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BY EMAIL and E-FILE May 27, 2021 Mr. Jean-Denis Charlebois

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BY EMAIL and E-FILE May 27, 2021 Mr. Jean-Denis Charlebois Hydro One Networks Inc. Tel: (416) 345-5393 7th Floor, South Tower Cell: (416) 902-4326 483 Bay Street Fax: (416) 345-6833 Toronto, Ontario M5G 2P5 [email protected] www.HydroOne.com Joanne Richardson Director, Major Projects and Partnerships Regulatory Affairs BY EMAIL AND E-FILE May 27, 2021 Mr. Jean-Denis Charlebois Secretary of the Commission Canadian Energy Regulator 517 Tenth Avenue SW Calgary, Alberta T2R 0A9 Dear Mr. Charlebois: File: OF-Fac- IPL-H117-2020-02 01 - Hydro One Networks Inc.’s Application to Perform Component Replacement Station Work at St. Lawrence Transmission Station Impacting International Power Lines L33P and L34P, (EC-11) & (EC-18) - Information Request Responses Please find attached Hydro One Networks Inc.'s ("Hydro One") responses to the Canadian Energy Regulator’s Information Requests received May 20, 2021, in regards to Hydro One's Application pursuant to section 69 of the Canadian Energy Regulator Act, to perform station and related facilities work at St. Lawrence Transmission Station (“TS”) impacting International Power Lines (“IPL”s) L33P and L34P in Cornwall, Ontario. File: OF-Fac- IPL-H117-2020-02 01. An electronic copy of the Information Request Responses has been filed using the Canadian Energy Regulator’s electronic submission system. Sincerely, Joanne Richardson Cc: Julia Gonzalez and Whitney Punchak - CER Staff Filed: 2021-05-27 L33P and L34P Exhibit I Tab 1 Schedule 1 Page 1 of 8 1 CER INTERROGATORY #1 2 3 Reference: 4 Environment Matters 5 Project Activities and Potential Soil Contamination 6 i. Hydro One, Application to Perform Component Replacement Work at St. Lawrence 7 Transmission Station (TS), Environmental and Socio-Economic Assessment (ESA), 8 Table A-1: Circumstances and Interactions Requiring Detailed Biophysical and 9 Socio-Economic Information, Heritage Resources, page 6 of 29 (PDF pages 37 and 10 50 of 70), [C12383-1] 11 ii. Hydro One, Application to Perform Component Replacement Work at St. Lawrence 12 TS, Appendix A: Interactions Table, pages 1 to 2 of 2 (PDF pages 61 to 62 of 70), 13 [C12383-1] 14 iii. Hydro One, Application to Perform Component Replacement Work at St. Lawrence 15 TS, ESA, Section 2.0 Effects Assessment and Mitigation, 2.2 Potential Effects and 16 Mitigation during Construction, Soil and Soil Productivity, page 20 of 29 (PDF page 17 51 of 70), [C12383-1] 18 19 Preamble: 20 In reference: 21 i. Hydro One states that the scope of work of the Project includes associated trenching, 22 spill pits, connections and protections upgrades. On page 37 of the same reference, 23 Hydro One provides a table listing circumstances and interactions requiring detailed 24 biophysical and socio-economic information (Table A-1). Under soil and soil 25 productivity, this table indicates that soils or sediments may contain contaminants or 26 that the Project may result in the contamination of soils. 27 28 In reference: 29 ii. Hydro One presents the Interactions Table for the Project. Hydro One indicates that 30 excavation and soil disturbance will occur within the previously disturbed station 31 fence to facilitate the installation of the transformers and associated connections. It 32 states that it is not expected that excavations or stockpiles will migrate offsite with 33 implemented mitigation measures. This table does not provide any potential 34 interactions of the Project with soil and soil productivity in relation to excavation and 35 soil disturbance, nor does describe any potential effects and associated mitigation 36 measures. Filed: 2021-05-27 L33P and L34P Exhibit I Tab 1 Schedule 1 Page 2 of 8 1 In reference 2 iii. Hydro one states that information about the soil quality in the area was obtained from 3 a 1999 BEAK Phase I report for the station and surrounding area. The reference also 4 indicates that sampling activities in the past occurred in 1998 during the soil 5 screening program. At that time, nine sample locations were sampled. Of those, four 6 locations exceeded the applicable site condition standard for polychlorinated 7 biphenyls and total petroleum hydrocarbons below the power transformers. In the 8 reference, Hydro One further confirms that any soil excavated for the installation of 9 the transformers leaving the station will be tested and disposed of accordingly. 10 11 The transformers will also be placed on spill pits to mitigate the contamination of the 12 site from uncontrolled releases of transformer fluids. 13 14 The Commission of the Canada Energy Regulator (Commission) requires 15 clarification regarding the activities to be carried out by Hydro One. In addition, the 16 Commission requires additional information regarding soil contamination, and 17 associated measures to mitigate and manage contamination. 18 19 Interrogatory: 20 Provide the following: 21 a) Confirmation whether the Project activities to be undertaken as part of construction 22 include trenching, excavation and soil disturbance. 23 24 b) Contamination Discovery Contingency Plan (Plan) in the event that contaminated 25 soils are discovered during construction, and the Plan should include measures 26 regarding handling, testing and disposal of contaminated materials. 27 28 c) A copy of the updated Phase I Environmental Site Assessment report, if available, or 29 a commitment that an updated Phase I Environmental Site Assessment report will be 30 provided to the CER prior to commencing the work. 31 32 d) A commitment that Hydro One will file with the CER a Notice of Contamination for 33 any confirmed contamination identified during Project activities, in accordance with 34 the CER’s Remediation Process Guide. Filed: 2021-05-27 L33P and L34P Exhibit I Tab 1 Schedule 1 Page 3 of 8 1 Response: 2 a) Confirmed. Excavation, soil disturbance and trenching will be undertaken as part of 3 the Project’s construction activities. 4 5 b) To better inform site conditions and work requirements, an updated soil sampling 6 program was conducted. That program, and its findings were conducted in the period 7 between Hydro One submitting this IPL Application to the CER, and prior to the 8 receipt of these CER Staff Information Requests. Hydro One engaged an 9 environmental specialist/consultant to undertake specific site soil studies at St. 10 Lawrence TS and that report, the Transformer Spill - Limited Environmental 11 Investigation report (the “Report”) is provide at Attachment A to this response. 12 13 The Report indicates that no contamination is currently present in the areas proposed 14 for excavation. The most recent environmental site assessment conducted shows that 15 the levels of potential contaminants in areas around the electrical transformer are 16 below the applicable criteria. The appropriate property use classification would be 17 industrial/commercial/ community (“I/C/C”) as per Ontario Regulation (“O. Reg.”) 18 153/04. Therefore, the appropriate generic Site Conditions Standard (“SCS”) would 19 be the Table 2 SCS for I/C/C property use and coarse textured soils in a non-potable 20 groundwater use setting (“Table 2 - SCS”). 21 22 Hydro One has protocols and criteria for working with contaminated materials and 23 are designed to be compliant with local environmental and waste management 24 regulations. These are provided in Table 1: Criteria for Re-Use of Contaminated Soil 25 on Hydro One Property, below. Based on the above-mentioned Report, as provided at 26 Attachment A, Hydro One does not expect to encounter soil contamination at the 27 Project site. 28 29 Additionally, Hydro One will continue to conduct soil testing throughout the Project’s 30 construction activities, and appropriate soil handling and waste management 31 protocols will be followed. Hydro One will be following the soil management 32 protocol and guidance in Table 1, below. Filed: 2021-05-27 L33P and L34P Exhibit I Tab 1 Schedule 1 Page 4 of 8 1 Table 1: Criteria for Re-Use of Contaminated Soil on Hydro One Property 2 (Soil may only be used if all shaded boxes are ticked) Criteria Item Yes No The material consists solely of earth and does not include aggregate, rock, bituminous material, coal or coal residue, concrete, masonry, wood, debris, metal, plastic, or any other waste material or construction debris Potential for off-site migration of contaminants (soil or groundwater) Adverse effect (specifically this would pertain to off-site given that on-site, workers would be equipped with appropriate PPE) The material removed will be re-used for the purpose of backfilling The material will be backfilled in the same location from which it was removed and not transported to another part of the site The material will be backfilled within 100 m of water wells The material will be backfilled within 100 m of residences The material removed is located in close proximity of a fence line and/or property line where the potential for adverse effect would be greater Groundwater encountered during excavation The material is backfilled around perforated drainage pipes The contaminated material will be used as backfill providing the surrounding soil is also contaminated or assumed/expected contaminated based on knowledge of the site and results of previous subsurface investigations The contribution of the contaminated materials increases the likelihood of contamination going off-site There are waterbodies, catch basins, manholes, drainage swales etc. within 30 m of the location where the contaminated material will be used as backfill 3 Excavated soil may not necessarily be classified as a "waste" if it has a purpose (i.e. to be 4 used as backfill). However, for this to be permissible, ALL Table 1 criteria must be. For Filed: 2021-05-27 L33P and L34P Exhibit I Tab 1 Schedule 1 Page 5 of 8 1 clarification this means all the shaded boxes in Table 1 must be marked off for each soil 2 sample taken.
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