Getting Nowhere with the TSSA and MOE

I contacted the person from the Ministry of the Environment, who had come with the TSSA inspector last time. February 2019 had THREE gasoline vapour infiltrations inside my home.

I was told that the TSSA inspector and the MOE representative would be present at a scheduled refuelling, and they would contact me in advance. I made sure I could be present.

They arrived as scheduled yesterday, March 14, 2019. I let them into my house and showed them the windows and doors. We walked around outside the house on the north side, so they could see that there were storm windows and storm doors, and no gaping holes in my exterior or rotten window frames with holes. We went into the basement, to establish that there were no gasoline odours seeping up through the slab. This would happen if the underground gasoline storage tank was leaking, or had leaked. They said they wanted to get a sense of what my house smelt like, prior to a tanker refuelling. I had been careful to not do any priming, in the bedroom with plaster repairs in progress.

Again, neither individual brought any type of equipment to gather air samples.

I predicted that there would NOT be a gasoline infiltration as the wind was blowing south – southeast. The TSSA dude tried to claim the wind was blowing in the opposite direction. This wasn’t what the Environment Canada website said, just a few minutes prior.

The TSSA representative tried to claim that that I did not understand the code pertaining to vents. Here’s that code again, from the 2017 TSSA Liquid Fuels Handling Code (SKU 2425551):

ventpipescode

He tried to tell me that this code ONLY pertained to vents on aboveground tanks, which this was not. I told him that the TSSA had emailed me this code in reply to my inquiry, so I did not have further context for this code. If I wanted to buy my own copy, the CSA (Canadian Standards Association) would be happy to sell me one, for $ 135.00:

https://store.csagroup.org/ccrz__ProductDetails?sku=2425551

(Why this code is not accessible public knowledge is a mystery to me. I could not find any PDF copies online. I asked at the library, thinking they might have access. The woman who helped me spent quite awhile searching, even Western University’s catalogue, but there was not a copy to be found. She also found the link where a copy could be ordered but on the library’s computer the price was $135.00 USD. She was baffled by the high price of the document, and the obstructive secrecy.)

He pulled up his copy of the code on his phone, which included the context for the section on vents. I read it, the MOE representative read it and oops ! It did NOT apply to aboveground gasoline storage tanks – these were excluded from this section. It was the correct section of code for venting on an underground tank. (WTF TSSA inspector ?!)

Eventually the tanker truck showed up to do a fill. I sat with the TSSA dude and the MOE dude in my kitchen, waiting to see if there would be a gasoline infiltration. The MOE guy looked out the window in the door, watching the vents, to see if he could see the vapours as they were venting.

As predicted, there was no gasoline infiltration. I have been upfront when I have reported the infiltrations to the Ministry of the Environment that the gasoline vapour infiltrations are NOT happening with every fill.

I explained, again, that as a homeowner – there was nothing I could do to correct this situation. Even a 20 foot tall solid masonry fence – which the city certainly would not permit – could not prevent the gasoline vapours from drifting over or around, to settle and sink into my yard or be forced through the small spaces around my windows and doors when the wind blows from the west or northwest.

Even if my house was sealed with windows that didn’t open – I would have a ventilation intake – probably on the north side of my house, as that was where the furnace and water heater were vented.

The TSSA dude suggested an air purifier. I strongly doubted this would help with gasoline vapours as they are designed for ordinary household issues – like damp, mold, smoking and pet allergens.

Despite the vent code stating plainly that the vents were to be located so that the gasoline vapours would not enter a building – it says this twice – or affect people – the TSSA dude continued to claim that the vent was in compliance.

I asked why the vent had been relocated, and he said that it was due to some electrical issue, and also the ventilation system for the convenience store. What ? That building was RENOVATED – and there was plenty of space for their ventilation system to go. In fact they had moved the entrance doorway. An underground gasoline storage tank is much bigger than any electrical components.

They sat around for about 45 minutes . There was no gasoline odour inside or outside my house.

Some stuff was said off the record – but overall what I was told came down to this:

  • since they had not witnessed a problem, they would not be returning for a further inspection. It was up to me to prove there is a problem
  •  if I continued to report these issues, and the TSSA inspector was sent again as a result, that I would be charged an hourly rate plus travelling time. Frankly, this felt like a threat
  • even if there was clear documentation of gas infiltration, that it would be up to the gas station owner to correct this problem (vent location), as on paper the vent location was in compliance with the TSSA’s CSA code

The burden of proof is on my shoulders. The TSSA, MOE or gas station owner or parent company is exempt from proving that there is NO PROBLEM.

Did I mention that I have emailed my local city councillor, Michael Van Holst a couple of times regarding this issue, and that he has never even acknowledged my emails ?

I’m not going to shut up and pretend there is no problem. There is a very serious problem, and I did not make it, and there is nothing I can do to mitigate it.

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