h<..:Human Environment
it or not--set
held
in Stockholm
in 1972--whether
w
ppr ciatcd
new horizons
of concern
for all governments,
for all multinational
industries,
and for most largo
national
companies,
such
as Imperial.
The United
Nation s Environmental
Program,
under Maurice
Strong,
was formally
inaugurated
in 1973.
Nairobi
in Kenya was
selected
as permanent
headquarters
for the Governing
Council,
session
of the
Executive
Director,and
his staff.
At the serond
Governing
Council
held in March 1974, program
activities
were
allocated
at $18 million
for 1974 and $20 million
for 1975.
Priority
items were:
art
1

- Environmentally
sound technology
related
to human
settlements,
such as low-cost
building
techniques,
water
and waste treatment.
- Protection

of

the

- Management

of

arid

- A Global
priority

environment.

regions

and

reclamation

Environmental
Monitoring
System
pollutants
and their
effects.

- An International
environmental

governmental
be assigning

marine

Referral
information.

Service

Maurice
Strong
has encouraged
organizations
to cooperate
United
Nations
consultative

for

of
for

sources

deserts.
monitoring

of

international
nonwith the program
and will
status
to such bodies.

on Mr. Strong's
recommendation,
an International
Centre
for Industry
and the Environment
was brought
into existence
at
Geneva
in July
1973.
The Centre
will
serve
as the prime communiand the u. N.
cations
channel
between
industry
and b~siness
industr y, through
IPIECA
·
mental
program.
The petroleum
.
E nviron
·
1 Conservat
ational
petroleum
Industry
Environmenta
ion
t
CI
n ern
d.
b
f th
.
Association)
is one of ten foun ing mem ers o
. e International
The International
Chamber of Commerce is also a member
Centre.

 11,

Hl

'h,1it11i.1n

1. <' c·.

1 th

n

h,

Uc;,rd,
Mr.
J. l
l•:nv 1 onm< nt.a I C<">mmi
t
,.
ot

:l

w,HJ f:orma l ly i naugura
<:.
1 , y Wink l< r. undertaking
aubata
is open to inter~~. i ~:~
M mb r hip
n,1 l c i 1 •omp ni s involved
in internrJt
ir..,r ~
,nd p romin, and to internatior~
~r ~
uh as CONCOWE,API, PACE, a ., CP~.
11 11~ '/\

.,n

r

Th purpose of IPIECA is to repr~aer~
nd to have consultative
stat~s
w· th
Environm ntal Program.
IPIECA wil
nd assistance
of other oil industry
ncourage
them in environmental
uplication
of effort.

There

r.

gr

.,p

was only

one major internaticr.a:.
c,.. .=e:re,..c-:. on
concern to -::·ne si_ .:..r,d1s-:r
-:!rid
1 Conference:
en _l.ar ::..ne 20:_ l. _ior;
The conference:
adop-:ed
a ·,ery
mpr hensive
re-draft
of the 1954 Con·Jention
':.0 -::0·,er a 1 ::inds
of
llution
from ships rather
than just oil.
It is ca:led
" Inter.!:ro-- s~.:..ps
national
Convention
for the Prevention
of Po:.:.~~ion
1973".
The technical
aspects
of different
types~=
po"l:iltion
are
of Pollution
vered by five separate
annexes.
Annex I, "Pre7en~ion
by Oil",
and Annex II,
"Control
of Pollution
by _-ozious
I.:.q.1id
Substances
in Bulk",
are mandatory
by all states
rati=yir.g
~he
Convention.
n ironm ntal
issues
of direct
h · was the IMCO Internationa
h ld in London last
October.

The basic
hart

measures

( 1)

International
and required

(2)

International
prosecution.
The more

adopted

standards
equipment.
means

important

of

were:

of control
inspectio

technical

of

shio

n, enforce

requireme

o ve ~nts

ent,

and

nt s adopted

were:
(1)

Limitations
on oil discharge
vessel,
speed,
proximity
to
be 50 miles
from land,
must
oil/nautical
mile.

accord ing to size of
coast
in es; e.g.,
ust
not exceed 60 litres
of

 - 3 -

Chart

(2)

Refinement

of

Load-On-Top

procr·durca.

(3)

Inclusion
of oil.

of

(4)

Compulsory
and short

use of
hauls.

(S)

Compulsory
phasing
in of segregated
ships
contracted
for after
December

3

all

petroleum

shore

a in the

pr0<luc

ballast

tanks

for

definition

special

ballast
for
31, 197 5.

areas

all

new

The Convention
will
come into
force
one year after
ratification
by at least
15 statea,whose
combined
merchant
fleets
constitute
not less than 50% of the world's
merchant
shipping
as
measured
by gross
tonnage.
Earliest
anticipated
effective
date
is June 1975.
3.

United

States

Overview

The year began with high hopes by environmentalists
for
quick
action
on many major issues.
The year ended with most
citizens
aware that
their
energy wants and environmental
philosophies
were on a collision
course,
and with industry
even more
frustrated
with ever-tightening
screws
of an ever-increasing
legislated
plans.
bureaucracy,comrnitted
by unattainable

Chart
4

The original
Administrator
of EPA, William
Ruckelshaus,
was replaced
by Russel
Train,
who had been Chairman
of the
President's
Council
on Environmental
Quality.
The rule-making
in 1973; if anyt hing,
it was more
pace of EPA did not diminish
hectic.
The National
Pollutant
Discharge
Elimination
System,
under which all
industrial
and municipal
dischargers
must have a
permit,
got under way.
It is proceeding
with interminable
EPA and industry
technocrats
over
argument
and confusion
between
definition
of permit
requirements.
All industries
must employ
best
practicable
technology
by mid 1977 and the "best
available
economically
achievable"
by mid 1983 and have a goal of zero
discharge
of pollutants
by 1985.
The administration
has
categorized
industry
into
twenty-one
groups
and must publish
effluent
guidelines
for each category
by fixed
dates
in 1974.
These guidelines
form the bases
for issuance
of discharge
permits
which are obligatory.
In air programs,
a court
extension
for meeting
1975 deadlines
37 metropolitan
regions.
The court

action
rescinded
a two-year
to
which EPA had granted
ordered
each region
to submit

 : t

t •

I

'I'll

Y•

• w numerous
court
actions
by e n v iron ment<. l i
I ' !.:\ ,n, I t ndu. t y, and by EPA versus
individua
1 c om pan 1. •
p rhaps
the most significant
is sue yt. t l
l>
II
] g adation
principle
in which
env iron mL ntc I . t t . must protect
air
quality
even wh e n it
is
n 11• h 1 , I •
ndards.

"l . .

ol concerns
ripened
in 1973 and wi l l
d ral
legislation
in 1974, which
will
1 siting
of all
utilities
and oth er
p mits
by federal
agencies,
and any o t h e r
n b
brought
under
federal
influence.
n

\

' I ( '\lit
It t I t \I h
'l'hl

n l,ll't

·n

n

1·.1,

1 , ,1n

I
t

crisis
has arrested
progress
in the u. s .
nm nt, on some fronts,and
no doubt
b ot h
nvironmentalist
actions
have softened.

N11l i n

l Wi.ldlife
ptl
"livability"
in l 7 2 •

Federation,
using
a c o mp osite
of
in the U.S.
at an i n dex of 53,

, oth r than
for
litter
control,
no n e w environno
major
significance
was passed.
On t h e
at both
the federal
and prov i n cial
lo y actions
num ou but indicated
some changes
in direction
ltrui.tlc
policies
in the
legislation.

m n
th
l

tn®tnt~
on the
indn.
y are:

p

(1)

most

significant

actions

affectinq

Th F ~ ral Efflue~t
Water
Quality
Standards
and
~ui~
lines
for refineries
emerged
as rational,
and
1nd1
ta.responsiveness
of the agency
to well
r
son d industry
argument.

th~

I
I
I

 - 5 -

(2)

The Federal
Government
did recognize
the potent i al
for energy
wastage
in the U.S. auto emission
standards
and, therefore,
promulgated
levels
for
contaminants
that
could be met without
the use of
catalyst
systems.

(3)

The recently
announced
B.C. Pollution
Control
Board
Objectives,for
Oil
Air Emission
and W9 ter Effluent
Refineries
and Chemical
Plants,do
not show the same
rationality
and understanding
by that
provincial
agency.

(4)

The Quebec Government's
first
draft
of a Projected
Air
Pollution
Control
Regulation
portrayed
a considerable
naivety
with respect
to air pollution
control
technology
and management.

(5)

Alberta's
display
cleanest

regulations
for Sour Gas Plants
continued
the Environment
Minister's
goal to be the
in Canada.

to

The Federal
Environmental
Protection
Service
completed
the set-up
of its
five regional
offices
but continue
the acquisition
of staff.
The roles
and activities
of these
regional
staffs
vary
with
geography,from
being
very aggressive
to nominally
passive.
In
most cases,
they are another
layer
of bureaucracy
with which to
contend.
As yet,
Environment
Canada has not published
a summary
report
on progress
or regression
in environmental
quality.
Annual
reports
by the Alberta
and Ontario
Departments
of Environment
and the Montreal
Air Pollution
Controller
provide
some data
for
specific
locations
which are useful
indicators.
Air quality
in the
City
of Toronto
has improved
over the past ten years
to a point
where
it met the U.S. primary
objective
of 0.03 ppm. for so2 in
1973.
The province
now monitors
the air in 44 Ontario
communities.
In the Province
of Ontario,
16 new municipal
sewage
to existing
plants
were approved
treatment
plants
and 23 extensions
in 1973, with expenditures
estimated
at $225 million.
In the same
127 industrial
installations
estimated
at $33 millon
were
period
approv;d,
and 25 applications
estimated
at $45 million
were pending
approval.
of solid
wastes
has received
considerable
provinces.
New litter
legislation
was
rovinces
The
City
of
Toll:>nto,
with
a
major
passe db y most P
•
.
•l problem
is studying
a proJect
to generate
steam
S
di spo Q
garbage
'

attention

The
from

handling

several

 - 6 for

buildings

in

the

city

core

from

120 0

On s per

day

of

refuse.

.
·he Federal
level
Noise
legislation
is being
drafted
at~
t of manufacture
at Lhc poLn
and
to control
machinery
and mobile
sources
.
.
f.
t l . onary
sources
Ontario
has proposed
noise
legislation
.ors
a i
from the operation
of mobile
sources.

s.

Environmental
Ontario
and

stages

in

Public

Attitude

Impact
Ottawa.

legislation

is

in

the

.

drafting

t owar a t~1 l
~nvirrn
.
In general
the attitude
of Cana d ians
ment continues
to exhibit
a fairly
high degree
o f conct:!rn • 'l' ~
emphasis
has shifted
from hounding
industries
for their
obv1ou:
implied
sins
of polluting
the air
and streams,to
more responsible
broader
concerns
of best
location
for new plants,and
of reason
for
existence.
In the energy
sector,
the growing
concern
regarding
foreign
ownership
and growing
nationalistic
protectionism
has
focussed
attention
toward
controlling
exports.
With exports
eliminated,
new energy
source
developmentswith
all
their
inherent
environmental
hazards
could be stopped
or, at worst,
slowed
down.

Several
of the major
energy
resource
developments--oil,
gas and electricity--include
the problem
of native
peoples
'
As
aboriginal
or treaty
rights
as well
as environmental
concerns.
major
hydro-electric
developments,
such as the Hydro-Quebec
's vast
James Bay power development,
deprive
several
thousand
Indians
of a
livelihood
from traditional
hunting
and fishing
pursuits,
the
environmental
consequences
have become widely
recogn ized.
This
recognition
of broad
social
effects
of changes
to the natural
environment
naturally
spills
over to the oil
and gas sector
in
concern
for northern
frontier
developments.
A public
opinion
poll
conducted
in Novemb er 1973 ranked
pollution
second
in degree
of effect
of six issues
which were
concerning
people.
On the question
of contribution
to environmenta
1--7~- damage by industrial
sectors,
petroleum
was considered
third
hi h~:
The most significant
finding
in recent
surveys
was that
over
80~ ~s ·•
of people
polled
felt
that
both government
and industry
should
d
more to combat pollution,
even if it meant higher
taxes
and h. h o
·
f or goods.
19 er
prices

Chart
~ -6~chart

 - 7 -

SECTION I I
PERFORMANCEAND PROBLEMS OF OPERATING FUNCTIONS
1.

Policy

The status
of Imper ia l 's environmental
achievements
and
is in keeping
with the Ex xon st a tem ent of corporate
policy
We are adhering
to ex is t ing environmental
standards
obj~ctives.
and are contributing
substantially
t o the efforts
of outside
associations,
groups,
such as PACE, CPA, and p r ov i n ci a l industry
to develop
realistic
regulations
. I n ge n e ral the relationship
between
both Imperial
and industry
g roups,a nd g o vernment
agencies
is very good.
The latter
g en u i nely seek consultation
with
industry
and take account
o f the ad v i ce which is given.

Chart

a-

2.

Accomplishments

facets
are:
Chart
9

and Objectives

(1)

of

Significant
accomplishmen
the company's
operations.

Exploration
and
Production

t s h a ve b ee n made in all
Some o f th e highlights

- Environmental
base li ne a nd impact
assessment study f or gas pl ant i n the Mackenzie
Delta.
- Premature
regulations
on dri l l ing mud
disposal
in the Arc t ic de f e rred . Industry/
Government
working
gro u p wi ll develop
by
June 1975.
- Plastic
membrane liners
insta lled
tank lots
and dykes at two Ar c tic
camp fuel
storage
depots.

Chart

10

{ 2)

Logistics

to seal
base

- Program
initiated
to develop
fa cilities
required
to meet Federal
Refiner y Effluent
Guidelines.
Dartmouth
and Mon treal
will
be costly.
Reduced S02 emissions
Dartmouth)
•

(Sarnia,

Montreal,

- Reduced hydrocarbon
emissions
b y th e
installation
of floating
roofs
(Montreal,
Sarnia,
Winnipeg).
_ Ioco major waste water
treatin
g project
continued,
to be completed
i n 1974,
including
sewer segreg a t i on , sour water
strippers
and biox unit.

 -

Chart
11

( 3)

Transportation

8 -

- complete
revis i on of e ng
for des i gn and constr u e t
to incorporate
environmen
- Initiated
to reduce

a prog r am with
their
oil
sp ill

.
· g standar
ds
ineerin
.
1s
. n of term1na
10
tal
s afeguards
.
outside
carrie
incidents
.

rs

- Environmental
progr am on Sarni a productE
pipeline
facilities,
75% comp~ ete,
.
including
block
va lves,
p i pe 1r P"' ":L1.o n,
high level
alarms,
c a t h odic pro e c ~i o 1 ,
Chart
12

(4)

Marketing

- Survey
agency

and program
facilities

dev e lop e d to upgr ade
and opera t ion s .

- Marketing
and facilities
for unleaded
gasoline.
- Awareness
associates.
Chart
13

(5)

Esso

Chemical

program

for

plan

c o mpleted

employees

and

- Disposal
greatly

well
at Redwater
ferti
reduced
water
effluent.

lizer

- Produced
caustic

an acceptable
at Sarnia
for

quality
sale
to

s a les

pla nt

of spent
pap e r mi l ld .

- Study completed
and const r uc tio n u n d er w y
on effluent
filtrat
i on sys t em at Sarnia.
Chart
14

(6)

Building
Products

- Reduced
suspended
Pont Rouge Plant.
- Eliminated
connecting

effluent
to city

solids

in

effl

at La S a l le
sewers.

uent

at

Pl ~nt by

- High energy
air
filtration
system s fo r
roofing
mill
fumes;
installed
(Edmonton)
and designed
(Winnipeg,
LaSalle).
Chart
15

(7)

Business
Development

I
I

·1'ties
and
_ Maj or u p gr ad in g o f f aci 1
.
procedures
at norther
n terminals.

- (Syncrude)
- Environmental
(4 volumes

Im pa ct Assessment
- 1200 pages)

is s ued

..

'-.

 - 9 -

- Published
project

4 monographs
related
site
and Beaver
Creek.

- Completed
established
Lease 17.

surface
water
study and
air monitoring
station

- In itiated
programs
to
of Syncrude's
efforts.
(8)

.:!harts

Oi l Spill

Incident

to

make public

on

aware

Repor t

The number of o i l s pills
reported
in 1973 increased
markedly
i n 19 7 3 over 197 2 (37 8 vs. 139).
It is suspected
that
a large
portion
of th e increase
is due to better
reporting
procedures
wh i c h h a ve been instituted.
The
Production
and Tra n spo r ta ti on Departments
were responsible
for the bulk of t he spi lls
- 45% each.
Of the total
number
of spills,
the propor t ion of minor spills
increased
(66%
vs. 56%) and the p r opo r t i on o f major spills
decreased
(10% vs. 16%) in 1973 . The total
volume of oil spilled
decreased
from 10 . 5 M bb l s. to 9.4 M bbls.

16
a nd

17

As to the causes
of t h e inci de nts,
in 1973 work error
60"fe - which is the
accounted
for 40% and equipmen t failure
reverse
of 1972.
In t he Pr od u cti on Department,
89% of the
spills
were due to equipment
fa il u r e . In the Transportation
Department
62% of the spills
were due to work error
and
63% involved
outside
carriers.
Both i n-house
and PACE
programs
are being
developed
to tr y to improve
the performance
of outside
carriers.
hart

3.

Major

Problems

Remaining

18
- Oil spill
contingency
major marine
casualty
offshore.

plan and response
capabi lity
for
and (b) well blow-out
in Ar ctic

(a)

_ Responding
to rapidly
increasing
government
ini tiatives
for
information
and proposed
regulations
in a t i mel y a nd authoritative
manner.
_ Jurisdictional
Federal
and

disputes
provincial

amongst
agencies.

_ Maintain
the level
of conunitment
'ally
in
middle
management
especi

Federal

age n c ies

to Env ir onmen tal
and below.

and between

Protection,

 - 10 -

- Gro wi ng trend
to
c riter ia, scope,

.

statemen

ts :

·
, ·t
f environmenta:
multip 1 ic i Yo
.
- Tim e dela y s in obtaining
f
proJec t s,
p ermits
from numerous
agencies,·
ors pec ific
Sync r u de, Cold Lake, Arctic
drilli
ng , e tc.

Ch a rt
19

- Rapidly

escalating

costs

- Impact on groun d wa t er,
Syncrude
operations.

of

constructio
Wa t er

Surface

- Convincing
some governments
to
approach
rather
than arbitrary
ambient
air quality
goals.
- Increasingly
severe
virtual
elimination
Cha r t

t

require
en v iro nme n t al impac
etc.,
not well de f ine d.

4.

e.g.

n.
a nd air

~
~ uali
·

ty

of

u se th e Ai r Manag e me n~
emiss i on l im i t s t o ac · .ie ? -

contaminant
restrictio
n s ma y f orce
of water
effl u ents
fro m p l ants.

Plans

20

Most of our problems
are shared
by th e res t of t h e
industry
and we are hopeful
that man y of the m c a n be reduced
to manageable
terms through
v igoro u s efforts
by indu s try
associations.
our plans,
therefore,
include
con tinu i ng to
play a leadership
role
in these
activities,
as approp riate
to
our interest.
Chart
21

In addition
to the more general
problems
above,
there
are,
of course,
a host of specific
pr
challenges
in the various
operating
departments.
programs
are being developed
and implemented
in a
A fe w exa mples
manner to handle
these
situations.
include:
- Optimizing
facilities
effluent
guidelines.
- Linalog
injection

inspection,
to combat

- Investigate
offshore.
Reducing

drilling

so 2

- Implementation
agency plants.

emissions

and operations

pressure
flowline

of new facility

meet

testing
and
corrosion.

mud disposal

for

to

technique

refineries
standar

and

outli ne d
oble ms a~a
Pla ns an d
sa ti s factory
woul d

n e w re finer

y

in hi b it or

s f o r the

g as

plant

Arctic

s.

d s and procedures

at

I

 - 11 -

- Continue
to work
very restrictive
fertilizer
plants.

with Alberta
Government
proposed
water
effluent

to modify th ir
guidelin
s for

 C

t

~'7eS

:.ations

re T•i.e-·

:;= ?~C:::

f

ac--::.· -~·:...a,
a::.-~~,..-'-:, ~~- :.;f
functions
c:: ~~=-:"1-:::.o:- :.:"'"
..c.-1e:---J:~5.
:ii~- ...: ' 'd,f ..__:..,
acti ,-ities
~-:de~-=.-a:--:e:-... 8'~ re~~=--=-s~ 0:. ·.1~;-.f":;:

Chart

( 1)
2.:-.d :)_ s 4:r:..:) _:~i0~1
~t :ea'::-? ~es S& ...,,,....1 rJ'
•
_ ...
•
,, -.... ;
r7 · ,.)
se?:':..o:1s
::;!."o.::~e:-s
.::-..
:--e=:'":1-g ,.:..;. rJ.,,Jc ~. .........

port2t..io:i
-

no

"T'

ass··-ir:g

- Conerage
Mar~e~~ng

so:e

ce:::.:.ca.:ed

fa<::..l:.:::.:.es

....

;

.,,

·1•0..:.:::1 :Oe :..C'l,f:;.:.:-. a:..:.. oi::.. ~r":.:·~r.4:.a

assc~:.2~es

~y

~~~

1

•

t

,:1,_,.3_

· r</1

2'£~

1

e%c;spt

·973.

(3)

Proposed
Cor?Orate
?s:..ic:,_, a:-.d ?:a:-. fc:,r Col ..e;;ction
3nd
Disoosa 1 o:: ··as.:e
Gi ~
Task Force ::ound tha~ i~~ ~r ~a ...:7 generally
wa ts 0·1
( slops
and of::-spec.
p:::::-oc-.....c'ts)·· ere pz:obably
bigg ,_r
problems
than custo~ers'
,as~e
oi:.
- Agreed upon a policy.

(4)

Review of Exxon TTor_d-ride
Concerns
and Activities.

( 5) Task Force Report
on i.·ecess:.ty
Ships
at Sarnia
Dock
- Recommended
Region Oil Spill
marine
terminals
using
Sarnia
- Work done tJill
provide
model
locations
if required.
- Growing
trend
in U.S. to requ
loading
and unloading.
during
(6)

Review

(7)

Report

of

Oil

Spill

and Methods

of

Booming

Committee
example.

sur·,ey

a 11

for

quick

action

at

ire

booming

Experience

of

for

othe.r.

ships

19 7 ?.

by Marketing
on Environmental
Risk Analysis
Assessment
of Agency Plants
and Action
P l an for

Upgrading
(8)

Corp:,rate

Conser,ation

En-.ri.r-onrental

Endorsement
Environmental

Facilities

and Operatic·-·

of PACE Response
to
Impact Assessment.

Ontario

Green

Paper

on

I

'

 -

l

( ) Rev·e • f Transportati
Impr vement of
rthern
\ 10} Stud_· of basis
environmental

n Department's
Plans
for
Pr duct Terminal
Facilities.

r federa 1-pr
legislati
n.
f

vincia

l jurisdiction

in

Informal
c rdinati
n was a hieved
through
day-to-day
tacts
with the operating
departments
at Head Office
corresp
ndence,
telephone,
and visits
with the field.
2.

Audit,

Man p ower,

K· pe nditures

and

conand by

Budget

( 1) Audit
The Coordinator
and or Assistant
Coordinator
made visits
to a ll of th e refineries,
to the Sarnia
Chemical
Plant,
an d to explor a tion
activitie
s in the North.
Environmental
pro te ction
problem s and programs
were reviewed
with
local
man agement
and t e chnical
people.
( 2 ) Manpo wer

Char t
23

Impe r ial ' s t ota l M.P .T . manpower occupied
with E.P.
activit
i es i ncrease d from 76.5 in 1972 to 87.1 in 1973.
Increased
acti vi ties
in E&P a nd Marketing
accounted
for
most of the add i ti on . For comparison
purposes,
Exxon
U.S.A. 's en v ironmenta
l con s ervation
effort
increased
from
220 people
in 19 72 to 373 in 1973.
(3)

Expenditures

and

Budgets

The predicted
expenditure
l e v e l s for e nvironmental
protection
measures
cont i nue a t a high
level
throughout
the forecast
period.
Refi n er y proj e cts account
for
nearly
half
the expend i tures
a nd the se are mainly
required
for water
quality
improvement.

Chart
24

This
Chart
25
25A
25B

3.

pattern
is very simil a r t o Exxon U.S.A. 'sand
u.s. Industry
in general
as the Char t (25) indicates.
u.s. industry
must make these
i nv es tm e nt s to meet
statutory
regulations.

to

No such information
comparisons.

make

useful

the President
International

in

Service

dischargin

to

Executive

Staff
. g his

is

and

availab

l e in

Canada

to

Depar tm en t s

assistance
duties
as

wa s provided
Ch airman
of

to
the

 I I
( ll.t11\\1

1

I

11' II

lP

1dh

111

1• 111111111111

I' I l l\l!

I I

I

I I1
, I t II

'I \\ 1l "

I

'

I

I

1 1111111
iI

11

t

,I

rnl\1

I

1

',

n c was prov i d e d
for. similar
indus try

l

II\, 11 h

1

ll\

11

I

rdinator
ga v e the
papers
at
i n l , . ntinq
•1)ll\tn\u1ity s cndnars.

111d [\
, I ,, p
nI

•1II I Y 1
I

l'

, •,1 l1ml1 • , .n,i

0

1,: n1 11 , •11,,, d p1· w id d bi
I h,

Pl\ P1 l' 11 t m nt
In,
1•:11vl 1 ,, ,111 I\I ,t !\,,, •lin1.

1'1 ochwl

Pl
th,
'I'll I
I \ldy,
11 D l 1,qk
1t
P (Hht1•l
P 11
lht
dlip1H111
wu
11 1 v
<~oVt'llllmnl
qu l i l y nq\t

u 1•1,mph, 1 , i,
1 \ i.
w,w .11.1 1 pr v i d d to Explor a tion
and
n ·t m nl:
, . ch 1. I
m nt of regulations
for
t 1h i ll i n q t tui
This in-house
expertis
e
,·y v 1l u1l l ' fr
n g
ins
with the Federal
in t \\ 1 fril l ing
)f · fin ry effluent
water
l .1 in
wh n · ish toxicity
tests
were involved.

wh
:p
n •p
\ l

•rb

nv i r. nm
t'

l qi c 1 xpert i s e to
n1,m CJ m n
review
and control
Sludy
f Richards
Island .
wi 1 I
xc
d $1 mill i on in cost.

off
deral
and provi ncial
government
n Ls
o d al with recog n ize d industry
ha s beco me c l early
n "g u l tory processes

11t:.1 1 c

ooc• i l i n
og n iz a.

Th
coordinatio
n staff , regio na l a nd local
f un ct·o n l m n ge me n ts and tec hn ica l pe ople h a ve con tinued
I mp r i l' s positio
n a~ th e major d ri v i ng f orce in i ndustry
act· o n s .

Th e c o or d i n a tion
sta ff sp e nt ne ar ly
relat e d work .
ti me i n 197 3 on industry

500/o of

their

(1) PACE
The existence
of PACE is now well reco gnized
as the
liaison
point
for federal
agencies
in all env i ronmen tal protection
matters
of the industry
outside
the E.P. are a.
The
Petroleum
Ass ociations
have
rolls
of PACE and the Provincial
b e en delineated
for provincial
environmental
qual ity concerns.
Th e provincial
associations
will be the first
point
of contact
and PACE will
provide
technical
and policy
adv ice when
requested
or deemed necessary.
The major
in

1973 were:

accomplishments

and a ctivit

ies

of

PACE

 - 15 -

hart
?6

(2)

(a)

Co~pletion
of consultations
in rational
which r~sulted
Regulations
and Guidelines

(b)

Promulgation
regulations
systems.

(c)

An informal
appeal
to the B.C. Pollution
Control
Board
aga~nst
the severity
of refinery
air emissions
and
water
effluent
quality
objectives.
Only minor success
was achieved
and there
are still
serious
points
at
issue.

(d)

Obtained
deferral
spill
prevention

(e)

Coordination
planning
and

(f)

Trials
cleared

(g)

Research
assessment
waters.
than the

(h)

Initiated
Storage

for

Oil

(i)

prepared
brief
for Ontario
Petroleum
Association
respond
to Ontario
Government's
Green Paper on
Environmental
Impact Assessment.

to

CPA and

of C~nadian
which do not

with Environmen
Refinery
Liquid

Canada,
Effluent

automotive
emission
control
mandate use of catalyst

of unrealistic
regulations
at

of cooperative
oil
training
activities

and very costly
marine terminals.

oil

spill
contingency
was stepped
up.

of the PACE-Steltner
boom at
the way for commercialization.

Sarnia

and Montreal

funds expended
on a rapid-test
method for
of the toxicity
to fish of refinery
effluent
If successful,
this will give better
control
96-hour
regulatory
test.
work on a National
Code of Design
Terminals
and Marketing
Bulk Plants.

APOA

The Environmental
Conservation
Committee
of
1973 began to take hold of the industry's
environmental
problems
and organized
itself
to deal more effectively
the Federal
Government.

CPA in
with

The Arctic
Petroleum
Operators'
Association
con tinued
their
Arctic
Research
Coordination
role,
but also
took
on a negotiating
responsibility
with federal
regulatory
agencies.
progress
was made in setting
the ~asis
for the
Lad
use and Drilling
Fluid
Disposal
Regulations.
APOA
s~nsored
another
successful
three-day
Environmental
Seminar

 - 16 at

Yellowknife

i n early

Octo b e r .

The company par ti c ipat es in two local
industry
en vironmental
associations
- - Larnbton at Sarnia
and Laval
i n Montreal
East.
Imperial,
o f co ur se , a lso s hares
in
CAGSL's environmental
stud y cos t s.
The total
budgets
o f th e various
associations,
for environmental
studies
of co n s ortia
in which Imperial
ticipates,
amounted
to $5.9 mil lio n . I mperial's
s hare
these
costs
was $438,000,
as i ndi c a t e d on Chart
(27).

Chart
27

an d
parof

These are certainly
not s t a gg e ring
sums when th e
range of activities
and pote nti a l valu e received
is considered.
They are,
however,
on l y a p a rt of th e cost
and
effort
story,and
would more t h an d ouble
if the multiplier
effect
of salaries
and expenses
o f involved
I mperial
personnelwere
added to the total.
va l ue received
can only
be assured
by having
competent
peo p le ,who insi s t on
objectivity,
know the capabilit
y of con s ultants,
and monitor
their
work.
5.

Government

Relations

Government
agencies
at a ll l e v e ls have repeatedly
stated
their
desire
and need for our i n put s ince they hold
Imperial
in high regard
for cooper a t i on , t e chnical
competence,
and commitment
in environmental
matters
. In mos t cases,
they have listened
and the effort
has been worthwhile.
The
burgeoning
staffs
in the various
agenc i es have an insatiable
thirst
for information,
which leads
to a n ever-increasing
number of questionnaires
and industry
/gov ernment
task
forces
to develop
regulations.
Major

concerns
in governmen t relatio
n s are in
three
areas.
First,
lack of cooperati
o n be tw e en some
federal
government
departments
and othe r s -- Environment
canada,and
Transport
and Northern
Affairs,
fo r example,
and
the frictions
between
the federal
go v ernment
a n d some
provincial
agencies.
Secondly,
and of grow in g concern,
is
the trend
to request
financial
informati
o n, s uch as general
operating
costs
and profitability
before
t h e t e ch n ical
aspects
of a real
or suspected
proble m hav e eve n been
assessed.
The third
area is how the p r ocedures
for
Environmental
Impact Assessment
of new pr ojects
will
be
developed
and employed.
Vigilance
wi ll be re q uired
to ensure
that
process
is rational;
otherwise
ec o-m ani a could
lead
to
economic
stagnation.

 -

6.

Public

l 7

·

Relations

In the first
section
or t:.hl r· poll,
111 fc>ltl1 l I 1 •
attitude
to the environment
wna nAm 1 1 c1J l ti th
lJUI . :xi of
a number of issues.
Two subj C..!l· 1.r . 1 1 wh I, II t I 11
business
to the public
and which nt I 11 r•omm 1wl
attention
are lead in the ambient
nir
nd of 1
particu
1.arly tanker
incidents.
Rnv.i ronm, nt , 1. cone· r.n
be an important
factor
in the devolopm<'n
of n w pr.oj
with governments
committed
to environmN,lnl
imp,,ct
,n
1
before
granting
approva 1 to proceed.
It wi 11 b
cruc: i. , I
industry
to do its environmental
homework we l l br f o.r,
environmental
hearing
forums.

June

7,

1974

 BUDGET

- 1974 $18 MILLION

1975 $20 MILLIO

PROGRAM
- ENVIRONMENTALLY SOUND TECHNOLOGYFOR
UNDERDEVELOPEDCOUNTRIES
- PROTECTIONOF MARINE ENVIRONMENT
- MANAGEMENT OF ARID REGIONS,DESERT RECLAMATION

- GLOBAL MONITORINGSYSTEMFOR POLLUTANTS&
EFFECTS
- INTERNATIONAL REFERRAL SERVICEFOR ENVIRONMENTAL INFORMATION

 INTERNATIONAL

CONVENTION

FOR PREVENTION OF POLLUTION FROM SHIPS 1973

COMPLETEREDRAFT OF 1954 CONVENTION
COVERSOIL CARGO,CHEMICA~S,BILGES, SEWAGE,GARBAGE
BASIC MEASURESADOPTED:

1.

INTERNATIONAL STANDARDSFOR CONTROL OF SHIP
MOVEMENTS,TANKER DESIGN & EQUIPMENT

2.

INTERNATIONAL MEANS OF INSPECTION,ENFORCEMENT,&
PROSECUTION

 INTERNATIONAL

CONVENTIONS (I

TECHNICAL REQUIREMENTS
1.

NO DISCHARGE OF OILY BALLAST WATER WITHIN 50 ~ lLES OF HORE
NOT EXCEED 60 LITRES OIL/NAUTICAL MILE
NOT EXCEED 1/.15,000thCARGO CAPACITY

2.

LOAD-ON-TOPPROCEDUREREFINED

3.

ALL PETROLEUM PRODUCTSIN DEFINITION OF OIL

4.

COMPULSORYSHORE BALLAST FOR SPECIAL AREA

5.

SEGREGATEDBALLAST FOR ALL NEW HIPS FT·

D . 31, 1 75

 U.S. 1973 OVERVI EW

1.

ENERGY CRISIS RETARDED ENVIRONMENTAL CLAMOR

2.

ROLE-MAKING BY EPA CHARGED ON

3.

NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
- ALL DISCHARGESTO WATER REQUIRE PERMIT
- BEST PRACTICABLE TECHNOLOGYINSTALLED BY 1977
- BEST AVAILABLE TECHNOLOGYBY 1983
- ZERO POLLUTANT DISCHARGEBY 1985

4.

NUMEROUS COURT ACTIONS

5.

NON-DEGRADATIONPRINCIPLE CHALLENGED

6.

LAND-USE CONTROL LEGISLATION BLOSSO I G

 5

SUMMARY
OFAIRQUALITY
CONTROL
PLANS

CHICAGO NEWARK SANFRANCISCO
CA
L.
ILL./IND
.
N.J./Nl/CONN
.

MORE
STATIONARY
SOURCE
CONTROL
.....
GASSTATION
VAPOR
RECOVERY
( 90%).. .. .. .... ... .
ORGAN
ICSOLVENT
CONTROLS
........

v
v

.

MASSTRANSIT
IMPROVEMENTS
... .. . . .
I BUSLANE
MILES........
CARPOOL

.

CARPOOL
MATCHING
SYSTEM
. .. . . .. . .
EMPLOYEE
INCENTIVES
FORMASS
TRANSIT
.............
..
BICYCLE
LANEMILES ...........
INSPECTION
- MAINTENANCE
.......
CATALYTIC
RETROFIT
ONSOME
MODELS
.............

75

45

v

J

STATE STATE
LOCAL PRIVA
TE

.
.
.

PARKING
SPACE
LIMITATION
.......
CORE-AREA
PARKING
RESTRICTIONS
.........

.

.

GASLIMITATIONS
FORMID'77 .....

.

VEHICLE
TRAVEL
REDUCTION
NEEDED
.. .

CARS
CARS MEO.-TRUCK
CA
RS
'71-'75
CARS
TAXIS MEO:-TRUCK
CARS

250

250

i
J

AREA-WIDE
AREA
-W\DE
34o/o 97°/o

 RANKING OF PUBLIC ATTITUDE TO ISSUES

Degree of Effect %
Great
Deal

Some

Little

1.

PRICES. . . . . . . . . . . . . . . . . . . . . . . .

74

22

4

2.

POLLUTION .. ·.. . . . . . . . . . . . . . . . .

58

29

13

3.

ENERGY SUPPLYAND COST

50

33

17

4.

LABOUR UNREST (STRIKES)

45

36

19

5.

UNEMPLOYMENTJOB
OPPORTUNITY...............

.

FOREIGN INVESTMENT .........

.

6.

 PUBLIC RANKI
OF INDUSTRIAL

G

CO TRIBUTORS

TO ENVIRONMENTAL

DAMAGE

Do Cause
DamagL
CHEMI CALS . . . . . . . . . . . . . . . . .
PULP ANDPAPER ...........
PETROLEUM . . . . . . . . . . . . . . . . .
TOBAGCO . . . . . . . . . . . . . . . . . . .

94
86
83
63

LUMBERI NG . . . . . . . . . . . . . . . . . 59
RAI LWAYS . . . . . . . . . . . . . . . . . . 37
ELECTRI C UTI LITI ES . . . . . . . . . 29

Cause a
Great Deal
of Damagg_
75
57
50

35
28

 POLICY

& OBJECTIVES

PERFORMANCE IN KEEPING WITH IMPERIAL'S & EXXO 'S
CORPORATE POLICY & OBJECTIVES

ADHERING TO EXISTING REGULATIONS
CONTRIBUTING TO DEVELOPMENT OF
REALISTIC REGULATIONS VIA INDUSTRY
GROUPS
Cl)

 ACCOMPLISHMENTS

EXPLORATION & PRODUCTION
BASELINE & IMPACT ASSESSMENTSTUDY FOR ARCTIC
GAS PLANT
PREMATURE ARCTIC DRILLING MUD REGULATIONS
DEFERRED
PLASTIC MEMBRANE LINERS INSTALLED AT TWO

ARCTIC FUEL STORAGE DEPOTS

 LOGISTICS

PROGRAMINITIATED TO MEET FEDERAL REFINERY
EFFLUENT GUIDELINES.MONTREAL& DARTMOUTHWILL
BE COSTLY.
REDUCEDS02 EMISSIONS(SARNIA, MONTREAL,DARTMOUTH)
REDUCEDHYDROCARBONEMISSIONSBY FLOATING ROOFS
(MONTREAL, SARNIA, WINNIPEG)
MAJOR WASTE WATER TREATING PROJECTAT IOCO TO BE
COMPLETEDIN 1974

o

 ACCOMPLISH MENTS

TRANSPORTATION

MAJOR UPGRADING OF NORTHERN TERMINALS

COMPLETE REVISION OF ENGINEERING STANDARDS

PROGRAM TO REDUCE OIL SPILL INCIDENTS BY
OUTSIDE CARRIERS

 ACCOMPLISHMENTS

MARKETING

SURVEY& PROGRAM
DEVELOPED
TO UPGRADE
AGENCY FACILITIES
& OP RATIONS
UNLEADED GASOLINE MAHK[llNb

ft

r/\Llllflf(,

PLAN COMPLETED
AWAR N SS PRO RAM

ASSOCIATES

OR

~p r (

~

?

L

r.)

 ACCOMPLISHMENTS

ESSO CHEMICAL
DISPOSAL

WELL

AT

REDWATER

WATER

EFFLUENT

SARNIA

SPENT CAUSTIC

CONSTRUCTION
EFFLUENT

UNDER

FILTR'ATION

REDUCED

SOLD TO PAPER MILLS

WAY ON SARNIA
SYSTEM

 ACCOMPLISHM ENTS

BUILDING

PRODUCTS

REDUCED SUSPENDED SOL I DS IN PONT ROUGE
EFFLUENT
ELIMINATED

LA SAL LE EFFLUENT

BY CONNECTING

TO CITY SEWERS
HIGH ENERGY AIR
ROOFING

MILL

FILTRATION

SYSTEMS FOR

FUMES,

INSTALLED

& LA SALLE)

(EDMONTON),

DESIGNED

(WINNIPEG

 ACCOMPLISHMEN TS

BUSINESS

DEVELOPMENT

-

(SYNCRUDE)

ISSUED . ENVIRONMENTAL

IMPACT

PUBLISHED

RELATED

SITE

AND

MONOGRAPHS
BEAVER

COMPLETED
ESTABLISHED

TO PROJECT

CREEK

SURFACE
AIR

ASSESSMENT

WATER STUDY

MONITORING

AND

STATION

 NUMBER
OFREPORTED
OIL PILL
1973
- BYFUNCTION

200

172

172

I

150
en
_J
_J

Q..

en
~

108*

100
56

50

45
28
10

0

I

I

I

29

5
I

1972•73
1972'73
1972 73
1972 '73
PRODUCTION LOGISTICS TRANSPORTATION
MARKETING
*OUTSIDE
CARRIERS

 NUMBER
OFREPORTE
D OILSPILLS
1973
- BYCAUSES

200

18 7

150

0
76

72

50

0

43 *

TANK
OVERFLO

OTHER

.
ORKERROR

CORROSION

* PRODUCTION
DEPT

OTHER

QUIPE T FAILURE

 MAJOR PROBLEMS REMAINING

OIL SPILL CONTINGENCYPLAN & RESPONSECAPABILITY
MAJOR MARINE CASUALTY
WELL BLOW-OUTIN ARCTIC OFFSHORE
RESPONDINGTO GOVERNMENTINITIATIVES
INFORMATION
PROPOSEDREGULATIONS
GOVERNMENTALJURISDICTIONALDISPUTES
AMONGST FEDERAL AGENCIES
BETWEENFEDERAL & SOME PROVINCIAL GENCIE
MAINTAIN LEVEL OF ENVIRONM NTAL COMMITM Nl
ENVIRONMENTAL IMPACT STATEM NlS

 MAJOR PROBLEMS REMAINING
{Continued)

TIME DELAYS DUE TO MULTIPLICITY OF PERMITS & AGENCIES
RAPIDLY ESCALATINGCOSTSOF CONSTRUCTION
IMPACT OF SYNCRUDEOPERATIONSON GROUND WATER,
SURFACE WATER, & Al R QUALITY
SELLING Al R MANAGEMENTAPPROACH

CONTAMINANTRESTRICTIONS
MAY ELIMINATEWATER
EFFLUENTS FROM PLANTS

 -

-

PLANS

MOST PROBLEMS SHARED

BEST TACKLED

BY INDUSTRY

BY INDUSTRY

ASSOCIATIONS

CONTINUE

LEADERSHIP

AS APPROPRIATE

TO OUR NEEDS
I\J

0

 PLANS (Continued )
RESPONSETO SPECIFICPROBLEMSINCLUDE:
OPTIMIZATION OF FACILITIES TO MEET EW REFl ERY EFFLUE T
GUIDELINES

LINALOG INSPECTION,PRESSURETEST! G, I
COMBAT FLOWLINE CORROSIO

B TOR

ECT

INVESTIGATE MUD DISPOSALTECH QUES Fv
REDUCING so2 EMISSIONSFOR REF ER E
IMPLEMENTATION OF NEW FACILIT

T

AT AGENCIES

WORK WITH ALBERTA TO MODIFY P
GUIDELINE FOR F TILIZER PLA T

P

L

T --

 ENVIRONMENTAL

QUALITY COMMITTEE 1973 ACTIVITIES

1.

REPORTON DISTRIBUTIONPROBLEMSOF LEAD-FREEGASOLINE

2.

STATUS OF EMPLOYEEENVIRONMENTALAWARENESSPROGRAM

3.

CORPORATEPOLICY FOR HANDLING WASTE OIL

4.

REVIEW OF EXXON WORLD-WIDEE. P. ACTIVITIES

5.

STUDY AND REPORTOF SHIP-BOOMINGMETHODS

6.

REVIEWED1972 CORPORATEOIL SPILL EXPERIENCE

7.

ENVIRONMENTAL RISK ANALYSIS OF MARKETING AGENCY PLANTS

8.

REVIEW OF TRANSPORTATIONDEPARTMENTNORTHERNTERMINAL PLANS

9.

REVIEWED BASIS FOR JURISDICTION OF ENVIRONMENTALLEGISLATION

 ENVIRONMENTAL

MANPOWER SUMMARY

(MAN YEARS)

1972

LOGISTICS

..................

EXPLORATION/PRODUCTION....
ESSOCHEMICAL ..............
TRANSPORTATION ............
MARKETING..................
C'.

POOOOClS-. . -

.:,,-

_...

COORD. DEPT.................
RESEARCH

Full
Time

Part
Time

Full
Time

Part
Time

12
2
2
2
1

20
14
8
4
2
1.4
0.1

11
3
2
1
3

21
18
8
4.5
4
2

......

............
BUS. DEVELOPMENT
REGION 0/S COORD. ..........

1973

6

5
3

3
1

..................
49.5

27
TOTAL 1.0.L.

................

TOTAL EXXON U.S.A. ..........

76.5
220

0.5
58.1

30

88.1

7

 BUDGET EXPENDITURES {$MM)

1974

1975

1976

1977

22.7

23.3

14.1

21.3

11.2

EXPLORATl ON/PRODUCTION ...........

3.4

4.0

3.1

4.0

9.0

ESSOCHEMICAL .....................

0.8

0.7

0.7

4.5

1.0

1.0

6.0

7.0

5.0

6.0

1973
LOGISTICS

.........................

MARKETING

.......................

-

TRANSPORT
ATl ON

...................

2.8

5.4

3.3

1.9

2.0

BLDG. PRODUCTS

...................

0.5

0.5

0.4

0.3

0.3

0.2

3.7

7.8

8.3

4.3

31.4

43.6

36.4

45.3

33.8

10

17

11

14

12

BUSINESSDEVELOPMENT
SYNCRUDE (IOL) .....................

% OF TOTAL CAPITAL BUDGET ........

:

~

 U.S. INDUSTRY SPENDING
ON AIR & WATER POLLUTION CONTROL
% of Total

CapitalSpending

$MM

(1974)

Industry

1973

1974

1977

IRON& STEEL
........

419

11.7

17.6

20 .1

AUTOS..............

257

11.2

10. 1

10.0

CHEM
1·CALS ..........

631

10.2

0.

573

22.8

PULP& PAPER
......

..

1

MINING..............
PETROLEUM..........

1,

2

.7

2.

.8

 COSTOF
ENVIRONMENT
AL REGULATIO S
CE TS PER BA
1966

1970

975

EXXONCORP. LESS EXXON, USA

BASE

3

15

EXXON, USA

BASE

0

2

JS PETROLEUM INDUSTRY

BASE

9

 COST OF ENVIRONMENTAL

Name
APOA

.............. .......
,•

CAGSL.....................

·.

CPA . . . . . . . . . . . . . . . . . . . . . . . .

ASSOCIATIONS (1973)

Total

IOL

Budget

Share

$ 566,000

$165,000

4,740,000

180,000

?

?

LAMBTON IND. SOC.

..........

156,000

29,800

LAVAL IND. ASSOC.

..........

157;200

22,000

164,300

41,700

.. . ... ...... . . . .. . . .. .
PROV. PETRO. ASSOC'S . . . . . . ...
PACE

TOTAL ......

.-...........

EX CAGSL . . . . . . . . . . . . . . . . . .

?

?

$5,783,500

$438 ,500

$1,043,000

$258,500

(1 /27)