CONTAMINATION IDENTIFICATION AND ASSESSMENT PLAN FOR THE TRANS MOUNTAIN PIPELINE ULC TRANS MOUNTAIN EXPANSION PROJECT NEB CONDITION 46
August 2017 REV 4 687945 01-13283-GG-0000-CHE-RPT-0036 R4
DRAFT for Review
Trans Mountain Pipeline ULC Kinder Morgan Canada Inc. Suite 2700, 300 – 5th Avenue S.W. Calgary, Alberta T2P 5J2 Ph: 403-514-6400
Trans Mountain Pipeline ULC Contamination Identification and Assessment Plan Trans Mountain Expansion Project 687945/August 2017
TABLE OF CONCORDANCE National Energy Board (NEB) Condition 46 is applicable to the following legal instruments: OC-064 (CPCN), AO-003-OC-2 (OC2), AO-002-OC-49 (OC49), XO-T260-007-2016 (Temp), XO-T260-008-2016 (Pump 1), XO-T260-009-2016 (Pump 2), XO-T260-010-2016 (Tanks) and MO-015-2016 (Deact). Table 1 describes how this Plan addresses the Condition requirements applicable to Project activities.
TABLE 1
LEGAL INSTRUMENT CONCORDANCE WITH NEB CONDITION 46: CONTAMINATION IDENTIFICATION AND ASSESSMENT PLAN
OC-064 AO-003-OC-2 (OC2) AO-002-OC-49 XO-T260-007-2016 XO-T260-008-2016 XO-T260-009-2016 XO-T260-010-2016 MO-015_2016 NEB Condition 46 (CPCN) (OC49) (Temp) (Pump1) (Pump2) (Tanks) (Deact) Trans Mountain must file with the NEB for approval, at least 4 months prior to Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan commencing construction, a Contamination Identification and Assessment Plan that includes: a) a description of the procedures that have been implemented to-date, and that will be implemented prior to or during construction, to identify and assess pre-existing solid, liquid or gaseous contamination that could be disturbed by, or affect, the Project, including whether site investigations have been or will be undertaken; b) a demonstration of the adequacy of the procedures in a) with reference to Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this relevant standards, guidelines, and best practices, including how historical Plan Plan Plan Plan Plan Plan Plan Plan land use has been taken into account and discussion of the potential for chemicals of concern to not be detectable by smell or by sight; c) the information that has been or will be reported by Trans Mountain, Section 6.0 of this Plan Section 6.0 of this Plan Section 6.0 of this Plan Section 6.0 of this Plan Section 6.0 of this Plan Section 6.0 of this Plan Section 6.0 of this Plan Section 6.0 of this Plan including to whom and when, concerning the pre-existing contamination; d) a summary of its consultation with Appropriate Government Authorities, Section 2.0 of this Plan Section 2.0 of this Plan Section 2.0 of this Plan Section 2.0 of this Plan Section 2.0 of this Plan Section 2.0 of this Plan Section 2.0 of this Plan Section 2.0 of this Plan potentially affected Aboriginal groups and affected landowners/tenants. In its summary, Trans Mountain must provide a description and justification for how Trans Mountain has incorporated the results of its consultation, including any recommendations from those consulted, into the plan; and e) confirmation that Trans Mountain will update the relevant Environmental Section 1.0 of this Plan Section 1.0 of this Plan Section 1.0 of this Plan Section 1.0 of this Plan Section 1.0 of this Plan Section 1.0 of this Plan Section 1.0 of this Plan Section 1.0 of this Plan Protection Plan(s) to include any relevant information from the Contamination Identification and Assessment Plan.
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EXECUTIVE SUMMARY The Contamination Identification and Assessment Plan (the Plan) was prepared to meet National Energy Board (NEB) Condition 46 regarding the Trans Mountain Expansion Project (“the Project” or “TMEP”). This Plan was completed to ensure appropriate handling of contamination to protect workers, public and the environment and demonstrates Trans Mountain Pipeline ULC’s (Trans Mountain’s) commitment to mitigate potential risk from exposure to pre-existing contamination from disturbed soil and/or water that could be disturbed by, or affect, the Project. This Plan outlines the identification and assessment of pre-existing areas of potential contamination within the Project Footprint, including procedures for managing contamination identified in the additional searches completed to update the preliminary inventory of potentially contaminated sites (TERA Environmental Consultants [TERA] 2013a) (CIPCS). Relevant standards, guidelines, and best practices to be followed during the construction works are included in this Plan.
In conjunction with the preparation of this Plan, additional works were completed to update the CIPCS and to create an updated inventory of potentially contaminated areas located within, or immediately adjacent to the Project Footprint. Properties reviewed were characterized as resulting in a low, moderate, or high risk for encountering contamination within the Project Footprint. A total of 40 areas were classified as moderate risk and four areas were classified as having a high risk.
In order to determine if adequate characterization information was available for areas ranked as high risk, previously collected data was evaluated for specific properties, where available. The four high risk areas include portions of the Project Footprint which crosses through the former University of Alberta Ellerslie Waste Management Facility in Edmonton (KP 26.3 to KP 26.8) in Alberta (AB), Kamloops Airport (KP 840.9 to KP 841.5), Surrey/Langley area (KP 1154.8 to KP 1157.9) and City of Coquitlam (KP 1168.7 to KP 1173.1) in British Columbia (BC). Through this data review, it was determined three individual properties within the identified high risk areas require subsurface intrusive investigation prior to construction to develop construction mitigation plans. These three properties are located in the Surrey/Langley area (two properties) and City of Coquitlam (one property).
A Contamination Resource Specialist (Resource Specialist) will ensure the appropriate response and mitigation is carried out during construction in high risk areas. When working in areas of moderate risk, the Environmental Inspector will ensure workers are aware of the potential to encounter contamination. In the event unexpected contamination is encountered the Contamination Discovery Contingency Plan (Appendix B of the Environmental Protection Plans [EPPs]) will be initiated, and a Resource Specialist will direct response activities.
The Project will be constructed along several third-party properties with various current and historical activities, which may have resulted in impacts to soil, groundwater, vapour, and/or sediments. Trans Mountain will notify the NEB and the owner of the property should impacts in these areas be identified prior to, or during, construction works. Trans Mountain will ensure contaminated waste material encountered during construction within the pipeline construction footprint is tracked and managed appropriately. Should impacts be identified on Trans Mountain properties, Trans Mountain will address them according to the guidance provided in the NEB Remediation Process Guide (2011).
Trans Mountain has initiated consultation and will continue to work with Appropriate Government Authorities, landowners, and any potentially affected Aboriginal groups to ensure issues concerning contamination are addressed. Trans Mountain has also provided responses to Information Requests (IRs) on issues related to potential contamination as a result of the NEB hearing process.
This Plan is part of the Environmental Management Plans (Section 3.0 of Volume 6 of the Environmental Plans) to ensure that the applicable procedures for managing contamination are followed, and where necessary, the applicable mitigation measures are implemented. In addition, pertinent information from this Plan will be used to update the Project-specific EPPs (Volumes 1 through 5, 9 and 10 of the Environmental Plans).
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TABLE OF CONTENTS Page TABLE OF CONCORDANCE ...... i EXECUTIVE SUMMARY ...... ii 1.0 INTRODUCTION ...... 1 1.1 Project Description ...... 1 1.2 Objectives ...... 2 1.3 Links to other Trans Mountain Environmental Plans ...... 2 1.4 Commitments Management ...... 4 2.0 CONSULTATION AND ENGAGEMENT ...... 5 3.0 PROJECT INTERACTIONS ...... 6 4.0 CONTAMINATED AREAS IDENTIFICATION AND ASSESSMENT APPROACH ...... 8 4.1 Environmental and Socio-Economic Assessment ...... 8 4.2 Inventory of Potentially Contaminated Sites ...... 8 4.3 Desktop Phase I Environmental Sites Assessments ...... 9 4.4 Update to the Inventory of Potentially Contaminated Sites ...... 9 4.5 Contamination Risk Classification ...... 10 4.6 Updated List of Moderate or High Risk Areas ...... 11 4.7 Pre-Construction Environmental Site Investigation ...... 15 4.7.1 Environmental Site Investigations on High Risk Sites ...... 15 4.7.2 Coquitlam Landfills High Risk Area ...... 18 4.7.3 Third-Party Properties ...... 18 5.0 PROCEDURES FOR MANAGING CONTAMINATION DURING CONSTRUCTION...... 20 5.1 Contamination Management Responsibilities ...... 20 5.2 Management of Contaminated Materials ...... 22 5.2.1 Soil ...... 22 5.2.2 Water ...... 27 5.2.3 Ambient Air Vapour and Landfill Gas Monitoring ...... 29 5.2.4 Waste Disposal ...... 29 5.2.5 Transportation of Waste ...... 29 5.2.6 Contingency Planning ...... 30 6.0 MONITORING AND REPORTING ...... 31 6.1 Monitoring ...... 31 6.1.1 Excavation Monitoring ...... 31 6.1.2 Material Tracking...... 31 6.2 Notification ...... 32 6.3 Reporting ...... 33 7.0 RELEVANT STANDARDS, GUIDELINES AND PRACTICES...... 34 7.1 Federal Guidance and Regulatory Policy ...... 34 7.2 Provincial Guidance and Regulatory Policies ...... 34 8.0 SUMMARY ...... 36 9.0 REFERENCES ...... 37
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LIST OF APPENDICES Appendix A TMEP Management of Pre-Existing Contamination Flow Chart ...... A-1 Appendix B Consultation and Engagement ...... B-1 Appendix C Listing of Reports Reviewed as Part of High Risk Sites Assessment ...... C-1 Appendix D Summary of High Risk Sites Desktop Assessment ...... D-1 Appendix E Summary of High Risk Sites Intrusive Assessments ...... E-1 Appendix F Record of Stakeholder Notifications of Plan ...... F-1 Appendix G Aboriginal Groups Identified for Consultation Regarding the Contamination Identification and Assessment Plan ...... G-1
LIST OF FIGURES Figure 1 High Risk Contaminated Areas - Edmonton ...... D-7 Figure 2 High Risk Contaminated Areas - Kamloops Area ...... D-8 Figure 3 High Risk Contaminated Areas - Surrey and Langley Area...... D-9 Figure 4 High Risk Contaminated Areas - Coquitlam East ...... D-10 Figure 5 High Risk Contaminated Areas - Coquitlam West ...... D-11
LIST OF TABLES Table 1 Legal Instrument Concordance with NEB Condition 46: Contamination Identification and Assessment Plan ...... i Table 2 Trans Mountain Plans Linked to this Plan ...... 3 Table 3 Updated Inventory of Potentially Contaminated Moderate or High Risk Sites within Project Footprint ...... 11 Table 4 Properties within Identified High Risk Areas ...... 14 Table 5 Soil Sampling Approach Summary ...... 26 Table 6 Typical PCOCs Associated with Site Activities ...... 27 Table 7 PCOCs and Applicable Media ...... 27 Table B-1 Summary of Public Consultation - May 2012 to June 30, 2015* ...... B-2 Table B-2 Summary of Government Authority Consultation Activities Related to the Plan (May 2012 to June 2015) ...... B-4 Table B-3 Summary of Government Authority Consultation Activities Related to the Plan (July 2015 to February 2017) ...... B-5 Table B-4 Summary of Aboriginal Issues and Concerns Related to Contamination ...... B-7 Table F-1 Record of Notification ...... F-1
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1.0 INTRODUCTION The Contamination Identification and Assessment Plan (the Plan) was prepared to meet National Energy Board (NEB) Condition 46 regarding the Trans Mountain Expansion Project (“the Project” or “TMEP”). The Plan was submitted to Appropriate Government Authorities, potentially affected Aboriginal groups and affected landowners/tenants in November 2016 for a review and feedback period, which concluded in February 2017. Trans Mountain incorporated any feedback received into the final Plan or has provided rationale for why input has not been included, as summarized in Appendix B.
Since the November 2016 release of the draft Plan, engineering design has continued to progress and there have been design updates that are described in detail in TMEP Fall 2016 Project Updates (www.transmountain.com/environmental-plans). All of the design updates have been reviewed, and the relevant Project design updates have been incorporated into this Plan. It is anticipated that route refinement will continue to occur as engineering design progresses, though future changes are anticipated to be minor in nature. Subsequent changes will be reviewed in consideration of impacts to this Plan.
This Plan outlines the identification and assessment of areas of potential contamination along the Project Footprint. This Plan will be part of the Environmental Management Plans (Section 3.0 of Volume 6 of the Environmental Plans) to ensure that the applicable procedures for managing contamination are followed, and where necessary, the applicable mitigation measures are implemented. In addition, pertinent information from this Plan will be used to update the Project-specific Environmental Protection Plans (EPPs) (Volumes 1 through 5, 9 and 10 of the Environmental Plans).
1.1 Project Description Trans Mountain filed its Facilities Application (the Application) with the NEB in December 2013. In developing its Application, Trans Mountain Pipeline ULC (Trans Mountain) commenced an engagement and communications program of extensive discussions with landowners, engagement with Aboriginal groups and consultation with affected stakeholders. This program was intended to gather input from these groups into the Application and supporting Environmental and Socio-economic Assessment (ESA), and to continue to assist Trans Mountain in the design and execution of the Project. Trans Mountain is also working with Appropriate Government Authorities to carry out the necessary reviews, studies and assessments required for the Project.
For ease of description, the following terms are used.
Kilometre Post (KP): describes distances measured along the centreline of the pipeline.
Project Footprint: includes the area directly disturbed by surveying, construction, clean-up and operation of the pipeline, as well as associated physical works and activities (including the temporary construction lands and infrastructure, the pipeline, reactivation, facilities, the Westridge Marine Terminal, and access roads). For clarity, specific components of the Project Footprint are further described by Trans Mountain below.
• Temporary construction lands and infrastructure refers to preparatory works to be undertaken prior to Project construction and includes temporary camps, stockpile sites, equipment staging areas and borrow pits located on land that has been previously disturbed, as well as access roads within the first 10 km of each designated construction spread. For ease of assessing Project interactions, these access roads were considered as part of the overall access road network.
• Pipeline construction footprint refers to the total area used to construct the pipeline and includes the right-of-way and temporary workspace.
• Reactivation of currently deactivated pipeline segments include engineering assessment under Section 45 of the National Energy Board Onshore Pipeline Regulations and associated construction activities. Currently known ground disturbance activities and associated access (as of December 2016), were assessed to determine the Project interactions. For ease of assessing Project interactions, these access roads were considered as part of the overall access road network.
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• Facilities refer to pump stations, terminals (Edmonton, Sumas, and Burnaby), and associated infrastructure (i.e., traps), most of which are located on land that has been previously disturbed. Westridge Marine Terminal has infrastructure located on land and in the marine environment, and is included in the Facilities component of the Project.
• Access roads include new temporary and permanent roads and existing roads that may require upgrades or improvements. For ease of assessing Project interactions, this includes the access roads to be developed as part of temporary construction lands and infrastructure, as well as those accesses associated with reactivation.
Contingency Alternate Routes: refers to three alternate pipeline routes segments that have been assessed for use if construction on the preferred route is not feasible. These are not included in the Project Footprint since they are considered contingency alternates, however these have been assessed as part of the assessment for contaminated areas that may impact the project.
• Raft River, in BC (KP 713.1 to KP 714.4), is an alternate open cut contingency alignment. The preferred primary crossing method, a horizontal directional drill (HDD), does not support an open cut contingency crossing method at the same location.
• Pembina River, in Alberta (KP 133.0 to KP 134.7), is an alternate open cut contingency alignment. Similar to Raft River, the preferred primary crossing method (HDD) does not support an open cut contingency crossing method at the same location.
• Westridge Delivery Lines (WDL KP 0.0 to WDL KP 3.4) is an alternate contingency alignment for a trenched installation around the Burnaby Conservation Area in BC. The preferred pipeline corridor requires tunnel construction and does not support a trenched contingency option; therefore, an alternate trenched contingency alignment has been identified.
Variances: as part of the Project Footprint update that occurred in December 2016, a number of route revisions located outside of the Project corridor were identified. Trans Mountain is in the process of seeking approval from the NEB in 2017 for these route realignments. All of the variances have been reviewed in consideration of impacts to this Plan and revisions have been incorporated.
1.2 Objectives This Plan demonstrates Trans Mountain’s commitment to appropriately manage and mitigate potential risk from exposure to pre-existing contamination in soil and/or water that could be disturbed by, or affect, the Project. The Plan outlines the identification and assessment of pre-existing areas of potential contamination within the Project Footprint and incorporates an update to the preliminary inventory of potentially contaminated sites (TERA Environmental Consultants [TERA] 2013a) (CIPCS). The Plan has the following objectives:
• to determine if pre-existing contamination is present;
• to provide details on reporting of pre-existing contamination;
• to provide mitigation to update the EPPs that incorporates relevant information as specified in this Plan and its supporting documentation; and
• to provide a risk rating for potentially contaminated areas located within the Project Footprint. Relevant standards, guidelines, and best practices to be followed during the construction works are also included in this Plan.
1.3 Links to other Trans Mountain Environmental Plans Information from other environmental plans prepared for the Project that are related to the Contamination Identification and Assessment Plan has been considered. The links between this Plan and other Trans Mountain management plans are provided in Table 2.
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TABLE 2
TRANS MOUNTAIN PLANS LINKED TO THIS PLAN
Environmental Plan Description of the Environmental Plan Linkage to this Plan Pipeline EPP The Project EPPs contain Trans Mountain’s The EPP includes general construction (Volume 2 of the Environmental Plans) environmental procedures and mitigation measures to measures related to contamination and (NEB Condition 72) be implemented during construction of the various potential contaminated sites crossed by the components of the Project. The measures serve to Project. The Contamination Discovery Facilities EPP avoid, reduce or mitigate potential adverse Contingency Plan is located within the (Volume 3 of the Environmental Plans) environmental effects. The EPPs serve as reference appendices of each of the EPPs (NEB Condition 78) information for construction and inspection personnel to (Volumes 1 through 5, 9 and 10 of the support decision-making and to provide direction to Environmental Plans). more detailed information (i.e., resource-specific Westridge Marine Terminal EPP (Volume 4 of the Environmental Plans) mitigation, management and contingency plans). (NEB Condition 81)
Other Project-specific EPPs (Volumes 1, 9 and 10 of the Environmental Plans) Groundwater Management Plan The Groundwater Management Plan provides a The Contamination Identification and (Volume 6 of the Environmental Plans) description of the mitigation measures to be employed Assessment Plan includes measures for by Trans Mountain to protect groundwater resources how contaminated groundwater, if during Project construction. encountered, will be characterized and handled. Socio-Economic Effects Monitoring Plan (SEEMP) The purpose of the SEEMP is to monitor adverse socio- The SEEMP includes factors or indicators (Volume 6 of the Environmental Plans) economic effects of the project during construction. to be monitored, including worker’s health (NEB Condition 13) and safety. Worker Accommodation Strategy (NEB Condition 59) The purpose of the Worker Accommodation Strategy is The Worker Accommodation Strategy to provide a final summary of all the accommodations, includes measures to protect workers and including the location of any temporary work camps. In to identify and assess lands for the event temporary work camps are used, a description environmental effects prior to setting up a of how the potential environmental and socio-economic temporary camp. impacts have been assessed and a description of additional mitigation measures will be provided. Water Well Inventory (NEB Condition 93) The purpose of the Water Well Inventory is to physically The Water Well Inventory will provide the verify the location of water wells that are within 150 m of locations of wells in proximity to the Project either side of the centre of the pipeline right-of-way prior corridor. Should a contaminated area be to commencing construction. identified along the Project Footprint which is a result of Trans Mountain operations, including construction related activities the Water Well Inventory will confirm presence of water well locations in its vicinity. Trans Mountain will notify water well owners if contamination is discovered during construction within 150 metres of a water well identified in Condition 93. Consultation Reports – Protection of Municipal Water The purpose of the Consultation reports is to report on The Consultation Reports allow for open Sources (NEB Condition 94) Trans Mountain’s consultations with municipalities and dialogue of any concerns related to regional districts, communities and Aboriginal groups contamination to be raised should it be related to the protection of municipal and community linked to pipeline construction. water sources. Groundwater Monitoring Program The purpose of the Groundwater Monitoring Program is The Groundwater Monitoring Program will (NEB Condition 130) to monitor groundwater quality within vulnerable monitor and ensure appropriate aquifers along the pipeline route as well as at terminals management of impacted groundwater. and pump stations. Post-Construction Environmental Monitoring (PCEM) The PCEM Reports will provide a discussion of the For areas along the route where Reports effectiveness of mitigation, reclamation, or contaminated sites are encountered the (NEB Condition 151) compensation measures that were committed to and procedures laid out in the Plan will be implemented during construction of the Project. The implemented so that mitigation measures PCEM Reports will describe the corrective actions taken and procedures are adequately employed. during construction and provide recommendations for These areas will be monitored during the future remedial action in order to accomplish the goals PCEM Program. of mitigation or reclamation where measures implemented were not effective.
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1.4 Commitments Management Trans Mountain made a number of commitments regarding the Project during the OH-001-2014 proceedings and engagement activities up to May 2016. Commitments were made to improve and optimize Project planning and mitigation measures. As Trans Mountain has consolidated its commitments into a Commitments Tracking Table in accordance with NEB Condition 6, the table of commitments in each plan has been removed.
The updated Commitments Tracking Table was filed with the NEB pursuant to NEB Condition 6 and is available on Trans Mountain’s web site at www.transmountain.com. Trans Mountain continues to monitor and track compliance with its commitments and will update, post to its website and file with the NEB updated versions of the Commitments Tracking Table according to the timeframes outlined in NEB Condition 6. Commitments with specific relevance to this Plan have been considered and incorporated into this Plan.
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2.0 CONSULTATION AND ENGAGEMENT Consultation and engagement activities related to contamination identification and assessment were completed between May 2012 and February 2017 with Appropriate Government Authorities, potentially affected Aboriginal groups, and affected landowners/tenants. Opportunities to discuss contamination and identify issues or concerns were provided to public stakeholders through online information, workshops, meetings and ongoing engagement activities during the reporting period. Appendix B includes a comprehensive record of these engagement activities, stakeholder feedback and Trans Mountain responses.
The draft Plan was released in November 2016 for review. Feedback was requested by February 2017. Trans Mountain incorporated any feedback received into the final Plan or has provided rationale for why input has not been included, as summarized in Appendix B.
Engineering design changes were issued in the TMEP Fall 2016 Project Update document (www.transmountain.com/environmental-plans) along with a further request for feedback. All of the changes have been reviewed, and the relevant Project design updates have been incorporated into this Plan.
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3.0 PROJECT INTERACTIONS In the event that unanticipated contamination is discovered during any stage of the Project the Contamination Discovery Contingency Plan is located within the appendices of each of the EPPs (Volumes 1 through 5, 9 and 10 of the Environmental Plans) and will be implemented. This Plan addresses the following Project components, which are defined in Section 1.1.
Temporary Construction Lands and Infrastructure A preliminary review of the temporary construction lands and infrastructure locations including temporary camps, stockpile sites, equipment staging areas and borrow pits was conducted. Most of the temporary construction lands and infrastructure are located on previously disturbed land that will not likely require excavation of material, although some grading or earth movement could be required. The temporary construction lands and infrastructure project interactions are limited to potential disturbance of surface and near surface soils due to the nature of the activities to be completed on the temporary land uses, limiting the exposure to any potential existing contamination to near surface soils, compared to the deeper excavations for the pipeline construction. The locations of temporary construction lands and infrastructure locations will be assessed based on final siting and agreements.
A historical review and potential contamination assessment (desktop Phase I ESA) is being conducted for the temporary work spaces. These assessments will include review of:
• environmental and historical records and reports, if available, from databases, government, and municipal agencies, and
• aerial photographs indicating that the historical land use and ownership to identify previous land use that could potentially result in contamination.
If the desktop review suggests potential for contamination, site visits to document current site and neighboring properties’ conditions may be warranted and completed. Identified areas of potential environmental concern (APECs) will have a risk ranking of low, moderate or high risk assigned to qualitatively reflect the potential for contamination from the APEC to affect the temporary construction and infrastructure use sites. Temporary construction and infrastructure use sites that are assigned a risk ranking of moderate or high, may warrant further investigation (e.g., intrusive investigation) to assess the interaction potential existing contamination may have on the Project. They would also be identified on the Alignment Sheets within NEB Condition 60 Plan.
Pipeline Construction Footprint This Plan addresses the pipeline construction footprint (including the permanent easement) which is where soils will be excavated and there is a risk to encounter contaminated materials.
Access Roads The access roads consist primarily of pre-existing and upgraded government maintained roads or highways and forest service roads. Based on a review of pre-existing, and upgraded roads they generally appeared to be located in undeveloped, forested areas or fields. Construction of some additional access roads will be required. Road construction work will likely consist of grading and tree removal. It is not anticipated that excavation of material will be required in these areas and if excavation of material is required it is assumed that there is a low risk for contamination to be encountered as the roads will be located in undeveloped, forested areas or fields. The probability of encountering contaminated media is low; therefore, these areas were not included in the review.
Reactivation The reactivation area was previously constructed. It is anticipated that there will be limited excavation works conducted along the reactivation segments. The Plan includes review of the releases reported by Trans Mountain between 1953 and 2014 in the reactivation areas.
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Facilities This Plan addresses Trans Mountain facilities (pump stations, terminals [Edmonton, Sumas, and Burnaby], and associated infrastructure [i.e., traps]) located on land that has been previously disturbed, where there is a risk to encounter contaminated materials.
Contingency Alternate Routes The contingency alternate routes are generally located in residential, agricultural, or undeveloped land with the exception of the Pembina River contingency route which potentially may cross commercial or industrial properties and the Westridge Delivery Lines contingency route where there is a gas station and other commercial or industrial activities in one area of the route. The probability of encountering contaminated media during excavation of soils is low in the residential, agricultural, and undeveloped areas and moderate in the commercial/industrial areas along the contingency alternate routes. Should contamination be encountered, the procedures laid out in the Plan and the Contamination Discovery Contingency Plan (Appendix B of the EPP) will be implemented so that mitigation measures and procedures are adequately employed.
Variances A revision to the draft Plan filed for public consultation occurred as a result of the Edmonton ATCO route realignment. A new high risk site, the former Ellerslie Waste Management Facility (University of Alberta), has been identified and added to the Plan. The high risk site is further detailed in Sections 4.0 and 5.0.
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4.0 CONTAMINATED AREAS IDENTIFICATION AND ASSESSMENT APPROACH Trans Mountain intends to manage contamination through several steps: identify, manage, monitor and report. Each step in the process is covered in the following sections. This section outlines the steps Trans Mountain has taken, to identify and assess pre-existing solid, liquid or gaseous contamination for the Project. The applicable provincial and federal standards, guidelines and practices that are applicable to the Project are discussed further in Section 7.0. The Plan will help to minimize encountering unanticipated contamination and allow the contractor to effectively plan and coordinate construction works.
The entire Project corridor was considered during the initial phase of the project (Section 4.1 and 4.2). This screening identified potential sites which could be sources of contamination and have the potential to impact the project during construction. This screening included potential contamination sources originating on lands within the Project corridor and from sources originating off-site which may migrate to the Project Footprint via subsurface or surface flow. The cursory inventory screened areas with higher level of development and activity from those in natural areas. The screening included lands located within 150 m surrounding the proposed Project corridor (the Study Area). The approach to the initial screening included review of current and historical aerial photographs and publicly accessible business listings in urban areas for the Study Area. The initial screening did not include other forms of records review or database searches, a site visit, or sampling or analysis of soil, water or air. Risk classification levels were assigned to identify areas of interest (Section 4.5). Desktop Phase I ESA’s were then completed on the identified areas of interest generally following the CSA Standard Z768-01 (R2012) (Section 4.4).
The Plan addresses areas where existing contamination may not have been identified by including procedures for managing contamination during construction in areas including procedures for identifying contamination in areas that are not known, or suspected, to be contaminated.
4.1 Environmental and Socio-Economic Assessment As part of the Application for the Project, Volume 5A, Section 7.2.2 of the ESA (TERA 2013b) an assessment of the known spills and contaminated sites along the existing TMPL system and within the proposed Project corridor at the time of filing (December 2013) was provided. The assessment also identified hydrostatic discharge locations. To identify spills and known contaminated sites along the existing TMPL system right of way, a search of the company’s historical records was conducted for the Project. In response to the historical releases, various remedial methods were employed to the standards of the time. The locations of historical spills will be monitored during construction for signs of contamination. If a site with previously unknown contamination is encountered, the Contamination Discovery Contingency Plan, will be implemented, which is found in the appendices of the updated EPPs (Volumes 1 through 5, 9 and 10 of the Environmental Plans).
4.2 Inventory of Potentially Contaminated Sites The CIPCS (TERA 2013a) was conducted to identify potential sites that could be sources of contamination and have the potential to affect the Project Footprint. Aerial photography and publicly accessible building listings were reviewed for urban areas within the Project Footprint as well as TMPL system spill locations based on the Project Footprint and a review of the historic data available to TMEP.
The findings of the CIPCS study identified a total of 192 areas of interest within the Project Study Area related to activities by both third parties and Trans Mountain. Sites that had low potential to impact the Project Footprint considering factors such as potential contamination present (e.g., media and type) and the pathway between the potential contamination and subject property (e.g., distance, orientation, and vector) were removed. Ninety-three areas were identified as of interest, located within the Project corridor, 75 m on either side of the pipeline centreline, as defined at the time of filing in December 2013. Of the 93 areas within the Project corridor, 43 areas were identified as low risk, 3 low/moderate risk, 25 moderate risk, 2 moderate/high risk, and 19 high risk. An explanation of the risk classification for the properties is presented in Section 4.5 and the moderate and high risk areas are listed in Table 3 (Section 4.6).
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Since the completion of the CIPCS, additional information has been collected to further assess the potential sites and an update of the CIPCS has been prepared. The updated CIPCS is presented in Section 4.4 through Section 4.6.
4.3 Desktop Phase I Environmental Sites Assessments Desktop Phase I Environmental Site Assessments were conducted in 2013 for locations where historic releases of volumes greater than 100 barrels occurred along the existing TMPL system. Based upon Trans Mountain having completed remediation on all of their spills, it was determined that the likelihood of encountering contamination would be low. However, as a conservative measure, and given the age of some of these spills, and the changes in regulatory standards, a spill volume equivalent to 100 barrels was established as a threshold for the size of spills that may have potential for residual environmental impacts that would persist and be encountered during construction given its considerable size. The results of the Desktop Phase I Environmental Site Assessments were reviewed to determine a risk classification for the potential to encounter contaminated media during the Project and confirm which sites may require pre-construction intrusive environmental site assessment work.
Based on the 2013 Desktop Phase I Environmental Site Assessments, the following locations are located within the Project Footprint and were identified as posing a moderate risk of encountering contaminated media during the Project. Refer to Section 4.5 for the definition surrounding moderate risk:
• Edmonton Station (KP 0) (TERA 2013c);
• Subject Property at KP 99.9 (TERA 2013d);
• Subject Property at KP 270.8 (TERA 2013e);
• Albreda Pump Station (KP 439.9) (TERA 2013f);
• Subject Property at KP 491.1 (TERA 2013g);
• Subject Property at KP 493.2 (TERA 2013h);
• Blackpool Pump Station (KP 732.3) (TERA 2013i);
• Kamloops Pump Station (KP 846.6 to KP 847.6) (TERA 2013j);
• PetroCan Takeoff Station (KP 841) (TERA 2013k);
• Hope Pump Station (KP 1040.9) (TERA 2013l);
• Wahleach Pump Station (KP 1075.1) (TERA 2013m);
• Burnaby Terminal (KP 0.1) (TERA 2013n); and
• Westridge Marine Terminal (KP 3.2) (TERA 2013o). 4.4 Update to the Inventory of Potentially Contaminated Sites This section documents the updates Trans Mountain completed to provide additional assessment of potentially contaminated sites along the Project Footprint. Updates to the CIPCS included conducting a records review and an evaluation of the information collected according to the Canadian Standards Association (CSA) Standard Z768-01 (R2012) and in the Alberta Environment and Parks (AEP) Environmental Site Assessment Guidelines Draft (Government of Alberta 2013). The reviews were limited to publicly available records that were obtainable within reasonable time constraints, and records that were practically reviewable (i.e., provided in a manner and form that yields information relevant to the subject property without the need for extraordinary analysis). The searches included the standard, publicly available, historical searches typically completed for Phase I Environmental Site Assessments and Stage 1 Preliminary Site Investigations (PSI) based on the CSA Standard Z768-01 (R2012) “Phase I Environmental Site Assessment” and the BC MOE Technical Guidance 10 – Checklist for Reviewing a Preliminary Site Investigation (BC MOE 2005). The update to the CIPCS included:
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• a review of available web mapping and publicly available business listings in 2015 to develop an updated inventory of potentially contaminated sites;
• an assignment of a risk classification to the identified potentially contaminated areas based on interpretation of aerial photographs, the facility and/or land use and professional judgement;
• a refined review of past TMPL system spill locations based on the Project Footprint and a review of the historic data available to TMEP; and
• a review of publicly available records including: land title searches; the Petroleum Tank Management Association of Alberta (Alberta only); Abacus Datagraphics (Alberta only); the Alberta Energy Regulator (Alberta only); Environmental Site Assessment Repository (Alberta only); Geographic Land Information Management Planning System (Alberta only); the Federal Contaminates Sites Inventory; aerial photographs; municipal/district and fire department records; local topography; street directories (BC only); and the BC Site Registry Search (BC only).
These desktop Phase I ESA reviews provided a refinement of the risk classification for each of the subject properties, which was based on the potential for contamination to affect the Project Footprint and the characteristics of the contamination. The desktop Phase I ESA searches included properties within 100 m and up to 300 m of the Project Footprint, for the records reviews. For areas initially classified as high risk, reports were obtained and reviewed where available (e.g., publicly available records via the BC Site Registry Search). A listing of the reports obtained and reviewed from BC Site Registry search is provided as Appendix C. 4.5 Contamination Risk Classification As part of this update to the CIPCS, a risk classification was introduced to better reflect the potential contamination concerns and simplify the procedures for management of potential contamination. Potentially contaminated properties located within or immediately adjacent to the Project Footprint were categorized as having a low, moderate, or high potential to affect the Project Footprint. The qualitative risk ranking was based on category attributes that reflect the likelihood of contamination from the source area to impact the Project Footprint and specifically the soil and groundwater disturbed by the project. For example, attributes considered relate to the potential or known contaminants of concern, the media potentially or known to be contaminated, and the receptor and pathway, including the distance from the source of the potential or known contaminant may migrate. This categorization provides the basis for areas where additional environmental assessment may be required prior to construction or when a Resource Specialist will be required on-site during construction to determine the appropriate response if contamination is encountered. The following outlines the contamination risk classification for the potentially contaminated properties along the Project Footprint.
• Low Risk Property – Identified in the updated CIPCS as having current and/or historical activities that are not likely to have resulted in contamination impacting the Project Footprint. For example:
- The potential contaminated source area is a significant distance from, or orientation to, the subject property and is unlikely to impact the subject property.
- Project activities are unlikely to interact with potential contamination given the contaminant depth or project activity.
• Moderate Risk Property – Identified in the updated CIPCS as having a potential to impact the Project Footprint. These are uninvestigated potential contaminated source areas with moderate potential to confirm presence of contamination. Insufficient information is available to conclude that land use, intensity, potential contamination type, or contaminated media or pathway between the potential contaminated source area and Project Footprint do not present a low risk. Potential contamination type can be readily identified through field screening. Examples of activities that resulted in a moderate risk classification include the following: historical TMPL system spills, Trans Mountain facilities, wellsites, landfills, gas stations/cardlocks, and industrial areas (excluding those identified in the High Risk Properties).
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• High Risk Property – Identified in the updated CIPCS as a property with current and/or historical activities that have known contamination, or will likely have contamination, within the Project Footprint. For example:
- Land use confirmed through investigation results to have generated contamination within the Project Footprint.
- Based on contamination type, proximity and orientation between the source and the Project Footprint, potential contamination appears likely to have mobilized from the source area into the Project Footprint.
- Project activities are likely to interact with the contamination given the contaminant depth and project activity.
• The four general areas classified as High Risk include Kamloops Airport (KP 840.9 to KP 841.5), Surrey/Langley (KP 1154.8 to KP 1157.9) and Coquitlam (KP 1168.7 to KP 1173.1) in BC; the former University of Alberta Ellerslie Waste Management Facility in Edmonton (KP 26.3 to KP 26.8) in Alberta.
During the assessment, areas that did not contain commercial or industrial activities or had not previously been developed were anticipated not to have the potential for contamination that could impact the Project. These areas were not included in the contamination risk classification listed above.
4.6 Updated List of Moderate or High Risk Areas The updates to the CIPCS identified a refined list of moderate or high risk properties that are potentially contaminated and are located within or immediately adjacent to the Project Footprint Attributes considered to evaluate the risk of immediately adjacent properties relate to the land use and intensity of the use and potential contamination present (e.g., media and type) and the pathway between the potential contamination and subject property (e.g., distance, orientation, and vector). Table 3 presents a summary of the moderate or high risk areas.
TABLE 3
UPDATED INVENTORY OF POTENTIALLY CONTAMINATED MODERATE OR HIGH RISK SITES WITHIN PROJECT FOOTPRINT
Approximate Potential Contaminants of Risk Project Segment4 KP1 Northing2 Easting2 Zone Description3 Concern (PCOCs) Classification Edmonton to Hinton KP1 5934232.148 343548.376 U12 Historical Spill PHCs, metals, PAHs Moderate KP 26.3 to 5923205.400 330935.460 U12 Former Ellerslie Waste Metals, Volatile organic High KP 26.8 Management Facility compounds (VOCs), (University of Alberta) Salinity, Radionuclides (note, possible area of groundwater contamination) KP 40 5930416.821 323295.547 U12 Husky (gas station) PHCs, metals, PAHs, glycols Moderate 5935679.770 306783.192 U12 Industrial Area PHCs, PAHs, metals, VOCs, Moderate KP 57.6 to glycols, PCBs, and other KP 60.4 chemicals KP 94.8 5938728.227 669906.176 U11 Historic Spill PHCs, metals, PAHs Moderate KP98.3 5938419.86 666466.47 U11 Former Asbestos Dump Asbestos Moderate KP 99.9 5938079.036 665010.364 U11 Historic Spill PHCs, metals, PAHs Moderate 5937877.804 664998.719 U11 Industrial Facility and PHCs, PAHs, metals, VOCs, Moderate KP 99.2 to Holding Ponds glycols, PCBs, and other KP 100.5 chemicals KP 124.5 5939089.696 641389.087 U11 Well Site PHCs, metals, PAHs, salinity, Moderate herbicides KP 133 to 5939607.000 632254.000 U11 Pembina River PHCs, PAHs, metals, VOCs, Moderate KP 134 contingency route glycols, PCBs, and other chemicals
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TABLE 3 Cont’d
Approximate Potential Contaminants of Risk Project Segment4 KP1 Northing2 Easting2 Zone Description3 Concern (PCOCs) Classification Edmonton to Hinton KP 164 5940398.858 602374.509 U11 Well Site PHCs, metals, PAHs, salinity, Moderate (cont’d) herbicides KP 180.3 5941014.661 586404.698 U11 Facility Site PHCs, metals, PAHs, salinity, Moderate herbicides KP 191.3 5941274.480 575609.308 U11 Facility Well Site PHCs, metals, PAHs, salinity, Moderate herbicides KP 201.2 5938918.082 566245.673 U11 Possible Well Site PHCs, metals, PAHs, salinity, Moderate herbicides KP 216.3 5939294.896 551574.852 U11 Possible Well Site PHCs, metals, PAHs, salinity, Moderate herbicides KP 226.2 5938901.135 542111.536 U11 Possible Vehicle Salvage PHCs, metals, PAHs, glycols Moderate Yard KP 245.4 to 5936358.33 523439.43 U11 Tank Farm (Gibson PHCs, metals, PAHs Moderate KP 245.7 Energy) KP 270.8 5932904.508 501407.424 U11 Historic Spill (note, PHCs, metals, PAHs Moderate possible area of groundwater contamination) Hinton to KP 439.9 5836648.038 351635.680 U11 Historic Spill PHCs, metals, PAHs Moderate Hargreaves KP 489.2 5875750.547 349362.602 U11 Hargreaves Trap Station PHCs, metals, PAHs, Moderate (Reactivation Area) herbicides KP 491.1 5874490.819 347740.633 U11 Historic Spill (note, PHCs, metals, PAHs Moderate possible area of groundwater contamination) KP 493.2 5873422.870 345903.865 U11 Historic Spill (note, PHCs, metals, PAHs Moderate possible area of groundwater contamination) KP 516.1 to 5858206.262 345971.384 U11 Valemount Landfill Metals, nitrogen, chloride, Moderate KP 516.5 phenols, VOCs, PHCs KP 608.1 5777969.743 343398.946 U11 Blue River Airport salinity, glycol Moderate KP 650.9 5739504.125 339732.333 U11 Service Station PHCs, metals, PAHs, glycols Moderate KP 732.3 5716577.167 696917.485 U11 Blackpool Station Historic PHCs, metals, PAHs Moderate Spill Black Pines to Hope KP 841 5620769.012 681591.411 U10 PetroCan Takeoff Historic PHCs, metals, PAHs Moderate Spill (note, possible area of groundwater contamination) KP 840.9 to 5620427.937 681416.772 U10 Kamloops Airport (note, VOCs, salinity, glycol High KP 841.5 possible area of groundwater contamination) KP 846.6 to 5615259.964 682781.709 U10 Kamloops Terminal Tank PHCs, metals, PAHs Moderate KP 847.6 Farm (KP 847 Historic Spill) KP 847.6 to 5615101.031 682948.447 U10 Pembina Terminal PHCs, metals, PAHs Moderate KP 84.8 Hope to Burnaby KP 1040.9 5470093.657 614236.991 U10 Hope Tank Farm PHCs, metals, PAHs Moderate (Historic Spill) KP 1042 5470098.874 613270.589 U10 Former Service Station PHCs, metals, PAHs, glycols Moderate KP 1048 5469086.108 607680.630 U10 Chevron Cardlock PHCs, metals, PAHs, glycols Moderate KP 1048.1 5469086.108 607680.630 U10 Hope Husky PHCs, metals, PAHs, glycols Moderate KP 1074.3 5450436.782 592876.858 U10 Wood Manufacturing PHCs, metals, PAHs, VOCs, Moderate antisapstain, and other chemicals KP 1075.1 5449877.742 592375.796 U10 Wahleach Station PHCs, metals, PAHs Moderate (Historic Spill) KP 1111.9 5435104.914 561718.147 U10 Sumas Pump Station PHCs, metals, PAHs Moderate KP 1112.7 to 5434997.492 560685.860 U10 Sumas River Asbestos Moderate KP 1112.9 (Potential Asbestos)
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TABLE 3 Cont’d
Approximate Potential Contaminants of Risk Project Segment4 KP1 Northing2 Easting2 Zone Description3 Concern (PCOCs) Classification Hope to Burnaby KP 1154.8 to 5447759.390 523245.310 U10 Surrey/Langley PHCs, metals, PAHs, High (cont’d) KP 1157.9 Industrial Area (note, VOCs, PCBs, antisapstain, possible area of and other chemicals groundwater contamination) KP 1159.3 to 5448372.361 520016.332 U10 Industrial Area PHCs, metals, PAHs, VOCs, Moderate KP 1160.1 8 PCBs, antisapstain, and other chemicals KP 1165.4 to 5450856B.74 514561.741 U10 Port Mann Landfill Metals, nitrogen, chloride, Moderate KP 1166.5 5 phenols, VOCs, PHCs KP 1168.7 to 5452718.106 511663.031 U10 Coquitlam High Risk PHCs, metals, PAHs, High KP 1173.1 Area (note, possible area VOCs, PCBs, glycols, of groundwater antisapstain, and other contamination) chemicals KP 1173.9 to 5453868.888 508124.629 U10 Train Loading Area PAHs, metals, herbicides Moderate KP 1174.6 KP 1177.2 to 5456577.455 505171.071 U10 Burnaby Moderate Risk PHCs, metals, PAHs Moderate KP 1179.7 Area Burnaby to KP 0.1 5457424.089 504716.455 U10 Burnaby Tank Farm PHCs, metals, PAHs Moderate Westridge (Historic Spill) KP 3.2 5459322.059 503452.999 U10 Westridge Terminal PHCs, metals, PAHs Moderate (Historic Spill) KP 0.1 to 5458648.000 502999.000 U10 Westridge Delivery Lines PHCs, PAHs, metals, VOCs, Moderate KP 3.2 contingency route glycols, PCBs, and other chemicals Notes: 1 KPs are approximate. KPs are based on the SSEID005.1. 2 Northing and easting of Areas of Interest are provided for the approximate middle point of the Area of Interest. 3 Description is interpreted from aerial imagery. 4 There were no moderate or high risk sites identified within the reactivation area between Darfield and Black Pine (43 km length KP 764.6 to KP 806.5).
The four areas classified as high risk are comprised of one or more individual sites. Publicly available information on the individual sites within these areas in BC was reviewed from the BC Site Registry to assess the risk classification of each of the sites within the high risk areas. For the site in Alberta, the Alberta Environmental Site Assessment Repository was searched along with other publicly available sources (i.e., Alberta university and government libraries).
Reports were reviewed to assess:
• whether the site had been satisfactorily remediated;
• if contamination remained and posed a potential impact to the Project Footprint; or
• if contamination remained but either because of its nature or spatial distribution, the contamination posed low risk to the Project Footprint.
The PCOCs associated with the current and historical activities on the high risk sites were reviewed to determine if there is a potential for the presence of contaminants that could impact the Project Footprint. The following considerations were used regarding the type of contaminants that could have potential to impact the Project Footprint:
• elevated concentrations of petroleum hydrocarbons, metals, or solvents in soil or water, as well as vapours, that could pose human health and/or environmental management issues during excavation and construction activities;
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• elevated concentrations of chlorinated solvents that could pose a risk to pipeline coatings over time; or
• elevated concentrations of contaminants (e.g., dissolved PHCs, or metals) that may travel via groundwater or landfill leachate into and along the pipeline trench as a preferential pathway.
Table 4 presents a summary of the properties within each of the four high risk areas and Figures 1 through 5 present the former University of Alberta Ellerslie Waste Management Facility in Edmonton (Figure 1), Kamloops Airport (Figure 2), Surrey/Langley (Figure 3) and Coquitlam (Figures 4 and 5) high risk areas. On each figure, the relevant portion of the Project Footprint is shown in relation to the property boundaries of the identified high risk areas and sites.
Appendix D presents a brief description of the site conditions for each of the sites that were identified in the BC Site Registry, or other available sources (i.e., Alberta Government library for the former University of Alberta Ellerslie Waste Management Facility) and summarizes the rationale for classifying the sites as high risk or why, after review of the additional information, the site likely poses a low or moderate risk of potentially impacting the Project Footprint. Based on the review of the Site Registry data, environmental assessment work was completed in December 2016 at three of the BC sites to further assess the contamination within the Project Footprint. A summary of these assessment results is provided in Appendix E.
TABLE 4
PROPERTIES WITHIN IDENTIFIED HIGH RISK AREAS
High Risk Approximate Site Risk Area KP1 Description Current/Former Site Use PCOCs Classification Southwest KP 26.3 to Former University of Alberta Ellerslie Sorting, storage, and Metals, VOCs, Solvents, Salinity, High Risk Edmonton KP 26.8 Waste Management Facility processing hazardous solid Radionuclides (note, possible area of groundwater and liquid chemical waste, contamination) radioactive waste, and other miscellaneous waste (1972 to 2007) Kamloops KP 840.9 to Suncor Kamloops Terminal Distribution terminal for Benzene High Risk Airport KP 841.5 2955 Tranquille Road, Kamloops marketing refined petroleum BC Site Registry Site Number: 3087 products. (note, possible area of groundwater Petroleum products refinery contamination) (1954 until 1983). Temporary Progressive Air Small Aircraft Engine Dichlorobenzenes, 1,1,1 Low Risk Laydown 2965 Airport Drive, Kamloops Repair/Rebuild. Trichloethane (TCA), Carbon Area BC Site Registry Site Number: 668 tetrachloride Surrey/Langley KP 1155.3 to Former Mainland Holdings lease area Salt Storage. Chloride, Sodium, Salinity Low Risk Industrial Area KP 1155.6 9930 – 197th Street, Langley BC Site Registry Site Number: 13355 KP 1156 to S&R Saw Mills Ltd. Former saw mill and wood Benzene, LEPH, Anthracene, High Risk2 KP 1156.2 19395 98A Avenue, Surrey preservation operations. Benzo(a)pyrene, Fluoranthene, BC Site Registry Site Number: 17693 Phenanthrene, Pyrene, Pentachlorophenol, Tetrachlorophenol, Trichlorophenol, Antimony, Arsenic KP 1156.2 to 19399 98A Avenue, Surrey Affected site, contamination Same as for 19395 98A Avenue Low Risk3 KP 1156.4 BC Site Registry Site Number: 17694 likely originated from 19395 98A Avenue. KP 1156.2 to City of Surrey Lands fronting 19399 From unknown upgradient MTBE, Benzo(a)pyrene High Risk4 KP 1156.4 98A Avenue, Surrey source (note, possible area of groundwater contamination) Coquitlam High KP 1168.9 to Former Lougheed Warehouse and Industrial complex. LEPH, HEPH Low Risk Risk Area KP 1169.1 Terminal Truck and trailer 2381 Rogers Avenue, Coquitlam maintenance. BC Site Registry Site Number: 8345 Used oil and diesel USTs.
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TABLE 4 Cont’d
High Risk Approximate Site Risk Area KP1 Description Current/Former Site Use PCOCs Classification Coquitlam High KP 1169.9 to Great Canadian Casino Casino. Not documented in available Moderate Risk Area KP 1170.4 2100 United Boulevard, Coquitlam Truck terminal and reports Risk5 (cont’d) BC Site Registry Site Number: 9109 maintenance. Leeder Landfill. KP 1171.9 to Former Fraser Mills Industrial and Commercial Xylene, VPH, LEPH, HEPH, 1,2- High Risk KP 1172.1 8 – 10 King Edward Street, Coquitlam operations. dichlorobenzene, cis-1,2- BC Site Registry Site Number: 7829 Laminated lumber product Dichloroethylene, (note, possible area of groundwater production. Chlorobenzene, Arsenic, Barium, contamination) Lumber Storage. Cadmium, Chromium, Copper, Lead, Silver, Tin, Zinc, Methane, Carbon Dioxide KP 1172.3 to Coquitlam Landfill Golf Course. HEPH, PAHs, Arsenic, Copper, High Risk KP 1173.2 1001 United Boulevard, Coquitlam Landfill. Cadmium, Lead, Zinc, Methane, BC Site Registry Site Number: 2194 Carbon Dioxide (note, possible area of groundwater contamination) Notes: 1 KPs are approximate. KPs are based on the SSEID005.1. 2 Based on site assessment conducted in December 2016, sodium contamination was identified in the native clay materials. Although, based on precedent presented to MoE by others for nearby sites, the sodium concentrations are related to naturally elevated background conditions. An exemption request can be made to BC MoE for naturally elevated background concentrations; however, that is not currently Trans Mountain’s intention. If this is obtained, the risk can be downgraded to low. The site was determined to be moderate risk as suspected contamination was not identified within the pipeline construction footprint at investigation locations. 3 Based on site assessment conducted in December 2016, the site was determined to be low risk as suspected contamination was not identified near the pipeline construction footprint. 4 Based on site assessment conducted in December 2016, the site was determined to be high risk as contamination in the form of MTBE and benzo(a)pyrene concentrations greater than the drinking water use standards were identified in the pipeline construction footprint. Although based on precedent presented to MoE by others for nearby sites, an exemption request can be made to BC MoE for DW standards to not apply at the site. Trans Mountain does not currently intend to apply for an exemption, however if one is obtained, the risk can be downgraded to low. 5 Based on the available reports this site is classified as moderate risk to impact the Project Footprint however as described in Section 4.6.1 three former landfills operated in the Coquitlam High Risk Area. Elevated soil, groundwater or vapour concentrations sourced from the former landfills may present high risk of potential impact to the Project Footprint.
Identification of PCOCs in the field will be conducted during construction as described in Section 5.2.1.2 on Field Identification of PCOCs. 4.7 Pre-Construction Environmental Site Investigation 4.7.1 Environmental Site Investigations on High Risk Sites As described in Section 4.6 and presented on Table 4, the assessment of high risk sites in the Inventory of Potentially Contaminated Sites identified four areas as high risk (Southwest Edmonton, Kamloops Airport, Surrey/Langley Industrial Area, and Coquitlam High Risk Area). Within these high risk areas, a total of six individual properties were classified as high risk (Table 4). Following a review of publicly available information it was determined that intrusive subsurface investigation should be performed at three of these properties to assess for the presence or degree of contamination.
The results of this investigation work will facilitate the Contractor’s hazard assessment, planning for safe work procedures, and development of appropriate site-specific mitigation, remediation, and/or monitoring measures during construction to manage impacted materials appropriately and ensure worker health and safety at all high risk sites. Site-specific mitigation measures may include dewatering as needed during construction and off-site disposal, and measures to ensure the pipeline corridor does not become a preferential migration pathway for the existing contamination., such as the placement of a trench plug with a lower permeability (<10-8 m/s) than the pipeline bedding material, as detailed in Section 5.0. Site-specific plans will be filed with NEB 2 months prior to construction in the area of the high risk site.
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The following summarizes the results of the intrusive subsurface environmental site investigations conducted in December 2016 for the three properties (S&R Saw Mills, City of Surrey land fronting 19399 98A Avenue and former Fraser Mills).
Surrey/Langley Area S&R Saw Mills Site (19395 98A Avenue) As described in Appendix D, no site plans or reports presenting the spatial distribution of the contaminants were available in the publicly available documents, however contamination was described to be present in the northwest and southeast corners of the property. The Project Footprint (from about KP 1156 to KP 1156.2) crosses through the southern portion of this subject property.
Investigation results did not identify concentrations of the PCOCs which exceeded the applicable CSR standards in soil or groundwater. Groundwater was encountered at a depth of 1.5 mbg, in a sand and gravel formation. The sodium concentration in one sample exceeded the applicable CSR standard, however sodium is not a PCOC and the elevated concentration is likely attributed to natural occurring presence within the native clay unit, which may originate from a marine geological deposit.
Subsequent to filing of the Plan, publicly available information was identified confirming that for two nearby sites with the same lithology, exceptions were obtained from the BC MoE for accepting that the sodium concentrations within the native clay were naturally occurring and not contamination. Based on this precedence, a similar exception could be obtained to remove the identified contamination for sodium at the S&R Saw Mills property. However, for now, the site is considered as high risk and appropriate management and mitigation measures will be implemented during construction.
City of Surrey Lands Fronting 19399 98A Avenue As indicated by documents on the BC Site Registry, contaminants from the S&R Saw Mills site migrated onto the 19399 98A this property located to the west, and also the City of Surrey lands. The extent of the migration is unknown. The Project Footprint (from approximately KP 1156.2 to KP 1156.4) crosses through the City of Surrey lands immediately south of the 19399 98A Avenue property, where contamination may be present.
Investigation results from the City of Surrey lands fronting 19399 98A Avenue site in Surrey/Langley area identified Methyl tert-butyl ether (MTBE) and benzo(a)pyrene concentrations in groundwater that exceeded the CSR DW standards. MTBE was not a PCOC associated with the activities on the adjacent S&R Saw Mills site and the source is unknown at this time. Benzo(a)pyrene is a PCOC for the adjacent S&R Saw Mills property, however benzo(a)pyrene can also be detected when silty sediments are present with the groundwater sample. Groundwater was encountered at approximately 3 m to 3.3 m below grade within the native alluvial sand and gravel. Investigation results did not identify concentrations of the PCOCs which exceeded the applicable CSR standards in soil.
Subsequent to filing of the Plan, publicly available information was identified confirming that for two nearby sites with the same lithology, exceptions were obtained from the BC MoE for not applying drinking water standards. Based on this precedence, a similar exception could be obtained to remove the identified contamination for MTBE and benzo(a)pyrene at the City of Surrey lands. However, for now, the site is considered as high risk and appropriate management and mitigation measures will be implemented during construction.
Coquitlam High Risk Area Former Fraser Mills site (8 – 10 King Edward Street) As described in Appendix D, the Project Footprint (from approximately KP 1171.9 to KP 1172.1) crosses through the northern portion of the subject property and will encounter extensive fill, including woodwaste, refuse, and sand fill. No monitoring data was available since 2004 in the publicly available reports and there is potential for project activities to encounter elevated vapour, soil metal and hydrocarbon contamination.
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Investigation results from the former Fraser Mills site (8 – 10 King Edward Street) in Coquitlam identified concentrations of metals (cadmium, lead and zinc) in soil and concentrations of benzene and 1-4-dichlorobenzene in groundwater that exceeded the CSR standards. Soil contamination was identified in the upper 1 m to 2 m below ground surface and groundwater was encountered at about 2 m below ground surface. Site stratigraphy consisted of granular fill overlying organic wood refuse fill between 1 m and 2 m thick, overlying 0.6 m to 1 m thick peat deposits which was underlain by clay. Domestic waste (plastic, aluminum, steel, glass, and paper) was found mixed with the granular fill interval. A summary of the investigation results for these three sites is presented in Appendix E. The results will be used to provide the basis for hazard assessment, safe work procedures development and contamination management planning in preparation for construction activities in these areas. Based on the soil and groundwater results and field observations and screening, the procedures outlined in Section 5 for managing contamination during construction will be implemented at these three properties. Regulatory Notification(s) as detailed in Section 6.2 will be required for the contamination management. Environmental assessment through intrusive investigation was deemed not necessary at the following three High Risk sites since publicly available documentation will provide a sufficient level of detail to facilitate the Contractor’s hazard assessment, planning for safe work procedures, and development of appropriate mitigation measures. A summary of the site conditions described in the reviewed information, and additional site specific rationale for not conducting additional site investigation, is presented in the following:
• The former University of Alberta Ellerslie Waste Management Facility (Southwest Edmonton Area):
- Based on the site conditions documented in a publicly available report (AMEC 2008), contaminants of concern in soil and groundwater identified at the subject property include VOCs, solvents, metals, radionuclides (Tritium), and salinity. Soil contamination was identified beginning from a depth of about 2 m below grade and impacted groundwater may be encountered within 2.5 to 3.5 m from the ground surface.
- Changes in the soil and groundwater quality since 2008 are unknown, however assuming that there has not been any remediation since the 2008 investigations, the contaminants of concern are likely still present at the subject property.
- For the site specific remedial measures plan for this Site, the radionuclides of concern (tritium [3H]) poses a potential exposure hazard via consumption; the Health Canada water guideline for tritium is based on a human health drinking water consumption risk. The exposure pathway is therefore groundwater. Mitigation measures for the FEWMF as part of pipeline construction, will be designed to limit migration of tritium through the exposure pathway (i.e., groundwater). Potential mitigation options that are effective against contaminant transport in groundwater include low permeability barriers or plugs and HDPE or Geosynthetic liners. Barriers would be installed across the full cross-section of the trench or at the base or sides of the pipeline trench to minimize migration of groundwater or vapours through the more permeable bedding material. Materials for trench plugs will be evaluated for their effectiveness and may include compacted clay or bentonite, or other low-permeability (<10-8 m/s) material such as concrete, controlled density fill or unshrinkable fill having a much lower permeability than the surrounding pipeline bedding material. Similar evaluation of mitigation measures are to be completed for all other PCOCs identified at the FEWMF.
• The Kamloops Airport area:
- The PCOCs (petroleum hydrocarbons) as described in Appendix D are considered manageable during construction (between approximately KP 840.9 to KP 841.5) at the southeastern boundary of the Suncor Kamloops Terminal (BC Site Registry Site No. 3087).
- The temporary workspace needed for the drag section of pipe to be placed on the surface, located adjacent to the Progressive Air facility (BC Site Registry Site No. 668) will be limited to removal of topsoil and there will be no contact with potentially impacted groundwater.
• The former Coquitlam Landfill, 1011 United Boulevard, Coquitlam Area:
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- Project activities on the former Coquitlam Landfill will likely encounter landfilled waste, landfill gas and leachate impacted groundwater. The Project Footprint (from approximately KP 1172.3 to KP 1173.2) crosses through the eastern and northern portion of the subject property. Management of waste materials may be required and modifications or allowances for the current landfill leachate and vapour collection systems could be required.
- Previous investigations have been completed within the Project Footprint, as described in Appendix D, and provided adequate information regarding the stratigraphy, depth to water and contaminants of concern, therefore no additional intrusive investigation was required.
A summary of the publicly available information is presented in Appendix D for these three sites. In consideration of the procedures that will be in place for managing contamination during construction (Section 5), along with the historical data, sufficient information is available for pre-construction hazard assessment and development of safe work procedures and waste management in preparation of construction activities in this area. 4.7.2 Coquitlam Landfills High Risk Area In addition to the Coquitlam Landfill, two other former landfills were operated in the Coquitlam high risk area; these were the Tera Nova Landfill (KP 1166.3 to KP 1167.9, three separate regions), and Leeder Landfill (KP 1165.3 to KP 1168). A fourth small former unnamed dump site was also identified by BGC (2016) between approximately KP 1164.4 to KP 1164.5, west of the northern approach to the Port Mann Bridge. The history of the landfills including construction, waste type, thickness, and lateral extents are documented in BGC (2016).
Elevated soil, groundwater or vapour concentrations sourced from the former landfills potentially present high risk to impact the Project Footprint. Therefore, additional controls will be required within these areas for contaminant management, and include at a minimum:
• a Resource Specialist (Section 5.1) will be present during excavation construction works in high risk areas;
• excavated material may contain refuse/contaminated soil and will require off-site disposal as it will not be suitable for use as fill;
• the contractor will be responsible for developing an appropriate site-specific health and safety plan to address worker and public protection when working in and around the landfill and exposure to solid waste, landfill gas and leachate and associated contaminants of concern. The site-specific health and safety plan will address landfill gas monitoring procedures;
• the Contractor will develop a site-specific plan to address mitigation and remediation measures specific to the contaminants of concern for the area to prevent the pipeline trench from becoming a conduit for contamination, including landfill gas mitigation measures at the entry and exit of the pipeline through the landfills. Mitigation measures may include a low permeability trench plug across the full cross-section to prevent migration of landfill gas and leachate through the more permeable bedding material; and
• alterations to the leachate and vapour control may need to be considered.
The contractor will also be responsible for developing an appropriate site-specific health and safety plan to address worker and public protection when working in and around the landfill and exposure to solid waste, landfill gas and leachate and associated contaminants of concern. The site-specific health and safety plan will address landfill gas monitoring procedures.
4.7.3 Third-Party Properties The Project is being constructed along several third-party properties with various current and historical activities which may have resulted in impacts to soil, groundwater, vapour, and/or sediments. These sites are not currently captured within public directories (e.g., the BC Site Registry and the Alberta Environmental Site Assessment Repository) and as such, no information is available. Should existing
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Trans Mountain Pipeline ULC Contamination Identification and Assessment Plan Trans Mountain Expansion Project 687945/August 2017 contamination in these areas that is not sourced from Trans Mountain’s activities be identified prior to or during construction works, Trans Mountain will notify the NEB and the owner of the property of the identified contamination. Trans Mountain will ensure contaminated waste material encountered during construction within the pipeline construction footprint is tracked and managed appropriately and notify Appropriate Regulatory agencies of contamination found in the excavation footprint area. Trans Mountain will not contact regulatory authorities directly regarding existing historical third-party contamination that may extend beyond the excavation footprint area on third-party properties; the responsible party, the land owner, at their discretion can notify the authorities, as required by applicable laws and regulations.
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5.0 PROCEDURES FOR MANAGING CONTAMINATION DURING CONSTRUCTION This section outlines Trans Mountain’s procedures for managing contamination for the Project and aligns with the Mitigation Plan and with applicable provincial and federal policies. A flow chart detailing how potential or known contamination will be characterized and managed on the low, moderate, and high risk properties is included in Appendix A. The risk classification for the properties are presented in Tables 3 and 4 (Section 4.6).
This Plan documents mitigation measures for management of contamination, and will be included as part of the Environmental Plans (Volume 6). Note that some additional information is included in this Plan that is not included in the Project EPPs. The relevant Project EPP measures are included below, and notes in square brackets indicate which information is also found in the Pipeline EPP (Volume 2 of the Environmental Plans). Similar measures are also found in other EPPs as applicable (see Table 2 [Section 1.3] for a list of related plans).
5.1 Contamination Management Responsibilities The following details the responsibilities of those involved with managing contamination within the Project Footprint.
Responsibilities – 1. An Environmental Inspector is responsible for monitoring compliance with Environmental environmental and socio-economic commitments, undertakings and conditions Inspector of permits and approvals, as well as applicable environmental legislation, Trans Mountain’s policies, procedures, and industry-accepted standards. [Section 4.0 Environmental Compliance] 2. An Environmental Inspector will work with the Resource Specialist that may be required to support the Project. [Section 4.0 Environmental Compliance] 3. An Environmental Inspector will organize on-site meetings in consultation with the Construction Manager or designate and, as the need arises, to address resource-specific issues as well as review construction methodologies. [Section 4.0 Environmental Compliance] 4. An Environmental Inspector will approve waste disposal facilities in accordance with Trans Mountain’s policies and procedures and backfill sources with the help of the Resource Specialist. 5. An Environmental Inspector will notify the Resource Specialist when he/she is required on site prior to beginning work on a site ranked as high risk for potential contamination, or where results of field screening result indicate the potential for contamination. 6. An Environmental Inspector will ensure workers are aware when construction is taking place in areas ranked as moderate or high risk as designated in this plan. These sites will be added to the Environmental Alignment Sheets or otherwise communicated to the Contractor. 7. An Environmental Inspector will ensure the contractor follows the guidance outlined in the Contamination Discovery Contingency Plan, in the event contamination is encountered and will work with a Resource Specialist.
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Responsibilities – 1. The Resource Specialists will provide advice on mitigation measures for field Contamination issues and environmental resource features based on their specific areas of Resource specialized training and experience, including contamination. [Section 4.0 Specialists1 Environmental Compliance] 2. The Resource Specialists will assist Environmental Inspector in selection of appropriate Trans Mountain approved waste disposal facilities based on characterization results of the soils to be disposed of 3. The Resource Specialist will review the Contractor’s assessment that backfill material sources meet applicable environmental quality guidelines or standards. 4. The Resource Specialist will conduct analytical soil and groundwater sampling where deemed necessary in high risk areas or where field screening by Environmental Inspector identifies the potential for contamination or for off-site disposal of soil or groundwater. 5. The Resource Specialist will be responsible for compliance with federal, Alberta, and or BC guidelines or standards associated with contamination including characterization of soil and water, overseeing excavation of contaminated material, stockpiling and disposal of waste and completing waste manifests on behalf of the Project. 6. The Resource Specialist will complete detailed records of contamination identified during construction work. Responsibilities – 1. The Contractor is responsible for the safe handling and storage of contaminated Contractor material including: • developing site specific plans to address health and safety issues as well as mitigation and remedial measures specific to the contaminants of concern for sites where contamination has been confirmed; • preparation of temporary stockpile areas; • staging of excavation activities; • ensuring that field staff have appropriate Personal Protective Equipment (PPE) based on the anticipated PCOCs identified at each location; • ensuring equipment is suitable for operating in the potentially contaminated areas and upon completion of works in a contaminated area, decontamination of all equipment in contact with contaminated material; and • contacting the Environmental Inspector if potentially contaminated material is encountered or if an environmental emergency (i.e., oil spill) occurs during construction. 2. The Contractor is responsible for arrangement and hauling of contaminated materials off-site by a licenced hauler, where applicable, to the disposal facility specified and approved by Environmental Inspector and Trans Mountain. The Contractor is also responsible for arrangement and hauling of backfill material from the location approved by the Environmental Inspector and Trans Mountain. 3. The Contractor is responsible for sourcing appropriate imported backfill and ensuring it meets applicable guidelines and standards. Note: 1 The Resources Specialist will be someone with direct contaminated sites field experience, with at a minimum, field experience with soil and groundwater sampling, field screening of soils, soil and groundwater management and remediation, an appropriate professional designation (e.g., P. Eng, P. Geo, P. Bio) and a minimum of 4 years’ experience in contaminated sites. The Resource Specialist would provide field presence on high risk sites and work under the direction more senior contaminated sites professional.
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5.2 Management of Contaminated Materials The following sections detail how soil and groundwater will be characterized and handled in the event that contamination is encountered during construction works within the construction footprint area. On third-party properties, contamination originating from a known third-party source located outside this footprint is to be addressed by the landowner.
5.2.1 Soil
Contaminated 1. Review known areas of contamination identified in Section 4.6 of this Plan Soils (Section 3.0 of Volume 6 of the Environmental Plans). 2. Implement the Contamination Discovery Contingency Plan (see Appendix B of the EPP) in the event that contaminated soils are discovered during construction. 3. Adhere to applicable measures provided in the Waste Management Standard (see Section 3.1 of Volume 6 of the Environmental Plans) for handling of contaminated material. [Section 7.0 General Pipeline Construction Mitigation Measures]
5.2.1.1 Excavation/Trenching
Excavation in 1. The Environmental Inspector will review the area prior to excavation to confirm if Areas of conditions are consistent with the findings in the CIAP and note if there are any Contamination changes in conditions that may indicate a potential for soil contamination (including confirming with Operations group whether there have been spills within the Project Footprint that will impact construction). The Environmental Inspector will notify the Resource Specialist prior to excavation commencing in a high risk site or area. For moderate risk sites, Environmental Inspectors and workers will be aware of potential contamination presence. 2. Ensure a Resource Specialist, with experience in contamination, is present in excavation in high risk areas or where contamination has been suspected based on field screening. Where suspected groundwater/soil contamination is encountered during construction, implement the Contamination Discovery Contingency Plan (CDCP) (Appendix B of the EPP). [Section 11.0 Stringing, Welding, Trenching and Lowering-in] 3. Ensure contaminated soil and water are not transported off-site or disposed of until analytical results have been received as per federal and provincial regulations and legislation. The decision as to when excavations can be backfilled will be made in consultation with the Environmental Inspector and Resource Specialist. [Section 11.0 Stringing, Welding, Trenching and Lowering-in] 4. Prevent the pipeline trench from being a preferential pathway conduit for potentially contaminated groundwater from high risk areas adjacent to the pipeline construction footprint (e.g., the landfill located adjacent to KP 522) by installing clay berms and/or trench plugs to contain contaminants to the site, and/or backfilling the trench with well compacted imported clay material to prevent contaminant migration. [Section 10.0 Stringing, Welding, Trenching and Lowering-in] 5. Ensure excavated contaminated soils are stockpiled in lined and bermed soil stockpile areas to prevent leaching of contaminants and surface run-off.
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Excavation in 6. The Contractor shall ensure sediment control measures are constructed around Areas of the immediate area of the excavation and that at all times the sites of the Contamination excavation are stable. The Contractor shall ensure that all excavation works are (cont’d) undertaken in a manner that minimizes the mixing of different material types (i.e., soils characterized as contaminated or meeting standards/guidelines). If groundwater is encountered in excavations, dewatering may be required. This is more specifically detailed in Section 5.2.2. Stockpiling 1. Materials (LDPE liner or equivalent) shall be available to line stockpile areas for Contaminated contaminated materials encountered during the excavation works. Should Soil contaminated soils be encountered, construction works will be stopped and a separate lined and bermed stockpile area will be prepared for the contaminated soils. Prior to transporting soils off-site or reusing soils in the excavation, soil samples will be collected by the Resource Specialist and the suspected impacted stockpiles will be characterized according to Section 5.2.1.1. 2. For stockpiled soil on high risk sites to be re-used as backfill material, it must be sampled in accordance with provincial requirements and meet applicable environmental quality provincial guidelines or standards. For stockpiled soil on medium or low risk sites, no sampling is required for re-use as backfill, if field screening did not identify any potential for contamination. If field screening did identify potential contamination, then the stockpiles must be sampled and meet applicable environmental quality provincial guidelines or standards before re-use. 3. Contaminated soil stockpiles are to be covered to protect them from rain/wind/runoff until a decision on soil management is made (i.e., reuse or off-site disposal). 4. Stockpiles with different soil characterizations (hazardous waste versus non-hazardous waste) shall be segregated and stockpiled appropriately (i.e., lined and bermed stockpiles). Hot Loading 1. Hot loading, involving the excavation and immediate transport of soils off-site for disposal at an approved facility is permitted where soils have been previously characterized and provided the items in the transportation of waste section (Section 5.2.4) are met. 2. A Resource Specialist must be present during hot loading of contaminated soil to document the activities. Asbestos 1. If asbestos or asbestos containing materials (ACMs) are discovered through field Discovery screening during construction the following measures will be implemented: • excavation activities will cease; and • engineering controls will be enacted to mitigate dust. Mitigation will include soaking the area of suspected asbestos with water. 2. A sample will be collected for bulk asbestos analyses at an approved laboratory 3. If necessary to continue work, personnel in the area affected by asbestos will wear appropriate PPE including half mask or full mask respirators with HEPA filters for which they have previously been fit-tested. Personnel air sampling will be required to demonstrate engineering control enacted to mitigate dust are effective. 4. Soils containing, or suspected to contain asbestos will be segregated, wetted, and covered until appropriate disposal is determined, following receipt of laboratory analyses. Disposal methods will follow requirements of the approved receiving facility.
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Backfilling/ 1. The Contractor is to identify potential sources for backfill prior to construction Backfill Selection that do not contain contaminants or weed infestations and obtain prior approval from, Trans Mountain for the use of these materials and sources. [Section 12.0 Backfilling]. Trans Mountain will obtain landowner approval of the use of these materials and sources. 2. When required, only soils meeting the applicable guidelines or standards will be used as imported backfill. The Contractor will ensure imported backfill material meets the applicable guidelines and standards. 3. The Resource Specialist, in consultation with Trans Mountain, will determine if required the preferred backfilling and remedial options. Mitigative 1. If contamination is identified in the area and has the potential for migration as a Measures result of the Project, mitigative measures and remediation options will be evaluated based on site specific factors and designed considering the site conditions and contaminants of concern. 2. Mitigation measure methods that could be considered for use in preventing migration of contamination from the pipeline trench through the more permeable bedding material may include a low permeability trench plug across the full cross-section of the pipeline trench, or placement of impermeable liners along the trench where contamination is in contact with the trench. Materials for trench plugs or impermeable liners will be evaluated and may include compacted clay or bentonite, or other low-permeability material such as concrete, controlled density fill or unshrinkable fill having a much lower permeability than the surrounding pipeline bedding material. High density polyethylene (HDP) or geosynthetic liners may also be considered along lateral sections of the trench that are in contact with the soil contamination.
5.2.1.2 Field Identification of PCOCs A Resource Specialist will be on site during construction at high risk sites to identify PCOCs and ensure the appropriate response and mitigation is carried out. In addition, the Environmental Inspector will ensure workers are aware when construction is taking place in sites identified as moderate and high risk sites, as listed on Table 4. For high risk sites, pre-construction intrusive investigations will also be completed to confirm the level of contamination of associated PCOCs, unless PCOCs have been sufficiently assessed by others as reported in publicly available documents obtained during the desktop Phase I ESAs. The data will confirm the potential for encountering these PCOCs in the high risk areas, particularly those that are not readily identifiable through field indicators.
Field indicators of PCOCs that can be identified visually or by odour (for example Petroleum Hydrocarbons, PAHs, glycols, ACMs) include, but are not limited to:
• Unusual odour, soil colour and texture that may indicate the presence of contaminants in the soil.
• Staining - typically stained soils are darker and may have a “wet” appearance, Stained soils may have a distinct oily feel.
• Buried debris; such as chemical containers, steel drums, automotive parts, cleaning rags, tanks, barrels, bottles, timbers, potential ACMs and boxes or other containers that may have contained or are associated with hazardous materials.
Specifically for asbestos or ACMs, field indicators will include visual observation to identify asbestos (e.g.,serpentine rock, fibrous appearance, greasy luster), ACMs (e.g., brake pads, cement piping, vinyl tiles, home insulation, cement siding) or asbestos deposit areas (e.g., former landfills, asbestos dumps) supported by a handheld portable analyzer (i.e., microPHAZIR™ by ThermoFirsh Scientific). Field indicators adjacent to historical asbestos deposit areas will also include signs of waste deposition (e.g., fill, liners, surficial evidence).
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Field indicators of PCOCs that cannot be identified by visual or olfactory indicators (for example solvents, metals, salinity, herbicides, PCBs) include, but are not limited to:
• Based on the contaminated sites inventory, the sites where PCOCs that cannot be observed visually or through smell generally are present in conjunction with hydrocarbon contamination (e.g., lead with hydrocarbons for gasoline contamination, etc.), as shown in Table 4.
• If field indicators of contamination are identified (as listed above), a Resource Specialist will use field screening instruments to further confirm their presence, and also to determine the presence or absence of a contaminant that cannot be identified visually or by odour.
• Field screening instruments include: an Organic Vapour Analyzer (OVA) or a Photoionization Detector (PID) (for hydrocarbons, solvents), X-Ray Fluorescence (XRF) Analyzer (for metals), microPHAZIR™ AS Asbestos Analyzer and Clor-N-Soil 50 (for PCBs), or other equivalent industry accepted instruments for screening for PCOCs not readily detectible visually.
5.2.1.3 Soil Sampling Soil sampling will be carried out:
• within the pipeline construction footprint at sites ranked as high risk, when contamination is encountered during construction, under the direction of a Resource Specialist;
• within the pipeline construction footprint when suspected contamination (e.g., staining, odour, sheen, presence of potential ACM), or elevated field screening results) is encountered, under the direction of a Resource Specialist;
• if soils are transported off-site to an approved disposal facility, soil sampling must include specific acceptance parameters (e.g., flashpoint, paint filter test, leachability) at the respective facility in addition to confirming the level of PCOC contamination (e.g., hazardous waste);
• if backfill material is being brought onto the site. Sampling of imported backfill material is the responsibility of the Contractor; or
• if reusing excavated material where contamination is suspected.
Soil sampling within the pipeline construction footprint will be conducted by a Resource Specialist, in accordance with the applicable standards or guidelines as listed below:
• properties in Alberta: AEP Alberta Environmental Site Assessment Guidelines Draft (Government of Alberta 2013); or
• properties in British Columbia: BC MOE Technical Guidance 1 – Site Characterization and Confirmation Testing (BC MOE 2009).
Soil samples will be collected according to the BC Field Sampling Manual (BC MWLAP 2013), for areas located in BC and according to the CCME Guidance Manual (CCME 2016) for areas located in Alberta.
Soil sample submissions for laboratory analyses will be approved by an Environmental Inspector and/or a Trans Mountain representative.
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TABLE 5
SOIL SAMPLING APPROACH SUMMARY
PCOCs Sampling Plan Petroleum Hydrocarbons • Sample ID, date sampled, location, and depth interval; • Field observations including soil description; • Field measurements including vapour readings obtained from an OVA; and • Collect soil sample for analysis. Record whether preservative was used and if so, the type of preservative in field notes. VOCs • Sample ID, date sampled, location, and depth interval; • Field observations including soil description; • Field measurements including vapour readings obtained from a PID; and • Collect soil sample for analysis. Record whether preservative was used and if so, the type of preservative in field notes. PCOCs Sampling Plan Metals, PAHs, salinity, • Sample ID, date sampled, location, and depth interval; herbicides, glycols, other • Field observations including soil description; and chemicals • Field screening measurements including readings obtained from an X-Ray Fluorescence (XRF) Analyzer (for metals) or other equivalent industry accepted instruments; and • Collect soil sample for analysis. Record whether preservative was used and if so, the type of preservative in field notes. PCOCs Sampling Plan PCBs • Sample ID, date sampled, location, and depth interval; • Field observations including soil description; • Field measurements including vapour readings obtained from a Clor-N-Soil 50 (for PCBs) or other equivalent industry accepted instruments; and • Collect soil sample for analysis. Record whether preservative was used and if so, the type of preservative in field notes. Asbestos Containing Materials • Sample ID, date sampled, location, and depth interval; • Field observations including soil or potential ACM description; • Field measurements including readings obtained from a microPHAZIR™ AS Asbestos Analyzer or other equivalent industry accepted instruments indicating presence of greater than 1% asbestos fibres (i.e., Chrysotile, Anthophyllite, Tremolite, Actinolite, Amosite/Crocidolite); and • Collect soil sample with ACM or ACMs for analysis.
During soil sample collection, appropriate PPE for the potential hazards must be worn by the Resource Specialist conducting the sampling. The Resource Specialist handling the soil and/or groundwater shall wear PPE in accordance with regulatory requirements, the Contractor Health and Safety Plan and site-specific requirements. PPE will include at a minimum hard hat, steel toe boots, safety glasses, reflective clothing and appropriate hand-wear and may include respirators and fire protective clothing.
5.2.1.4 Analytical Testing As appropriate, soil or groundwater samples will be submitted to an approved laboratory for analyses. Samples will be submitted for select analyses of the PCOCs based on the activities identified at the site. A list of the PCOCs associated with the properties in the updated CIPCS is provided below (Table 6). For each PCOC identified in Table 6, the media (i.e., soil, groundwater, and vapour) that is typically affected is identified in Table 7. PCOCs potentially affecting vapour are identified in Table 7; although vapour sampling is not proposed, field ambient air vapour and landfill gas monitoring will be performed as necessary as described in Section 5.2.3.
For suspected contaminated areas identified during construction, where historical activities at the site are unknown, selection of parameter analysis will be dependent on the field screening results and would include analyses of parameter suites rather than specific individual parameters (e.g., PAHs rather than only one individual PAH parameter).
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TABLE 6
TYPICAL PCOCS ASSOCIATED WITH SITE ACTIVITIES
Activity Typical PCOCs1 Gas Station/Cardlock Facility, Bulk Fueling Terminal PHCs, metals, PAHs, glycols, MTBE Well Site/Facility, Pump Station, Valve Site PHCs, metals, PAHs, salinity, herbicides. MTBE Industrial Facility (including saw mills, wood treatment, pulp and paper mills, PHCs, metals, PAHs, VOCs, glycols, PCBs, antisapstain, and other chemicals concrete facilities, chemical facilities, and mineral manufacturing facilities) specific to the process. Dry Cleaner VOCs Recycling and Waste Facilities Metals, nitrogen, chloride, phenols, VOCs, PHCs, glycols, PCBs Car salvage yard and vehicle maintenance facility PHCs, metals, PAHs, glycols Airport PHCs, metals, VOCs, glycols, salinity, chloride Railway Track PAHs, metals, herbicides, and additional contaminants such as PHCs if spills have occurred along the railway tracks. Activity Typical PCOCs1 Landfill The PCOCs will be specific to the disposal facility and may include: metals, nitrogen, chloride, phenols, VOCs, PHCs, PAHs, and/or methane. Naturally occurring deposits of Asbestos or potential ACMs Asbestos Note: 1 Metals, where specified as a PCOC, will be limited to those parameters that are associated with each type of activity. A detailed site history and understanding of contamination source is required to thoroughly prepare a detailed list of PCOCs for broad based activity types
TABLE 7
PCOCS AND APPLICABLE MEDIA
Typical PCOCs1 Matrix Typically Affected PHCs Soil, Groundwater, Vapour Metals Soil, Groundwater PAHs Soil, Groundwater, vapour (light molecular weight PAHs like naphthalene) Glycols Soil, Groundwater MTBE Groundwater VOCs Soil, Groundwater, Vapour PCBs Soil Salinity Soil, Groundwater Herbicides Soil, Groundwater Antisapstain Soil, Groundwater Phenols Soil, Groundwater Nitrogen Groundwater Methane Vapour Asbestos Soil, Air
5.2.2 Water The following section details how contaminated water, if encountered, will be characterized and handled during construction works.
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Dewatering 1. Obtain approval from an Environmental Inspector prior to initiating dewatering trench with activities. [Section 11.0 Stringing, Welding, Trenching and Lowering-in] potentially 3. Adhere to TMEP water discharge procedures for water discharge, if any. Notify the contaminated Environmental Inspector if water that has been potentially contaminated with water hydrocarbons or other materials is to be discharged from the trench and follow the Contamination Discovery Contingency Plan (Appendix B of the EPP). 4. Should water be encountered in the excavation in the area identified as contaminated and is required to be removed from the excavation, the water will be: • pumped from the excavation and placed in an on-site storage tank while the water is characterized; or • hydrovaced from the excavation and transported to an approved facility for storage and disposal once the water has been characterized. 5. The Contractor will have appropriate storage containers that are compatible with the anticipated site-specific PCOCs. 6. The Contractor will minimize the amount of overland surface water infiltrating into the open trench during rain events to minimize the volume of water to be removed from the excavation
5.2.2.1 Sampling Water sampling will be carried out and samples submitted for analysis of the PCOCs as determined by the Resource Specialist when:
• suspected contamination (i.e., staining, odour, sheen) is encountered;
• groundwater, if encountered, in high risk areas, as determined by the Resource Specialist; or
• water is stored or discharged from the pipeline construction footprint. Samples will be collected for analysis of parameters as determined by provincial or municipal discharge permit requirements and the PCOCs identified for the area, if any.
Water samples will be handled according to the BC Field Sampling Manual (BC MWLAP 2013) for areas located both in BC and Alberta. During sampling, the following information will be recorded:
• sample ID, date sampled, and location;
• field observations (i.e., water clarity, presence/absence of a sheen, etc.);
• field monitoring parameters (i.e., pH, temperature, electrical conductivity, and headspace vapours); and
• if field filtering or preservative, including the type, is added to the sample at the time of collection.
During sample collection, appropriate personal protective equipment (PPE) for the potential hazards must be worn by the Resource Specialist conducting the sampling and/or workers conducting the sampling and workers handling the groundwater. Those sampling or handling the groundwater shall wear PPE in accordance with regulatory requirements, the Contractor Health and Safety Plan and site-specific requirements. PPE will include at a minimum hard hat, steel toe boots, safety glasses, reflective clothing and appropriate hand-wear and may include respirators and fire protective clothing.
5.2.2.2 Analytical Testing Water samples will be submitted to an approved laboratory for analysis. Water samples will be submitted for select analyses of the PCOCs based on the activities identified. Refer to Section 4.6 for a list of PCOCs associated with the site activities.
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Water sample submissions for laboratory analyses will be approved by an Environmental Inspector and/or a Trans Mountain representative.
5.2.3 Ambient Air Vapour and Landfill Gas Monitoring The following section details how ambient air vapour or landfill gas monitoring, if elevated gas concentrations are encountered (e.g., landfills in Coquitlam high risk area or PCOCs that may be present in vapour phase), will be assessed during construction works.
Gas monitoring would include using a handheld gas detector (Eagle 2 or equivalent) on site when working in the area of high risk areas including landfills or areas suspect of contamination, to monitor ambient air for methane gas, carbon dioxide, hydrocarbon vapours, H2S and oxygen and provide associated thresholds and procedures to undertake if they are exceeded. Engineered controls to be used during the construction if thresholds are exceeded may include, at a minimum, ventilation to minimize the potential for landfill gas accumulation in the trenches.
As a general health and safety requirement all workers working within the pipeline trench are required to wear a 4-way personal gas monitor.
5.2.4 Waste Disposal Waste that is generated during construction will be managed following the provincial requirements of the applicable provincial jurisdiction. Specifically, the waste will be managed according to the Waste Control Regulation - Alberta Regulation 192/1996 and BC Hazardous Waste Regulations – B.C. Reg. 63/88. If contaminated soil is excavated, testing and approval is required prior to transportation and disposal at an approved disposal location.
Communication and documentation of the waste disposal testing and manifest requirements will be completed and kept on file as required by the applicable provincial jurisdiction. Waste disposal in Alberta and BC requires testing and approval prior to disposal.
5.2.5 Transportation of Waste
Waste and 1. Follow measures outlined in the Waste Management Standard (see Section 3.1 of Hazardous Volume 6 of the Environmental Plans) for storage of waste or hazardous materials Material on the work site. [Section 7.0 General Pipeline Construction Mitigation Measures] Storage 2. All personnel will be made aware of their responsibilities for proper handling, identification, documentation and storage of hazardous materials and wastes. [Section 7.0 General Pipeline Construction Mitigation Measures]
Prior to transportation or disposal of hazardous waste, a Provincial Identification Number (PIN) is required. In Alberta, a Hazardous Waste Consignor Registration form must be completed and submitted to AEP. In BC, a Schedule 5 Form 1 (S. 43) Registration Form will be completed and submitted to the BC MOE by Trans Mountain. The Generator Number will then be recorded on the hazardous waste manifests.
Approvals for disposal of the waste will be obtained from the selected landfills or facilities prior to moving the material.
Transportation of contaminated material shall only be undertaken as follows:
• waste management must follow the Waste Control Regulation (Alberta Regulation) or the BC Hazardous Waste Regulations as specified in Section 5.4;
• wastes shall only be removed for off-site disposal after the material has been characterized and there is a waste approval authorization from the accepting facility; and
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• the Resource Specialist shall be present when wastes are being transported off-site to ensure the appropriate manifests are completed and shall record the following information:
- transporter’s name, address, and license plate;
- the type and quantity of waste;
- PIN of the waste generating property;
- the name and address of the person or company the waste was delivered to (the consignee); and
- the date the waste was delivered to the consignee.
5.2.5.1 Authorized Disposal Facilities Prior to construction, disposal facilities will be identified and waste disposal capabilities (i.e., types of waste the facility is able to receive) will be confirmed including whether the facility is authorized to accept non-contaminated media, media exceeding commercial or industrial land use standards/guidelines, and hazardous waste material. The disposal facilities must be on the list of Trans Mountain approved facilities.
5.2.5.2 Alternative Disposal Locations Should alternative disposal locations be identified, they must be approved by Trans Mountain prior to use.
5.2.6 Contingency Planning A Contamination Discovery Contingency Plan has been developed, which will be implemented in the event that suspected contamination is discovered during construction so that mitigation measures and procedures are adequately employed to manage the identified contamination. The Contamination Discovery Contingency Plan demonstrates that Trans Mountain has taken appropriate measures to ensure its personnel, employees, contractors and subcontractors are prepared to effectively address any contamination discovered during construction. This Contamination Discovery Contingency Plan is located within the appendices of each of the EPPs (Volumes 1 through 5, 9 and 10 of the Environmental Plans).
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6.0 MONITORING AND REPORTING This section outlines Trans Mountain’s approach for monitoring prior to or during construction and associated reporting for pre-existing contamination.
6.1 Monitoring The following documentation is required for field environmental monitoring.
6.1.1 Excavation Monitoring During excavation monitoring where contamination is encountered, the Resource Specialist will document the following information:
• site characteristics;
• areas being excavated or backfilled;
• number of stockpiles, approximate volumes, and characterization of each;
• quantity and type of waste being removed from the site;
• quantity and type of backfill being used in the excavation;
• photographic records throughout the excavation works;
• environmental concerns (i.e., spills on-site from equipment);
• contamination in addition to what was anticipated; and
• sampling conducted including the number of samples collected and the parameters analyzed.
If suspected contaminated water is encountered during the excavation works, the following will be noted:
• colour, clarity, sheen (if present) and any odours;
• approximate depth and volume of water present;
• the approximate flow rate (if flowing into excavation);
• volume removed (if water is removed from the excavation), where stored, and if the water was treated;
• photo documentation of the water in the excavation and the storage area; and
• any environmental concerns (i.e., water filling the excavation resulting in overtopping of the excavation).
6.1.2 Material Tracking When contaminated soils are being removed from the site or clean imported material brought onto site, the following information will be documented or documents collected:
• tracking of contaminated soil stockpile locations including characterization of each stockpile and where the material in each stockpile originated from;
• tracking of clean imported soil and where the material was being backfilled;
• collection of waste transportation documentation (manifests, bill of lading, etc.) for each load of material transported off-site to an approved facility;
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• maintenance of a daily trucking log including;
- license plate of the truck(s);
- approximate volume of material transported off/on-site; and
- final material destination;
• record of the representative samples associated with each stockpile/load of material transported off-site.
6.2 Notification The Project will be constructed along several third-party properties with various current and historical activities which may have resulted in contamination to soil, groundwater, vapour, and/or sediments. Should existing contamination that is not sourced from Trans Mountain’s activities in these areas be identified prior to or during construction works, Trans Mountain will notify the owner of the property of the identified contamination as well as the NEB and other Appropriate Regulatory agencies, as appropriate, of contamination found within the construction footprint area. Trans Mountain will ensure contaminated waste material encountered during construction within the pipeline construction footprint is tracked and managed appropriately. Trans Mountain will not contact regulatory authorities directly regarding existing historical contamination on third-party properties that may extend beyond the construction footprint area. The responsible party, the land owner, at their discretion can notify the authorities as required by applicable laws and regulations.
Should impacts be identified on Trans Mountain properties or as a result of releases that occur as a result of Trans Mountain’s construction activities, Trans Mountain will implement appropriate mitigation and remediation measures in accordance with the NEB Remediation Process Guide (2011). Notification to regulatory agencies when contamination is identified, prior to or during construction, will proceed according to the NEB’s Remediation Process Guide (2011). The notification will be provided in writing to the NEB Secretary of the Board as soon as practicable as well as to other affected regulatory agencies, municipalities, Aboriginal groups and other stakeholders.
Trans Mountain will also notify water well owners if contamination is discovered during construction within 150 metres of a water well identified in Condition 93.
The notification process for each of the provincial regulators are described below.
Alberta In Alberta, Trans Mountain will report, under the Environmental Protection and Enhancement Act (EPEA), any contamination identified as the result of Trans Mountains operations that is or has the potential to migrate off the right-of-way or off facility and have an adverse effect to provincial lands. The initial reports are submitted by phone (1-800-222-6514) and a reference number will be issued. A written report must be submitted to AEP within seven days after the initial reporting. This applies to recent and pre-existing contamination.
British Columbia Off-site migration notification will be implemented in British Columbia should any contamination related to TMEP operations with the potential to migrate off the right-of-way or off facility be present.
If contamination is identified, and removed, Notification of Commencement and Completion of Independent Remediation (NIR) are required to be submitted to the BC MOE. A BC MOE Site Risk Classification is also required to be submitted with a NIR.
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6.3 Reporting In areas where contamination was encountered during construction, the following information will be recorded by the Resource Specialist:
• date of investigative works completed;
• location of the contaminated media encountered;
• quantity of contaminated soil transported off the property;
• quantity of water, if any, treated or transported off the property;
• identify the receiving location(s) for the soil or groundwater;
• quantity of soils replaced in the excavation including the amount of sourced material;
• analytical results of the characterization sampling completed; and
• analytical results for the backfill material.
The records should ensure materials are tracked from excavation to disposal or reuse destinations.
The information listed above will be used in reporting to the NEB under the Remediation Process Guide (2011) as well as other agencies and stakeholders.
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7.0 RELEVANT STANDARDS, GUIDELINES AND PRACTICES This Plan has been developed in accordance with the applicable provincial and federal guidance and regulatory policies. The standards, guidelines and practices that are specific to the Contamination Identification and Assessment Plan and have been considered in the preparation of the Plan are presented below.
7.1 Federal Guidance and Regulatory Policy The federal regulatory guideline for handling of contamination is the NEB Remediation Process Guide and the federal regulatory policy and guidance document is defined by the CCME. The CCME developed the Canadian Environmental Quality Guidelines (CEQGs) (CCME 1999) for the quality of aquatic and terrestrial ecosystems including guidelines for water quality, soil quality, and sediment quality. The guidelines were developed to protect ecological receptors in the environment as well as human health associated with the types of land and water use. The environmental soil quality guidelines are derived using toxicological data to determine the threshold level of effects for the key ecological receptors. In addition to the CEQGs, CCME also developed the Canada-Wide Standards (CWS) for Petroleum Hydrocarbons (PHC) (CCME 2001) F1-F4 at federal sites in soil.
7.2 Provincial Guidance and Regulatory Policies The key provincial regulatory policy and guidance documents include:
• AEP Alberta Environmental Site Assessment Guidelines Draft (Government of Alberta 2013); and
• BC MOE Environmental Management Act (EMA).
The Alberta EPEA and the Water Act form the legislative basis of AEP's policies on the management of contaminated soil and groundwater. The Alberta Environment and Sustainable Resource Development Tier I and Tier II Soil and Groundwater Remediation Guidelines (2014) provides the guidelines for soil and groundwater remediation. The Waste Control Regulation (Alberta Regulation 192/1996 amended 62/2013) provides for a transportation tracking system, and an approval process for storage, treatment and disposal facilities for hazardous waste and hazardous recyclables. The broad framework to manage these wastes is established in Alberta’s EPEA.
The EMA is the primary element of the legislative framework protecting the environment and human health in BC. The EMA sets out the requirements for investigation, management, and remediation of contamination within the province, and also prescribes requirements for waste disposal and discharge. There are multiple regulations that provide standards, protocols, and guidelines to enable the Act including the CSR (BC Regulation 184/2016) and the Hazardous Waste Regulation (HWR) (B.C. Regulation 179/2016). The CSR is the enabling regulation under the EMA that includes procedures for the investigation and reporting of contamination. The CSR prescribes numerical standards for soil, sediment, groundwater, and vapour quality for specific land, sediment, and groundwater uses. A new set of CSR standards, Stage 10 (Omnibus) will be in effect as of November 2017. Any contaminated site work to be completed subsequent to that date will incorporate the new standards. The HWR regulates the handling, storage, transportation, treatment and disposal of hazardous waste in BC.
As landfills have been identified as high risk sites within BC, the applicable regulations and guidelines specifically regarding landfills include:
• Landfill Gas Management Regulation (LGMR), R/1243/2008/48, effective January 1, 2009;
• Landfill Gas Management Facilities Design Guidelines, prepared by Conestoga-Rovers & Associates for the BC Ministry of Environment March 2010 pursuant to Section 7 of the LGMR;
• Landfill Criteria for Municipal Solid Waste, 2016;
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• Landfill Criteria for Municipal Solid Waste, Draft Interim Second Edition, November 2013, and;
• Guidelines for Environmental Monitoring at Municipal Solid Waste Landfills, Ministry of the Environment.
Some of these documents referenced above apply to only operating landfills and after 2009. However, the following documents have relevant sections pertaining to closed landfills:
• Section 7 and 10.3.4 of the Landfill Criteria for Municipal Waste, Second Edition, and;
• Sections 3, 4, 5 and 6 of the Guidelines for Environmental Monitoring at Municipal Solid Waste Landfills.
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8.0 SUMMARY Trans Mountain submitted a Facilities Application (the Application) to the NEB in December 2013 for the Project. On May 19, 2016, Trans Mountain received the NEB’s Conditions for the Project. This Plan was completed to ensure appropriate handling of contamination to protect workers, public and the environment and demonstrates Trans Mountain’s commitment to mitigate potential risk from exposure to pre-existing contamination in soil and/or water that could be disturbed by, or affect, the Project. This Plan addresses the requirements of NEB Condition 46.
Trans Mountain undertook a review of potentially contaminated areas along the Project corridor including conducting publicly available historical searches. An inventory of potentially contaminated sites was developed and the properties located along the Project corridor were characterized as having a low, moderate, or high risk for encountering contamination within the Project Footprint. The review identified 40 properties classified as moderate risk and four areas classified as high risk. The four high risk areas include portions of the Project Footprint which crosses through the former University of Alberta Ellerslie Waste Management Facility in Edmonton (KP 26.3 to KP 26.8), Kamloops Airport (KP 840.9 to KP 841.5), Surrey/Langley area (KP 1154.8 to KP 1157.9) and City of Coquitlam (KP 1168.7 to KP 1173.1) in BC. A search of the BC Site Registry was completed to identify, where available, previously collected data to assess sites ranked as high risk. For the site located in Alberta, a search of the Alberta Environmental Site Assessment Repository was conducted as well for publicly available reports in university and government libraries. Through this review, it was determined that an intrusive environmental investigation was required for three high risk properties in Surrey/Langley (two) and Coquitlam (one) high risk areas prior to construction. A summary of the environmental investigation results has been included in this report and will be used to for pre-construction hazard assessment and development of safe work procedures and contamination management planning in preparation of construction activities in these areas.
During construction in high risk areas, a Resource Specialist will be on site during work in these areas to determine the appropriate handling and mitigation measures if contamination is encountered. When working in areas of moderate risk, the Environmental Inspector will ensure workers are aware of the potential to encounter contamination. In the event unexpected contamination is encountered the Contamination Discovery Contingency Plan (Appendix B of the EPPs) will be initiated, and a Resource Specialist will direct response activities.
The Project will be constructed along several third-party properties with various current and historical activities, which may have resulted in impacts to soil, groundwater, vapour, and/or sediments. Should impacts in the Project Footprint be identified prior to or during construction works, Trans Mountain will notify the NEB, as well as the owner of the property of the impacts. Trans Mountain will also notify water well owners if contamination is discovered during construction within 150 metres of a water well identified in Condition 93. Trans Mountain will ensure contaminated waste material encountered during construction within the pipeline construction footprint is tracked and managed appropriately. Should impacts be identified on Trans Mountain properties, or as a result of Trans Mountain construction or historical activities, Trans Mountain will address them and provide notification to NEB according to the guidance provided in the NEB Remediation Process Guide (2011).
Trans Mountain has initiated consultation and will continue to work with Appropriate Government Authorities, landowners, and any potentially affected Aboriginal groups to ensure that issues concerning contamination are addressed. Trans Mountain has also provided responses to IRs on issues related to potential contamination as a result of the NEB hearing process.
This Plan outlines the identification and assessment of areas of potential contamination along the Project Footprint. This Plan will be part of the Environmental Management Plans (Section 3.0 of Volume 6 of the Environmental Plans) to ensure that the applicable procedures for managing contamination are followed, and where necessary, the applicable mitigation measures are implemented.
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9.0 REFERENCES Alberta Environment and Sustainable Resource Development. 2014. Tier I and Tier II Soil and Groundwater Remediation Guidelines (2014). Website: http://esrd.alberta.ca/lands-forests/land- industrial/inspections-and-compliance/documents/AlbertaTier1Guidelines-May23-2014.pdf; http://esrd.alberta.ca/lands-forests/land-industrial/inspections-and- compliance/documents/AlbertaTier2Guidelines-May21-2014.pdf
AMEC Earth & Environmental (AMEC). 2008. University of Alberta Ellerslie Waste Management Facility. 210 – 127 Street, Edmonton, Alberta. 2008 Annual Report including the Groundwater Monitoring Program. Submitted to: University of Alberta, Office of Environmental Health & Safety, Edmonton, Alberta. December. Available through Alberta Government Library.
British Columbia Ministry of Environment. 1990. Environmental Management Act – Spill Reporting Regulation. Website: http://www.bclaws.ca/civix/document/id/complete/statreg/263_90. Accessed: August 22, 2016.
British Columbia Ministry of Environment. 2005. Technical Guidance 10 – Checklist for Reviewing a Preliminary Site Investigation. Website: http://www.env.gov.bc.ca/epd/remediation/guidance/technical/pdf/tg10.pdf. Accessed: January 14, 2016.
British Columbia Ministry of Environment. 2009. Technical Guidance 1 – Site Characterization and Confirmation Testing. Website: http://www.env.gov.bc.ca/epd/remediation/guidance/technical/pdf/tg01.pdf. Accessed: January 14, 2016.
British Columbia Ministry of Water, Land and Air Protection. 2013. British Columbia Field Sampling Manual. Website: http://www.env.gov.bc.ca/epd/wamr/labsys/field-sampling- manual/pdf/2013/field_sample_man2013.pdf. Accessed January 14, 2016.
BGC Engineering. Impacts of Pipeline Construction Across Historic Coquitlam Landfills. Prepared for Transfer Mountain Pipeline ULC, Trans Mountain Expansion Project. April 2016.
Canadian Council of Ministers of the Environment. 1999. Canadian Environmental Quality Guidelines. Website: http://www.ccme.ca/en/resources/canadian_environmental_quality_guidelines/. Accessed November, 2015.
Canadian Council of Ministers of the Environment. 2001. Canada-wide Standards for Petroleum Hydrocarbons in Soil. Website: http://www.ccme.ca/en/resources/contaminated_site_management/phc_cws_in_soil.html. Accessed January 14, 2016.
Canadian Council of Ministers of the Environment. 2016. Guidance Manual for Environmental Site Characterization in Support of Environmental and Human Health Risk Assessment, Volume 1 Guidance Manual. Website: GuidanceManualEnvironmentalSiteCharacterization.
Government of Alberta. 2013. Alberta Environmental Site Assessment Standard (Draft for review only). Print.
National Energy Board. 2011. Remediation Process Guide. Website: https://www.neb- one.gc.ca/sftnvrnmnt/nvrnmnt/rmdtnprcssgd/rmdtnprcssgd-eng.pdf. Accessed January 21, 2016.
TERA Environmental Consultants. 2013a. Draft – Cursory Inventory of Potentially Contaminated Sites for the Trans Mountain Pipeline ULC Trans Mountain Expansion Project. Prepared for Trans Mountain Pipeline ULC. October.
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TERA Environmental Consultants. 2013b. Environmental and Socio-Economic Assessment for the Trans Mountain Pipeline ULS Trans Mountain Expansion Project – Volume 5A: ESA – Biophysical – Section 7.0: Environmental Effects Assessment. Prepared for Trans Mountain Pipeline ULC. December.
TERA Environmental Consultants. 2013c. Preliminary Draft – Desktop Phase I Environmental Site Assessment of Edmonton Station for the Trans Mountain Pipeline ULC. Prepared for Trans Mountain Pipeline ULC. May.
TERA Environmental Consultants. 2013d. Desktop Phase I Environmental Site Assessment of Subject Property at KP 83 for the Trans Mountain Pipeline ULC. Prepared for Trans Mountain Pipeline ULC. July.
TERA Environmental Consultants. 2013e. Desktop Phase I Environmental Site Assessment of Subject Property at KP 253 for the Trans Mountain Pipeline ULC. Prepared for Trans Mountain Pipeline ULC. July.
TERA Environmental Consultants. 2013f. Desktop Phase I Environmental Site Assessment of Albreda Pump Station for the Trans Mountain Pipeline ULC. Prepared for Trans Mountain Pipeline ULC. July.
TERA Environmental Consultants. 2013g. Desktop Phase I Environmental Site Assessment of Subject Property at KP 470 for the Trans Mountain Pipeline ULC. Prepared for Trans Mountain Pipeline ULC. July.
TERA Environmental Consultants. 2013h. Desktop Phase I Environmental Site Assessment of Subject Property at KP 472 for the Trans Mountain Pipeline ULC. Prepared for Trans Mountain Pipeline ULC. July.
TERA Environmental Consultants. 2013i. Desktop Phase I Environmental Site Assessment of Blackpool Pump Station for the Trans Mountain Pipeline ULC. Prepared for Trans Mountain Pipeline ULC. July.
TERA Environmental Consultants. 2013j. Preliminary Draft – Desktop Phase I Environmental Site Assessment of Kamloops Pump Station for the Trans Mountain Pipeline ULC. Prepared for Trans Mountain Pipeline ULC. July.
TERA Environmental Consultants. 2013k. Desktop Phase I Environmental Site Assessment of PetroCan Takeoff Station for the Trans Mountain Pipeline ULC. Prepared for Trans Mountain Pipeline ULC. July.
TERA Environmental Consultants. 2013l. Desktop Phase I Environmental Site Assessment of Hope Pump Station for the Trans Mountain Pipeline ULC. Prepared for Trans Mountain Pipeline ULC. July.
TERA Environmental Consultants. 2013m. Desktop Phase I Environmental Site Assessment of Wahleach Pump Station for the Trans Mountain Pipeline ULC. Prepared for Trans Mountain Pipeline ULC. July.
TERA Environmental Consultants. 2013n. Desktop Phase I Environmental Site Assessment of Burnaby Terminal for the Trans Mountain Pipeline ULC. Prepared for Trans Mountain Pipeline ULC. August.
TERA Environmental Consultants. 2013o. Preliminary Draft – Desktop Phase I Environmental Site Assessment of Westridge Marine Terminal for the Trans Mountain Pipeline ULC. Prepared for Trans Mountain Pipeline ULC. August.
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APPENDIX A
TMEP MANAGEMENT OF PRE-EXISTING CONTAMINATION FLOW CHART
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Pre‐Existing Contamination Identification and Pre‐Construction Activities Construction Activities Post‐Construction Activities Assessment
Property Identified in Low Risk Property ‐ Conduct site visit to confirm Soil the updates to the YES Site Activities are YES Identified in the updates to activities at the Subject Property are ‐ Notify regulatory agencies per Cursory Inventory of reflective of the CIPCS as having current those identified during the updates Section 6.2 Potentially updates to the CIPCS. Contaminated Sites and/or historical activities to the CIPCS. ‐ Review PPE requirements to ensure (CIPCS) that are not likely to have sufficient for contamination resulted in contamination NO encountered. NO impacting the pipeline ‐ Identify field indicators of impact corridor. and characterize soils per AEP/BC TG1 (refer to Section 5.2.1.2 and 5.2.1.3). ‐ Segregate and stockpile soils (refer to Section 5.2.1.1). Re‐assess based on a ‐ Site personnel wear ‐ Assess to confirm reuse, disposal, site visit to determine appropriate PPE. and handling procedures (refer to if Subject Property is ‐ Screen/characterize soils Section 5.2.1.1). low, moderate, or per AEP/BC TG1 (refer to ‐ Coordinate with soil disposal ‐ Have materials available to create Moderate or High Risk high risk. Section 5.2.1). facilities (refer to Section 5.2.3 and Property temporary stockpile areas should ‐ Screen/characterize Contamination YES 5.2.4). Identified in the updates contaminated soil be encountered. groundwater per BC Field Identified CIPCS (Sections 4.5, 4.6, and ‐ Have available a list of waste Water Sampling Manual and CCME ‐ Upon completion of 4.7) as the following: disposal sites for the potential ‐ Notify regulatory agencies per Guidance Manual (refer to construction/management of ‐ Historical TMEP spills contaminant types in the area. Section 6.2. Section 5.2.2). contaminated soil and/or water ‐ Well sites NO ‐ Review PPE requirements to ensure Contamination prepare a summary report Identification and ‐ Gas Stations/Cardlocks sufficient for contamination Handle as potentially contaminated YES detailing the investigation findings Assessment Plan not ‐ Landfills encountered. during construction with stockpile and works completed and notify required to be ‐ Dry cleaners Contamination ‐ Characterize water (refer to Section and sampling [or pre‐investigate if NO regulators per Section 6.2 and 6.3. implemented. ‐ Industrial areas (excluding Identified 5.2.2.1 and 5.2.2.2). those identified in the High preferred] ‐ Contain water (refer to Section Risk Properties) 5.2.2). ‐ Surrey/Langley Area Soil ‐ Coordinate with waste disposal identified as a High Risk ‐ Notify regulatory agencies per Section 6.2. facilities (refer to Section 5.2.3 and Property ‐ Prepare site specific contaminant management 5.2.4). ‐ Coquitlam Area identified as procedures including appropriate HSE precautions a High Risk Property reflecting findings of the pre‐construction investigation. Contaminated media ‐ Identify field indicators of impact and collect discovery is NO additional soil samples to characterize soils to be suspected during disposed of to meet AEP/BC TG1 (refer to Sections ‐ Re‐use of non‐contaminated soils construction. 5.2.1.2 and 5.2.1.3). as per Section 5.2.1.1. ‐ Conduct pre‐investigation ‐ If stockpiling prior to disposal, segregate soils activities along the pipeline according to characterization, if required (refer to YES corridor, as necessary to Section 5.2.1.1). High Risk Property assess hazards and plan ‐ If hot loading soils for disposal refer to Section Stop works and Identified in the updates to waste management 5.2.1.1. YES contact the the CIPCS (Sections 4.5, 4.6, needed. Contamination ‐ Assess to confirm reuse, disposal, and handling ‐ Upon completion of Supervisor or and 4.7) as a property with ‐ Map boundaries of Identified procedures (refer to Section 5.2.1.1). construction/management of Environmental current and/or historical identified contaminated ‐ Coordinate with waste disposal facilities (refer to contaminated soil and/or water Inspector. activities that could impact material and potential Section 5.2.3 and 5.2.4). prepare a summary report Project Footprint. contamination relevant to Water detailing the investigation findings Project Footprint. ‐ Notify regulatory agencies per Section 6.2. and works completed and notify NO ‐ Prepare site specific contaminant management regulators per Section 6.2 and 6.3. procedures including appropriate HSE precautions reflecting findings of the pre‐construction investigation. ‐ Characterize water (refer to Section 5.2.2.1 and 5.2.2.2). ‐ Contain water (refer to Section 5.2.2). ‐ Coordinate with waste disposal facilities (refer to Section 5.2.3 and 5.2.4). Trans Mountain Pipeline ULC Contamination Identification and Assessment Plan Trans Mountain Expansion Project 687945/August 2017
APPENDIX B
CONSULTATION AND ENGAGEMENT Consultation and engagement activities related to the contamination identification and assessment were completed with Appropriate Government Authorities, potentially affected Aboriginal groups, and affected landowners/tenants. Opportunities to discuss contamination and identify issues or concerns were also provided to stakeholders during workshops and ongoing engagement activities. Consultation and engagement opportunities began in May 2012 with the Project announcement and are ongoing.
1.0 CONSULTATION AND ENGAGEMENT OVERVIEW: DRAFT PLAN DEVELOPMENT Reports on public consultation activities completed between May 2012 and June 30, 2015 were filed with the NEB and are available in the Application (Volume 3A: Stakeholder and Volume 3B: Aboriginal; Filing ID A55987) as well as in Consultation Update No. 1 and Errata, Technical Update No. 1 (Filing ID A59343) / Consultation Update 2 (Filing IDs A62087 and A62088), Consultation Update 3 (Filing IDs A4H1W2 through A4H1W8) and Consultation Update 4 (Filing ID A72224). These reports include results of consultation conducted to date, identification of issues and concerns as well as Trans Mountain’s response and are included below. Where appropriate, Trans Mountain’s response has been updated to reflect information developed since the original response was provided during the NEB proceeding for the Project.
Consultation and engagement activities completed between July 1, 2015 and February 2017 have not been filed on the public record with the NEB. Any new issues and concerns identified during this period, as well as Trans Mountain’s response, are described below. 2.0 CONSULTATION AND ENGAGEMENT OVERVIEW: DRAFT PLAN The draft Plan was released for review and feedback November 22, 2016. The comment period closed on February 28, 2017. Email or mail notification regarding the Plan was sent to 141 public stakeholders, 17 regulatory authorities, 114 Aboriginal groups and all affected landowners. The notification included a summary description of the Plan, a request for review, the timing of the comment period and contact information. Aboriginal groups were offered the opportunity for an in-person meeting to review the Plan. See Appendix F for a complete list of notified stakeholders. In addition to direct notification, the online posting of each Plan was promoted through Trans Mountain's weekly e-newsletter, Trans Mountain Today, which provides Project updates, regulatory information, stories and interviews to more than 6,000 subscribers. Each week Trans Mountain Today included a focus on a specific plan, or group of plans, as well as a reminder of all plans available for review.
2016: • September 22 - Wildlife Mitigation and Habitat Restoration Plans;
• September 29 - Pipeline Environmental Protection Plans;
• October 6 - Air Quality Management Plans;
• October 13 - Watercourse and Water Ecosystems Plans;
• October 20 - Vegetation Management Plans;
• October 27 - Air Quality Plans;
• November 3 - Socio-Economic Effects Monitoring Plan;
• November 10 - Access Management Plan;
• December 22 - General promotion all plans; and
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• December 29 - General promotion all plans.
2017: • January 5 - General promotion all plans; and
• January 12 - General promotion all plans.
Trans Mountain is committed to ongoing engagement throughout the life of the Project. The start and end date for the review and comment period for each environmental management plan is defined. These timelines are required to allow time for preparation of the final Plan in order to meet regulatory requirements and NEB submission dates.
3.0 CONSULTATION AND ENGAGEMENT: ACTIVITIES AND FEEDBACK
Consultation and engagement activities completed with identified stakeholder groups are described below, including: public stakeholders (Section 3.1); regulatory authorities (Section 3.2); Aboriginal groups (Section 3.3); and landowner/tenants (Section 3.4).
Feedback on the draft Plan, Trans Mountain’s response, and where each issue or concern is addressed in the Plan has been outlined in each section according to stakeholder group.
3.1 Public Consultation 3.1.1 Public Consultation Summary – May 2012 to June 2015 Feedback regarding the Contamination Identification and Assessment Plan received during public consultation and engagement activities between May 2012 and June 30, 2015 is summarized in Table B-1.
TABLE B-1
SUMMARY OF PUBLIC CONSULTATION - MAY 2012 TO JUNE 30, 2015*
Issues or Concern Summary Trans Mountain Response Where Addressed South Coquitlam was built on landfill (broader The extent of the landfills in the Coquitlam area is known to Trans Mountain Volume 4B - Project than just Eagle Quest Golf Course). Landfill and has been taken into consideration for the pipeline design and Design and Execution - creates leachate, ground disturbance issues, contaminated sites management. The landfills have been identified as a Construction and issues with methane controls. high risk for potential for contamination. Trans Mountain commits to having Section 4 and 5 of this Plan a qualified Resource Specialist to be present during trench excavation activities where there is a high risk of contamination. In the event contamination is discovered during construction, the Contamination Discovery Contingency Plan will be implemented (found in the appendices of the Project-specific EPPs, Volumes 1 through 5, 9 and 10 of the Environmental Plans). Study corridors have pre-existing industrial A review and risk ranking of publicly available documents for identified Volume 5A - ESA - contamination that may be disturbed by contaminated sites has been completed. High risk for potential Biophysical pipeline construction and may need to be contamination sites have been identified and pre-assessment in these Section 4 of this Plan remediated. areas will be completed to confirm anticipated contamination levels. Will need to plan for appropriate mitigation and Trans Mountain commits to having Inspectors for identifying and mitigating Volume 5A - ESA - handling of industrial heavy metal environmental effects, including contamination during construction. Trans Biophysical hydrocarbons and potential asbestos in the Mountain commits to having a qualified Resource Specialist to be present Section 4 and 5 of this Plan soil. during trench excavation activities where there is a high risk of contamination. In the event contamination is discovered during construction, the Contamination Discovery Contingency Plan will be implemented (found in the appendices of the Project-specific EPPs, Volumes 1 through 5, 9 and 10 of the Environmental Plans). Note: * Included in NEB Project proceedings.
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3.1.2 New Interests, Issues, Concerns and Response – July 2015 to February 2017 No new issues or concerns with respect to contamination identification and assessment were raised by stakeholders through engagement and communication opportunities during the July 2015 to February 2017 reporting period.
3.2 Regulatory Consultation Trans Mountain has initiated consultation and will continue to work with appropriate government authorities to ensure that issues concerning contamination are addressed and responses have been provided. The consultation activities and feedback with government authorities with specific relevance to this Plan are summarized in Table B-2.
3.2.1 Regulatory Consultation Summary – May 2012 to June 2015 Feedback regarding contamination and identification assessment plan received during regulatory consultation between May 2012 and June 30, 2015 is summarized in Table B-2.
3.2.2 Feedback Regarding the Draft Plan (July 2015 to February 2017) Regulatory feedback regarding the draft Plan is described in Table B-3.
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TABLE B-2
SUMMARY OF GOVERNMENT AUTHORITY CONSULTATION ACTIVITIES RELATED TO THE PLAN (MAY 2012 TO JUNE 2015)
Date of Commitments/ Stakeholder Group/Agency Method of Consultation Follow-up Actions/ Name Contact Activity Comments/Summary Comments Where Addressed in Plan? Parks Canada Agency - Email March 19, 2013 J. Deagle informed that Parks Canada had no registered No follow-up related to contaminated sites Section 4.0 identifies moderate and high risk sites. No Jasper National Park contaminated sites of the coordinates provided. sites are listed in Jasper National Park. Parks Canada Agency - Meeting October 2, 2013 Team members met with Jasper National Park staff to No follow-up related to contaminated sites Section 4.0 identifies moderate and high risk sites. No Jasper National Park discuss the scope of NPS 24 TMPL system reactivation sites are listed in Jasper National Park. through Jasper National Park, results of spills studies, valve automation and placement scenarios and vehicle access. City of Abbotsford Meeting March 5, 2014 Team members had a meeting to discuss examples of No follow-up related to contaminated sites Section 5.0 pipeline interactions with existing infrastructure, topsoil handling, general pipeline construction and soil handling procedures, drainage and surface irrigation, ditches and canals and post-construction monitoring.
Page B - 4
TABLE B-3
SUMMARY OF GOVERNMENT AUTHORITY CONSULTATION ACTIVITIES RELATED TO THE PLAN (JULY 2015 TO FEBRUARY 2017)
Date of Commitments/ Stakeholder Group/ Method of Consultation Follow-up Actions/ Agency Name Contact Activity Comments/Summary Comments Where Addressed in Plan? Conference call with ESD Phone; Email January 19, 2017 Two areas of high risk (two properties - former Fraser Mills Revisions to the Plan included updating Section 4.0 Condition 46, Section 4.0, Appendix D (Margaret Birch, Hagan site and Coquitlam Landfill) fall within the project footprint and Appendix D to include publicly available Hohndorf); feedback also in the City of Coquitlam (KP 1168.5 to KP 1173) - City of information regarding the two high risk areas. In Condition 46, Section 5.0 provided via email to SE&C on Coquitlam landfills high risk area. Risk is high - potential addition, a pre-assessment investigation was January 12, 2017 contaminants to be found: PHCs, metals, PAHs, VOCs, completed at the Fraser Mills property and results of Condition 46, Section 6.0 PCBs, glycols, antisapstain, and other chemicals. During the investigation are summarized in Section 4 and construction in high risk areas, a Resource Specialist will Appendix E of the Plan. be on site during work in these areas to determine the Section 5.0 details the requirement for a Resource appropriate handling and mitigation measures if Specialist at high risk sites. contamination is encountered. When working in areas of Section 6.0 identifies reporting provisions and states moderate risk, the Environmental Inspector will ensure that reporting will be provided to workers are aware of the potential to encounter stakeholders. However, only regulatory notifications contamination. In the event unexpected contamination is and any supporting reports, (as needed) will be encountered the Contamination Discovery Contingency provided to the provincial Site Registry. Plan (Appendix B of the Environmental Protection Plans Page B [EPPs]) will be initiated, and a Resource Specialist will direct response activities.
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5 The City of Coquitlam requests that any inspection and resultant contamination investigation reports be provided to the City for information and future reference. Any reports prepared shall be supplied by the proponent to the Provincial Site Registry. BC MOE, BC Parks, FLNRO Webinar February 17, 2017 Trans Mountain hosted a webinar to review the draft Plan. This Plan was developed to identify and assess pre- Condition 46, Sections 4 & 5 Presentation Questions received during the webinar were: existing contamination that could be disturbed by or • Is there a summary of the works completed over the affect the Project (Sections 4 and 5). It has been last few years? posted for comment on the www.transmountain.com • There seems to be some intrusive work being done at website three high risk sites. Has it caused TMEP to develop Trans Mountain has identified within this Plan site specific precautionary approaches? Or do the procedures to manage contamination during risks vary, so it is more of a reactive process? Is there construction including ensuring mitigation measures any cautionary activity? What is done with the pre- are in place for preventing the pipeline trench from assessment information? Do you prepare the corridor being a preferential pathway conduit for properly as part of the construction plan? Are any contamination (Section 5). Trans Mountain commits remedial activities completed before construction to having a qualified Resource Specialist to be starts? present during trench excavation activities where there is a high risk of contamination. No revisions to the Plan were made as a result of the comments.
Trans Mountain Pipeline ULC Contamination Identification and Assessment Plan Trans Mountain Expansion Project 687945/August 2017
3.3 Aboriginal Engagement Since April 2012, Trans Mountain has engaged with Aboriginal communities that might have an interest in the Project or have Aboriginal interests potentially affected by the Project, based on the proximity of their community and their assertion of traditional and cultural use of the land along the Project corridor to maintain a traditional lifestyle. The objectives of Aboriginal engagement are to:
• have an open, transparent and inclusive process that seeks to exchange information in a respectful manner;
• address concerns shared by those who might have an interest in the Project or have Aboriginal interests potentially affected by the Project;
• incorporate feedback into Project planning and execution; and
• provide opportunities to maximize Project benefits to Aboriginal communities and Aboriginal groups.
A comprehensive Aboriginal engagement process is led by experienced engagement advisors in Alberta and BC, specialized in the areas of Aboriginal relations, law, economic development, education, training, employment and procurement. Trans Mountain’s engagement process for the Project is flexible, allowing each community and group to engage in meaningful dialogue in the manner they choose and in a way to meet their objectives and values.
Each community had the opportunity to engage with Trans Mountain, depending on Project interests and potential effects. The following opportunities to engage have been provided:
• Project announcement;
• initial contact with Aboriginal community or Aboriginal group;
• meetings with Chief and Council and meetings with staff;
• host community information session(s);
• conduct Traditional Land Use studies and socio-economic interviews;
• identify interests and concerns; and
• identify mitigation options.
Issues and concerns related to contamination raised during Aboriginal engagement from between early 2012 to February 2017 are summarized in Table B-4.
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TABLE B-4
SUMMARY OF ABORIGINAL ISSUES AND CONCERNS RELATED TO CONTAMINATION
Issue or Concern Date of Where Summary Aboriginal Group Method of Contact Consultation Activity Summary Trans Mountain Response Addressed Proximity of pipeline to existing asbestos Gunn Métis Local 55 Supplemental Filing No. December 2014 This Plan was developed to identify and assess pre-existing contamination that Section 4 dump, and risk of environmental 2 to NEB could be disturbed by or affect the Project. and 5 of contamination. Trans Mountain commits to having Inspectors for identifying and mitigating this Plan Traditional Land Use August 21, 2014 environmental effects, including contamination during construction. Trans Study provided to Trans Mountain commits to having a qualified Resource Specialist to be present during Mountain trench excavation activities where there is a high risk of contamination. In the event contamination is discovered during construction, the Contamination Discovery Contingency Plan will be implemented (found in the appendices of the Project-specific EPPs, Volumes 1 through 5, 9 and 10 of the Environmental Plans). Concern about recent spill and contamination Lower Nicola Indian Band Aboriginal Oral Hearing November 14, 2014 This location is known and is being managed by from that spill Trans Mountain. at approximately 50 m east of KP 949.8. Trans Mountain commits to having Inspectors for identifying and mitigating environmental effects, including contamination during construction. Trans Mountain commits to having a qualified Resource Specialist to be present during trench excavation activities where there is a high risk of contamination. In the event
Page B contamination is discovered during construction, the Contamination Discovery Contingency Plan will be implemented (found in the appendices of the Project-specific EPPs, Volumes 1 through 5, 9 and 10 of the Environmental Plans).
- Concern about old dump site identified at Simpcw First Nation Field survey/Traditional June 6-10, 2013 This Plan was developed to identify and assess pre-existing contamination that could 7
approximately 30 m south of KP 670.4 and Ecological Knowledge be disturbed by or affect the Project. There are no known high or moderate risk sites potential leaching into stream at this location. Trans Mountain commits to having Inspectors for identifying and mitigating environmental effects, including contamination during construction. Trans Mountain commits to having a qualified Resource Specialist to be present during trench excavation activities where there is a high risk of contamination. In the event contamination is discovered during construction, the Contamination Discovery Contingency Plan will be implemented (found in the appendices of the Project-specific EPPs, Volumes 1 through 5, 9 and 10 of the Environmental Plans). Concern about potential Project contamination Coldwater First Nation Coldwater First Nation May 12, 2014 This Plan was developed to identify and assess pre-existing contamination that Section 4 impacts to water and aquatic habitat, including Information Request could be disturbed by or affect the Project. and 5 of but not limited to the aquifer located beneath filing Trans Mountain committed to assess the aquifer in and around IR #1, as per NEB this plan Coldwater Indian Band IR #1, the surface Condition 39. The aquifer assessment and site specific mitigation measures will be water flows in and around IR #1 and fish and developed prior to construction. fish-bearing watercourses within Nlaka’pamux Trans Mountain commits to having Inspectors for identifying and mitigating territory. environmental effects, including contamination encountered during construction. Trans Mountain commits to having a qualified Resource Specialist to be present during trench excavation activities where there is a high risk of encountering contamination. In the event contamination is discovered during construction, the Contamination Discovery Contingency Plan will be implemented (found in the appendices of the Project-specific EPPs, Volumes 1 through 5, 9 and 10 of the Environmental Plans).
TABLE B-4 Cont'd
Date of Consultation Issue or Concern Method of Activity Where Summary Aboriginal Group Contact Summary Trans Mountain Response Addressed Concern about spills over Halalt First Nation Letter February 24, 2017 NEB Condition 46, requires that pre-existing contamination that could be disturbed by or affect the Section 3 100 barrels as a threshold to Project be identified and assessed. Therefore, carrying out desktop reviews for sites with releases over be reported as a spill under 100 barrels was selected based on the condition criteria. the Environmental Trans Mountain is federally regulated and complies with all spill reporting and remediation Management Act. (Historic requirements identified by the National Energy Board (NEB) and the NEB Remediation Process Guide Spills, Section 3 Approach) (2011). The NEB’s release reporting and remediation criteria have changed several times since they were initially established. Trans Mountain’s past and current practice is to conduct remedial activities in compliance with the applicable reporting and remediation requirements of the time. While no spills are acceptable, when one does happen, it is cleaned up with the oversight of the National Energy Board. In addition, the majority of spills happen within facilities where containment is complete and clean-up can be done quickly with very little or no environmental impact and cost. Concern about Standard of Halalt First Nation Letter February 24, 2017 This Plan was developed to identify and assess pre-existing contamination that could be disturbed by Sections 4 and Care in British Columbia and or affect the Project (Sections 4 and 5). 5 B-4expectation of this Trans Mountain has identified within this Plan procedures to manage contamination during construction standard to be applied to all including ensuring mitigation measures are in place for preventing the pipeline trench from being a
Page B contaminated sites preferential pathway conduit for contamination (Section 5). Trans Mountain commits to having a qualified Resource Specialist to be present during trench excavation activities where there is a high risk of contamination. Intrusive investigations were completed in 2017 at select high risk sites in BC and
- compared to the current applicable CSR standards, in order to plan accordingly. As a federally, 8
regulated company Trans Mountain will manage contamination within the Project Footprint, using the NEB Remediation process guide. The BC CSR standards for impacts related to Trans Mountain operations will be followed should there be the potential for contamination to migrate off right of way or off facility. In the event third-party impacts are identified during the Project, Trans Mountain will notify the property owner of the impacts.
Trans Mountain Pipeline ULC Contamination Identification and Assessment Plan Trans Mountain Expansion Project 687945/August 2017
Trans Mountain will provide a copy of this Plan to affected Aboriginal groups for their review, and their feedback will be incorporated, as appropriate.
Trans Mountain continues its liaison with Indigenous and Northern Affairs Canada, the Government of Canada’s Major Projects Management Office, the BC Ministry of Aboriginal Relations and Reconciliation, and the Alberta Ministry of Aboriginal Affairs to provide updates regarding Trans Mountain’s engagement activities with Aboriginal groups.
3.31 Identifying Aboriginal Groups for Consultation Trans Mountain used the First Nations Consultative Area Database Public Map Service to identify the Aboriginal groups with traditional territories that cross areas identified in the preliminary contaminated site list. Appendix E lists the Aboriginal Groups identified for consultation.
3.3.2 Consultation Activities A letter was sent to the list of Aboriginal Groups listed in Appendix G with a copy of the draft Plan in November 2016. Where appropriate and upon request, a follow up meeting was arranged to discuss this Plan in more detail and address any concerns.
Trans Mountain has summarized the feedback received through Trans Mountain’s engagement on this Plan in Table B-3 and the summary includes how Trans Mountain responded to and addressed the concern or issue. It should be noted that although the engagement process will also provide for opportunity for general discussion about Project construction and associated Aboriginal issues and opportunities; only feedback/issues directly related to contamination identification and assessment are provided in this Plan. Other issues and topics raised have been captured in the corresponding mitigation plan as appropriate.
This final Plan will be shared with the Aboriginal groups at the same time as the report is filed with the NEB in 2017.
3.4 Landowners/Tenants Trans Mountain has implemented a comprehensive landowner engagement process for the TMEP to:
• ensure landowners are informed of the Project and how it may affect them;
• enable landowners to gain an understanding of their rights under the NEB Act, and the regulatory process and their opportunities for comment within the NEB regulatory process; and
• have a number of opportunities to discuss the Project, identify my concerns or questions they may have with the project, and have those questions and concerns addressed by Trans Mountain.
In addition to these opportunities for engagement, Trans Mountain is required to provide formal notifications of landowners under Sections 87 and 34 of the NEB Act, and Trans Mountain has or will, at the appropriate time, provide such notices.
Individual landowners and tenants have different preferences with respect to communications, and Trans Mountain tailors its communications as requested. Land representatives working for Trans Mountain have been in discussions with landowners for over three years and issues or concerns raised with land agents have been documented in the Project landowner database, addressed within site specific construction plans and documented within the land rights agreements. Trans Mountain has filed reports with the NEB providing details on the landowner engagement program and results to date. In accordance with NEB Condition 99, records of engagement and consultation with landowners and tenants will be filed with the NEB at least two months prior to commencing construction and every six months thereafter until five years after commencing Project operations.
Trans Mountain’s landowner/tenant consultation strategy includes the activities described below.
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1. Prior to Project approval - obtain landowner permission for survey, provide information on the project and landowner rights, provide copies of land agreement documents to the landowners for their review and consideration, dialogue with each landowner to answer questions and address concerns raised by landowners, provide Project updates, and disseminate any other information necessary to satisfy landowner requests and regulatory requirements. After addressing outstanding questions and issues, obtain land agreements from landowners voluntarily. Land agreements have and will address specific landowner concerns regarding construction and reclamation activity. 2. After obtaining a Certificate of Public Convenience and Necessity from the NEB, Trans Mountain will provide Section 34 notices indicating the detailed route for the pipeline and the specific lands affected by the Project, and complete any additional regulatory procedures required prior to commencement of construction, including providing reasonable notice through land agents of commencement date and activities. Trans Mountain land representatives will continue to maintain contact with landowners through construction to answer questions and address any issues that may arise. Following construction, maintain communication with landowners to discuss reclamation activities and timing. Upon completion of reclamation, Trans Mountain will transition the Project land program to operations.
Respecting this report, Trans Mountain notified landowners by letter in September 2016 that NEB Condition plans were being released for consultation and feedback. The landowner notification letter requested that landowners review the reports available on the TMEP website, or alternatively contact their assigned land representative or Trans Mountain directly if they wished to receive hard copies of the reports to review. No responses or requests for copies of the reports were received by Trans Mountain and no concerns or questions about the reports were expressed by landowners.
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APPENDIX C
LISTING OF REPORTS REVIEWED AS PART OF HIGH RISK SITES ASSESSMENT
Former University of Alberta Ellerslie Waste Management Facility, Edmonton (210 – 127 Street) AMEC Earth & Environmental (AMEC). 2008. University of Alberta Ellerslie Waste Management Facility. 210 – 127 Street, Edmonton, Alberta. 2008 Annual Report including the Groundwater Monitoring Program. Submitted to: University of Alberta, Office of Environmental Health & Safety, Edmonton, Alberta. December. Available through Alberta Government Library.
Progressive Air Services Ltd (Site 668) Environmental Services, Annual Groundwater Monitoring Progressive Air Plant Site, Kamloops, British Columbia, February 1, 1999, Petroleum Enviro Services.
Environmental Services Phase III Environmental Site Assessment, January 5, 1995, Petroleum Enviro Services.
Kamloops Distribution Terminal - 2955 Tranquille Road, Kamloops (Site 3087) Notification Received About Likely or Actual Substance Migration to Neighbouring Site, September 21, 2007, Petro-Canada.
2014 Compliance Report, BC Ministry of Environment Discharge Permit 10712, Suncor Kamloops Terminal, 2955 Tranquille Road, Kamloops, BC, March 31, 2015, SLR Consulting (Canada) Ltd.
2013 Compliance Report BC MOE Discharge Permit 10712 Suncor Kamloops Terminal 2955 Tranquille Road, Kamloops, BC, March 1, 2014, SLR Consulting (Canada) Ltd.
2012 Permit Compliance Report, Suncor Distribution Terminal, 2955 Tranquille Road, Kamloops, BC, February 1, 2013, SLR Consulting (Canada) Ltd.
2011 Compliance Report, Suncor Distribution Terminal, 2955 Tranquille Road, Kamloops, BC, March 28, 2012, SLR Consulting (Canada) Ltd.
Groundwater Monitoring and Subsurface Hydrocarbon Recovery at the Petro-Canada Terminal, Kamloops, British Columbia, Location No. 81953, 1999, January 1, 2000, O’Connor Associates.
Former Mainland Holdings Lease Area - 9930 - 197th Street, Langley (Site 13355) Certificate of Compliance Issued Using Risk Based Standards, Affected Site Management Area. May 30, 2012, BC MOE.
Certificate of Compliance Issued Using Risk Based Standards, Lease Area. May 30, 2012, BC MOE.
Addendum Report - Standards Review, Portion of 9930-197th Street, Langley, BC, MOE Site Id - 13355, CSAP Pa 11-051, March 27, 2012, SNC Lavalin Environmental Inc.
Summary of Site Condition, January 18, 2012, John Decesare.
Human Health and Ecological Risk Assessment, Lease Area at 9930-197th Street, Langley, BC, December 19, 2011, SNC Lavalin Environmental Inc.
Request for No Further Action for Vertical Delineation of Chloride and Salinity in Marine/Glaciomarine Clay, Lease Area at 9930 - 197th Street, Langley, October 21, 2011, SNC Lavalin Inc., Environment Division.
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Former S&M Sawmill - 19395 98A Avenue, Surrey (Site 17163) Notice of Independent Remediation Initiation Submitted, September 17, 2014, Phoenix Environmental Services Ltd.
Notification Received About Likely or Actual Substance Migration to Neighbouring Site, September 17, 2014, Phoenix Environmental Services Ltd.
19339 98A Avenue, Surrey (Site 17164) Notification of Likely or Actual Migration. BC MOE. 2014-09-15. 2381 Rogers Ave, Coquitlam (Site 8345) Notice of Independent Remediation Initiation Submitted (WMA 28(2)), May 21, 2003, ARO Environmental Inc./BC MOE.
2100 United Boulevard, Coquitlam (Site 9109) Notice of Independent Remediation Initiation Submitted (WMA 28(2)), September 27, 2004, Morrow Environmental Consultants Inc./Ashley Smith.
8-10 King Edward Street, Coquitlam (Site 7829) Conditional Certificate of Compliance Issued (WMA 27.6(3)), April 23, 2004, BC MOE.
8-10 King Edward St, Coquitlam, BC, Site Id 7829, CCOC Application-Response to Request for Information, July 17, 2003, Golder Associates Ltd.
Confirmation of Remediation, 8-10 King Edward St, Coquitlam, BC, January 14, 2003, Golder Associates.
Detailed Site Investigation, Remedial Plan and Risk Assessment, 8-10 King Edward St, Coquitlam, BC, March 15, 2002, Golder Associates Ltd.
Stage 1 Preliminary Site Investigation, 8-10 King Edward, Coquitlam, BC, April 1, 2000, Next Environmental Inc.
1001 United Boulevard, Coquitlam (Site 2194) Approval in Principle, September 6, 2007, BC MOE.
Site 2194 Coquitlam Landfill 2014 Annual Approval in Principle Report, April 1, 2015, AECOM.
Site 2194 Coquitlam Landfill 2013 Annual Approval in Principle Report, April 1, 2014, AECOM.
Site 2194 Coquitlam Landfill 2012 Annual Approval in Principle Report, May 6, 2013, AECOM.
Site 2194 Coquitlam Landfill 2011 Annual Approval in Principle Report, April 1, 2012, AECOM.
Metro Vancouver, Site 2194 Coquitlam Landfill 2009 Annual Approval in Principle Report, April 1, 2010, AECOM.
Letter, Re: Application Status for Site Id: 2194 (Coquitlam Landfill Storage), Great Vancouver Regional District, January 11, 2007, Golder Associates Ltd.
Letter, Re: Approval in Principle Application for Coquitlam Landfill (Site#: 2194), November 5, 2003, Greater Vancouver Regional District (Burnaby).
Environmental Site Assessment, Risk Assessment and Remediation Plan, Coquitlam Landfill, Coquitlam, BC, May 13, 2002, Golder Associates.
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APPENDIX D
SUMMARY OF HIGH RISK SITES DESKTOP ASSESSMENT Edmonton High Risk Site Former University of Alberta Ellerslie Waste Management Facility, Edmonton (210 – 127th Street) Operations at the former University of Alberta Ellerslie Waste Management Facility, located at 210 – 127th Street (Quarter section SE, Section 25, Township 51, Range 25, West of the 4th Meridian), included sorting, storage, and processing solvent wastes, wastewater, solid wastes, corrosive wastes and vials between 1972 and 2007 (AMEC 2008). Activities that took place at the facility included neutralization of acid waste and processing and crushing chemical vials for disposal. During the first 10 to 15 years of operations water generated from operation of the chemical waste incinerator was stored in a wastewater pond located in the northeast corner of the subject property. Since the mid-1980s, an aboveground storage tank (AST) has been used to store this wastewater (AMEC 2008). Solvents including halogenated organic compounds were stored on-site in ASTs and later in drums which were located behind concrete berms providing secondary containment. The former Ellerslie Waste Management Facility occupies an area of approximately 2,500 m3. By 2008 much of the facility had been decommissioned with only the field office building remaining on the property. The Project Footprint (from approximately KP 26.3 to KP 26.8) passes through the subject property, including the area of the former wastewater pond (Figure 1).
Groundwater monitoring at the site was required under the University of Alberta’s Environmental Protection and Enhancement Act (EPEA) approval (Permit No. 20370-01-00) issued for operation of the waste management facility until 2008. Contamination in groundwater and soil is documented at the subject property on the eastern portion which appears to be sourced from the former wastewater pond, however concentrations of soil and groundwater which exceed the applicable criteria have also been measured on the western portion of the property (AMEC 2008).
Specific soil data was not reported in the 2008 groundwater monitoring report however the report does indicate that concentrations of dichloromethane and trichloromethane in soil greater than the applicable standard have been measured. Solvent concentrations in soil that exceed the applicable criteria are encountered at about 2 m below grade and extend to about 7 mbg (AMEC 2008).
Contaminants of concern in groundwater on the subject property are VOCs, metals and salinity. VOCs that exceed the applicable criteria (and the maximum documented concentration) are dichloromethane (6,200 mg/L), trichloromethane, and tetrachloromethane. In addition, concentrations of sodium (9,960 mg/L) and chloride (9,670 mg/L) that exceed the applicable criteria have been measured in groundwater (AMEC 2008). Concentrations of dissolved metals which exceed the applicable criteria are nickel (0.246 mg/L), iron (67.4 mg/L), manganese, selenium (0.0735 mg/L) and uranium (0.115 mg/L).
In addition to these parameters, the groundwater monitoring programs includes a radioactive isotope scan (tritium [3H] and radiocarbon [14C]) and solvent scan (acetone, benzene, ethyl ether, methanol, methylethyl ketone, and xylenes) (AMEC 2008).
In 2008, investigations were still being undertaken to delineate the vertical and horizontal extent of contamination in groundwater and soil at the subject property (AMEC 2008). Groundwater flow is towards the northeast and the contaminant plume in groundwater was observed to be migrating in this direction. Recorded depth to groundwater indicate spring water levels are generally higher than during the fall measurements with seasonal variation of 1 m common. In May 2008 depth to groundwater ranged from about 2.5 m to 4.2 m below grade (mbg) and fall measurements were generally within a range of about 3.5 mbg to less than 5 mbg.
In consideration of the spatial distribution of the contamination, as of 2008, the Project Footprint overlaps with areas of contamination. Changes in the soil and groundwater quality since 2008 are unknown, however assuming that there has not been any remediation since then the contaminants of concern are still present at the subject property. Therefore, this section of the Project Footprint (from about KP 26.3 to KP 26.8) has a high potential of being impacted by the subject property and is classified as a high risk area.
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Kamloops High Risk Sites Suncor Kamloops Terminal, 2955 Tranquille Road, Kamloops (BC Site Registry Site Number: 3087) The Suncor Kamloops Terminal site, located at 2955 Tranquille Road, is currently used as a distribution terminal for marketing refined petroleum products and between 1954 and 1983 it was operated as a petroleum products refinery. This site is in close proximity to the Project Footprint in three areas: (1) along the eastern boundary of the site between about KP 840.9 to KP 841.2; (2) in the southeastern boundary of the site between about KP 841.3 and KP 841.5; and (3) southwest of the site in area designated for temporary storage during construction of the Project (Figure 2).
The 2014 Suncor Kamloops Terminal Compliance Report (SLR 2015) (SLR Report) indicates that the average depth to groundwater beneath the subject site ranges from approximately 5 to 6 mbg and the groundwater flow direction changes seasonally from southwest, towards the Thompson River, to northeast, towards the Project Footprint.
The following summarizes the level of risk that the site may pose on the three identified sections of the Project Footprint noted above:
1. Project Footprint section KP 840.9 to KP 841.2: The SLR Report indicates that BTEX, MTBE, VHw, and EPHw (C10-19 groundwater concentrations along the eastern property boundary are less than the applicable CSR Drinking Water standards. 2. Although concentrations along the eastern property boundary of the subject site are currently less than the applicable standards, due to the seasonal groundwater flow direction towards the Project Footprint section KP 840.9 to KP 841.2, and that the facility is still active, there is potential for future migration towards this section of the Project Footprint. The subject site is classified as moderate to low risk to impact this section of the Project Footprint. 3. Project Footprint KP 841.3 and KP 841.5: The SLR Report indicates that groundwater concentrations along the southeastern property boundary are less than the applicable CSR standards. However, at one monitoring well location, P95, located in the southeast corner of the site, during the March 2014 monitoring event an apparent thickness of LNAPL accumulation (2 mm) was recorded. Subsequent monitoring in 2014 reported concentrations less than CSR DW standard. This section of the Project Footprint may be at higher risk to be impacted by contamination migrating from the site. 4. Project Footprint temporary storage: Per the SLR Report, contamination has migrated in groundwater off-site west and southwest of the site property boundary. Specifically, towards the southwest, benzene concentrations in groundwater measured from wells in or near the Project Footprint (monitoring location 129, 131, and 142) in 2014 exceeded the applicable CSR Drinking Water (DW) criteria (maximum concentration range 54 mg/L). This section of the Project Footprint provides temporary storage areas and ground disturbance will be limited to removal of topsoil. Therefore, based on the depth to groundwater, the subject site is classified as low risk to impact the Project Footprint.
Based on the review for the three different Project Footprint in the near vicinity of the site, this site is classified as a high risk site.
Progressive Air, 2965 Airport Drive, Kamloops (BC Site Registry Site Number: 668) Operations at the Progressive Air site, located at 2965 Airport Drive, include a small aircraft engine maintenance and repair facility. Prior to 1994 rinse water from engine degreasing was disposed of in a rock lined pit (Petroleum Enviro Services, 1995). Contaminated soils were removed, although confirmatory soil sampling was not completed as of 1999 (Petroleum Enviro Services, 1999). The site received an Approval in Principle (AIP) for groundwater remediation plan which included a pump and treat system. Remediation was expected to take five years, beginning in 1999. No reports were available for this property beyond 1999.
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Potential contaminants of concern are dichlorobenzenes, 1,1,1 trichloethane (TCA), carbon tetrachloride. In 1998 the maximum concentration in groundwater of 1,2 Dichlorobenzene was 550 µg/L (compared to an aquatic life CSR standard at the time of 25 µg/L), 1,3 Dichlorobenzene was 260 µg/L, (compared to an aquatic life CSR standard at the time of 25 µg/L), and 1, 4 Dichloroethane was 160 µg/L (compared to an aquatic life CSR standard at the time of 40 µg/L).
This is a proposed temporary storage area for the project, where ground disturbance will be limited to removal of topsoil, and there will be no contact with the potentially impacted groundwater, which averages about 5 to 6 mbg. This section of the Project Footprint is considered at low risk to be potentially impacted by the subject site.
Surrey/Langley High Risk Sites Former Mainland Holdings lease area, 9930 – 197th Street, Langley (BC Site Registry Site Number: 13355) The Former Mainland Holdings lease area, located at 9930-197th Street, has been re-classified as low risk based on the BC Site Registry reports. A risk based COC was issued in 2012 (BC MOE 2012). Mainland Holdings operated a salt storage area on the eastern portion of the site. Contamination related to chloride and sodium in soil and chloride and salinity in groundwater. Although the Project Footprint is within the southern boundary of this site (Figure 3), the constituents present pose minimal risk to the project activities during or post construction.
S&R Saw Mills Ltd., 19395 98A Avenue, Surrey (BC Site Registry Site Number: 17693) Operations at the now vacant former S&R Saw Mills, located at 19395 98A Avenue, included use of wood preservation with antifungal chemicals (NIR 2016). The Project Footprint (from about KP 1156 to KP 1156.2) is within the southern boundary of the subject property (Figure 3). Further west, the Project Footprint is located south of the southern boundary of the subject property.
Contamination is documented on the subject property on the eastern portion (at one point specified as southeast side of the site) and in the northwest portion of the site. No site plans documenting the spatial distribution of the contamination are included in the publicly available reports. Nor is there information provided on depth of soil contamination or depth to groundwater. A Notification of Off-site Migration was issued to the property located to the west (19399 98A Avenue) in 2015 (NIR 2015).
Following a remedial excavation completed in March 2016 (NIR 2016) documented contaminants of concern in soil remaining on the subject property are Pentachlorophenol (maximum concentration 239 ug/g). Soils containing elevated concentrations of Pentachlorophenol, Tetrachlorophenol and Trichlorophenol were removed during the excavation.
Contaminants of concern in groundwater on the source site (and the maximum documented concentration) are Pentachlorophenol (14,900 ug/L), 2,3,4,6 Tetrachlorophenol (3820 ug/L), 2,3,5,6-tetrachlorophenol (311 ug/L) 2,4,5-trichlorophenol (4150 ug/L), LEPHw (9180 ug/L), Anthracene (4.2 ug/L), Fluoranthene (13.5 ug/L), Phenanthrene (32.8 ug/L) and Pyrene (11.5 ug/L). In addition, there are documented groundwater concentrations of benzene, antimony, arsenic that exceed the CSR DW standard, and Benzo(a)pyrene concentrations that exceed the upper cap concentrations on the subject site.
Without an understanding of the spatial distribution of the contamination, it is not possible to assess if the Project Footprint overlaps with areas of contamination. Therefore, this section of the Project Footprint (from about KP 1156 to KP 1156.2) is considered potentially high risk to be impacted by the subject property.
19399 98A Avenue, Surrey (BC Site Registry Site Number: 17693) The subject property, located at 19399 98A Avenue, is affected by the former S&R Saw Mills, located to the east at 19395 98A Avenue. The Project Footprint (from about KP 1156.2 to KP 1156.4) is located south of the southern boundary of the subject property. Contaminants of concern were documented in the previous subsection for the source property. Again, as no spatial distribution of the contamination is available at this time, the Project Footprint is considered potentially high risk to be impacted in this area.
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Trans Mountain Pipeline ULC Contamination Identification and Assessment Plan Trans Mountain Expansion Project 687945/August 2017
Coquitlam High Risk Sites Former Lougheed Warehouse and Terminal, 2381 Rogers Avenue, Coquitlam (BC Site Registry Site Number: 8345) Facilities at the former Lougheed Warehouse and Terminal, located at 2381 Roger Avenue, included used oil and diesel underground storage tanks. The Project Footprint (from about KP 1168.9 to KP 1169.1) is located south of the southern boundary of the subject site (Figure 4).
A remedial excavation was conducted in 2003 to remove petroleum hydrocarbon contamination associated with former used oil and diesel tanks (Aro 2003). Soil exceeding Industrial Land Use (IL) CSR standards located beneath a concrete ramp attached to the building was not removed. Concentrations of HEPH in soil under the concrete ramp were 11,676 mg/kg at a depth of 4.0 mbg. Adjacent samples to the east (833 mg/kg) and to the west (less than 40 mg/kg) were less than the IL HEPH CSR standard.
Concentrations of hydrocarbons in groundwater sampled from monitoring wells following the excavation were less than the detection limit (Aro 2003).
Based on the review of the reports available through the BC Site Registry, the subject site is re-classified from high risk to low risk to impact this section of the Project Footprint.
Great Canadian Casino, 2100 United Boulevard, Coquitlam (BC Site Registry Site Number: 9109) The Great Canadian Casino property, located at 2100 United Boulevard, was developed on top of the closed Leeder landfill, an industrial landfill that operated between 1960 and 1986. The property has also been used as a truck terminal (warehouse) and truck maintenance facility between 1975 and 2004. In 2004 before being developed as part of the Casino expansion, it was used for overflow parking (Morrow, 2004). The Project Footprint (from about KP 1169.9 to KP 1170.4) is located about 100 m south of the subject property (Figure 4).
A remedial excavation was planned to be conducted in 2004 to a depth of about 2.7 mbg (Morrow 2004). No information is available on the site registry regarding the contaminants of concern or the spatial distribution of the contamination. The site registry also did not contain a notification to neighbouring property owners that there has been likely or actual migration of substances from the subject property. Therefore, this site is considered to be classified as low potential risk to impact to the Project Footprint.
The Leeder Landfill, which occupied a larger area than the subject property, is considered to present a high risk of impact to the Project Footprint. Three former landfills operated in the Coquitlam High Risk Area. The risks from elevated soil, groundwater and vapour concentrations sourced from these former landfills may present high risk of potential impact to the Project Footprint and are discussed together in Section 4.6.1.
Former Fraser Mills, 8 – 10 King Edward Street, Coquitlam (BC Site Registry Site Number: 7829) The former Fraser Mills site, located at 8 – 10 King Edward Street, currently is used for various commercial and industrial activities and was formerly operated by Glulam Products producing laminated lumber products (1967 to 1975) and for lumber storage by Fraser Mills (early 1900s to 1967) (Golder 2002). Extensive fill, including woodwaste, refuse, sand fill, was used on site to raise the site grade (Golder 2002). The Project Footprint (from about KP 1171.9 to KP 1172.1) runs through the northern portion of the subject property (Figure 5).
A conditional COC for risked based monitoring was issued for the subject property in 2004 (BC MOE 2004). Although not on file, the registry lists a 2008 report titled Letter RE: Request for discontinuance of groundwater monitoring program Conditional Certificate of Compliance (CCC). A remedial excavation was completed at the subject property in 2002 (Golder 2003), however no active remediation was completed in the northern portion of the site.
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Trans Mountain Pipeline ULC Contamination Identification and Assessment Plan Trans Mountain Expansion Project 687945/August 2017
As document in the DSI (Golder 2002) soil concentrations in the northern portion of the subject property at BH2 exceed the IL/CL CSR standard for HEPH at 0.5 (5700 mg/kg) and at 1.4 (7100 mg/kg). In the northern portion of site, there is about 2 m of woodwaste and refuse fill located about 0.5 to 1 mbg which overlies peat. Heavy metal exceedances have been documented in the in wood refuse layer including in samples collected from the northern portion of the site. Metals concentrations in soil that exceeded the applicable standard are barium (maximum concentration of 3100 mg/kg at 0.3 to 0.6 m), cadmium (maximum concentration of 10.4 mg/kg at 0.4 m), chromium (maximum concentration of 176 mg/kg at 0.3 to 0.6 m) lead (maximum concentration 317 at 0.4 m), and zinc (maximum 527 mg/kg at a depth of 2.4 m). At one location in the northern portion of the site an exceedance for chromium (concentration 79.7 mg/kg) was identified in the mineral fill at a depth between 0.05 and 0.3 m.
The documented groundwater flow direction is towards the north and north-east (Golder 2002). Concentrations of chlorobenzene (maximum concentration 15 ug/L) that exceeded the applicable AW CSR standards were identified at two monitoring wells. The depth to groundwater at the site is about 1 to 2 mbg.
Elevated methane vapour concentrations have been identified, including in the northern portion of the subject property related to decaying woodwaste and refuse fill, as well as underlying peat.
No monitoring data was available since 2004 in the publicly available reports. However, as the Project Footprint crosses through the northern portion of site which includes several metres of miscellaneous fill material there is potential to encounter elevated vapour, soil metal and hydrocarbon concentrations. The subject property is classified as high risk to impact the Project Footprint.
Coquitlam Landfill, 1001 United Boulevard, Coquitlam (BC Site Registry Site Number: 2194) The Coquitlam Landfill site, located at 1001 United Boulevard, is impacted by the former landfill operations. The Project Footprint (from about KP 1172.3 to KP 1173.2) runs through portions of the eastern and northern property boundary of the subject site (Figure 5). The Project Footprint intersects remediation facilities including the leachate collection system and potentially the landfill gas collection system.
The landfill was constructed on native soil (peat/silt) without a liner. A perimeter toe drain leachate collections system captures shallow groundwater flowing outwards from the central portion of the landfill. Corrugated steel manholes were originally installed along the length of the collection system; however, the steel corroded and the manholes were later lined with PVC (AECOM 2015). Further repair work on the leachate collection system was conducted in 2011 and 2012 in areas along west, north, and east sides of the landfill. A geomembrane barrier was added along the outer edge of the leachate collection system trench for improved containment (AECOM 2015). The leachate collection system appears to have effectively collected leachate and prevented significant contamination of the shallow aquifer beyond the collection perimeter and nearby surface waters (AECOM 2015). Deeper groundwater flow by-passes the leachate collection system in underlying sand aquifer and flows southward towards the Fraser River (AECOM 2015).
Regardless of the generally effective performance of the leachate collection system, the Project Footprint is between the contamination sources and the leachate collection system impacted groundwater will likely be encountered during construction activities. The shallow groundwater is within 1 or 2 mbg (Golder 2002). Monitoring well MW-J north of the leachate collection system, historically showed signs of impact by leachate, however as documented by AECOM (2015) the water quality has since improved. Groundwater quality in the intermediate aquitard reflects landfill leachate impacts at MW99-4l (north of landfill, and north of the Project Footprint). AECOM (2015) reports that these impacts may be a result of Residual contamination from leachate collection system pump breakdown in 2008. Specific constituents or their concentrations are not documented in the 2014 Annual Approval in Principle Report (AECOM 2015). Also along this area of the northern perimeter of the landfill a new leachate seep was identified in February 2015 (AECOM 2015).
Groundwater sampled from monitoring well MW95-6D, located east of the subject site and within the Project Footprint, contained concentrations of cadmium that exceeded AW and DW CSR standards during a monitoring event in 2014.
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Trans Mountain Pipeline ULC Contamination Identification and Assessment Plan Trans Mountain Expansion Project 687945/August 2017
There is potential to encounter landfilled material during excavation within the Project Footprint (BGC 2016). Samples collected from sediments in Nelson Creek (Golder 2002), west of the Project Footprint contained concentrations of hydrocarbons and metals greater than the applicable standards.
Active landfill gas management takes place at the subject site. Since 1993 the Coquitlam Landfill Gas Company has purchased landfill gas for fuel supply. An extensive landfill network of gas extraction wells and collection piping is operated and maintained across the site (AECOM 2015). Sections of the Project Footprint may be constrained by the current landfill gas collection system.
Based on the landfill material, elevated groundwater concentrations and landfill gas concentrations, this section of the Project Footprint (from about KP 1172.3 to KP 1173.2) is classified as high risk to be impacted by the subject site. The existing infrastructure at the subject site (i.e., leachate collection system and landfill gas collection system) present constraints within the Project Footprint.
01-13283-GG-0000-CHE-RPT-0036 Page D-6
1126000 1126500 1127000 1127500 1128000 1128500
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BRITISH ALBERTA COLUMBIA
Dawson 127 Street South-west Grande !(2 Creek Prairie !(97 !(43 M cLean Cresce Prince n George Edmonton t !(16 Hinton
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m 0 100 200 300 1126500 1127000 1127500 1128000 1128500 ALL LOCATIONS APPROXIMATE 201702_MAP_CH2M_CS_00944_RevD.mxd 679500 680000 680500 681000 681500 LAC DU BOIS GRASSLANDS PROTECTED AREA FIGURE 2 LAC DU BOIS HIGH POTENTIAL CONTAMINATED AREAS ¯ GRASSLANDS KAMLOOPS AREA PROTECTED AREA TRANS MOUNTAIN EXPANSION PROJECT
M Monitoring Well Location
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5620800 Road, Kamloops Paved Road Resource Road
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Projection: NAD 1983 UTM Zone 10N. Monitoring Well Location: CH2M 2017; Pipeline SSEID005.1, KPs, !( Centreline, & Footprint provided by UPI April 3, 2017; TMPL Route Revision 0 provided by KMC, May 2012; Transportation: AltaLIS 2014, BC MFLNRO 2012 & NRCan 2015; Geopolitical Boundaries: AltaLIS 2016, NRCan 2003; First Nation Lands: Government of Canada 2017; Parks and Protected Areas: NRCan 2017 & BC MFLNRO 2008; Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, !( USDA, USGS, AeroGRID, IGN, and the GIS User Community. 5620800 Site ID 3087 This document is provided by Kinder Morgan Canada Inc. (KMC) for use by the intended recipient only. This information is confidential and proprietary Kamloops Distribution Terminal to KMC and is not to be provided to any other recipient without the written consent of KMC. It is not to be used for legal, engineering or surveying 2955 Tranquille !( !( purposes, nor for doing any work on or around KMC's pipelines and KAMLOOPS Road, Kamloops facilities, all of which require KMC's prior written approval.
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!( 522000 522500 5448800 523000 523500 524000
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101 Ave Railway Site ID 17163 Site ID 13355 19395 98A Avenue, Surrey 9930 197th Street , Langley City / Town Site ID 17164 19399 98A Avenue, Surrey Indian Reserve / Métis Settlement
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Projection: NAD 1983 UTM Zone 10N. !( 100A Ave Monitoring Well Location: CH2M 2017; Pipeline SSEID005.1, KPs, !( 01 Centreline, & Footprint provided by UPI April 3, 2017; TMPL 197 St LANGLEY - 2 !.( Route Revision 0 provided by KMC, May 2012; Transportation: !( AltaLIS 2014, BC MFLNRO 2012 & NRCan 2015; Geopolitical DISTRICT t !( S Boundaries: AltaLIS 2016, NRCan 2003; First Nation Lands: KP 1157 !( Government of Canada 2017; Parks and Protected Areas: NRCan !( !( 2017 & BC MFLNRO 2008; Service Layer Credits: Source: Esri, !( 16MW-S2-2 DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, 16MW-S1-1 5448000 KP 0 USDA, USGS, AeroGRID, IGN, and the GIS User Community. !( !( !.( !( !( M M !( !( !( !( !( !( !( !.( M M M !( !( !( !( This document is provided by Kinder Morgan Canada Inc. (KMC) for use by !. !( !( !( the intended recipient only. This information is confidential and proprietary !( 16MW-S1-2 98A Ave 2 to KMC and is not to be!( provided to any other recipient without the written 16MW-S2-1 16MW-S2-3 0 consent of KMC. It is not to be used for legal, engineering or surveying KP 1155 1 purposes, nor for doing any work on or around KMC's pipelines and S facilities, all of which require KMC's prior written approval. t Golden Ears Way O 201 St
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MAP NUMBER PAGE 201702_MAP_CH2M_CS_00944_REVD SHEET 1 OF 1 DATE CH2M REF. REVISION June 2017 687945 D SCALE PAGE SIZE DISCIPLINE 1:7,500 11x17 CS DRAWN CHECKED DESIGN 2 CMR DJN CMR 0 5447200 0 S m t 0 100 200 300 522500 523000 523500 524000 524500 ALL LOCATIONS APPROXIMATE 201702_MAP_CH2M_CS_00944_RevD.mxd 511000 511500 512000 512500 5453600 513000 513500
FIGURE 4 HIGH POTENTIAL CONTAMINATED AREAS ¯ 5453600 COQUITLAM EAST e v A United Blvd Offramp TRANS MOUNTAIN EXPANSION PROJECT rn o H Tra Warrick St pe ns-C a M Monitoring Well Location ana C 1+7 da H TS Golden Dr wy !. Kilometre Post (KP)
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!(
508500 509000 509500 510000 510500 KP 1174 !.(
!( FIGURE 5 !( HIGH POTENTIAL CONTAMINATED AREAS
5453600 ¯ COQUITLAM WEST
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CapilanoWay !.(
Although there is no reason to believe that there are any errors associated with the data used to generate this product or in the product itself, users of these data are advised that errors in the data may be present.
BRITISH 511000 ALBERTA COLUMBIA
Dawson Grande !(2 Creek Prairie !(97 !(43
Prince George Edmonton !(16 Hinton Edson Brigantine Dr Quesnel Red Valemount Jasper Deer
Blue River 2 Williams !( Lake !(97 Calgary Terra Darfield !(1 Nova Kamloops Landfill Kelowna Vancouver !(3 (Burnaby) Hope USA
MAP NUMBER PAGE
5452000 201702_MAP_CH2M_CS_00944_REVD SHEET 1 OF 1 DATE CH2M REF. REVISION June 2017 687945 D SCALE PAGE SIZE DISCIPLINE 1:7,500 11x17 CS DRAWN CHECKED DESIGN CMR DJN CMR
m SURREY 0 100 200 300 508500 509000 509500 5452000 510000 510500 511000 ALL LOCATIONS APPROXIMATE 201702_MAP_CH2M_CS_00944_RevD.mxd Trans Mountain Pipeline ULC Contamination Identification and Assessment Plan Trans Mountain Expansion Project 687945/August 2017
APPENDIX E
SUMMARY OF HIGH RISK SITES INTRUSIVE ASSESSMENTS The following provides a summary of the subsurface investigations conducted in December 2016 at the three properties identified as high risk areas and recommended for investigation prior to construction. In these areas, results of the intrusive environmental assessment were required to support pre-construction hazard assessment and develop safe work procedures and site specific waste management plans in preparation of construction activities.
Surrey/Langley High Risk Sites S&R Saw Mills Ltd., 19395 98A Avenue, Surrey, BC An investigation at the former S&R Saw Mills, located at 19395 98A Avenue, Surrey was conducted to evaluate soil and groundwater quality in the southern portion of the property in an area which the Project Footprint overlaps. Operations at the former saw mill included use of wood preservation with antifungal chemicals and contaminants of concern in soil on the subject property include chlorophenols and in groundwater include chlorophenols, petroleum hydrocarbons and dissolved metals. As no information on the spatial distribution of the contamination was available on December 16, 2016 three boreholes were advanced with solid stem augers and each was completed as a monitoring well (Figure 3, Appendix D). Following well development, one groundwater sampling event was conducted on December 21, 2016.
Investigation results indicated distinct soil stratigraphy between the west and east areas investigated, where the grade also changes by about 3 m. In the western portion of the investigation area the soil stratigraphy consisted of sandy gravel fill, about 0.60 m thick, overlying clayey silt, which transitioned to clay at a depth of approximately 1.5 m and extended to the end of the boring at 4.5 m. In the eastern portion of the investigation area, the soil stratigraphy consisted of sand and gravel to the maximum depth investigated, 3 m below grade. Groundwater was measured at a depth of about 1.5 m in the eastern portion of the subject property where MW16-S2-2 and MW16-S2-3 are located and at 3.6 m below grade in the western monitoring well, MW16-S2-1.
Investigation results from the subject property area did not identify concentrations of the contaminants of concern which were greater than the applicable CSR standards in soil or groundwater. The sodium concentration in one soil sample exceeded the applicable CSR standard, however sodium is not a PCOC and the elevated concentration is likely attributed to natural occurring presence within the native clay unit, which may originate from a marine deposit.
Of note, chemical odour and elevated vapour readings, relative to the other samples, were observed at the eastern-most investigation location (MW16-S2-3) and chlorinated phenols concentration were detected at concentrations marginally greater than the laboratory detection limit in soil at this location.
City of Surrey Lands Fronting 19399 98A Avenue, Surrey, BC Following receipt of the appropriate permits an investigation was conducted on City of Surrey lands fronting 19399 98A Avenue, Surrey to evaluate soil and groundwater quality within the Project Footprint. The subject lands may be affected by the former S&R Saw Mills, located to the east at 19395 98A Avenue, however no information on the spatial distribution of the contamination was available. Therefore, on December 16, 2016 two boreholes were advanced and completed as monitoring wells (Figure 3, Appendix D). Boreholes were advanced with solid stem augers. Following well development, one groundwater sampling event was performed on December 21, 2016.
Investigation results indicate that the soil stratigraphy generally consisted of 1 m to 2 m of sand and gravel fill overlying native alluvial sand and gravel. Groundwater was measured at about 3 m to 3.5 m below grade within the alluvial sand and gravel.
Concentrations of previously identified contaminants of concern in analyzed soil samples are less than applicable CSR standards. Concentrations of previously identified contaminants of concern in analyzed groundwater samples are all less than the applicable CSR standards.
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Concentrations of MTBE in MW16-S1-1 (18 ug/L) and benzo(a)pyrene in MW16-S1-2 (0.062 ug/L) are greater than the CSR drinking water use standards (15 ug/L and 0.01 ug/L, respectively). Although benzo(a)pyrene is a parameter of concern at the adjacent property located at 19395 98A Avenue, MTBE was not identified as a parameter of concern and the source of this MTBE is unknown. The analytical data was compared to the CSR drinking water use standards as a conservative measure. The application of drinking water use standards may be modified in the future should new information be obtained to support a modification.
Elevated groundwater concentrations of MTBE in the Project Footprint identified at one location, 16MW-S1-1 is isolated as the MTBE and concentration in groundwater samples collected from monitoring wells within the Project Footprint to the east and west were less than the drinking water use standard. There is potential that elevated concentrations of benzo(a)pyrene, in excess of the drinking water use standard, extend further to the west of 16MW-S1-2 as no further monitoring wells were installed to the west. The potential for undelineated benzo(a)pyrene contamination in groundwater has been identified and appropriate monitoring and management measures will be performed if groundwater is encountered during excavation in this area. Figure 3 in the Plan shows the location of borings/monitoring wells in relation to the Project Footprint and the other investigation locations.
Coquitlam High Risk Sites Former Fraser Mills, 8 – 10 King Edward Street, Coquitlam, BC With permission of the current landowner, an investigation was conducted at the former Fraser Mills property located at #8 – 10 King Edward Street in Coquitlam to evaluate soil and groundwater quality in the northern portion of the property in an area which the Project Footprint overlaps. Contaminants of concern in soil identified by Golder (2002) included HEPH and total metals (i.e., barium, cadmium, chromium, lead and zinc). Chlorobenzene was identified in groundwater (Golder 2002). On December 15, 2016 three boreholes were advanced and completed as monitoring wells (Figure 5, Appendix D). Boreholes were advanced with solid stem augers. Following well development, one groundwater sampling event was performed on December 21, 2016.
Investigation results indicate that the soil stratigraphy generally consisted of granular fill overlying organic wood refuse fill between 1 and 2 m thick, overlying 0.6 to 1 m thick peat deposits which was underlain by clay. Domestic waste (plastic, aluminum, steel, glass, and paper) was found mixed with the granular fill interval. Groundwater was encountered at approximately 2 m below grade within the organic peat layer.
Metals contamination (cadmium, lead, and zinc) was observed within the upper 1 to 2 m of the ground surface in the silty sand and organics layers at the two westernmost investigation locations. The maximum measured concentration of cadmium was 3.0 mg/kg, of lead was 391 mg/kg and of zinc was 439 mg/kg. Concentration of benzene (0.097 mg/kg) within the upper 2 m at the western most location is greater than the CSR IL standard (0.04 mg/kg). Concentration of HEPH19-32 in one sample (5,800 mg/kg) is greater than the CSR IL standard (5,000 mg/kg) (16MW-C-1 at a depth of 1.8 m to 1.9 m); however, the concentration of EPH19-32 with silica gel clean-up (1,650 mg/kg) performed to assess the anthropogenic component of hydrocarbon from the same sample, which is less than the CSR IL HEPH standard. This confirms the HEPH concentration was a result of the naturally occurring hydrocarbons due to the presence of decaying organic matter and not from an anthropogenic source.
Groundwater concentrations for the contaminants of concern are all less than applicable standards, with the exception of 1-4-dichlorobenzene concentration in MW16-C-2 (1.5 ug/L) and MW16-C-3 (1.3 ug/L), which exceeds the CSR drinking water use standard (1.0 ug/L). The analytical data was compared to the CSR drinking water use standards as a conservative measure. The application of drinking water use standards may be modified in the future should new information be obtained to support a modification.
Another noteworthy observation from the investigation was that upon opening of the newly installed monitoring wells during groundwater sampling, field staff observed pressure release from the well casing which was attributed to a buildup of landfill gas in the well.
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APPENDIX F
RECORD OF STAKEHOLDER NOTIFICATIONS OF PLAN
TABLE F-1
RECORD OF NOTIFICATION
Regulator/Stakeholder Group Contact Name (if applicable) Date Method of Contact Landowners N/A September 11, 2016 Letter Aboriginal Groups (please refer to N/A September 26, 2016 Letter Appendix E) Vancouver Fraser Port Authority Tim Blair September 20, 2016 Email Jasper National Park of Canada Mayabe Dia September 20, 2016 Email Alberta Environment and Parks Corinee Kristensen September 20, 2016 Email Ministry of Transportation and Lisa Gow September 20, 2016 Email Infrastructure BC Parks Ken Morrison September 20, 2016 Email BC Oil and Gas Commission Brian Murphy September 20, 2016 Email Ministry of Natural Gas Development Linda Beltrano September 20, 2016 Email Forests, Lands and Natural Andrea Mah December 22, 2016 Email Resource Operations Forests, Lands and Natural Susan Fitton September 20, 2016 Email Resource Operations FVAQC Roger Quan October 21, 2016 Email ECCC Phil Wong October 21, 2016 Email ECCC Rachel Mayberry October 28, 2016 Email ECCC Coral Deshield December 21, 2016 Email ECCC Phil Wong December 21, 2016 Email Vancouver Fraser Port Authority Patrick Coates September 20, 2016 Email Department of Fisheries and Oceans Sandra Hollick-Kenyon December 3, 2016 Email Department of Fisheries and Oceans Alston Bonamis December 3, 2016 Email City of Edmonton N/A November 29, 2016 Letter City of Spruce Grove N/A November 29, 2016 Letter Municipality of Jasper N/A November 29, 2016 Letter Parkland County N/A November 29, 2016 Letter Strathcona County N/A November 29, 2016 Letter Town of Edson N/A November 29, 2016 Letter Town of Hinton N/A November 29, 2016 Letter Town of Stony Plain N/A November 29, 2016 Letter Village of Wabamun N/A November 29, 2016 Letter Yellowhead County N/A November 29, 2016 Letter City of Kamloops N/A November 29, 2016 Letter City of Kamloops RCMP Detachment N/A November 29, 2016 Letter City of Merritt N/A November 29, 2016 Letter City of Merritt RCMP Detachment N/A November 29, 2016 Letter Clearwater Chamber of Commerce N/A November 29, 2016 Letter District of Clearwater N/A November 29, 2016 Letter District of Clearwater RCMP N/A November 29, 2016 Letter Detachment Interior Health N/A November 29, 2016 Letter Merritt Chamber of Commerce N/A November 29, 2016 Letter Northern Health N/A November 29, 2016 Letter
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TABLE F-1 Cont’d
Regulator/Stakeholder Group Contact Name (if applicable) Date Method of Contact Regional District of Fraser Fort N/A November 29, 2016 Letter George Thompson Nicola Regional District N/A November 29, 2016 Letter Town of Blue River N/A November 29, 2016 Letter Venture Kamloops N/A November 29, 2016 Letter Village of Valemount N/A November 29, 2016 Letter Village of Valemount RCMP N/A November 29, 2016 Letter Detachment Nicola Stock Breeder's Association - N/A November 29, 2016 Letter on behalf of the BC Cattlemen's Association Grassland's Conservation Council N/A November 29, 2016 Letter Thompson Rivers University N/A November 29, 2016 Letter Southern Interior Weed Management N/A November 29, 2016 Letter Committee Fraser Basin Council N/A November 29, 2016 Letter Northwest Invasive Plant Council November 29, 2016 (NWIPC) Grassland’s Conservation Council N/A November 29, 2016 Letter Abbotsford Chamber of Commerce N/A November 29, 2016 Letter Abbotsford Police Department N/A November 29, 2016 Letter ASCA N/A November 29, 2016 Letter BC Invasive Species N/A November 29, 2016 Letter BC Ministry of Children and Family N/A November 29, 2016 Letter Development BC Ministry of Social Development N/A November 29, 2016 Letter BC Nature N/A November 29, 2016 Letter BC Wildlife Federation N/A November 29, 2016 Letter Burnaby Board of Trade N/A November 29, 2016 Letter Burnaby RCMP Detachment N/A November 29, 2016 Letter Chilliwack Chamber of Commerce N/A November 29, 2016 Letter Chilliwack Economic Partners N/A November 29, 2016 Letter City of Abbotsford N/A November 29, 2016 Letter City of Burnaby N/A November 29, 2016 Letter City of Chilliwack N/A November 29, 2016 Letter City of Coquitlam N/A November 29, 2016 Letter City of New Westminster N/A November 29, 2016 Letter City of Port Coquitlam N/A November 29, 2016 Letter City of Port Moody N/A November 29, 2016 Letter City of Surrey N/A November 29, 2016 Letter Coquitlam RCMP Detachment N/A November 29, 2016 Letter Corporation of Delta N/A November 29, 2016 Letter District of Hope N/A November 29, 2016 Letter Eagle Creek N/A November 29, 2016 Letter Fraser Valley Invasive Plant Council N/A November 29, 2016 Letter Fraser Valley Regional District N/A November 29, 2016 Letter Glen Valley Watershed Society N/A November 29, 2016 Letter Hope Chamber of Commerce N/A November 29, 2016 Letter Hope Community Policing Office N/A November 29, 2016 Letter Langley Chamber of Commerce N/A November 29, 2016 Letter LEPS N/A November 29, 2016 Letter LFVAQCC N/A November 29, 2016 Letter Metro Vancouver N/A November 29, 2016 Letter Newton RCMP Detachment N/A November 29, 2016 Letter RCMP Division ‘E’ N/A November 29, 2016 Letter Sapperton Fish and Game N/A November 29, 2016 Letter
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TABLE F-1 Cont’d
Regulator/Stakeholder Group Contact Name (if applicable) Date Method of Contact Stoney Creek N/A November 29, 2016 Letter Surrey Board of Trade N/A November 29, 2016 Letter Surry Environmental Partners N/A November 29, 2016 Letter Surrey RCMP Detachment N/A November 29, 2016 Letter Township of Langley N/A November 29, 2016 Letter Township of Langley RCMP N/A November 29, 2016 Letter Detachment TriCities Chamber of Commerce N/A November 29, 2016 Letter Upper Fraser Valley Regional N/A November 29, 2016 Letter Detachment Village of Anmore N/A November 29, 2016 Letter Village of Belcarra N/A November 29, 2016 Letter Yorkson N/A November 29, 2016 Letter ACGI Shipping N/A November 29, 2016 Letter Barnett Marine Park N/A November 29, 2016 Letter BC Ambulance N/A November 29, 2016 Letter BC Chamber of Shipping N/A November 29, 2016 Letter BC Coast Pilots (BCCP) N/A November 29, 2016 Letter BROKE (Burnaby Residents N/A November 29, 2016 Letter Opposed to Kinder Morgan Expansion) Canadian Pacific (CP) Rail N/A November 29, 2016 Letter Canexus- Ero- Newalta-Univar N/A November 29, 2016 Letter Community Advisory Panel (CAP) Canexus Chemicals N/A November 29, 2016 Letter Chevron N/A November 29, 2016 Letter CN Rail N/A November 29, 2016 Letter Council of Marine Carriers N/A November 29, 2016 Letter District of North Vancouver N/A November 29, 2016 Letter Empire Shipping N/A November 29, 2016 Letter Erco Worldwide N/A November 29, 2016 Letter First Nation Emergency Services N/A November 29, 2016 Letter Society (FNESS) First Nation Health Authority N/A November 29, 2016 Letter Fraser Health Authority N/A November 29, 2016 Letter Inchcape Shipping N/A November 29, 2016 Letter Island Tug and Barge N/A November 29, 2016 Letter Kask Brothers N/A November 29, 2016 Letter Ledcor Resources and N/A November 29, 2016 Letter Transportation Limited Partnership Mason Agency (Shipping Service) N/A November 29, 2016 Letter MLA- Burnaby Lougheed N/A November 29, 2016 Letter MLA- Burnaby North N/A November 29, 2016 Letter MLA- Coquitlam – Burke Mountain N/A November 29, 2016 Letter MLA- North Vancouver Lonsdale N/A November 29, 2016 Letter MLA- North Vancouver Seymour N/A November 29, 2016 Letter MLA- Port Moody- Coquitlam N/A November 29, 2016 Letter MP- Delta N/A November 29, 2016 Letter MP- North Burnaby Seymour N/A November 29, 2016 Letter MP- North Vancouver N/A November 29, 2016 Letter MP- Vancouver Centre N/A November 29, 2016 Letter MP- Vancouver East N/A November 29, 2016 Letter MP- Vancouver Quadra N/A November 29, 2016 Letter MP- West Vancouver – Sunshine N/A November 29, 2016 Letter Coast – Sea to Sky Country North Shore NOPE N/A November 29, 2016 Letter
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TABLE F-1 Cont’d
Regulator/Stakeholder Group Contact Name (if applicable) Date Method of Contact North Vancouver Chamber of N/A November 29, 2016 Letter Commerce Pacific Coast Terminal N/A November 29, 2016 Letter Pacific Pilotage Authority N/A November 29, 2016 Letter Pacific Wildlife Foundation N/A November 29, 2016 Letter Peter Kiewit Infrastructure Co. N/A November 29, 2016 Letter Seaspan N/A November 29, 2016 Letter Shell Terminal N/A November 29, 2016 Letter Simon Fraser University N/A November 29, 2016 Letter SMIT Marine N/A November 29, 2016 Letter Suncor Terminal N/A November 29, 2016 Letter UBC Stellar Sea Lion (Marine N/A November 29, 2016 Letter Mammal) Research Centre Vancouver Aquarium N/A November 29, 2016 Letter Vancouver Board of Trade N/A November 29, 2016 Letter Vancouver Coastal Health Authority N/A November 29, 2016 Letter Vancouver Pile and Dredge N/A November 29, 2016 Letter West Vancouver Chamber of N/A November 29, 2016 Letter Commerce Westward Shipping N/A November 29, 2016 Letter Wild Bird Trust N/A November 29, 2016 Letter Metro Vancouver Regional District Ali Ergudenler November 29, 2016 Email Metro Vancouver Regional District Roger Quan November 29, 2016 Email
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APPENDIX G
ABORIGINAL GROUPS IDENTIFIED FOR CONSULTATION REGARDING THE CONTAMINATION IDENTIFICATION AND ASSESSMENT PLAN
• Adams Lake Indian Band • Kelly Lake First Nation
• Aitchelitz First Nation (Stó:lō) • Kelly Lake Métis Settlement Society
• Alexander First Nation • Ktunaxa Nation
• Alexis Nakota First Nation • Kwantlen First Nation (Stó:lō)
• Aseniwuche Winewak Nation • Kwaw-kwaw-aplit First Nation (Stó:lō)
• Ashcroft Indian Band (N'laka'pamux Nation) • Kwikwetlem First Nation
• Asini Wachi Nehiyawak • Lake Cowichan First Nation
• Boothroyd Band (N'laka'pamux Nation) • Leq’a:mel First Nation (Stó:lō)
• Boston Bar Band (N'laka'pamux Nation) • Lheidli-T’enneh First Nation
• British Columbia Metis Federation • Lhtako Dené Nation
• Canim Lake Band (Tsq’escen') • Little Shuswap Indian Band
• Canoe Creek (Stswecem'c Xgat'tem) Indian • Louis Bull Tribe Band • Lower Nicola Indian Band (N'laka'pamux • Chawathil First Nation (Stó:lō) Nation)
• Cheam First Nation (Stó:lō) • Lower Similkameen Indian Band
• Clinton Indian Band / Whispering Pines • Lyackson First Nation
• Coldwater Indian Band (N'laka'pamux • Lytton First Nation (N'laka'pamux Nation) Nation) • Matsqui First Nation (Stó:lō) • Cook’s Ferry Indian Band (N'laka'pamux Nation) • Métis Nation of Alberta Gunn Métis Local 55
• Cowichan Tribes • Metis Nation of British Columbia
• Enoch Cree Nation • Métis Regional Council Zone IV of the Métis Nation of Alberta • Ermineskin First Nation • Michel First Nation • Foothills Ojibway Society • Montana First Nation • Halalt First Nation (CNA) • Musqueam Indian Band • High Bar • Nakcowinewak Nation of Canada • Horse Lake First Nation (Treaty 8) • Neskonlith Indian Band • Hwlitsum First Nation (CNA) • Nicola Tribal Association *** • Kanaka Bar • Nicomen Indian Band (NTA) • Katzie First Nation • Nooaitch Indian Band (N'laka'pamux Nation) • Kelly Lake Cree Nation • O’Chiese First Nation
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• Okanagan Indian Band (added by OGC) • Squamish Nation
• Oregon Jack Creek Band (N'laka'pamux • Squiala First Nation (Stó:lō) Nation) • St'at'imc Chiefs Council • Paul First Nation • Stó:lō Collective *** • Penelakut First Nation • Stoney Nakoda First Nation • Penticton Indian Band • Sts'ailes Band (Chehalis Indian Band) • Peters Band (Stó:lō) (Stó:lō)
• Popkum First Nation (Stó:lō) • St'uxwtews (Bonaparte Indian Band)
• Qayqayt First Nation (New Westminster) • Stz'uminus First Nation (Chemainus)
• Saddle Lake Cree • Sucker Creek
• Samson Cree Nation • Sumas First Nation (Stó:lō)
• Scowlitz First Nation (Stó:lō) • Sunchild First Nation
• Seabird Island Band (Stó:lō) • Tk'emlups te Secwepemc (Kamloops)
• Sechelt • Toosey Indian Band
• Semiahmoo First Nation • Treaty 8 Nations of Alberta
• Sencoten Alliance • Tsawwassen First Nation
• Shackan Indian Band (N'laka'pamux Nation) • Tsilhqot’in National Government
• Shuswap Indian Band • Ts'kw’aylaxw (Pavilion Indian Band)
• Shuswap Nation Tribal Council • Tsleil-Waututh Nation
• Shxw’ow'hamel First Nation (Stó:lō) • Tsuu T'ina First Nation
• Shxwhá:y Village (Stó:lō) • Tzeachten First Nation (Stó:lō)
• Simpcw First Nation • Union Bar Indian Band (Stó:lō)
• Siska Indian Band (N'laka'pamux Nation) • Upper Nicola Band (N'laka'pamux Nation)
• Skawahlook First Nation (Stó:lō) • Upper Similkameen Indian Band
• Skeetchestn First Nation • Westbank First Nation
• Skowkale First Nation (Stó:lō) • Whitefish (Goodfish) Lake First Nation
• Skuppah Indian Band (N'laka'pamux Nation) • Williams Lake (T'exelc) Band
• Skwah First Nation (Stó:lō) • Xat’sull First Nation (Soda Creek)
• Soowahlie Indian Band (Stó:lō) • Yakweakwioose Band (Stó:lō)
• Splatsin First Nation • Yale First Nation (Stó:lō)
• Spuzzum First Nation (N'laka'pamux Nation)
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