Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 1 of 52

Metro Vancouver Information Request No.2 to Trans Mountain Pipeline ULC

Table of Contents

Subject Page 2.1 Common Air Contaminants 3 2.2 Volatile Organic Compounds 17 2.3 Photochemical Modelling 24 2.4 Spill Modelling 25 2.5 Health Risk Assessment 28 2.6 Socio- Economics 39 2.7 Environment and Parks 40 Attachments 1 United States Environmental Protection Agency AP-42 Compilation of Air Pollutant Emission Factors, Chapter 1.5 Liquefied Petroleum Gas Combustion, http://www.epa.gov/ttnchie1/ap42/ch01/final/c01s05.pdf 2 Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, September 25, 2014 3a Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, November 13, 2014 – Excerpt 1: Introductions and Meeting Notes and Actions from September 25, 2014 meeting 3b Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, November 13, 2014 – Excerpt 2: Operational Assumptions and Photochemical Modelling Update 4 RWDI letter to Lesley Matthews, Trans Mountain, December 22, 2014 5 Guidelines for Air Quality Dispersion Modelling in British Columbia, British Columbia Ministry of Environment, Victoria, British Columbia, March 2008http://www.bcairquality.ca/reports/pdfs/air_disp_model_08.pdf] 6 Levelton Consultants (2007) Air Toxics Emission Inventory & Health Risk Assessment Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 2 of 52

[http://www.metrovancouver.org/about/publications/Publications/Air_Toxic s_Emission.pdf]

7 Health Canada (2014) Health Canada’s response to the Request for Comments on Human Health Risks indicated by Environment Canada’s modelling of Trans Mountain Expansion (TMX) air emissions, November 27, 2014 8 Canadian Council of Ministers of the Environment (2007) Guidance Document On Continuous Improvement (CI) And Keeping-Clean-Areas- Clean (KCAC): Canada-wide Standards for Particulate Matter and Ozone. [http://www.ccme.ca/files/Resources/air/pm_ozone/1389_ci_kcac_e.pdf] 9 [Extracts from] Website of the Invasive Species Council of Metro Vancouver http://www.iscmv.ca

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 3 of 52

Trans Mountain Pipeline ULC (“Trans Mountain”) Trans Mountain Expansion Project Information Request No. 2

2.1 Common Air Contaminants

2.1.1 Particulate Matter Emission Estimates for Vapour Combustion Unit

References:

i) A3S1U1, Application Volume 5C, Biophysical Technical Reports, Air Quality and Greenhouse Gas Technical Report, PDF page 203 of 567. ii) A4A4E3, Supplemental Air Quality Technical Report for Technical Update No.2, August 22, 2014, page 14. iii) Attachment 1, United States Environmental Protection Agency AP-42 Compilation of Air Pollutant Emission Factors, Chapter 1.5 Liquefied Petroleum Gas Combustion, http://www.epa.gov/ttnchie1/ap42/ch01/final/c01s05.pdf, Table 1.5-1, page 1.5-3. iv) Attachment 2, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, September 25, 2014, page 3, Action 11. v) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, pages 10 to 11. vi) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, page 38, Figure 4. vii) Attachment 2, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, September 25, 2014, page 6, Action 22. viii)A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, page 21.

Preamble:

Reference (i) states that exceedances of Metro Vancouver’s objectives for 24-hour PM10 and PM2.5 were predicted to occur for the Application Case. It is also stated that the largest contributor to predicted PM2.5 concentrations is the existing vapour combustion unit (VCU) at Westridge Marine Terminal. Particulate matter is one of the air contaminants of greatest concern in Metro Vancouver due to its potential health effects Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 4 of 52

and because there is no known threshold for adverse effects. Any increase in particulate matter levels is expected to result in an increase in negative health impacts.

Reference (ii) states that, for that update, combustion emissions of CACs associated with operation of the VCU in the Base and Application Cases were estimated based on the United States Environmental Protection Agency AP-42, Chapter 1.5: Liquefied Petroleum Gas Combustion (US EPA, 2008) for particulate matter (PM) and carbon monoxide. For nitrogen oxides (NOx), emission rates based on a vendor performance guarantee were selected for use in the CALPUFF model.

Reference (iii) is the US EPA document mentioned above, and provides butane and propane emission factors for industrial and commercial boilers.

Reference (iv) records that there was a discussion regarding the PM emission rates estimated for the VCU and that vendor estimates, similar to those provided for NOx, would be an improvement over AP-42 emission factors. Also recorded is an action item for Trans Mountain to provide more detailed information on the PM emissions from the vendor.

Reference (v) describes a Vapour Combustion Unit (VCU) as an open combustion stack with a burner element located near ground level that is enclosed so as to contain a visible flame. It explains that the differences between a VCU and an enclosed ground flare include that a VCU has a number of safety features and that it achieves a greater combustion efficiency. Reference (v) does not explain how a VCU is similar to an industrial or commercial boiler nor does it provide more detailed information on the PM emissions from the vendor.

Reference (vi) provides the VOC emission rate during ship loading as a function of time.

Reference (vii) records that Greg Hill of Trans Mountain stated that it is possible that during maintenance on the vapour recovery unit (VRU) the VCU could operate continuously for 24 hours. In Action 22, RWDI committed to provide emission rates for the situation when a VCU would be running 24 hours during VRU maintenance.

Reference (viii) states that modelling was completed for normal operating conditions not for a VRU maintenance scenario. This reference does not provide emissions for the VCU assuming it runs continuously for 24 hours during VRU maintenance.

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Request:

a) Please specify which of the four sets of emission factors from Reference (iii) were used to estimate PM emissions from the VCU.

b) Please explain how a VCU is similar to an industrial or commercial boiler and why it is appropriate to use emission factors for a boiler to represent emissions from a VCU, as compared to emission estimates provided by the VCU vendor.

c) Please provide more detailed information on the PM emissions from the vendor of the VCU, such as stack test results from similar equipment.

d) Our understanding is that propane gas is added to the VCU to improve combustion efficiency. As a result, combustion emissions from the VCU may not be as peaked as the VOC loading emissions. Please describe how propane fuel is added to the VCU as a function of time during ship loading.

e) Please provide on the same plot as the one shown in Reference (vi): the flow rate of propane gas added to the VCU and the PM and NOx combustion emissions from the VCU as a function of time. Please also include on the same plot, the 24-hour average PM and NOx emissions used in the dispersion modelling.

f) Please provide information on VRU maintenance scenarios, including how often this will occur, and the duration of maintenance time.

g) Please provide isopleth maps of predicted rolling 24-hour average PM2.5 and PM10 concentrations resulting from continuous operation of the VCU during a 24- hour maintenance scenario.

2.1.2 Combined Case

References:

i) Attachment 2, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, September 25, 2014, page 4, Action 13. ii) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, page 15.

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Preamble:

Reference (i) records that there was a discussion regarding an updated combined case with emissions from the Burnaby Terminal (BT), Westridge Marine Terminal (WMT) and Marine emissions using the Marine Emission Inventory Tool (MEIT).

Reference (ii) provides a combined case of predicted concentrations from marine emissions plus project emissions (WMT and BT) plus the ambient background but does not provide annual emissions from these sources.

Request:

a) Please provide a table that includes annual emissions for an updated combined case from the Burnaby Terminal, Westridge Marine Terminal and marine emissions using the Marine Emission Inventory Tool.

2.1.3 Comparative Results

References:

i) Attachment 2, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, September 25, 2014, page 4, Action 17. ii) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, pages 18-19.

Preamble:

Reference (i) records that there was a discussion regarding the difficulty in following the changes between the initial 2013 Application and the updated 2014 technical filings.

Reference (ii) states that information “providing summary tables of the original 2013 and updated 2014 technical details used in the air quality assessments” could not be included in Technical Update No. 4 due to time constraints, but that Trans Mountain commits to providing these summary tables and aims to make these available during the next round of intervenor information requests in January/February 2015.

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Request:

a) Please provide a comparison of key changes between the initial 2013 Application and the updated 2014 technical filings, including emission inputs, model results and relevant plots.

2.1.4 CALMET

References:

i) A3W7A9, Metro Vancouver IR#1, IR 1.6.10, page 100. ii) A3Y2K9, Responses to Information Request from Government of Canada, Environment Canada (GoC EC), IR No.1.103a, page 198. iii) A4A4E3, Supplemental Air Quality Technical Report for Technical Update No.2, August 22, 2014. iv) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, pages 3 to 5. v) A4F5H8, Supplemental Marine Air Quality and Greenhouse Gas Technical Report #2 and ESA Significance Rating, November 26, 2014. vi) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, Figure 4.1-6.

Preamble:

Reference (i) states that “the Burrard Inlet water mass appears to be shown to have an incorrect land-use”.

In Reference (ii) Trans Mountain stated that “there were errors in the land use data processing for the Burnaby and Westridge Marine Terminals Air Quality Regional Study Area. This will be rectified in Technical Update No. 1 to be filed in Q3”.

Reference (iii) states that “The land use assignments in the modelling (CALMET model) completed for the 2013 Technical Report were found to be faulty for the Burrard Inlet Area. It was noted that there were errors in the land use data processing for the Burnaby and Westridge Marine Terminals. Land use assignments for the Burrard Inlet Area have been corrected to reflect the correct current land use in this update (in an updated run of the CALMET model)”.

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Reference (iii) provides a plot (Figure A.6) of the revised land-use that appears to continue to show discrepancies in assignments of land-use. For example, issues of note in the plot include:  Burrard Inlet shows non-continuous water with a forested bridge between Burnaby Mountain and Belcarra.  A straight line division between urban and forest near Burnaby Mountain.  The urbanized areas of New Westminster, Lynn Valley, Deep Cove, Lynnmour, Seymour Heights, and Blueridge are depicted as forest.  Port Moody has been assigned a continuous urban land use with many forested areas missing including a 500 m by 2.5 km forested block.  Burnaby Lake (a park 1.5 km by 3.5 km) is entirely missing and has been depicted as urban.  Large areas in Richmond are not shown as agricultural but have been represented as forest.

Reference (iv) provides another revised plot (Figure 1.3-1) that is different than Reference (iii) Figure A.6.

Reference (iv) Figure 1.3-1 also appears to show discrepancies in assignments of land- use. In the figure, the predominant land-use covering much of the study area is shown as “agricultural land” and most of the forested features in Burnaby are missing. Environment Canada’s plot in Reference (iv) appropriately shows the predominant land- use as “urban”, but is also missing most of the forested features throughout Burnaby.

The main issues of concern related to Reference (iv) Figure 1.3-1 are:  The predominant land-use covering the majority of the study area is shown as “agricultural land” when it should be depicted as “urban”.  The predominantly forested Burnaby Mountain (a forested block approximately 2.5 km by 4 km) is missing and has not been considered in land-use classification.  The forested areas surrounding Capitol Hill are missing and have not been included in land-use classification.  The forested areas of Burrard Inlet Conservation Area have not been included in the land-use classification.  Forested areas of other large parks throughout Burnaby are not shown to be included including Confederation Park, Burnaby Lake Park, and Deer Lake Park.  Other smaller forested areas that are much farther from the Project have been included such as two small areas in south Burnaby.  The land-use of a golf course in south Burnaby (Riverway Golf Course) has been included while many golf courses closer to the Project have not, including Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 9 of 52

Burnaby Mountain Golf Course, Kensington Pitch and Putt, Seymour Golf and Country Club and Northlands Golf Course.

The most important land-use to accurately depict in the model would be the land-use surrounding the main emission sources such as the Westridge Terminal, Burnaby Terminal and tanker traffic through Burrard Inlet. The land-use assignment would play an important role in CALMET otherwise it would not be an input parameter to the model.

Intervenors in References (i), (ii) and (iv) have raised questions about the CALMET land-use depicted, including for subsequent plots provided by Trans Mountain [References (iii) and (iv)]. The most recent land-use plot provided [Reference (iv), Figure 1.-3.1] does not accurately depict the land-use of the study area as Metro Vancouver understands it.

Request:

a) Please provide the land-use that was used to represent Burnaby Mountain Conservation Area in the CALMET modelling.

b) Please confirm that the land-use classification used in the CALMET model is depicted in Figure 1.3-1 of Reference (iv).

c) Please provide one figure containing the terrain and land-use plotted directly from the GEO.DAT input file used in Reference (iii).

d) Please provide the entire CALMET.inp file used in the Terrestrial assessment (Reference iii).

e) Please provide the entire CALMET.inp file for Marine assessment [Reference (v)].

f) Please provide the entire GEO.DAT file for Terrestrial assessment [Reference (iii)].

g) Please provide the entire GEO.DAT file for Marine assessment [Reference (v)].

h) Please provide a figure of extracted wind speed and direction (presented as a wind rose) at the Westridge Terminal [from the CALMET used in Reference (iii)] and compare to meteorological observations collected at Westridge Terminal depicted in Reference (vi).

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i) Please provide a figure of extracted wind speed and direction (presented as a wind rose) from a location in Indian Arm with a latitude of 49.323194° and longitude of -122.931717° from the CALMET used in Reference (iii). Please compare this wind rose with a wind rose generated from WRF model output at the same location.

2.1.5 Model Plan Commitments

References:

i) A3S1U3, Application Volume 5C, Biophysical Technical Reports, TR 5C-4 - Air Quality and Greenhouse Gas Technical Report. ii) A4A4E3, Supplemental Air Quality Technical Report for Technical Update No.2, August 22, 2014. iii) A4F5H8, Supplemental Marine Air Quality and Greenhouse Gas Technical Report No.2 and ESA Significance Rating, November 26, 2014. iv) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee. v) A3Y1F4, Human Health Risk Assessment of Westridge Marine Terminal Technical Report, June 2014.

Preamble:

Reference (i) Appendix B - Detailed Model Plan states the planned air quality dispersion model output would include:  spatial distribution maps of air quality parameters including maxima, exceedance frequencies, and annual averages.  locations of maximum concentrations provided in figures.  tables of concentrations predicted at select receptors of interest.  for cumulative (“combined”) effects of terrestrial and marine emissions, model results over the 1 km grid interpolated to gridded receptors around the Burnaby Terminal and Westridge Terminal.

Reference (i) provides combined effects of both terrestrial and marine emissions.

Reference (ii) provides updated model results for terrestrial emissions only.

Reference (iii) provides updated model results for marine emissions only.

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Based on Reference (ii) and Reference (iii), it is not possible to determine the locations of maximum concentrations nor the spatial distribution of the predicted concentrations from terrestrial and marine emissions combined.

The only combined results that have been filed by Trans Mountain to the NEB are 4 plots in Reference (iv) which represent only 4 of the 25 pollutant/averaging period combinations provided in Table 26 of Reference (ii).

There have been no results tables filed to the NEB by Trans Mountain that show updated results of the combined effects of both terrestrial and marine emissions.

Request:

a) Please provide a table that provides the combined effects of the Application Case (terrestrial and marine emissions) with and without ambient background for predicted concentrations of: 24-hour maximum PM10, annual PM10, 24-hour maximum PM2.5, annual PM2.5, 1-hour maximum Carbon Monoxide (CO), 8- hour maximum CO, 1-hour maximum Oxides of Nitrogen (NOx), annual NOx, 1- hour maximum Nitrogen Dioxide (NO2), 24-hour maximum NO2, annual NO2, 1- hour maximum Sulphur Dioxide (SO2), 24-hour maximum SO2 and annual SO2.

b) Please provide spatial plots showing the combined effects of the Application Case (terrestrial and marine emissions) with ambient background for predicted concentrations of each of: 24-hour maximum PM10, annual PM10, annual PM2.5, 1-hour maximum Sulphur Dioxide (SO2), 24-hour maximum SO2 and annual SO2. In each plot please provide the location of the maxima. Please use an isopleth contour range starting at the minimum value predicted and ending at the maximum value predicted in increments of 1 ug/m3 for PM2.5, 2 ug/m3 for PM10, and 5 ug/m3 for SO2.

c) Please provide spatial plots showing the Base Case of the terrestrial assessment with ambient background for predicted concentrations of each: 24-hour maximum PM10, annual PM10, 24-hour maximum PM2.5, annual PM2.5, 1-hour maximum Sulphur Dioxide (SO2), 24-hour maximum SO2 and annual SO2. In each plot please provide the location of the maxima. Please use an isopleth contour range starting at the minimum value predicted and ending at the maximum value predicted in increments of 1 ug/m3 for PM2.5, 2 ug/m3 for PM10, and 5 ug/m3 for SO2.

d) Please provide spatial plots showing the Application Case of the terrestrial assessment with ambient background for predicted concentrations of each: 24- Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 12 of 52

hour maximum PM10, annual PM10, 24-hour maximum PM2.5, annual PM2.5, 1- hour maximum Sulphur Dioxide (SO2), 24-hour maximum SO2 and annual SO2. In each plot please provide the location of the maxima. Please use an isopleth contour range starting at the minimum value predicted and ending at the maximum value predicted in increments of 1 ug/m3 for PM2.5, 2 ug/m3 for PM10, and 5 ug/m3 for SO2.

e) Please provide a table that provides the combined effects of the Application Case (terrestrial and marine emissions) with and without ambient background for predicted concentrations at select receptors of interest including: Westridge Elementary School, Confederation Park Elementary School, Ecole Capitol Hill Elementary School, Lochdale Community School, Montecito Elementary School, Forest Grove Elementary, Sherwood Park Elementary, resident Westridge 1 [Reference (v) - location ID: 47], resident Westridge 2 [Reference (v) - location ID: 48], and resident Westridge 3 [Reference (v) - location ID: 49], resident Dollarton [Reference (v) - location ID: 19] and Tsleil-Waututh [Reference (v) - location ID: 10].

f) Please provide a table that provides the combined effects of the Base Case (terrestrial and marine emissions) with and without ambient background for predicted concentrations at select receptors of interest including: Westridge Elementary School, Confederation Park Elementary School, Ecole Capitol Hill Elementary School, Lochdale Community School, Montecito Elementary School, Forest Grove Elementary, Sherwood Park Elementary, resident Westridge 1 [Reference (v) - location ID: 47), resident Westridge 2 [Reference (v) - location ID: 48], and resident Westridge 3 [Reference (v) - location ID: 49], resident Dollarton [Reference (v) - location ID: 19] and Tsleil-Waututh [Reference (v) - location ID: 10].

2.1.6 Nitrogen Dioxide Results

Reference:

i) A4A4E3, Supplemental Air Quality Technical Report for Technical Update No.2, August 22, 2014, page 29.

Preamble:

Reference (i) shows that the nitrogen dioxide value established for Ambient Background is higher than the predicted Base Case + Ambient Background. For example, the 1- Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 13 of 52

hour NO2 ambient background is given as 111.0 ug/m3 while the Base Case + Ambient Background is given as 84.0 ug/m3. Similarly the 24-hour and annual NO2 ambient background provided is greater than the Base Case + Ambient Background.

Request:

a) Please recalculate nitrogen dioxide values presented in Reference (i) by predicting NOx, then converting to NO2 and then adding an ambient background of NO2. Please do this for both the Base Case and Application Case.

2.1.7 Elevated Receptors

Reference:

i) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, page 20.

Preamble:

Reference (i) indicates that a flagpole receptor height of 1.5 metres was used to evaluate human health exposure in the breathing zone. It is agreed that this height is appropriate to model ground-based human exposure. However, a height of 1.5 metres will not be suitable to predict results of elevated receptors especially when in close proximity to emission sources.

The passing of marine vessels underneath the Second Narrows Bridge and Lions Gate Bridge will represent an emission source directly below the bridge deck that will impact short-term exposure for people on the bridge. Since public access to the bridges will not be restricted it is conceivable that a short-term exposure of 1-hour is possible on the bridge decks. It is also known that traffic incidents can impede the flow of traffic on the bridge deck. During these times motorists have been confined on the bridge deck for upwards of several hours. However, a 24-hour exposure duration would be unlikely on the bridge deck and therefore the request for more information is limited to a 1-hour exposure period.

Request:

a) Please provide a table of the maximum 1-hour SO2, 1-hour NO2, and 1-hour CO from an elevated receptor located mid-span at the Lions Gate Bridge. Please provide results with and without an ambient background value added.

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b) Please provide a table of the maximum 1-hour SO2, 1-hour NO2, and 1-hour CO from an elevated receptor located mid-span at the Second Narrows Bridge which considers the combined effects of both terrestrial and marine emissions. Please provide results with and without an ambient background value added.

2.1.8 CALPUFF – Downwash

References:

i) A3S1U3, Application Volume 5C, Biophysical Technical Reports, TR 5C-4 - Air Quality and Greenhouse Gas Technical Report. ii) A4A4E3, Supplemental Air Quality Technical Report for Technical Update No.2, August 22, 2014. iii) A3Y2K9, Responses to Information Request from Government of Canada, Environment Canada (GoC EC), IR No.1.104, page 204. iv) A3Y2V0, Responses to Information Request from Metro Vancouver, IR No. 1.6.15, page 111.

Preamble:

Reference (i) indicates that downwash was incorporated using the Building Profile Input Program Plume Rise Model Enhancement (BPIP PRIME) algorithm, however no methodology is provided on which buildings and structures were included.

Reference (ii) provides updated results for Reference (i) but provides no methodology on which buildings and structures were included.

Reference (iii) states that building downwash has an important effect on the dispersion characteristics for emissions near building structures. Typically, it is a best practice within dispersion modelling reports to provide detailed information and supporting figures for how building downwash was modelled.

Metro Vancouver in Reference (iv) and Environment Canada in Reference (iii) both requested figures of the locations of all building structures considered in the BPIP PRIME algorithm for the Burnaby / Westridge modelling.

Reference (iii) states that a Google Earth file was included in response to GoC EC IR No.1.104, however Trans Mountain did not file this Google Earth file but rather two model input files that did not contain any figures.

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The two model files attached to Reference (iii) contain over a thousand lines of code. The code appears to contain hundreds of coordinates without any reference to which coordinate system, datum, or grid zone were used.

Request: a) Please confirm that Reference (ii) considered the same downwash as Reference (i).

b) Please provide a Google Earth file that identifies all buildings and structures considered in the BPIP for the Burnaby/Westridge modelling as committed to in Reference (iv) response to IR1.6.15b.

c) If a Google Earth file is not available, please provide a figure that is approximately 1 km by 1 km centered on the Westridge Terminal that identifies all buildings and structures considered in the BPIP for the terrestrial modelling.

d) If a Google Earth file is not available, please provide a figure that is approximately 1.5 km by 1.5 km centered on the Burnaby Terminal that identifies all buildings and structures considered in the BPIP for the terrestrial modelling.

2.1.9 Stations Used for Establishing Background Values for Burnaby

References:

i) Attachment 2, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, September 25, 2014, page 7, Action 27. ii) A4F5C9 Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, page 23.

Preamble:

Reference (i) records that there was a discussion on the use of one station versus multiple stations to establish the background value for the region.

Reference (ii) indicates that an analysis of several stations in the contained within the study area will be performed and will be provided during the next round of intervenor information requests in January/February 2015.

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Request:

a) Please provide a summary table of the results of the analysis and an explanation of how this analysis will be incorporated into the final results.

2.1.10 Emission Factors for the Vapour Recovery System

References:

i) Attachment 3b, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, November 13, 2014 – Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, November 13, 2014 – Excerpt 2: Operational Assumptions and Photochemical Modelling Update, page 9, Action 33. ii) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, page 37.

Preamble:

Reference (i) records that there was a discussion about testing results and HYSIS modeling of the Vapour Recovery System being better and more realistic than the US EPA AP-42 emission factors.

Reference (ii) indicates Trans Mountain will commit to providing summary tables of the HYSIS modeling and the Vapour Recovery Collection System testing results during the next round of intervenor information requests in January/February 2015.

Request:

a) Please provide summary tables of the HYSIS modeling and the Vapour Recovery Collection System testing results

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2.2 Volatile Organic Compounds

2.2.1 Collection Efficiency of Vapours during Ship Loading at Westridge Marine Terminal

References:

i) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, page 2. ii) A4A4E3, Supplemental Air Quality Technical Report for Technical Update No.2, August 22, 2014, page 23 and 24, Tables 17 and 18.

Preamble:

Reference (i) describes the “closed” system used to load ships with crude.

Reference (ii) provides the collection, H2S and mercaptan removal, VRU reduction and combustion efficiencies for the VRU and VCU.

Request:

a) Please provide a detailed explanation of how Trans Mountain will ensure the “closed” system for ship loading is effective. What monitoring systems will be used? How will leaks be detected and repaired? How often will these systems be inspected? What will be reported and how often?

b) Please explain how the H2S and mercaptan removal, VRU reduction and combustion efficiencies for the VRU and VCU will be monitored and reported.

c) Please provide annual collection, H2S and mercaptan removal, and combustion efficiencies for the existing VCU at WMT for the past five years.

d) Please provide a summary of leak detection and repair of the current vapour collection system at WMT for the past five years.

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2.2.2 Emissions of Total VOCs

References:

i) Attachment 4, RWDI letter to Lesley Matthews, Trans Mountain, December 22, 2014, pages 5-8. ii) A3S1U1, Application Volume 5C, Biophysical Technical Reports, Air Quality and Greenhouse Gas Technical Report, PDF pages 174 and 175. iii) A3S1U1, Application Volume 5C, Biophysical Technical Reports, Air Quality and Greenhouse Gas Technical Report, PDF page 200 (Table 5.17). iv) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, page 37.

Preamble:

Reference (i) provides updated Project total emissions of VOCs from the Westridge Marine Terminal for the Base Case (Tables 1.2-6 and Tables 1.2-7) and Application Case (Tables 1.2-8, 1.2-9 and 1.2-10). Fugitive ship emissions from loading are not included in these tables. The annual and maximum hourly VOC emission rates for the Vapour Combustion Unit (VCU) for the Base Case are 64.5 t/y and 19.1 g/s, respectively (Tables 1.2-6 and 1.2-7). The Project Only emissions from the VCU are - 53.4 t/y (Table 1.2-9).

Reference (ii) provides annual and maximum hourly emissions from Westridge Marine Terminal for Existing Conditions, which are understood to be the same as for the Base Case. The annual VOC emissions from the VCU are 5.0 t/y (Table 4.33) and the maximum hourly VOC emissions from the VCU are 1.1 g/s (Table 4.34).

Reference (iii) indicates that the Project only VOC emissions from the VCU in the original submission were -2.8 t/y.

Reference (iv) provides a calculated vapour capture efficiency of 99.9999% per vapour collection line. Therefore there will be some fugitive VOC emissions from ship loading on both annual and hourly bases.

Request:

a) Please provide a detailed explanation of why the Base Case VOC emissions from the VCU have increased substantially (from 5.0 to 64.5 t/y on an annual Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 19 of 52

basis and from 1.1 to 19.1 g/s on an hourly basis), resulting in a much greater decrease in Project Only VOC emissions from the VCU (from -2.8 to -53.4 t/y).

b) Please provide fugitive VOC emissions from ship loading on both annual and hourly bases using the vapour capture efficiency of 99.9999% reported in Reference (iv). Please also provide the annual and hourly benzene, toluene, ethyl benzene and xylene fugitive emissions from ship loading.

c) Please update the total VOC emissions to include fugitive emissions from ship loading.

2.2.3 Predicted Concentrations of BTEX

References:

i) A3S1U1, Application Volume 5C, Biophysical Technical Reports, Air Quality and Greenhouse Gas Technical Report, page 205, Table 5.21. ii) A4A4E3, Supplemental Air Quality Technical Report for Technical Update No. 2, August 22, 2014, page 29. iii) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, pages 17 and 18.

Preamble:

Reference (i) provides maximum predicted concentrations of benzene, toluene, ethyl benzene and xylene (BTEX) for the Application Case.

Reference (ii) provides revised maximum predicted concentrations of benzene, ethyl benzene, toluene and xylene for the Application Case. The revised one-hour benzene concentration is about one third of the original value (14.0 vs. 41.6 µg/m3) whereas the revised one-hour ethyl benzene, toluene and xylene concentrations are very similar to the original values (55.7 vs. 56.5 µg/m3; 136.0 vs. 144 µg/m3; and 114.0 vs. 115 µg/m3).

Reference (iii) provides a response to the question of why the revised benzene concentrations were one third the original values whereas the revised ethyl benzene, toluene and xylene concentrations were only a few µg/m3 lower than the original values. The response discusses the changes in BTEX emission estimation methodology. Given that the change in methodology seems to be the same for all components of BTEX, the Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 20 of 52

response does not explain why benzene concentrations decrease so much more than ethyl benzene, toluene and xylene concentrations.

Request:

a) Please provide a table that compares the benzene, toluene, ethyl benzene and xylene emission rates used to predict the one-hour average concentrations for the application case presented in Reference (i) and Reference (ii). In the same table, please also reproduce the predicted one-hour BTEX concentrations from Reference (i) and Reference (ii) for ease of comparison.

b) Please explain why the difference between the original and revised maximum predicted one-hour concentrations is so much greater for benzene than for toluene, ethyl benzene and xylene.

2.2.4 Benzene

References:

i) A3Y3X9, Addendum to: Modelling the Fate and Behaviour of Marine Oil Spills for the Trans Mountain Expansion Project, June 2014. i) A4A1Z9, Additional CALPUFF wind scenarios in response to NEB IR 2.024. ii) A3Y7L4, NEB Letter and Information Request No. 2 to Trans Mountain Pipeline, IR 2.21. iii) A3Y1F4, Human Health Risk Assessment Of Westridge Marine Terminal Technical Report, June 2014.

Preamble:

Reference (i) provides isopleth plots that show the predicted concentration for benzene with isopleth contours: 5-100, 100-200, 200-300, 300-400, 400-500, 500-580, 580-1000, and 1000-4000. Based on these isopleth contours it is not possible to determine the location of the predicted maximum or the spatial extent of the Alberta 1-hour Benzene objective level with a numerical value of 30 ug/m3.

Reference (ii) provides isopleth plots that show the predicted concentration for Benzene with isopleth contours of 5-100, 100-200, 200-300, 300-400, 400-500, 500-580, 580- 1000, 1000-4000 and >4,000. Based on these isopleth contours it is not possible to determine the spatial extent of the Alberta 1-hour Benzene objective level with a numerical value of 30 ug/m3. Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 21 of 52

In Reference (iii) the NEB notes that for some pollutants where a guideline or an objective is not available, Trans Mountain has compared modelled concentrations to other relevant provincial guidelines or objectives, whereas in other cases it has not. Furthermore, in Reference (iii) the NEB requests that Trans Mountain, for pollutants including benzene where there is no guideline or objective in the province in question and for which a guideline or objective from another province has not been used, choose the most appropriate guideline or objective, if available, from another jurisdiction.

Request:

a) In recognition of the Alberta 1-hour Benzene objective level of 30 ug/m3, please revise Reference (i) Figures 4.1 to 4.12 to include the following isopleth contours: 5-30, 30-100, 100-200, 200-300, 300-400, 400-500, 500-580, 580-1000, and 1000-4000, and >4000.

b) In recognition of the Alberta 1-hour Benzene objective level of 30 ug/m3, please revise Reference (ii) Figures 3.1.1 to 3.3.4 to include the following isopleth contours: 5-30, 30-100, 100-200, 200-300, 300-400, 400-500, 500-580, 580- 1000, and 1000-4000, and >4000.

c) For Reference (i), please provide a table that provides the maximum predicted 1- hour Benzene concentration at select receptors of interest including: Westridge Elementary School, Confederation Park Elementary School, Ecole Capitol Hill Elementary School, Lochdale Community School, Montecito Elementary School, Forest Grove Elementary, Sherwood Park Elementary, resident Westridge 1 [Reference (iv) - location ID: 47], resident Westridge 2 [Reference (iv) - location ID: 48], and resident Westridge 3 [Reference (iv) - location ID: 49], resident Dollarton [Reference (v) - location ID: 19] and Tsleil-Waututh [Reference (v) - location ID: 10].

d) For Reference (ii), please provide a table that provides the maximum predicted 1- hour Benzene concentration for each different scenario at select receptors of interest including: Westridge Elementary School, Confederation Park Elementary School, Ecole Capitol Hill Elementary School, Lochdale Community School, Montecito Elementary School, Forest Grove Elementary, resident Westridge 1 [Reference (iv) - location ID: 47], resident Westridge 2 [Reference (iv) - location ID: 48], and resident Westridge 3 [Reference (iv) - location ID: 49].

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2.2.5 Predicted Concentrations of Benzene and Mercaptans

References:

i) A3S1U3, Application Volume 5C, Biophysical Technical Reports, TR 5C-4 - Air Quality and Greenhouse Gas Technical Report. i) A4A4E3, Supplemental Air Quality Technical Report for Technical Update No.2, August 22, 2014. ii) A4F5H8, Supplemental Marine Air Quality and Greenhouse Gas Technical Report #2 and ESA Significance Rating, November 26, 2014. iii) A3Y1F4, Human Health Risk Assessment Of Westridge Marine Terminal Technical Report, June 2014.

Preamble:

Reference (i) Appendix B (Detailed Model Plan) states the planned air quality dispersion model output would include:  spatial distribution maps of air quality parameters including maxima, exceedance frequencies, and annual averages.  locations of maximum concentrations provided in figures.  tables of concentrations predicted at select receptors of interest.  for cumulative (“combined”) effects of terrestrial and marine emissions, model results over the 1 km grid interpolated to gridded receptors around the Burnaby Terminal and Westridge Terminal.

Reference (i) provides combined effects of both terrestrial and marine emissions.

Reference (ii) provides updated model results for terrestrial emissions only.

Reference (iii) provides updated model results for marine emissions only.

Based on Reference (ii) and Reference (iii) it is not possible to determine the locations of maximum concentrations nor the spatial distribution of the predicted concentrations of Benzene and/or Mercaptans from terrestrial and marine emissions combined.

There have been no results tables filed to the NEB by Trans Mountain that show updated results of the combined effects of both terrestrial and marine emissions.

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 23 of 52

Request:

a) Please provide a table that provides the combined effects of the Application Case and Base Case (terrestrial and marine emissions) with and without ambient background for predicted concentrations of: 1-hour maximum Benzene, annual Benzene, and 10-minute maximum Mercaptans. Please include comparison to the 1-hour and annual Benzene Alberta Objective, and Ontario Objective for 10- minute Mercaptans. In case of any exceedances of the Alberta or Ontario objectives, please include a frequency of exceedance in the table.

b) Please provide spatial plots (of the entire study area) showing the combined effects of the Application Case and Base Case (terrestrial and marine emissions) with ambient background for predicted concentrations of: 1-hour maximum Benzene, annual Benzene, and 10-minute maximum Mercaptans. In each plot please provide the location of the maxima. Please use an isopleth contour range starting at the minimum value predicted and ending at the maximum value predicted in increments of 1 ug/m3.

c) Please provide spatial plots (approximately 1 km by 1 km centered on the Westridge Terminal) showing the combined effects of the Application Case and Base Case (terrestrial and marine emissions) with ambient background for predicted concentrations of: 1-hour maximum Benzene, annual Benzene, and 10-minute maximum Mercaptans. In each plot please provide the location of the maxima. Please use an isopleth contour range starting at the minimum value predicted and ending at the maximum value predicted in increments of 1 ug/m3.

d) Please provide spatial plots showing the Base Case of the terrestrial assessment with ambient background for predicted concentrations of: 1-hour maximum Benzene, annual Benzene, and 10-minute maximum Mercaptans. In each plot please provide the location of the maxima. Please use an isopleth contour range starting at the minimum value predicted and ending at the maximum value predicted in increments of 1 ug/m3.

e) Please provide spatial plots showing the Application Case of the terrestrial assessment with ambient background for predicted concentrations of: 1-hour maximum Benzene, annual Benzene, and 10-minute maximum Mercaptans. In each plot please provide the location of the maxima. Please use an isopleth contour range starting at the minimum value predicted and ending at the maximum value predicted in increments of 1 ug/m3.

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 24 of 52

f) Please provide a table that provides the combined effects of the Application Case and Base Case (terrestrial and marine emissions) with and without ambient background for predicted concentrations of: 1-hour maximum Benzene, annual Benzene, and 10-minute maximum Mercaptans for predicted concentrations at select receptors of interest including: Westridge Elementary School, Confederation Park Elementary School, Ecole Capitol Hill Elementary School, Lochdale Community School, Montecito Elementary School, Forest Grove Elementary, Sherwood Park Elementary, resident Westridge 1 [Reference (iv) - location ID: 47], resident Westridge 2 [Reference (iv) - location ID: 48], and resident Westridge 3 [Reference (iv) - location ID: 49], resident Dollarton [Reference (v) - location ID: 19] and Tsleil-Waututh [Reference (v) - location ID: 10]. Please include comparison to the 1-hour and annual Benzene Alberta Objective, and Ontario Objective for 10-minute Mercaptans. In case of any exceedances of the Alberta or Ontario objectives, please include a frequency of exceedance in the table.

2.3 Photochemical Modelling

2.3.1 Cumulative Case

References:

i) Attachment 3a, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, November 13, 2014 – Excerpt 1: Introductions and Meeting Notes and Actions from September 25, 2014 meeting, Page 5, Action 21(b). ii) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee, Page 37.

Preamble:

Reference (i) records that there was a discussion regarding the projects to be included for TMEP assessment for the cumulative case as well as for photochemical modelling.

Reference (ii) states that further discussion between Metro Vancouver, Port Metro Vancouver and RWDI on this matter will be addressed at the next LFVAQCC meeting.

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 25 of 52

Request:

a) Please provide a timeframe for when Trans Mountain will develop a model plan in consultation with the LFVAQCC members for the additional modelling work.

b) Please provide a commitment to consult with the LFVAQCC members prior to starting this additional modelling work.

2.4 Spill Modelling

2.4.1 CALMET AND CALPUFF Methodology

References:

i) Attachment 5, Guidelines for Air Quality Dispersion Modelling in British Columbia, British Columbia Ministry of Environment, Victoria, British Columbia, March 2008 [http://www.bcairquality.ca/reports/pdfs/air_disp_model_08.pdf]. i) A3Y3X9, Addendum to: Modelling the Fate and Behaviour of Marine Oil Spills for the Trans Mountain Expansion Project, June 2014. ii) A4F5C9, Project and Technical Update No.4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee. iii) A4A4E3, Supplemental Air Quality Technical Report for Technical Update No.2, August 22, 2014.

Preamble:

Reference (i) states that preparation of input files involves the manipulation of thousands of pieces of information and that modellers must exercise a quality assurance / quality control (QA/QC) procedure to confirm the accuracy of the input source, receptor and meteorological data to confirm the proper behaviour of models.

Reference (i) provides recommendations for CALMET QA/QC process. These recommendations include the following:  Plot the terrain and land use from the GEO.DAT input file to ensure it matches with other maps of the area.

 Plot the locations of the meteorological observation stations to check whether they are located properly in the horizontal and vertical.

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 Plot the frequency distribution of surface wind speeds for different locations in the domain and at the surface station locations and check for reasonableness (compare with observations, consider the location, and what might be expected given the topography).

 Plot annual surface wind roses for different locations as well as the surface station locations and check for realism (compare with observations, consider the location, and what might be expected based on topography).

 For different 24-hour periods within a summer and winter season, plot a surface, midlevel and upper-level wind field every hour for a 24-hour period with light winds and stable conditions. Check for reasonableness of the wind fields in the domain (extent of terrain effects and the appropriateness of the settings that require expert judgment).

 Plot time series of average surface temperature by month for the source location as well as surface station locations. Compare with observations/climate normals. Check for reasonable monthly variation for the given locations.

 Plot time series of average surface temperature by hour-of-day for the source location as well as surface station locations. Compare with observations/climate normals. Check for reasonable diurnal variation for the given locations.

 Plot time series of average precipitation by month (if precipitation is an input) for one location as well as surface station locations. Compare with observations. Check for reasonable monthly variation for the given locations.

 Plot the frequency distribution of mixing heights for different locations. Check for reasonableness.

 Plot a time series of mixing heights for a 24-hour summer and winter period during a light wind, and a clear sky period. Examine the diurnal behaviour for reasonableness.

Reference (ii) provides little CALMET and/or CALPUFF methodology and none of the QA/QC plots recommended in Reference (i).

Reference (iii) provides several of the QA/QC plots recommended in Reference (i) such as plots of modelled wind fields, frequency of stability class, land-use and mixing heights, diurnal variation of modelled mixing heights, and monthly total precipitation.

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 27 of 52

Request:

a) Please provide a plot of the CALPUFF receptors used in Westridge domain [Reference (ii)].

b) Please provide a plot of the terrain and land-use from the GEO.DAT input file (used in the Westridge domain) to ensure it matches with other maps of the area.

c) Please provide a plot of the locations of the meteorological observation stations (used in the Westridge domain) to check whether they are located properly in the horizontal and vertical.

d) Please provide the entire GEO.DAT file used by CALMET (used in the Westridge domain).

e) Please provide an annual plot of wind speed and wind direction (depicted as a wind rose) from an extracted CALMET point (49.323194°, -122.931717°) in Indian Arm (from the Westridge domain).

f) Since prognostic data was not used in CALMET, please explain how predicted wind speed and direction (i.e., the main driver of dispersion) is estimated by CALMET in areas such as Indian Arm.

g) For the Westridge domain, please provide a time series plot of average surface temperature by month for the source location as well as surface station locations. Compare with observations and climate normals. Check for reasonable monthly variation for the given locations.

h) For the Westridge domain, please provide annual surface wind rose plots for different locations as well as the surface station locations and check for realism (compare with observations, consider the location, and what might be expected based on topography).

i) For the Westridge domain, please provide a frequency distribution plot of surface wind speeds for different locations in the domain and at the surface station locations and check for reasonableness (compare with observations, consider the location, and what might be expected given the topography).

j) For the Westridge domain, please provide plots for different 24-hour periods within a summer and winter season, plot a surface, midlevel and upper-level wind Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 28 of 52

field every hour with light winds and stable conditions. Check for reasonableness of the wind fields in the domain.

k) For the Westridge domain, please provide a time series plot of the diurnal variation of modelled mixing heights in winter and summer for the domain.

2.5 Health Risk Assessment

2.5.1 Human Health Risk Assessments: Emergency Response Air Monitoring Plans for Pipeline, Facilities, and Marine Transport

References:

i) A4D3F1, B279-4 - Westridge Marine Terminal Emergency Response Plan (ERP) (Publish Date July 2014) ii) A4D3F2, B279-5 - Trans Mountain Pipeline Emergency Response Plan (Publish Date July 2014) iii) A4D3F3, B279-6 - Terminals and Tank Farms Emergency Response Plan (Publish Date July 2014) iv) A4F7Q9, C289-6-2 - Province of B.C. Notice of Motion #2 and Attachments

Preamble:

The existing Emergency Response Plans for Trans Mountain Pipelines, Terminals and Tank Farms and Westridge Terminal provided in References (i), (ii) and (iii) include two air monitoring plans in section 10.7 of the ERPs:  Air Monitoring Plan for Unplanned Petroleum Release: Acute Public Health Risk Related to the Inhalation Pathway (February 2013)

 Air Monitoring Plan During a Fire: Acute Public Health Risk Related to the Inhalation Pathway (April 2013).

These two plans are common to all three ERPs [References (i), (ii) and (iii)], and include descriptions of air monitoring and sampling methods, equipment, monitoring considerations based on facility locations, monitoring criteria, a decision tree to guide monitoring plan operation, and details of data quality and management approaches.

The ERPs and associated air monitoring plans cover only land-based and marine terminal operations, and do not cover emergency response to marine spills from oil tankers in transit. In Reference (iv), the Province of British Columbia requests that the Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 29 of 52

National Energy Board compel Trans Mountain to file the Oil Spill Response Plan of Western Canada Marine Response Corporation. At the time of writing, the National Energy Board has not yet ruled on this request.

The Air Monitoring Plan for Unplanned Petroleum Release included in References (i), (ii) and (iii) indicates (page 1): “This air monitoring plan outlines the procedure to follow to obtain accurate and reliable air concentration data for screening against acute public exposure criteria. If the acute exposure criteria are exceeded then the data will be used for an acute human health risk assessment for the inhalation pathway. Dermal and oral exposure pathways may need to be assessed for long term risks during the clean up phase following the initial release response. This work plan only addresses the acute phase of the unplanned release response when the predominant exposure pathway to the public is through inhalation.”

The Air Monitoring Plan During a Fire included in References (i), (ii) and (iii) indicates (page 1): “This air monitoring plan outlines the procedures to obtain accurate, reliable, and quantifiable air concentration data for screening against acute public exposure criteria. In instances where air concentrations exceed acute exposure criteria the data may be used to complete an acute human health risk assessment for the inhalation exposure pathway. Dermal and oral exposure pathways may need to be assessed for long term risks following the fire. This work plan only addresses the acute phase of the exposure to fire by-products (e.g., residues).”

Both plans clearly acknowledge the potential requirement for human health risk assessment following unplanned releases and fires, as well as acknowledging the potential requirement to assess health risks associated dermal and oral exposure pathways. However, the plans do not contain any information on proposed risk assessment approaches, or the approach that would be taken in developing the scope and approach of such assessments.

Request:

Please provide: a) The Oil Spill Response Plan of Western Canada Marine Response Corporation, as requested by Province of British Columbia in Reference (iv). This response plan should include Air Monitoring Plans of similar detail and scope to those included in the Trans Mountain ERPs [References (i), (ii), and (iii)].

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b) Proposed risk assessment frameworks for assessing the acute and chronic human health impacts arising from multiple pathway exposure to pollutants from unplanned releases or fires at Trans Mountain facilities. These approaches should detail stakeholder consultation for development of risk assessment scope, general approaches to hazard identification, dose-response assessment, exposure characterization, and risk characterization. Linkages between the monitoring carried out during emergency response operations and risk assessment exposure characterization should be clearly defined. The expected roles and responsibilities of stakeholder groups such as health authorities, provincial, regional and local governments, and impacted public should be clearly specified.

2.5.2 Human Health Risk Assessments: 1-3 Butadiene as a Contaminant of Potential Concern

References:

i) A4D3F1, B279-4 - Westridge Marine Terminal Emergency Response Plan (ERP) (Publish Date July 2014) ii) A4D3F2, B279-5 - Trans Mountain Pipeline Emergency Response Plan (Publish Date July 2014) iii) A4D3F3, B279-6 - Terminals and Tank Farms Emergency Response Plan (Publish Date July 2014) iv) Attachment 6, Levelton Consultants (2007) Air Toxics Emission Inventory & Health Risk Assessment [http://www.metrovancouver.org/about/publications/Publications/Air_Toxics_Em ission.pdf] v) A4F5C9, B291-28 - Project and Technical Update No. 4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee vi) A3S2L1, Application Volume 5D, TR 5D-7 Screening Level Human Health Risk Assessment of Pipeline and Facilities Technical Report vii) A3S4X2, Application Volume 7, TR 7-3 Qualitative Human Health Risk Assessment of Westridge Marine Terminal Spills Technical Report viii) A3S4R1, Application Volume 8B, TR 8B-8 Screening Level Human Health Risk Assessment of Marine Transportation Technical Report ix) A3S4R2, Application Volume 8B, TR 8B-9 Qualitative Human Health Risk Assessment of Marine Transportation Spills – Marine Transportation Technical Report x) A3Y1F4, B107-1 - Human Health Risk Assessment of Westridge Marine Terminal Technical Report Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 31 of 52

xi) A3Y1E9, B106-1 - Human Health Risk Assessment of Facility and Marine Spill Scenario Technical Report xii) A3Y1F7, B108-1 - Human Health Risk Assessment of Marine Transportation Technical Report xiii) A3X6U1, B88-2 - Responses to Information Requests from Surrey Teachers' Association, Human Health Risk Assessment of Pipeline Spill Scenarios xiv) A4A4E3, B255-31 - Technical Update #2, Supplemental Air Quality Report and ESA Significance Ratings xv) Attachment 2, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, September 25, 2014, page 8, Action 31. xvi) Attachment 3a, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, November 13, 2014 – Excerpt 1: Introductions and Meeting Notes and Actions from September 25, 2014 meeting, page 6, Action 31.

Preamble:

The existing Emergency Response Plans (ERPs) for Trans Mountain Pipelines, Terminals and Tank Farms and Westridge Terminal provided in References (i), (ii) and (iii) include two air monitoring plans in section 10.7 of the ERPs:  Air Monitoring Plan for Unplanned Petroleum Release: Acute Public Health Risk Related to the Inhalation Pathway (February 2013)

 Air Monitoring Plan During a Fire: Acute Public Health Risk Related to the Inhalation Pathway (April 2013).

These two plans are common to all three ERPs [References (i), (ii) and (iii)], and include descriptions of air monitoring and sampling methods, equipment, monitoring considerations based on facility locations, monitoring criteria, a decision tree to guide monitoring plan operation, and details of data quality and management approaches.

Throughout the air monitoring plans, 1-3 butadiene is specified as a pollutant for which both real-time monitoring and grab sampling would be performed. Acute Exposure Guideline Levels (AEGL) and other health criteria for 1-3 butadiene are also included. Benzene is the only other volatile hydrocarbon species that receives this level of specific attention in the monitoring plans.

Metro Vancouver’s 2007 “Air Toxics Emission Inventory & Health Risk Assessment” [Reference (iv)] identified 1-3 butadiene as one of the most significant contributors to lifetime cancer risks associated with ambient toxic air pollutant exposure in the Metro Vancouver region. Through meetings between Trans Mountain personnel and the Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 32 of 52

Lower Fraser Valley Air Quality Coordinating Committee [LFVAQCC, References (xv) and (xvi)] committee members requested that Trans Mountain compare the pollutants included in Reference (iv) against those included in the Human Health Risk Assessments included in the Project application package [References (vi) through (xiii)]. Reference (v) Table 2.2-1 provides a summary of the requested comparison, and indicates that 1-3 butadiene is not included in any of the air quality modelling or Human Health Risk Assessments for the Project.

Given that emphasis is placed on measuring 1-3 butadiene in the ERP Air Monitoring Plans [References (i), (ii), (iii)] for existing Trans Mountain pipeline facilities, the complete exclusion of 1-3 butadiene from any of the air quality and human health risk assessments for the Project seems to be a significant oversight. Human Health Risk Assessments included in the project application package [References (vi) through (xiii)] justify Trans Mountain’s selection of contaminants of potential concern based on analysis of Cold Lake Winter Blend diluted bitumen, but updated air quality modelling for the Westridge Terminal [Reference (xiv), Table 4] now indicates that the expanded pipeline and terminals will be handling a range of products including High TAN Dilbit, Low TAN Dilbit, High TAN Synbit and Dilsynbit, Light Sour Crude, Light Synthetic Crude, Light Sweet Crude, and Refined Product.

Request:

Please provide: a) An explanation of the emphasis placed on the measurement of the 1-3 butadiene in the ERP air monitoring plans [References (i), (ii) and (iii)].

b) An assessment of the full suite of products indicated in Reference (xiv) for their potential to lead to air emissions of 1-3 butadiene under either normal pipeline and facility operating conditions, or unplanned release / fire conditions at pipeline and terminal facilities and marine transportation. If there is no potential for the release of 1-3 butadiene regardless of the product transported, this should be clearly documented and referenced with supporting data.

c) Should emissions of 1-3 butadiene be identified in the assessment requested above, please provide supplementary Human Health Risk Assessments and associated air quality assessments for all project locations (i.e. pipeline, terminals, marine transportation) in which these emissions could occur. These assessments should follow approaches and methodologies employed in References (vi) through (xiii).

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2.5.3 Human Health Risk Assessments: Contaminants of Potential Concern Associated with Range of Products Carried By Project Facilities

References:

i) A3S2L1, Application Volume 5D, TR 5D-7 Screening Level Human Health Risk Assessment of Pipeline and Facilities Technical Report ii) A3S4X2, Application Volume 7, TR 7-3 Qualitative Human Health Risk Assessment of Westridge Marine Terminal Spills Technical Report iii) A3S4R1, Application Volume 8B, TR 8B-8 Screening Level Human Health Risk Assessment of Marine Transportation Technical Report iv) A3S4R2, Application Volume 8B, TR 8B-9 Qualitative Human Health Risk Assessment of Marine Transportation Spills – Marine Transportation Technical Report v) A3Y1F4, B107-1 - Human Health Risk Assessment of Westridge Marine Terminal Technical Report vi) A3Y1E9, B106-1 - Human Health Risk Assessment of Facility and Marine Spill Scenario Technical Report vii) A3Y1F7, B108-1 - Human Health Risk Assessment of Marine Transportation Technical Report viii)A3X6U1, B88-2 - Responses to Information Requests from Surrey Teachers' Association, Human Health Risk Assessment of Pipeline Spill Scenarios ix) A3W7A9, C234-1-2 - Metro Vancouver Information Request No.1 to Trans Mountain May 9, 2014 x) A3Y2V0, B141-1 - Responses to Information Request No. 1 from Metro Vancouver xi) A4A4E3, B255-31 - Technical Update #2, Supplemental Air Quality Report and ESA Significance Ratings

Preamble:

Human Health Risk Assessments included in the project application package [References (i) through (viii)] justify their selection of contaminants of potential concern based on analysis of Cold Lake Winter Blend (CLWB) diluted bitumen. In the first round of Information Requests [Reference (x) page 90, request 1.6.54], Metro Vancouver requested that the Human Health Risk Assessments include: “assessment [of] contaminants of potential concern (COPC) that may arise from a variety of different product blends that are likely to be transported by the project, in order to characterize the potential range of risks and contextualize the risks associated with CLWB, the product that will be transported in the largest volumes.” Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 34 of 52

In response, Trans Mountain denied this request [Reference (xi) page 187-189, request 1.6.54], stating that “assessment of potential human health effects associated with other products carried in the pipeline is not being considered.” This was justified based on three lines of reasoning:  CLWB will represent a significant portion of the product transported by the project,  the large proportion of light-end hydrocarbons in CLWB diluent, leading to the potential for significant vapour release,  the availability of laboratory test data for the CLWB composition, physical properties, and behaviour under marine spill conditions.

However, Trans Mountain’s response does not provide any reference data orsensitivity analysis that supports the conclusion that use of CLWB in the Human Health Risk Assessments is conservative and fully representative of the potential health impacts associated with emissions from normal project operation or unplanned releases.

Subsequently, updated air quality modelling for the Westridge Terminal [Reference (xi), Table 4] now indicates that the expanded pipeline and terminals will be handling a range of products including High TAN Dilbit, Low TAN Dilbit, High TAN Synbit and Dilsynbit, Light Sour Crude, Light Synthetic Crude, Light Sweet Crude, and Refined Product. This analysis states that (page 12): “Each product is associated with different petroleum properties and a different chemical composition. Bulk properties such as the product vapor pressure affect its tendency to vaporize and form fugitive emissions. The chemical composition of the products affects the relative abundance of each compound, such as BTEX, H2S, or mercaptans.”

Further, the air quality analysis approach is modified to assess emissions from each of these different product types (page 12): “The air quality assessment now uses six representative products: High TAN Dilbit and Low TAN Dilbit to represent super heavy grades, High TAN Synbit/Dilsynbit to represent heavy grades, light sour and synthetic/sweet grades, and ethanol blended gasoline (to represent iso-octane) to represent refined products. These products were selected to be conservatively representative for each listed category based on their high vapor pressure and BTEX, H2S and mercaptans contents.”

This change in air quality modelling approach appears to indicate that Trans Mountain’s consultant RWDI was sufficiently concerned about the varying properties of different Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 35 of 52

products carried by the pipeline that 6 different products were included to ensure that estimated emissions were “conservatively representative”.

Request:

The following additional assessments are requested: a) In light of the revised air quality modelling approach that now includes consideration of 6 different products [Reference (xi)] that will be transported by the Project, please provide an assessment of contaminants of potential concern (COPC) that may arise from these different product groups. Potential emissions of these COPC under normal operations and unplanned release should be estimated and compared to the emissions already reported for CLWB. Areas where COPC emissions differ significantly from those used in the air quality assessment that formed the basis of the Human Health Risk Assessments [References (i) through (viii)] should be noted and the implications of these differences discussed.

b) Should the assessment requested in (a) above indicate the potential for significantly greater emissions of COPC for products other than CLWB, please provide supplementary Human Health Risk Assessments for all project locations (i.e., pipeline, terminals, marine transportation) in which these emissions could occur. These assessments should follow approaches and methodologies employed in References (i) through (viii).

2.5.4 Human Health Risk Assessments: Diesel Particulate Matter References:

i) Attachment 6, Levelton Consultants (2007) Air Toxics Emission Inventory & Health Risk Assessment [http://www.metrovancouver.org/about/publications/Publications/Air_Toxics_Emis sion.pdf] ii) A4F5C9, B291-28 - Project and Technical Update No. 4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee iii) A3S2L1, Application Volume 5D, TR 5D-7 Screening Level Human Health Risk Assessment of Pipeline and Facilities Technical Report iv) A3S4X2, Application Volume 7, TR 7-3 Qualitative Human Health Risk Assessment of Westridge Marine Terminal Spills Technical Report v) A3S4R1, Application Volume 8B, TR 8B-8 Screening Level Human Health Risk Assessment of Marine Transportation Technical Report Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 36 of 52

vi) A3S4R2, Application Volume 8B, TR 8B-9 Qualitative Human Health Risk Assessment of Marine Transportation Spills – Marine Transportation Technical Report vii) A3Y1F4, B107-1 - Human Health Risk Assessment of Westridge Marine Terminal Technical Report viii)A3Y1E9, B106-1 - Human Health Risk Assessment of Facility and Marine Spill Scenario Technical Report ix) A3Y1F7, B108-1 - Human Health Risk Assessment of Marine Transportation Technical Report x) A3X6U1, B88-2 - Responses to Information Requests from Surrey Teachers' Association, Human Health Risk Assessment of Pipeline Spill Scenarios xi) Attachment 2, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, September 25, 2014, page 8, Action 28. xii) Attachment 3a, Draft Minutes of the Trans Mountain Expansion Project Air Quality Update to LFVAQCC meeting, November 13, 2014 – Excerpt 1: Introductions and Meeting Notes and Actions from September 25, 2014 meeting, page 6, Action 28.

Preamble:

Metro Vancouver’s 2007 “Air Toxics Emission Inventory & Health Risk Assessment” [Reference (i)] identified diesel particulate matter (DPM) as the single most significant contributor to lifetime cancer risks associated with ambient toxic air pollutant exposure in the Metro Vancouver region. Through meetings between Trans Mountain personnel and the Lower Fraser Valley Air Quality Coordinating Committee [LFVAQCC, References (xi) and (xii)] committee members requested that Trans Mountain compare the pollutants included in Reference (i) against those included in the Human Health Risk Assessments included in the Project application package [References (iii) through (x)].

DPM was not specifically indicated in any of the project human health risk assessments completed to date, but in response to the LFVAQCC request, Trans Mountain have provided an analysis specifically focused on DPM [Reference (ii), page 24-28]. This analysis does not include details on how DPM emissions estimates were derived, or an indication of whether new dispersion modelling was performed to estimate DPM concentrations. Further, the analysis includes tabular results only, with no mapping of predicted DPM concentrations associated with project operation.

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 37 of 52

Request:

Please provide: a) Details on the methods used to determine DPM emissions, including identification of all sources associated with the project expected to emit DPM, and their locations. If DPM estimates are based on existing project emissions inventories, please provide a reference to the project document that provided details of the inventory.

b) Details on the use of new or existing dispersion modelling used to determine the reported DPM concentrations. If existing modelling was employed, please provide a reference the project document that provided details of the modelling.

c) Concentration contour maps showing the modelled DPM concentrations graphically, similar to those provided for other pollutants in Appendix D of Reference (ii).

2.5.5 Human Health Risk Assessments: Ozone, Fine Particulate Matter and Nitrogen Dioxide

References:

i) A4F5C9, B291-28 - Project and Technical Update No. 4, Part 12, Follow-Up to Requests from the Lower Fraser Valley Air Quality Coordinating Committee ii) Attachment 7, Health Canada (2014) Health Canada’s response to the Request for Comments on Human Health Risks indicated by Environment Canada’s modelling of Trans Mountain Expansion (TMX) air emissions, November 27, 2014. iii) Attachment 8, Canadian Council of Ministers of the Environment (2007) Guidance Document On Continuous Improvement (CI) And Keeping-Clean- Areas-Clean (KCAC): Canada-wide Standards for Particulate Matter and Ozone. [http://www.ccme.ca/files/Resources/air/pm_ozone/1389_ci_kcac_e.pdf]

Preamble:

During meetings between Trans Mountain personnel and the Lower Fraser Valley Air Quality Coordinating Committee (LFVAQCC) on September 25, 2014, and December 8, 2014 [Reference (i)], Environment Canada made two presentations detailing results of photochemical modelling for the Lower Fraser Valley airshed. This modelling attempted Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 38 of 52

to assess the impacts of the Project on regional ozone, fine particulate matter (PM2.5) and nitrogen dioxide levels.

In response to a request from Environment Canada, Health Canada reviewed the photochemical modelling results referenced above and provided comments in a November 27, 2014 letter addressed to Environment Canada [Reference (ii)]. In this letter, Health Canada states: “To minimise human health effects of the TMX project, it would be advisable for the Proponent to support and commit to Keeping Clean Areas Clean and Continuous Improvement as its goals. As needed, Health Canada will work with Environment Canada to determine appropriate and specific mitigation measures to ensure that the TMX project aligns with the principle of Keeping Clean Areas Clean and Continuous Improvement. More information and guidance on this subject can be obtained from a 2007 Canada Council of Ministers of the Environment (CCME) publication entitled “Guidance document on Continuous Improvement (CI) and Keeping-Clean-Areas-Clean (KCAC)”. To look only at numerical targets of air quality guidelines is also not in keeping with the full intent of the Canada-Wide Standards, which urges jurisdictions to take remedial and preventative actions to reduce anthropogenic emissions to the extent practicable in areas where ambient levels are below the CWS but still above levels associated with observable health effects. Health Canada reiterates its view that there are no lower limits for health effects due to PM2.5, ozone and NO2 exposure.”

The publication “Guidance document on Continuous Improvement (CI) and Keeping- Clean-Areas-Clean (KCAC)” is available in Reference (iii).

Request:

Please provide: a) Details on how the project design and ongoing operational and maintenance programs will ensure alignment with the principals of Keeping Clean Areas Clean and Continuous Improvement and articulated in Reference (iii). The geographic focus for this response should be the Canadian Lower Fraser Valley, and should include pipeline facilities, terminal facilities, and marine shipping operations.

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 39 of 52

2.6 Socio-Economics

References:

i) A3S0R0, Volume 2 Project Overview, Economics and General Information, page 2-42 ii) A3S0R0, Volume 2 Project Overview, Economics and General Information, page 2-43

Preamble:

Reference (i) states that the operations phase will boost the Canadian GDP by at least $13.3 billion over the first 20 years.

Reference (ii) states that oil producers’ revenues are forecast to rise $45.4 billion over the first 20 years of the pipeline’s operation having access to new markets through the Project. Reference (ii) also states that this $45.4 billion revenue associated with higher netbacks is expected to generate total federal and provincial fiscal benefits of $14.7 billion, with Alberta receiving $8.2 billion and the federal government $6.1 billion.

Request:

a) Please indicate what portion of the benefits related to the operations phase of the Project stated in Reference (i) is due to: 1. production of crude/oil (upstream economic activities) 2. operation of the pipeline 3. access to (new) markets outside Canada (downstream).

b) Please indicate what portion of the $45.4 billion oil producers’ revenues stated in Reference (ii) are due to exports to Asia/Pacific markets (i.e. markets outside Canada). What is the estimated share of Canadian market averaged over the 20 years of the pipeline’s operation?

c) Please provide details for the estimation of total federal and provincial fiscal benefits of $14.7 billion stated in Reference (ii), including what portion of the $14.7 billion benefits are due to: 1. production of crude/oil (upstream economic activities) 2. operation of the pipeline 3. exports to (new) markets outside Canada (downstream).

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 40 of 52

2.7 Environment and Parks

2.7.1 Trenchless Construction in Parks and Greenways

References: i) A3Z1V1, Trans Mountain’s response to Metro Vancouver Motion B-209-2- Attachment – Table page 12, 13, and 14 ii) A3W7A9, Metro Vancouver IR1, page 9 iii) A3X5Y6, Trans Mountain Response to Chris Amy, IR1 page 13 (Filing ID A60789) iv) A3Z8G0, Technical Update No. 1 Routing Update Figure 2.2(Filing ID A62087)

Preamble:

Metro Vancouver understands that it would be possible to mitigate some of the environmental impacts on sensitive ecosystems and Metro Vancouver Regional Parks through the use of trenchless installation.

Reference (i) page 13, states: “With respect to the Brunette Fraser Greenway note that Trans Mountain intends to use trenchless installation from the east side of North Road to a point west of North Road and between the rail embankment and Highway 1 embankment. As such the railway provides separation from the Greenway on the complete length of the pipeline that was otherwise routed in Lougheed Highway.”

Reference (ii) page 9, states: “Brunette Avenue interchange, TM commits to consult with MV in the development of the Project’s construction schedule within….”

The figure in Reference (iv) is the current mapping of the Proposed Alternate Pipeline Corridor. The Brunette Fraser Greenway portion does not include detail (in the reference it is mapped at 1:50,000). The new alignment covers sections of the Brunette Fraser Greenway, Hume Park in New Westminster, and the newly constructed off- channel habitat (a sensitive ecosystem). It is possible that in planning for this area, all of the critical and sensitive ecosystems have been avoided, or that trenchless installation will be utilized to avoid having to mitigate for damages to this area, but the details are lacking.

Reference (iii) page 13 states that: Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 41 of 52

“At its closest point in the Central Valley Greenway, the proposed pipeline would be approximately 100 m from the Brunette River and separated from it by the CN Railway. ….the pipeline is planned to be installed using trenchless methods and on the preliminary design drill path the pipeline could be as close as 20 metres at its closest point to the Brunette River, but at that location the pipeline would be at least 20 metres below ground surface. The exact pipeline centerline will be determined during the detailed engineering and design phase.”

Figure 2.2-16 in Reference (iv), illustrating the Pipeline Corridor Revisions-Brunette Valley/Lougheed Highway, shows the proposed Revised Pipeline Corridor north of the CN Rail line only for approximately half of the distance between North Road and where it crosses Highway #1. Reference (i) page 13, states that “the railway provides separation from the Greenway on the complete length of the pipeline that was otherwise routed in Lougheed Highway.” This statement seems to contradict the most recent mapping supplied by Trans Mountain. If the pipeline does drop south of the CN rail line, there are additional concerns with respect to impacts on the Brunette River, fish enhancement projects and the Brunette Fraser Greenway Trail.

Request:

a) Please provide detailed mapping (at 1:2000) as opposed to the 1:50,000 currently provided, including the location of trenchless installation/construction and details of where the entry and egress to the trenchless construction would be staged.

b) Please confirm whether the trenchless installation will be above or below ground in the construction between the rail embankment and Highway 1.

c) Please confirm whether the trenchless installation will avoid the recently restored habitat along the Brunette River in Hume Park.

d) Please confirm if there will there be trenchless installation in the recently constructed off-channel habitat across Columbia Street also along the Brunette River.

e) Please confirm, if this area is within the trenchless installation, the depth below ground of the installation in the region of Holmes/Lost Creek.

f) Please clarify the apparent anomaly between Figure 2.2-16 in Reference (iv), and Reference (i) page 13.

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 42 of 52

g) As discussed in Reference (iii), please confirm if the trenchless installation will be extended throughout most of the proposed pipeline location where it is near the Brunette Fraser Greenway.

2.7.2 Proposed Route Alignment and Impacts on Sensitive Ecosystems

References:

i) A3Z1V1, Trans Mountain’s response to Metro Vancouver Motion B-209-2- Attachment – Table page 12, 13, and 14 ii) A3S2S1, A3S2S3, A3S2S4, A3S2S6, A3S2S7, Application by Trans Mountain For Approval Of The Trans Mountain Expansion Project. Volume 6A, 6B, 6C iii) A3Z8G0, Technical Update No. 1 Routing Update Figure 2.2 (Filing IDA62087) iv) A3W7A9, Metro Vancouver Information Request No. 1, Dated May 9, 2014. page 22 of 106 v) A4A4E2, Trans Mountain Pipeline ULC – Technical Update #2 – Part 1 of 2 (File # A62400) B255-32, 33, and 34. Preliminary Marine Fish Habitat Offsetting Plan; Part 5 Wetlands WL of Concern, Part 01 and A4A4E5, Part 6 WL of Concern Part 02 vi) A4F4Z3, Environmental and Socio-economic Assessment 2014 Update for the Trans Mountain Pipeline ULC Trans Mountain Expansion Project (Dec. 1, 2014 Filed by Tera Environmental Consultants (page A-12) vii) A3X6A5, Response to City of Surrey IR No. 1.1a viii)A3Y2V0, Response to Metro Vancouver IR No. 1.15.02d ix) A3Y3X2, Response to Matsqui IR No. 1.02h

Preamble:

Metro Vancouver has reviewed References (i) to (vi) to seek more detailed routing alignment for the Brunette River region in New Westminster and Burnaby. More detailed mapping requests were made on October 1, 2014, at a meeting between Trans Mountain and Metro Vancouver. Specifically, mapping was requested for the alternative pipeline proposal routing adjacent to and crossing the Upper and Lower Brunette River.

The figure (map) in Reference (iii) is the current mapping of the Proposed Alternate Pipeline Corridor. The same routing is shown in the Update of December 1 [Reference (vii)], depicting coverage of a large swath of land including both the Upper and Lower Brunette River, the Brunette Fraser Greenway, Ministry of Transportation and Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 43 of 52

Infrastructure’s Enhancement Fisheries project (Holmes Creek), and Hume Park (New Westminster).

It is noted that Upper and Lower Brunette River and the riparian zones are still not listed or classified as a sensitive ecosystem in the wetland mapping [Reference (v)]. There are species listed under the Species at Risk Act (SARA) in this region of the Brunette River Greenway.

Another area of concern is the region north of the Brunette River between Holmes and Lost Creeks. This area has been the subject of an extensive habitat restoration project over the past three years, and the new off-channel habitat has just been completed. Monitoring of species success was completed during 2014 and two SARA-listed species of fish were found in the Brunette River and its off-channel habitat. Although Nooksack Dace are identified in Reference (iii), the other species does not appear to be identified or discussed in the Environmental and Socio-economic Assessment 2014 Update for the Trans Mountain Pipeline ULC Trans Mountain Expansion Project (Dec. 1, 2014) [Reference (vi)].

Routing in the area of Surrey Bend Regional Park continues to be a concern for the City of Surrey, Metro Vancouver and the Transportation Investment Corporation within Surrey Bend Regional Park.

Request:

a) Metro Vancouver requests more detailed mapping (at 1:2000) and environmental assessment detail for the Brunette Fraser Greenway region including more detailed mitigation and compensation plans. There have been extensive restoration projects undertaken between 2011 and 2014 by the Transportation Investment Corporation and Metro Vancouver including extensive riparian planting. Consistent with current standards, Metro Vancouver has been using native species, and a mix to support native pollinators. Please provide detailed plans for restoration, maintenance and stewardship of these areas so that there is no net loss of the ecological values that these projects provide.

b) Brunette River and Hume Park have recently undergone extensive restoration work, undertaken by the City of New Westminster, community groups, and Metro Vancouver. Please provide more detailed mapping and environmental assessment details of mitigation and compensation planning, which are required for this sensitive ecosystem included in the New Westminster Brunette Conservation Area. Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 44 of 52

c) For the region north of the Brunette River between Holmes and Lost Creeks, please confirm that there will be better planning for the endangered species in this sensitive ecosystem and provide details on this planning. d) Metro Vancouver is concerned that the implications of locating the pipeline outside of Surrey Bend Regional Park and within a corridor made up of the South Fraser Perimeter Road Corridor, the Golden Ears Connector Corridor and the CN Rail Corridor have not been adequately explored by Trans Mountain. Trans Mountain has referenced its rejection of a pipeline route down its existing Right of Way in the area due to impacts on residential neighbourhoods but has not discussed the option noted above. If the South Fraser Perimeter Road option has been fully explored, please provide the criteria used in the evaluation and the reason for its rejection as the preferred route. e) In Reference (i), the response to the Notice of Motion filed by Metro Vancouver respecting options for construction of the pipeline through Surrey Bend Regional Park, it is stated that horizontal directional drilling was not considered due to length limitations and the lack of space for temporary works. At a meeting between Metro Vancouver and Trans Mountain staff on October 1, 2014 focusing on engineering and utility issues, Trans Mountain staff stated that there are a number of options that could be considered to minimize the impact on Surrey Bend Regional Park including horizontal directional drilling and it was suggested that such options could be more fully explored at a technical workshop. Given the apparent contradiction in the two responses, please confirm whether pipeline construction options that may reduce visual and physical impacts on Surrey Bend Regional Park are feasible and under consideration. f) With respect to possible options for a pipeline corridor through Surrey Bend Regional Park, Reference (i), Trans Mountain’s July 11, 2014 response to the Notice of Motion filed by Metro Vancouver, noted that vegetation height would be restricted within the right-of-way through the park. Given that Surrey Bend is a strongly conservation-oriented park with limited access points and trails so as to protect natural values, please provide information on the measures Trans Mountain will incorporate in its right-of-way construction to ensure that the route does not become an unwanted trail corridor that compromises the ecological integrity of the park.

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 45 of 52

2.7.3 Seismic concerns

References:

i) A3Y2V0, Trans Mountain Response to Metro Vancouver IR No. 1, page 60 ii) A4F5F0, Trans Mountain Pipeline ULC, TMEP Westridge Tunnel Investigation 2014 Site Investigation Data Report (November 26, 2014) Appendix H SFU Geology Letter Report) iii) A3X5Y6, Trans Mountain Response to Chris Amy, IR1 page 13, section u) (Filing ID A60789) iv) A4F4Z3, Environmental and Socio-economic Assessment 2014 Update for the Trans Mountain Pipeline ULC Trans Mountain Expansion Project (Dec. 1, 2014)

Preamble:

An up-to-date summary of earthquake risks was requested by Metro Vancouver in Reference (i), concerning the risks to the supplementary tanks location for both construction and operations. In the response [Reference (i), page 60], Trans Mountain indicated that: “a study of the potential activity of faults crossing the proposed route in the Lower Mainland and Fraser Valley has been commissioned by Trans Mountain, and is currently being undertaken by Drs. John Clague and Doug Stead of the Department of Earth Sciences at Simon Fraser University.”

In Reference (iii), page 13, it is stated that: “No, seismic studies have not been conducted along the Brunette River. Geotechnical investigation to support horizontal directional drilling (HDD) along the route will be undertaken in 2014. ….”

Request:

Reference (ii) provided seismic analysis for Burnaby Mountain, but not for the Lower Mainland and Fraser Valley. Please provide the response that was outlined above in Reference (i) and further details that were mentioned in Reference (iii), regarding geotechnical investigation to be undertaken in 2014 to support horizontal directional drilling along the route, as this information does not appear to be included in Reference (iv).

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 46 of 52

2.7.4 Species at Risk

References:

i) A3X6A5, Trans Mountain Response to City of Surrey IR No. 1.1a ) ii) A3X5Z6, Trans Mountain Response to City of New Westminster IR No. 1 –(page 3 (d) and (e)) iii) A3Y2V0, Trans Mountain Response to Metro Vancouver IR No. 1 iv) A4F4Z3, Environmental and Socio-economic Assessment 2014 Update for the Trans Mountain Pipeline ULC Trans Mountain Expansion Project (Dec. 1, 2014 Filed by Tera Environmental Consultants (Page A-12)

Preamble:

In Reference (i), the Trans Mountain response to Surrey’s IR1, it is stated that: “A wildlife crew was in the area of Surrey Bend Regional Park in summer 2014 to review selected areas for the occurrence of biophysical attributes of critical habitat for Pacific water shrew….etc.”

In the Brunette River basin, Metro Vancouver operates the Brunette Fraser Greenway, which at a certain point crosses New Westminster’s Hume Park. Metro Vancouver and New Westminster have worked together to protect, enhance and restore the riparian habitat along this section of the Brunette River. Further upstream, a number of tributaries to the Brunette River including Still Creek, Eagle Creek, and Stoney Creek also provide valuable salmon habitat and have undergone extensive restoration to create and restore riparian habitat. Many other organizations have been involved in the restoration and enhancement of this resource that brings salmon into highly developed urban areas, where they had been severely reduced or absent for decades.

The integrity of the sensitive ecosystem at Brunette Fraser Greenway was raised by City of New Westminster in their first IR [Reference (i)] and by Metro Vancouver in their first IR [Reference (ii)]. Extensive enhancement works have occurred in both the Upper and Lower Brunette. This information is relevant to both Trans Mountain and to the National Energy Board process, and relevant to Metro Vancouver as a landholder in this vicinity. It will potentially also affect City of Burnaby, City of New Westminster and Port Metro Vancouver as well as indirectly affect City of Vancouver (Still Creek is within the Brunette Water Basin).

Further, the Brunette River system has one of the highest concentrations of the endangered Nooksack Dace, and much work has focused on this species and attempts to use the Recovery Strategy for Nooksack Dace in planning the habitat enhancements. Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 47 of 52

Hundreds of thousands of dollars and innumerable hours by dedicated volunteers could be put at risk by route choices for the Brunette corridor that do not take Species at Risk into careful consideration.

Request:

a) Please provide information on the planning for treatment of species of interest and the sensitive ecosystem of Surrey Bend.

b) Please provide copies of the biophysical field surveys conducted in Metro Vancouver’s regional parks as part of Trans Mountain’s assessment process. This information is needed to facilitate the thorough discussion of issues in the park-specific technical workshops proposed by Trans Mountain.

c) Based on Metro Vancouver’s review of Reference (iv) we are unable to find any reference to the Brunette River identifying this conservation area as one of the sensitive ecosystems. It is, however, identified in this reference as a unique vegetation ecosystem. It contains SARA-listed species. Metro Vancouver requests information as to why this is not listed as a Wetland (WL) of significance, despite its protection or the species of interest, and how Trans Mountain will be compensating Metro Vancouver for any loss of this sensitive ecosystem, or mitigating any damage to the habitat or threatened and endangered species.

d) Reference (iv) (p.32) does not identify or further discuss the two SARA listed fish species that were found to be present in the summer of 2014 by fisheries biologists. Please provide this information.

e) Post- construction monitoring will likely be in locations of high value wildlife habitats (e.g. select wetlands, sensitive areas, locations where there is high potential for species at risk). Please provide information on the plans for post- construction monitoring and/or compensation in the Brunette River Greenway, which is still not identified as a wetland (WL) of concern in Reference (iv) above.

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 48 of 52

2.7.5 Invasive Species

References:

i) Attachment 9, [Extracts from] Website of the Invasive Species Council of Metro Vancouver http://www.iscmv.ca

Preamble:

Within the riparian habitat of the Brunette River corridor, invasive species have been the focus of extensive removal and continued treatment. Most of the invasive species were likely introduced throughout development along the Brunette River many years ago when less attention was given to the introduction and control of invasive species.

If the Project is approved, during the construction and post-construction phases, it will be very important to keep up with the removal, maintenance and monitoring of invasive species, and careful replanting of native species in order to ensure long term viability of the native species.

Request:

For the sensitive ecosystem of the Brunette corridor, please provide a detailed species planting program, in addition to maintenance and monitoring plans for the post- construction phase including detailed plans for eradication of invasive species currently present and planning for post-construction removal of invasive species.

2.7.6 Mitigation and Compensation

References:

i) A3Y2V0, Trans Mountain’s response to Metro Vancouver IR 1.5.07(1) pages 70 – 72) ii) A3S2S1, A3S2S3, A3S2S4, A3S2S6, A3S2S7, Application by Trans Mountain For Approval Of The Trans Mountain Expansion Project. Volume 6A, 6B, 6C iii) A3Z1V1, Trans Mountain Response to Metro Vancouver Round 1 Intervenor IR Motion (page 23 and page 25)

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 49 of 52

Preamble:

Reference (i) states that: “The results of the additional surveys….and will be used to provide further details to the Environmental Protection Plans. Any additional site-specific mitigation measures resulting from these studies will be provided in the updated Environmental Protection Plans to be filed with the NEB a minimum of 90 days prior to the commencement of construction as per NEB Draft Conditions No. 29 to 31 of the NEB’s Letter – Draft Conditions.”

Reference (ii) states that: “the Project will not have a significant adverse effect on any biophysical or socio- economic element, provided the proposed mitigation measures are implemented”.

Reference (iii), in response to Metro Vancouver’s information requests regarding the Expert Advisory Panel states: “Trans Mountain will consider the Expert Advisory Panel as a community benefits initiative and seek feedback from other groups and communities on its perceived value and priority relative to other social, cultural and environmental proposals.”

In Reference (ii), page 25 it states: “Consequently, although operation of the pipeline will not result in a reduction of use or amount of publicly owned greenspace, the vegetation community along the operating right-of-way may be altered to allow operational access for pipeline integrity. To minimize alterations to existing vegetation, reclamation plants and seed mixes will be selected for compatibility with recreational use and ecology function.”

Trans Mountain Response to Metro Vancouver IR 1 [Reference (i)] states that: “TM is committed to investing in community benefits initiatives in municipalities and regions affected by the Project. Trans Mountain intends to contribute to community benefits in communities where it operates and has initiated discussions with local governments and organizations to explore community benefit opportunities related to its priority areas of environment, safety, emergency preparedness and response…..”

Compensation should be considered, in collaboration with Metro Vancouver, to improve the aquatic and riparian habitat of the Brunette River along the Brunette Fraser Greenway. Considerable funds have been expended along the Brunette River, both Upper Brunette and Lower Brunette, in the Holmes and Lost Creek area, the Hume Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 50 of 52

Park area and the Lower Brunette River. If there is no opportunity for compensation, then consideration should be given to ensuring that the entire portion that affects this Regional Greenway is trenchless installation.

Request:

a) The development and funding of an Expert Advisory Panel to monitor effects and provide oversight on cumulative effects should not be considered a community benefit initiative but should form a core component of the mitigation and monitoring plan for this Project. Please confirm that Trans Mountain will form an Expert Advisory Panel on the Marine Environment for Burrard Inlet with a mandate to advise the Project on mitigation and compensatory requirements related to construction and operation.

b) Please confirm Trans Mountain’s commitment to no net loss, and to maintaining full access within the Metro Vancouver Brunette Fraser Greenway. Please also confirm Trans Mountain’s commitment to discuss this in detail with the respective municipalities in addition to Metro Vancouver Regional Planning and Regional Parks Planning staff to ensure long-term viability of this corridor.

c) Please provide a list of compensatory agreements established with other community groups, and Trans Mountain’s confirmation that it will meet with Metro Vancouver Regional Parks and Regional Planning staff to discuss appropriate compensation for routing along the Brunette Fraser Greenway, and in Surrey Bend Regional Park. If routing should be changed to have any impacts upon Colony Farm Regional Park, it should also be included in these discussions.

2.7.7 Cumulative Impacts

References:

i) A3W7A9, Metro Vancouver Information Request No. 1, Dated May 9, 2014 ii) A3Y2V0, Trans Mountain Response to Metro Vancouver IR No. 1 (pages 71 and 72) iii) A3Z1V1, Trans Mountain Response to Metro Vancouver Round 1 Intervenor IR Motion (page 23 and page 25) iv) A3V6I2, Hearing Order, Appendix I, page 18: List of Issues. v) A3S0Q7, Project Application, Volume 1, Section 3.2.6, pages 1-66 – 1-67

Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 51 of 52

Preamble:

Reference (iv) identifies as Issue #5: The potential environmental and socio-economic effects of marine shipping activities that would result from the proposed project, including the potential effects of accidents or malfunctions that may occur.

Reference (v) states that: “Ship-related sensory disturbance will continue throughout the operations phase, however, animals affected by vessels will recover immediately after a vessel passes by. Sensory disturbance is concluded to be of low to medium magnitude and not significant for humpback whale and Steller sea lion.”

In general, the concerns that have been identified are with the cumulative impacts of increasing the marine shipping activities that will occur as a result of the increased traffic from the Westridge Terminal. The cumulative impacts of other port development and expansion in the Port of Vancouver, Deltaport and Roberts Bank Terminal 2 will also add significant marine traffic to the Salish Sea.

In Reference (i), Metro Vancouver suggested the development and funding of an Expert Advisory Panel with local marine experience in environmental monitoring, sampling and measurement to examine the potential for cumulative effects of increased activity (shipping and near shore development) in the Burrard Inlet and Salish Sea.

In Reference (iii), this was dismissed as beyond what is relevant, given the scope of the defined project and the NEB’s List of Issues. It is recognized that the proposed increase in shipping through the Burrard Inlet and Salish Sea that will result from the Project will be significant, adding approximately 14% to the existing shipping. The response states, “Trans Mountain will consider the Expert Advisory Panel as a community benefits initiative…..”

Request:

a) As noted in 2.7.6 above related to mitigation and compensation, please confirm that Trans Mountain will include development and funding for a multi-stakeholder Expert Advisory Panel on the Marine Environment for Burrard Inlet as a core component of the proponent commitments. This Panel could assist with consideration of cumulative effects of the Project, monitoring programs to measure the effects of construction and operations of Westridge and the increase in tankers in Burrard Inlet, emergency preparedness, spill response, and long term adaptive management that could be required particularly in the case of a worst case scenario. Trans Mountain Expansion Project File Number OF-Fac-Oil-T260-2013-03 02 Ref: Hearing Order OH-001-2014 Metro Vancouver Information Request No.2 Dated January 16, 2015 Page 52 of 52

b) There is still no clear answer to the questions that were raised in Reference (iii) regarding the cumulative effects of surface and subsurface disturbances from the hundreds of additional tankers to the aquatic life and marine mammals that frequent Burrard Inlet and Salish Sea including the Southern Resident Killer Whale population that is SARA listed. Please provide this information.