Attachment 5 to Northern Gateway Reply Evidence
AMEC Environment & Infrastructure, a Division of AMEC Americas Limited Suite 600 – 4445 Lougheed Highway, Burnaby, BC Canada V5C 0E4 Tel +1 (604) 294-3811 Fax +1 (604) 294-4664 www.amec.com
Geotechnical Response to Photographic Evidence Regarding Proposed Liquid Petroleum Pipelines from Nimbus Mountain to the Kitimat River Estuary Submitted by Murray Minchin of Douglas Channel Watch Proposed Northern Gateway Pipelines
Submitted to:
NORTHERN GATEWAY PIPELINES INC. Calgary, Alberta
Submitted by:
AMEC Environment & Infrastructure, a Division of AMEC Americas Limited Burnaby, BC
July 17, 2012
AMEC File: EG0926008 2100 100
Document Control No.: 1167-RE-20120716
7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
TABLE OF CONTENTS
Page
1.0 INTRODUCTION ...... 1
2.0 GEOTECHNICAL RESPONSES ...... 2
3.0 LIMITATIONS AND CLOSURE ...... 63
REFERENCES ...... 64
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IMPORTANT NOTICE
This report was prepared exclusively for Northern Gateway Pipelines Inc. by AMEC Environment & Infrastructure, a wholly owned subsidiary of AMEC Americas Limited. The quality of information, conclusions and estimates contained herein is consistent with the level of effort involved in AMEC services and based on: i) information available at the time of preparation, ii) data supplied by outside sources, and iii) the assumptions, conditions and qualifications set forth in this report. This report is intended to be used by Northern Gateway Pipeline and related consultants only, subject to the terms and conditions of its contract with AMEC. Any other use of, or reliance on, this report by any third party is at that party’s sole risk.
7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
1.0 INTRODUCTION
This report provides a geotechnical engineering response to photographic evidence submitted to the Joint Review Panel by Murray Minchin of Douglas Channel Watch. The evidence was submitted in written format in early January 2012 (the actual submission is not dated).
The response is contained on the following pages. The submitted evidence is reproduced on the left side of the table in the following pages and the responses are on the right side. The submitted evidence is only included where a response is made. The responses to geotechnical issues were prepared by AMEC Environment & Infrastructure (AMEC) while the input to certain issues such as spill response and previous oil spills were prepared by others as identified in the responses. Note that AMEC Environment & Infrastructure changed its name from AMEC Earth & Environmental in the fall of 2011.
Several previous geotechnical reports are cited repeatedly in the following discussion. These reports are:
AMEC (2011) Preliminary Hazard Assessment of Glaciomarine Clay, Kitimat Valley, submitted to Northern Gateway Pipelines Inc by AMEC Environment & Infrastructure, 21 November 2011, File No. EG0926008. This report is referred to as the “Glaciomarine Clay Report” and provides a review of all presently available information on glaciomarine clay in the Kitimat Valley.
AMEC (2010) Overall Geotechnical Report on the Pipeline Route Rev. R for the Enbridge Northern Gateway Project, Bruderheim, Alberta to Kitimat, BC, prepared by AMEC Environmental and Infrastructure for Northern Gateway Pipelines. This report is referred to as the “Overall Geotechnical Report” and provides an overall preliminary summary of geotechnical issues, input and recommendations.
AMEC (2012) Report on Quantitative Geohazard Assessment, Proposed Northern Gateway Pipelines, Prepared for Northern Gateway Pipelines Inc by AMEC Environmental and Infrastructure. Referred to as the Geotechnical Hazard Report. Geotechnical Hazards are summarized in the Overall Geotechnical Report and are broken down with more detail in the Geotechnical Hazard Report. https://www.neb-one.gc.ca/ll-eng/livelink.exe?func=ll&objId=814617&objAction=browse
Atkinson, G.M. 2009. Preliminary Seismic Evaluation of Enbridge Northern Gateway Pipelines Project. Report prepared for AMEC Earth & Environmental.
Dietzfelbinger, C. (2009). Location and properties of avalanche paths that affect the proposed northern gateway pipeline alignment through the Coast Mountains. Prepared by Bear Enterprises Ltd for AMEC Earth & Environmental, August 2009. Referred to as the Avalanche Report.
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 1 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
2.0 GEOTECHNICAL RESPONSES
As indicated above, the geotechnical responses and other responses are provided in tabular format to the points made in the photographic evidence submitted. In some cases, where there is repetition, reference is made to the points under which the evidence was first discussed. The same numbering scheme is used on both sides of the table and as much as possible, the responses on the right are spaced to be in close proximity to the points made in the original evidence.
The fact that there is not a response provided to a particular statement does not indicate acceptance of the statement by Northern Gateway or its consultants. The responses in this report are necessarily brief and there is a great deal of additional information provided on the issues discussed in the various filed documents.
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Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response INTRODUCTION COMMENTS ON INTRODUCTION i.1) The geologic hazards in the Hoult Creek and upper i.1) The geologic and geotechnical hazards in Hoult Kitimat River Valleys, the earthflows in the main Kitimat Creek and the upper Kitimat River valley have been Valley, and the extreme weather events experienced on identified. With appropriate planning, design and the western side of the Coast Mountains on British construction, the hazards can be mitigated. Columbia's north coast may be the Achille's heel of Preliminary details are contained in the Overall Northern Gateway Pipeline Limited Partnership's Geotechnical Report and additional information is proposal to move liquid petroleum products between contained in the Geotechnical Hazard Report. Further Alberta's Tar Sands, and tidewater at Kitimat, BC. investigations and engineering are expected during the detailed design phase of the project.
The pipeline route avoids areas of known earthflows
in the Kitimat Valley.
The heavier precipitation, double peaks of the stream flows and other similar weather and stream flow conditions are recognized and are included in the overall planning and design for the project. i.2) The majority of liquid petroleum pipelines in North i.2) While the majority of liquid pipelines are located America are to be found east of the Rocky Mountains in a east of the Coast Range by virtue of the source and relatively benign, rolling landscape. market locations, the Kinder Morgan (former TransMountain) oil pipeline has been successfully constructed and operated across difficult terrain including valleys in the Alberta Plains, the Rocky Mountains, and through the Coast Mountains including along the Coquihalla River Valley for over 50 years. i.3) The Hoult Creek and upper Kitimat River Valleys are i.3) The presence of geohazards including debris over 4,700 feet deep, very narrow, and are subject to flows, peak flow characteristics, rock fall and long lived and extremely moist weather systems coming avalanches in the Hoult Creek and upper Kitimat off the Pacific Ocean. These heavy rains and snowfalls, Valleys are recognized and have been discussed in in concert with the precipitous terrain and young age of the various cited geotechnical reports. The hazards the Coast Mountains result in major flooding events, can be suitably planned for and mitigated in the winter flash floods, rockfall, debris slides, and design and operation of the pipelines. It should be avalanches. noted that the impact of debris flows and avalanches on buried pipelines is far less than the impact of these hazards on road structures and the pipeline hazards can be readily mitigated.
i.4) The main Kitimat Valley is situated in the i.4) The Kitsumkalum-Kitimat Trough is NOT the Kitsumkalum-Kitimat Trough, a unique geologic feature in largest valley system north of the Fraser River. The that it is the largest valley system north of the Fraser Nass, Stikine and Skeena River Valleys are all River Valley which cuts through the Coast Mountains. It considerably larger. is an area subject to local seismic shaking as evidenced by a 1973 earthquake 18km from the proposed pipelines Small earthquakes can occur in the Coast Range as path, or from the nearby Haida Gwaii and Cascadia shown on Figure 3.1 of the Overall Geotechnical Faults which are capable of large, magnitude 8 to 9 Report. These events were included in the work that mega-thrust earthquakes. was done for the Seismic Report. As noted in the filed reporting (and not discussed in the Douglas Channel
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Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response Photographic Evidence Report), the seismic design motions are low to moderate compared to elsewhere on the BC Coast. i.4) The main Kitimat Valley is situated in the i.4 Continued) The Haida Gwaii Fault (the official Kitsumkalum-Kitimat Trough, a unique geologic name of this fault is the Queen Charlotte Fault) is feature in that it is the largest valley system north of NOT nearby. It is west of the Haida Gwaii (Queen the Fraser River Valley which cuts through the Coast Charlotte Islands) and is over 300 km west of the Mountains. It is an area subject to local seismic Kitimat Terminal. The Cascadia Fault (Cascadia shaking as evidenced by a 1973 earthquake 18km Subduction Zone) is even farther away – the northern from the proposed pipelines path, or from the nearby end is near the north end of Vancouver Island – about Haida Gwaii and Cascadia Faults which are capable of 400 km from the closest point on the Project. Both large, magnitude 8 to 9 mega-thrust earthquakes. faults are capable of generating large seismic events but only the Cascadia is a thrust zone, the Queen
Charlotte Fault is predominantly strike-slip. These faults are discussed in the referenced reporting.
The 1973 earthquake was discussed by Rogers in a 1973 paper (Rogers, GC (1973) The Terrace Earthquake of 5 November 1973; Can Jour of Earth Sciences, V13, N4 April 1976). He stated that there had been no seismic events recorded previously in the Terrace area and that the event was not related to the Kitimat Kitsumkalum Trough. He re-evaluated the location of the earthquake and estimated that it was located at 54.40°N, 128.83°W or about 19 km northwest of the closest point on the proposed pipeline at the crossing of Cecil Creek. The location is in the Skeena River valley. He concluded that it was a crustal earthquake similar to others that have occurred in the Coast Mountains. This was a relatively small earthquake and the occurrence of the earthquake has been taken into account by the seismic modelling that has been done to estimate future seismic motions. i.5) The main Kitimat Valley, particularly near the i.5) The presence of glaciomarine clay is discussed at Onion Lake Flats esker, the Wedeene Rivers, and the length in the Overall Geotechnical Report and in the proposed tank farm on Douglas Channel, have Glaciomarine Clay Report, neither of which are significant layers of glaciomarine clays, deposited as referenced or discussed in the Douglas Channel the valley filling glaciers retreated after the last ice Evidence. The terrestrial areas subject to earthflows age. These glaciomarine clay layers can be subject to have been mainly north of the Onion Flats glaciofluvial failure during seismic events, and may explain the delta and even in that area, are confined to certain large number of significant earthflows found in the areas. The clay layers south of the delta along the main Kitimat Valley. Earthflows can involve many pipeline route are mostly thin and are less sensitive than the clays reported farther north. All areas of hectares of soil, scour deeply into slopes, flow down known stability problems have been avoided by the slopes as low as 3 degrees, and travel over a pipeline route. Further investigations to check stability kilometre. conditions near the proposed pipeline route are planned during detailed investigations. i.6) The Panel has overflown the proposed dual i.6) The weather and climatic conditions have been pipeline and supertanker route, except for the upper allowed for in the preliminary design of the pipeline. Kitimat and Hoult Creek Valleys, due to poor weather Weather conditions change frequently and usually
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 4 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response conditions. This is no surprise to us who live on BC's with flexibility in helicopter flight scheduling, the north coast, squeezed as we are between the Pacific required observations can be made. The design team Ocean and the Coast Mountains. We are used to has flown along the route through the Coast valley bottom scudding heavily overcast weather Mountains on numerous occasions and the geology systems lasting several weeks at a time, and the mapping and drilling investigations along the tunnel cancelled flights, highway closures, and metre-a-day route were entirely helicopter supported. snowfalls they generate.
) The various comments in the Douglas Channel i.7) The following photographs should allow the Panel i.7 Photographic Evidence contain frequent a more intimate understanding of the extreme, misinterpretations of geology conditions and unforgiving landscape between the proposed west misinterpretations and misunderstandings of the way tunnel portal on Nimbus Mountain and the proposed that various geological conditions will be mitigated. tank farm near Kitimat, and the difficulty with which the Comments are made below relative to the various proponent will have building, maintaining, or photos. accessing, finding, containing, and cleaning spills. i.8) A note regarding the photographs; the smaller i.8) Note that the sizes of the photos in this document format photographs were easily found via Google are all similar. Image searches. The larger photographs are my own, and are not otherwise on the public record.
2.1) As discussed above, the Kitsumkalum-Kitimat 2.1) The Kitsumkalum-Kitimat Trough is the largest Trough in NOT the largest valley system to cut valley system to cut through the Coast Mountains in through the Coast Mountains north of the Fraser BC north of the Fraser River Valley. Hinting at the River. The Skeena, Nass and Stikine are all larger. geologic forces required to shrug aside those building the Coast Mountains along the rest of BC's coastline, The phrase “Hinting at the geologic forces required to there are 4 hot springs and the Tseax Volcano, all of shrug aside those building the Coast Mountains along which are to be found within the trough along its the rest of BC’s coastline” suggests that the forces eastern margin. building the Coast Mountains were somehow suspended or overcome by the forces that created the trough. This is NOT the case. The trough was formed by glacial deepening and erosion of a previously existing river valley, similar to many of the other large valleys on the coast.
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 5 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response
2.2) More on the seismic hazards in the Kitsumkalum- 2.2) Discussed later. Kitimat Trough, and the deeply cut valleys adjacent to it where the proposed pipelines are intended to be The Tseax Volcano (also called Aiyansh Volcano) is constructed, will follow later in this document. not shown on the map in the photo since it is north of the end of the Kitsumkalum trough proper along Tseax Creek which is tributary to the Nass River. The cone was the site of eruptions around about 1750. Volcanoes occur as a result of subduction processes at various locations around the Pacific Basin (the
“Pacific Rim of Fire”). The Tseax Volcano does not
result from special or unusual forces acting on the Kitsumkalum-Kitimat Trough and does not pose a hazard to the Project.
2.3.a) Kitimat experiences an average of 1.267 metres 2.3a) The value provided is incorrect for Kitimat of rain between the months of September and April, Townsite as provided in the 1970 to 2000 Climatic for an average of 181mm for those months. Normals on the official Environment Canada website http://www.theweathernetwork.com/statistics/precipitation/cl106 where the official value is 1.467 m (not 1.267): 4320/cabc0154 http://www.climate.weatheroffice.gc.ca/climate_normal s/results_e.html?stnID=402&lang=e&dCode=1&Statio nName=KITIMAT&SearchType=Contains&province=A LL&provBut=&month1=0&month2=12. This amount is high but not an unusual value for the coast of BC. High snow and rain falls have been allowed for in the preliminary design of the pipeline system and will be further considered during detailed design.
2.3.b) Kitimat experiences an average of 4.15 meters 2.3.b and c) High snow fall is not unusual in the Coast of snow between the months of November and March, Range and the pipeline and facilities will be designed for an average of 83cm for those months. for appropriate snow fall values as part of the overall http://www.theweathernetwork.com/statistics/precipitation/cl106 design. Pipelines are operated in numerous high 4320/cabc0154 snow areas. For example, Powder King in the Pine 2.3.c) While these rains and snowfalls are Pass receives 40 ft (12.2 m) annually on average considerable as compared to a great majority of other according to its website. Spectra and Pembina have Canadian cities, they pale to the rain and snow operated gas and oil pipelines that run through the experienced in the deeply cut valleys on the margin of base area of the ski area for many years. the trough through which the proposed pipelines must pass to enter the main Kitimat Valley.
Shames Mountain Ski Hill has 1200cm of average annual snowfall. That is over 39 feet of snow per year.
Shames Mountain is located 62km diagonally across the trough to the north west from Mount Hoult, upon whose lower slopes the proposed pipelines are to be constructed. http://www.ski-resorts.ca/36/canada/british-columbia/shames- mountain/ eng/livelink.exe?func=ll&objId=779695&objAction=browse
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Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response 2.3.d) These high coastal mountains on either side of the Kitsumkalum-Kitimat Trough quickly relieve moisture from the weather systems pouring in from the west, and delivers it through the Kitimat River and its tributaries to the Kitimat River estuary and the head of Douglas Channel. Ontario complains of its "lake effect" weather...BC's north coast has the "Pacific Ocean effect". 2.3.e) One example of how such weather can effect ) The design and routing constraints of a linear infrastructure is a storm from October 6 to 14, 2.3.d and e highway are very different from a pipeline. The 1991, about which a BC Government document pipeline route avoids the areas of lateral erosion from states, "Highway 37 between Terrace-Kitimat was the Kitimat River and the potential for lateral erosion closed for about 24 hours by flooding and shoulder will be taken into account during detailed design in the washouts. Two kilometres south of the Kitimat River Kitimat River valley and other valleys. bridge, a one-lane section of 150 m of highway disappeared into the river. The Kitimat River moved to the east, hitting a portion of highway where the embankment had not been riprapped. Tim Gleig, the District of Kitimat director of engineering services, stated that the Kitimat River rose more than 17 ft. (5.1 m) in just over 30 hours by high tide in the afternoon on October 10." (emphasis mine) http://www.env.gov.bc.ca/wsd/public_safety/flood/pdfs_word/flo ods_landslides_north.pdf 2.4) It is suggested that while viewing the remaining 2.4 and 2.5) It is true that if the Pacific Trails Pipeline photographs, the Panel be cognizant that the Pacific were to be constructed, the proponent might choose Trail Pipelines natural gas pipeline will be constructed the easiest route to construct, particularly if there is first, thereby having the ability to choose the safest not adequate joint planning to optimize use of the path through Hoult Creek and the upper Kitimat River corridor for more than one pipeline. It would still be Valleys, and through the glaciomarine clays of the feasible to construct a second safe route; however, main Kitimat Valley. the construction would be more expensive than it 2.5) The proponent must be aware of how having could be with joint planning. From the point of view of second dibs through such geologically hazardous best use of the terrain and the least overall terrain will increase the probability of ruptures in their construction cost, it would be preferable for all pipeline proposed liquid petroleum pipelines, and claims that, proponents to cooperate, thus reducing both construction costs and maintenance costs. This would "Northern Gateway has been attempting to engage the also reduce the overall width of the disturbed zone in proponents of the Pacific Trail Pipelines for an some areas and would optimize use of the terrain. extended period of time regarding collaboration on routing, construction and access management, and will continue to do so in the future." https://www.neb-one.gc.ca/ll-
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Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response
3.1 and 3.2) The elevation for Mount Athabasca is 3.1) The Hoult Creek Valley is where the proposed listed on-line at 11,452 ft while the elevation at the west tunnel portal on Nimbus Mountain is intended to Visitor Centre location is given on the UTS Map 83C3 be located, and where the proposed pipelines are to Columbia Icefield (1:50,000) as 1986 m. 1986 m = parallel Hoult Creek. 6516 ft. 11,452 – 6516 = 4936 ft which is greater than the 4700 ft stated for Hoult Valley. So the perspective 3.2) The mountains in the Hoult Creek Valley rise over example provided is incorrect. 4,700 feet above the valley floor on both sides of the valley. To put this into perspective, this is higher than Mount Athabasca rises above the Icefield's Parkway at the Columbia Icefields in Banff National Park.
3.4) The great rise from the valley floor to the peaks 3.4) It is true that at times there is poor visibility along on both side of the valley, in concert with their the route in the upper Kitimat Valley and Hoult Valley proximity to the Pacific Ocean, result in this and the west of Mount Nimbus. However, experience with upper Kitimat Valley being shrouded in low lying cloud extensive flying in the area during route evaluations and alpine heli-drilling for the proposed tunnels for a significant percentage of the year as compared to indicates that as storms cycle through the area during the main Kitimat Valley. This will result in a significant periods of poor weather, there is often a few hours of reduction in the Proponents intended aerial clearing that allows flying to be done. At other times, surveillance of the pipelines integrity, or of aerial there may be periods of relatively good helicopter access during emergencies. access. As an alternative, the existing logging roads are also potential routes for reconnaissance. The flying conditions are not dissimilar to those encountered during aerial patrols on other pipelines through the Coast Mountains where such patrols are used on an ongoing basis as part of the integrity management program.
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Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response
4.1) To be clear, this photo appears to have been 4.1) The proposed pipelines will have to parallel Hoult taken from the valley bottom of Hoult Creek. The Creek for 5km after leaving the proposed Nimbus pipelines will be routed along the lower valley slopes Mountain Tunnel, on the flanks of Mount Hoult which close to the existing logging road or toe of valley slope rises 4,788 feet above the valley floor. and will not be located on the valley floor where the photo was taken.
5.1) These geohazards are discussed in the Overall 5.1) In the above photograph, as indicated by the Geotechnical Report and also in the Geotechnical arrows, are 5 of the 11 avalanche / rockfall / debris Hazard Report. With suitable design methods, the chutes in the first 5km of the proposed pipelines path geohazards can be mitigated so there will be no after exiting the Nimbus Mountain tunnel. significant elevated hazard for the pipeline. Note that a buried pipeline is very different from a forestry road which is subject to the above ground impacts of debris flows and avalanches.
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 9 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response
7.1) This is the Nimbus Mountain west tunnel portal 7.1) A Forestry Technician is NOT a recognized slope. The proponent admits in its response to expert in slope stability or avalanches with respect to Douglas Channel Watch IR #1, (1.1.e) that a Forestry construction and operation of the proposed pipeline Technician, expert in determining whether a slope has and associated infrastructure such as the tunnels. been subject to past avalanches or rockfall, has not Therefore, there is no need for a Forestry Technician examined this slope. to inspect the slope. Personnel doing these types of 7.2) A paragraph number, followed by a capital letter, examinations are required to be Professional will indicate which indicating arrow in the photograph Engineers or Professional Geoscientists with is being discussed. appropriate experience and/or qualified in avalanche 7.A) Approximate location of the tunnel portal. safety with respect to design operations. The slope 7.B) Tunnel portal slope is covered by young trees as has been examined by the appropriately qualified evidenced by the high number of tops for a given area, personnel. See also: and their shorter height. http://www2.worksafebc.com/Publications/OHSRegula tion/Part4.asp#SectionNumber:4.1.1 7.C) Mature forest as evidenced by fewer tops for a given area and greater height than those indicated by arrow 7.B on the tunnel portal slope.
7.D) Extremely large avalanche slopes immediately to 7.1 to 7.D) As discussed later in this report and in the north and east of the tunnel portal slope. The small other Project documentation, while the slope above patches of snow indicated are the remains of the the Hoult Tunnel portal is not subject to major previous winters avalanches. This photograph taken in avalanches, a portal canopy is a potential mitigative mid October, 2011. measure to provide additional protection against the possibility of rock fall and avalanches. This is subject to ongoing work. There are large avalanche areas adjacent to the portal area, but the portals are not located within the area of these large avalanche chutes.
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 10 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response
8.1) The photo caption indicates that there are no 8.1) The forest below the proposed tunnel portal is fallen trees but there are several visible in the right very young, and there is no evidence of fallen mature half of the photo. The trees are small and are growing trees, or nurse logs. There are no burned ancient on poor soil conditions. The material likely consists of stumps either, so this slope was not burned by forest rocky soils from moraines deposited during the last fire prior to these trees growing. glaciation. The lumpiness may be partly rocky materials and partly soil piping (internal erosion of sandy materials). Such erosion tends to occur where the soil is not anchored by roots, producing higher areas where the trees are rooted. There is continuous moss cover indicating that there have been no processes disturbing the surface for a considerable length of time. The high moss growth is facilitated by high rainfall. The poor growing conditions are further indicated by the almost total lack of understory vegetation. The lack of large diameter trees is probably more a result of poor soil and growing conditions than destruction by fire or other events.
8.2) The lumpy appearance to the forest floor is due to 8.2) The surficial deposits are not rock slide material. the whole slope below, on both sides, and above Terrain typing (excerpt from the mapping appears where the proposed tunnel portal is to be located below) indicates that this area is covered colluvial being composed of rockslide material. materials on the upper part of the slope with various till (moraine) units on the lower part of the slope. The colluvial materials may include local rock fall material but there are not widespread large rock slide deposits. Photo 8.1 is consistent with colluvial and till (moraine
deposits) as noted above. See next page.
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Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response
An excerpt from the terrain mapping for the area under discussion appears above (GEM - Jacques Whitford AXYS (2010) Technical Data Report, Geology and Terrain, Enbridge Northern Gateway Project, prepared by D. O'Leary, M. Trommelen, and D. Huntley for Northern Gateway Project).showing the distribution of various surficial deposits. The red numbers are Rev R kilometre stations. The Hoult Tunnel portal final location has not been finalized but it is anticipated to be at approximately KP 1085.6 on the lower part of the ridge (this location may vary during detailed design). The legend was provided with the terrain typing; however, M indicates morainal materials (till) and C indicates colluvial materials.
9.1) This moss covered boulder in the photo is either a glacial erratic left behind by melting glacial ice or possibly a result of rock fall from higher up the slope. The extent of moss cover and lichens indicates that
this boulder did not fall recently. The tunnel portal will 9.1) Large boulders are encountered on the slope likely incorporate a portal cover extending from the below the proposed tunnel portal. portal proper to provide protection against rock fall, snow creek and related issues at the portal. Rock fall is not a major concern providing that the pipeline is suitably buried and protected.
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11.1) A small stream flowing partially above ground and partially through the rocky debris is completely consistent with the expected surficial geology conditions on this slope which consists of moraine (till) on the lower part of the slope and colluvium (material 11.1) A small stream appears and disappears on the moved under the influence of gravity) on the upper proposed tunnel portal slope. part of the slope. Both materials may have high local permeability due to being composed of coarse grained materials. 11.2) This further indicates the slope is made of boulders and rockslide material from previous 11.2) As discussed above, the slope is indeed rockslides, and/or rocky material carried downhill by composed of rocky materials but this material was not previous avalanches. deposited at this location by large avalanches or rock slides.
12.1) It is possible that this tree scarring is a result of rock fall. Local rock fall is possible on the upper part of the slope above the tunnel portal and pipeline design will be designed to mitigate this possible 12.1) There is scarring on the uphill sides of many hazard. However, other forces such as snow creep, trunks on the proposed tunnel portal slope. This is trees falling, wildlife and First Nations (culturally clear evidence of past rockfall and/or avalanche modified trees) may be responsible in part for the tree damage. scarring in this area. The reference provided is to the http://www.for.gov.bc.ca/hfd/pubs/docs/Lmh/Lmh55part1.pdf Snow Avalanche Management in Forested Terrain Land Management Handbook (published by BC Ministry of Forests) which does not discuss rock fall.
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12.2) Growth on left edge of scar suggests damage 12.2) The scar appears to be old and the bark has was incurred relatively recently as compared to the healed around the edge of the scar. The scar does age of the tree. not appear to be recent.
13.1) Heavily scarred trunk 3 metres from surveyors 13.1) The portal location has not been finalized – the tape indicating the west tunnel portal location. surveyor’s tape should not be taken as a final portal location. It is possible that this centre rot could be due to tree scarring from a rock fall event but there are no boulders visible in the photo. A portal canopy may be used on the west portal of the Hoult Tunnel to provide additional protection from rock fall and avalanches. Additional investigations in this area are anticipated; however, it is feasible to design the pipelines to be safe from avalanches and rock fall in this area.
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 14 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
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Evidence from Douglas Channel Watch Response 14.1) The final location of the portal has not been chosen and depends on a number of design considerations; however, the general area as shown in the photo appears to have suitable terrain.
14.1) Flagged location of Nimbus Mountain west tunnel portal location. 14.2) See comments above relative to rock fall potential and design to protect the pipeline. The 14.2) Tree to left of person is the scarred tree in conditions shown in the photo are similar to what is photograph 13. expected in this area and there are no conditions identified that are a major impediment to the safe design and operation of the pipelines.
14.3) Cross slopes in the photo appear to be relatively 14.3) Canopy is very thin as seen by the amount of flat (<20°) and would be too flat for local avalanche sky visible diagonally through forest. This would allow initiation. Assessment of avalanche potential at the for an increase in surface hoar frost to develop as site by a qualified avalanche technician (discussed in compared to a full forest canopy, increasing the the Avalanche Report) indicates that small avalanches likelihood of avalanches. might be possible at the portal site, but not major http://www.for.gov.bc.ca/hfd/pubs/docs/Lmh/Lmh55part1.pdf ones. A portal structure will be considered to protect the pipeline transition from the tunnel and avalanche control will be implemented as required during construction (final design of the portal has not been done).
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16.1) It is not unusual in this area where high winds and high snow loads occur for trees to have damaged tops. Without a detailed study, the reason for the damaged tops is not clear. See further details of the results of the avalanche study which are discussed above.
16.1) Many of the older hemlocks on the proposed tunnel portal slope have damaged tops.
17.1) The apparently consistent diameter is not a reliable indication that the trees were broken in a single event, although such an event (including events such as a storm with high winds) cannot be excluded.
17.2) Postulating that the trees were protected by 17.1) Many of the damaged tops appear to have been snowpack and the tops were broken off by an broken off in a single event as evidenced by the avalanche would imply a snowpack depth equal to the consistent diameter of the tree tops at the point of heights of the trees – this is not known but might be in damage, as well as the resultant spreading and the order of 20 m or more. Depths of this order are increased growth of the uppermost branches. not out of the question, but as noted above, wind and snow loads are other more likely reasons for the
damaged tops. 17.2) These trees may have been young enough to be protected by snowpack, but had their tops broken off 17.3) This dating is highly conjectural. While final by an avalanche. design of the portal has not been done, a portal canopy to provide rock fall and avalanche protection 17.3) Photographs 15.2, 15.3, 15.4, 16.1, and 17.1 to the transition of the pipeline at the end of the tunnel suggest the last major avalanche and/or rockfall event will likely be incorporated. In any case, rock fall and to happen on the proposed tunnel portal slope, avalanche hazards can be handled in this area with occurred between the age of the larger, scarred straightforward design methods. A safe transition hemlocks, and the young balsam. from the tunnel will be provided for the pipelines.
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18.1) This low rock bluff is rounded and moss covered 18.1) The first rock bluff is encountered approximately and no recent rock fall scars are apparent. 75 metres above the proposed tunnel portal. 18.2) The “lumpy” material is a combination of glacial 18.2) Lumpy forest floor indicates it is growing on till and morainal materials possibly combined with rockslide material. some rock fall material that is very old.
18.3) Curving tree trunks indicative of downhill creep 18.3) The curved trees (pistol butts) are a result of soil of rockslide material and/or being flattened by creep, possibly aided by erosion of sandy material. avalanche debris when young. This is a normal slope process on steep slopes. The pipeline and tunnel portal will be installed well below the surficial soil layers at lower elevation than the photo and so will not be adversely affected by the creep. There are no adverse conditions shown that cannot be adequately mitigated during design and construction.
18.4) There are no fallen mature trees, or nurse logs. 18.4) Contrary to the assertion that there are no mature fallen trees, there is a moss covered log of a mature tree on the lower right side of the photo.
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19.1 and 19.2) Note previous comments regarding the portal location which has not been finalized. The condition of the small bluffs is typical of rock bluffs in the area. There are no apparent recent rock fall scars. There may have been some past rock fall from 19.1) The second rock bluff, approximately 120 metres the bluffs which is an expected condition that has above the proposed tunnel portal. been allowed for in the design. 19.2) The bluff is composed of fractured rock, with many loose blocks exposed. 19.3) Contrary to the assertion that there are no fallen 19.3) There are no fallen mature trees, or nurse logs. mature trees, several old moss covered logs are visible in the photo.
20.1) Avalanche alder growing on an open slope, 20.1 and 20.2) Avalanches DO NOT occur annually or south of the rock bluffs, above the proposed tunnel semi-annually on the slope at the tunnel portal. See portal slope. detailed discussion in the Avalanche Report. This 20.2) This is significant as it proves avalanches occur photo may have been taken northwest of the portal annually, or semi-annually, on the south side of the where there is an active avalanche slope. As forested slope on Nimbus Mountain where the discussed in the Avalanche Report, the area of more active avalanches would not affect the portal and the proposed tunnel portal is planned. preliminary tunnel alignment has been chosen to avoid this area.
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Evidence from Douglas Channel Watch Response 20.3) Note young hemlock broken at mid-height in 20.3) This photo appears to be looking laterally into an foreground. Indicates recent avalanche damage as area of more active avalanche chutes. It was likely revealed by the unweathered coloration of exposed taken northwest of the tunnel portal (upstream along wood, and by the age of the tree. Hoult Creek) in an area of active avalanche chutes. These active avalanches are deflected from the portal location by the terrain and the portal area is not subject to significant avalanche hazard (see excerpt from Avalanche Report below). 21.1, 21.2) The area in the background may be the area referred to in the comment. This photo appears to have been taken in the same area as Photo 20.1 and is looking toward avalanche chutes which are not located above the portal area. See comments for Photo 20.1 above.
A detailed report on avalanches has been prepared referenced above as the Avalanche Report. The following is from the section on the west Hoult Tunnel portal: “This area contains the largest and most productive avalanche paths in the study area. The tunnel portal as shown on the 1:20,000 map Revision Q appears to be outside the areas directly affected by size 3 and 4 avalanches. The portal is located on a wooded spur that protrudes to the W above the confluence of two headwaters of Hoult Creek. The immediate portal area was ground checked on 29 May. The portal area is in 21.1) Avalanche alder growing above rock bluffs mature coastal forest with limited underbrush that above proposed tunnel portal slope. 21.2) Significant shows no signs of avalanche activity. The terrain is as it proves avalanches occur annually, or semi- between 30 and 35° steep and broken by small cliffs. annually, above the forested slope on Nimbus Construction activities may lead to some small Mountain where the proposed tunnel portal is planned. cutbank type avalanche hazards to size 2, but the 21.2) Note "flagging" of branches on downhill side of area is safe from large snow avalanches. The trees as a result of avalanches braking off uphill alignment near the site of the W portal Hoult corridor branches. shown on the map appears to pose relatively small . avalanche risks. However, this corridor is quite narrow. During building operations, workers and equipment must not stray outside it unless the paths have been stabilized or the stability is good. This should be taken into consideration when the building
logistics are planned. The areas adjacent on either side of the wooded spur are extremely active and large avalanche areas that should be entirely avoided.”
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22.1) Broken tree at top of second rock bluff, 22.1 and 22.2) As discussed for other photos above, it approximately 120 metres above proposed tunnel appears likely that this photo was taken in the active portal. avalanche area. The active avalanche area does not 22.2) Shattered nature of wood indicates the great affect the portal location. force required to break the tree.
23.1) Avalanche alder slope immediately adjacent to 23.1 and 23.2) This photo was apparently taken in the the north of the top of the second rock bluff, active avalanche area as discussed above. The approximately 120 metres above proposed tunnel avalanche conditions in this area are known as portal slope. discussed above. The portal and pipeline route are 23.2) Evidence of massive, frequent avalanches not subject to avalanches in this area, which was and/or rockfall. avoided. The avalanche area shown is beyond the portal area and will not affect the portal or pipeline.
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24.1 and 24.2) There are no unusual or unexpected 24.1) Slope immediately below north side of rock conditions shown on the photo. Some local rock fall bluffs, 120 metres above the proposed tunnel portal may occur and will be allowed for in the portal design slope. as discussed above. Most or all of the rock fall will 24.2) Note the consistent age, and proportionally stop well above the portal area. The small trees are higher number, of the younger trees on this slope. probably a result of growing conditions, not avalanches.
25.1 and 25.2) The avalanche conditions in this area 25.1) Base of avalanche path approximately 100 are known and are discussed in the evidence filed metres to the north of, and at approximately the same (see Avalanche Report). The portal is located outside elevation as the proposed tunnel portal. of the active avalanche path. 25.2) For reference, this is the avalanche slope to the left of arrow 7.E in photograph 7 in this document.
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26.1 and 26.2) As discussed above, the active avalanche paths near the Hoult Tunnel portal location
will be avoided. Large glacial erratics are common in this area and the large erratics were not a product of 26.1) One of several large boulders at the base of the recent rock fall, and may not be due to rock fall at all. avalanche path in photograph 25. The portal and pipeline appear to be beyond the area ) Evidence of the instability of the rock bands on 26.2 that would be affected by major rockfall. However, the slopes above, and very near to, the proposed rock fall hazards have been considered and will be tunnel portal. considered further during detailed design.
27.1) The photo shows continuous forest cover with 27.1) Avalanche initiation zones on the slope above no evidence of past avalanche tracks. As discussed the second rock bluff in the previous photographs. above the avalanche assessment indicated that large This very steep slope is directly above the proposed avalanches would not occur at the tunnel portal. tunnel portal slope. Nevertheless, additional protection will be considered depending on assessments of local conditions.
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28.1) Avalanches are a significant concern for surface facilities. However, with suitable planning and design, buried facilities can be safely installed and operated. Wherever possible, the pipeline and facilities have been planned to miss major avalanche paths but where necessary, additional cover or other protective measures will be implemented. Avalanche hazards have been compiled in the Geotechnical Hazard 28.1) A forest laid flat. Evidence of the destructive Report. Further details on avalanche hazards are power of periodically massive avalanches. also provided in the Overall Geotechnical Report.
29.1) The proposed pipelines proximity to the 29.1) The referenced seismic event was discussed epicentre of a 1973 4.2 magnitude earthquake, which previously in Section i.4. The 1973 event was a because of its shallow epicentre, produced ground relatively small earthquake and the occurrence of the shaking effects of V on the Modified Marcelli Scale, earthquake has been taken into account by the puts the proposed pipelines at risk for future seismic seismic modelling that has been done to estimate events and the avalanches, rockfalls, and debris slides future seismic motions. This earthquake magnitude they could initiate. would be unlikely to initiate the events stated at the pipeline RoW. In any case, such events have been considered in the overall hazard assessment that has been carried out. If additional rock falls or other hazards were triggered by a seismic event, they would be at locations where the potential for rock falls and other hazards had already been identified and allowed for in the pipeline design.
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Evidence from Douglas Channel Watch Response 29.2) According to the National Research Council, 29.2) While sensitive seismographs were only sensitive seismographs were first installed in western installed in the 1950’s, a seismograph capable of Canada in the 1950's. Before the installation of recording strong earthquakes throughout western BC sensitive seismographs, it was not possible to was installed in Victoria in 1898. The seismic models accurately record the location, depth, or magnitude of used to project the probable future seismic ground earthquakes in this area. motions make allowance for the time length of the http://www.nrcresearchpress.com/doi/abs/10.1139/e93-028 data set.
29.3) Using aftershocks from the Haiti earthquake of 29.3) Topographic amplification is a well known effect 2010, U.S. Geological Survey scientists confirmed that and will be taken into account as required during the seismic waves are amplified by ridges in the analysis of structures. landscape, describing the phenomenon as Topographic Amplification of seismic waves. http://www.nature.com/ngeo/journal/v3/n11/full/ngeo988.html#/a ccess
29.4) An earthquake on the nearby Haida Gwaii Fault 29.4) The effects of earthquakes on the Haida Gwaii in 1949 was 8.1 in magnitude, and produced ground (actually the Queen Charlotte) Fault have been taken shaking effects of VI on the Modified Marcelli scale in into account in the seismic modelling (see the Overall the Kitimat vicinity. It is also theorized by Dr. Michael Geotechnical Report and the more detailed Report on D. Higgins, that the last Cascadia Fault megathrust Seismicity). Note that the Queen Charlotte Fault is earthquake of 1700 caused enough shaking to initiate over 300 km west of the Kitimat Terminal. The an eruption of the Tseax Volcano, 140km northwest of Cascadia Fault (Cascadia Subduction Zone) is even Kitimat. farther away – the northern end is near the north end http://journals2.scholarsportal.info/details.xqy?uri=/03770273/v1 of Vancouver Island – about 400 km from the closest 79i1-2/149_tcmeo1wcaape.xml point on the Project.
29.5) Avalanches, rockfall, and debris slide hazards 29.5) All of these natural hazards have been taken due to topographic amplification of seismic waves are into consideration during the preliminary design of the a particular concern, considering how many buttresses pipelines and related facilities. The effects of glacial and loose rock on steep alpine slopes remain after the retreat are not a significant consideration for the rapid retreat of alpine glaciers in recent decades. proposed route, which was chosen to avoid areas that might be subject to rock avalanches resulting in part from glacial retreat.
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30.1) Split Mountain on the south side of the Skeena 30.1) Split Mountain is actually located NORTH of the River is 28 km from the proposed pipelines crossing of Skeena River and is about 89 km from the site (see the glaciomarine clay layered Onion Lake Flats esker location below). The striking mountain has no direct in the Kitimat Valley, and 10km away from the connection with seismic activity in the area. epicentre of the 1973 earthquake.
30.2) It is hard to imagine a more visually striking 30.2 and 30.3) The mountain did not “open” . In fact example evidencing the tremendous geologic forces at the chasm through the centre of the mountain was play in the Kitsumkalum-Kitimat Trough. formed by erosion along joints that cut through the 30.3) Mountains do not open with the silent grace of mountain. The joints can be seen on the photo below. rose buds.
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Close-up of Split Mountain (photo published on Internet). Note the steeply dipping joints along which erosion occurred, producing the chasm through the mountain.
31.1) This photograph is Hoult Creek, approximately 31.1) The crossing of Hoult Creek is upstream of the 500 metres downstream of the proposed tunnel portal location of the photo. At the proposed aerial crossing, slope on Nimbus Mountain. the creek is flowing in a narrow rock gully. In the photo below, the preliminary crossing is upstream of the waterfall.
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31.2) This is the creek referenced in 7.E of this document which is proposed to have an aerial crossing from the lower slope of Nimbus Mountain on the east side of Hoult Creek where the proposed tunnel portal is located, to the lower slopes of Mount Hoult on the west side of Hoult Creek. The proposed 31.2) Along Hoult Creek, the pipeline route is on the pipelines then begin their path to Kitimat, paralleling valley sideslope roughly paralleling a logging road. Hoult Creek and the Kitimat River for the majority of Hoult Creek is crossed at KP 1090.0 and Chist Creek that distance. at 1126.4. Thus, the pipeline route parallels Hoult Creek and the upper Kitimat River for 36.4 km. The pipeline route also parallels the lower Kitimat River from KP 1157.7 to 1163.1, or a distance of 5.4 km. The end of the pipeline is at KP 1175.6 (all values for Rev U). Thus, the pipeline closely parallels Hoult Creek and the Kitimat River for about 41.8 km or less than half of the distance from the Hoult Creek crossing to the terminal. 32.1) Hoult Creek, approximately 6km downstream of 32.1) The pipeline route at this location is not shown photograph 32, and 2km from the Kitimat in the photo but is above the logging road to the right River. of the photo.
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Evidence from Douglas Channel Watch Response
35.1) Response provided by Enbridge personnel. Three dams (or weirs) are present on the Kalamazoo River in the area of the July 26, 2010 Marshall incident. These are the Ceresco Dam (shown as photo 35.1) located approximately 5.8 miles downstream of the incident site, Kalamazoo River Dam in Battle Creek located approximately 16 miles downstream of the incident site, and the Morrow Lake Dam, which was located approximately 40 miles 35.1) Two dams on the Kalamazoo River greatly downstream of the incident site. Many factors reduced the length of the Kalamazoo River damaged affected the downstream transport and distribution of by the spill. oil within the Kalamazoo River, including the presence of the dams, the fact that the river was in flood stage, the presence and nature of vegetation along the riverbank, and many others. The Ceresco Dam and Kalamazoo River Dam are non-operational dams, and allow water to flow over their spillways (on the right of the photo of the Ceresco dam). At the time of the Marshall incident, the Kalamazoo River was in flood stage, and water was also flowing over the Ceresco Dam’s overflow weir (seen on the left of the photo). The upstream impoundment area did create a lower flow area and provided areas for oil recovery.
Morrow Lake, upstream of the Morrow Lake Dam, is considered to be the furthest downstream location affected by the spill. As a result of upstream containment efforts and other factors, limited amounts of free product were transported to Morrow Lake. Morrow Lake did create an effective settling area for any submerged oil that reached this downstream location, and was the focus of significant submerged oil recovery efforts in 2010 and 2011.
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36.1) Response provided by Enbridge personnel. Enbridge has been working with the EPA and other 36.1) One year after the spill into Talmadge Creek and regulatory agencies to recover submerged oil the Kalamazoo River, Enbridge and the U.S. associated with the Marshall spill. This effort has Environmental Protection Agency are finding it difficult been on-going since the spill, and will continue until to both locate, and clean up the dilbit which has Enbridge, the EPA and Michigan Department of sunken into the riverbed. Environmental Quality are satisfied that recoverable http://www.epa.gov/enbridgespill/pdfs/enbridge_directive_2011 submerged oil has been collected, and that no net 1006_workplan-modifications.pdf environmental benefit remains. Submerged oil present at Marshall in 2011 was typically in the form of millimeter-size droplets, distributed in the sediment matrix.
37.1) Returning from the gently rolling landscape of 37.1 and 37.2) These are not rock fall chutes but Michigan to the geographic and environmentally incised stream channels that can funnel debris flows inconvenient realities of the Hoult Creek Valley, down the hillsides and may be sources of or locally photograph 37 details the second and third avalanche, direct rock fall. The presence and details of
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Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response rockfall, and/or debris chutes indicated in photograph avalanche chutes and debris flow channels along 5 of this document. Hoult Creek are discussed in both the Overall Geotechnical Report and in the Geotechnical Hazard 37.2) The slopes of Mount Hoult are deeply incised by Report. Nine debris flow channels have been 11 avalanche and/or rockfall chutes, all of which run identified (see Geotechnical Hazard Report). perpendicular to, and cross, the proposed pipelines path.
37.A) The detailed hazard assessments of each the 37.A) Each of these avalanche, rockfall, and/or debris channels and avalanche chutes relative to transport chutes can funnel snow, ice, and rock from the near and deposition of avalanches, debris flows and rock vertical alpine walls up to 4,788 feet above the valley falls where geohazards have been identified is shown floor. in the Geotechnical Hazard Report. However, while 37.B) Evidence of "flagging" on trees left standing, the mountains above Hoult Creek have steep areas, where uphill branches are broken off during previous there are no significant cases of “near vertical alpine avalanches. walls”. 37.C) Approximately 50% of the trees in this stand were laid flat by a recent avalanche. The proposed 37.A, B and C) The pipeline system will be designed pipelines will cross this chute approximately 50 metres with respect to avalanches and debris flows among downslope of this stand. other natural hazards (geohazards) that occur along the route and the hazards will be mitigated. The general aspects of the design are discussed in the Overall Geotechnical Report and more details are provided in the Geotechnical Hazard Report. Sufficient depth of cover and additional protection will be provided so that the pipelines are protected against hazards such as debris flows, rock fall and avalanches. The hazards will pass harmlessly over or deposit on top of the buried pipelines without affecting them.
38.1) This is not a rock fall chute but the canyon likely does carry debris flows at times. One method to design the pipeline crossings of such chutes or canyons is to place the pipelines under the bottom of the canyon so that integrity of the pipelines will be ) The creek in the avalanche and/or rockfall chute 38.1 protected. Where steep gradients are present, indicated in 37.B and 35.C. The first log on the bottom concrete backfill will be considered to avoid right is approximately 10 metres from the logging road unconsolidated backfill being removed by high flows. which the proposed pipelines are to follow.
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Evidence from Douglas Channel Watch Response
39.A) This appears to be a debris flow channel, possibly on an alluvial fan (the location of the photo is not provided). This and similar crossings will be designed to put the pipelines at sufficient depth across the debris flow streams so that they are not affected by future channel changes (avulsion) or erosion. 39.B) It is more likely that the young trees are present due to the vegetation being destroyed by the debris flows that deposited the boulder alluvium in the photo. While the location was not provided, avalanches are probably not the cause of tree destruction on this alluvial fan. 39.A) One of the deeply incised gullies on the flanks of 39.C) The final pipeline route will not necessarily Mount Hoult. follow the road but will be located to cross debris flows 39.B) Evidence of periodically massive avalanches as on alluvial fans at the best location with respect to the indicated by the young growth on the side slope. terrain conditions. Deep cover and possibly other protective measures will be used on this and similar 39.C) Approximate path of the proposed pipelines, features to protect the buried pipelines. As noted perpendicular to a recent rock and debris slide. The elsewhere, roads on the surface are much more person seated is where the logging road should be, vulnerable than to debris flows and other geohazards and the proposed pipelines are to follow this road. such as erosion and avalanches.
40.1) This is a recent debris flow on an alluvial fan, not a rock slide. The recent timing is indicated by the fresh appearance of the materials, not the burial of the butt flares. The photo was taken in an accumulation area. The deposition of materials over the pipeline is not a major problem. In areas where erosion can occur, either as a direct result of such an event or due to stream avulsion (channel changes), the pipeline 40.1) Arrow indicates where flared bottom at the base will be buried to sufficient depth so that it is not of the snag should be. Buried flare of the snag, and exposed by erosion. Additional protection such as the base of the cottonwood to the right of it, indicates concrete coating may also be considered in particular this rockslide was a recent occurrence. cases.
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 31 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
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Evidence from Douglas Channel Watch Response
41.1) Arrows indicate sharp edges in a large deposit of 41.1) This is rock fall from an old logging road cut, not post-glacial rockfall material exposed by road building a rock avalanche. It is located on an old logging road in Hoult Creek Valley. spur above the valley bottom. If the pipeline were to 41.2) Sharp edges are evidence that this large be routed through such an area, the old failure would rockslide occurred in the post-glacial period, as they be excavated and scaled. Possibly rock anchors or were not subjected to the grinding forces of a glaciers shotcrete would be used as required to stabilize the weight. cut. Additional depth of cover or additional protection 41.3) The proponent is well aware of such events, and such as concrete coating or berms over the pipelines of their not being fully cognizant of all the hazards might also be considered. lurking above; "Debris flows, rock instabilities and soil 41.2) The failure is indeed recent and probably slope failures associated with high groundwater occurred in the last few tens of years following conditions, occur in localized areas. Rock avalanches construction of a logging road spur. are also known to occur, but the pipeline route was 41.3) As noted above, this is NOT a rock avalanche, but failure from a rock cut and the adjacent terrain that selected to avoid all areas identified, although they has created a rock fall. The failure appears to be may remain a concern on some access roads." have been triggered by undercutting during the road Indeed.(emphasis mine) construction. http://www.ceaa.gc.ca/050/documents_staticpost/cearref_2179 9/2213/Volume3/Vol_3_Main_Report.pdf
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Evidence from Douglas Channel Watch Response
42.1, 42.2, 42.3) It is possible that this boulder was a result of rock fall; however, it is moss covered and 42.1) Large boulder on proposed pipelines path above certainly did not fall recently. It is more likely that it is Hoult Creek. a glacial erratic. In any case, detailed evaluation of 42.2) This boulder rolled and bounced from the slopes rock fall potential will be carried out and suitable above, crashing through the forest, and came to rest protection provided where necessary. Mitigative at this location. The proposed pipelines are to be built methods for rock fall include avoidance of problem beside the logging road in the photograph. areas, extra cover, heavy wall pipe, concrete coatings, 42.3) Evidence that at any point on this 5km section of berms and protective measures over the pipe. Rock Hoult Creek, the proposed pipelines could suffer fall hazards are summarized in the Geotechnical complete ruptures due to impacts from falling Hazard Report and in the Overall Geotechnical boulders. Report.
43.1) The location of this cut is not stated. However, there are oversteepened cuts at various locations along the existing logging roads. The soil materials include glaciofluvial sand and gravel and glacial till (moraine). Cuts for older logging roads were typically not designed with geotechnical input and ravelling and shallow sliding may be widespread. The cuts for the pipeline grade will be designed to be stable in the long term. Additional measures may include rock blankets to control springs (soil piping failures), French drains 43.1) Finally leaving the confines of Hoult Creek, we to control surface and groundwater and other encounter the first of the lateral moraines in the upper measures typically not used on logging roads. Kitimat River Valley.
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Evidence from Douglas Channel Watch Response 43.2) Logging road cuts, approximately 20 feet in 43.2) The cuts along the rights-of-way will be left at width, along the faces of lateral moraines are slopes consistent with long term stability. susceptible to significant erosion and washouts. Dual pipeline right-of-ways, being wider, would see increased erosive forces.
44.1) The crossing method for Hunter Creek will consider the high flows, relatively frequent debris flows and channel avulsion that have occurred in the past and will continue to occur in the future. The debris flows have damaged or destroyed the existing bridge on several occasions and as noted previously, surface facilities such as roads and bridges are much ) Hunter Creek is a tributary to the Kitimat River 44.1 more prone to damage by debris flows and erosion from the north, entering the Kitimat River 3km than properly designed pipelines. The pipelines will downstream of Hoult Creek. It is the drainage on the be designed to avoid such occurrences and will not be opposite side of Mount Hoult from the proposed tunnel installed on the surface in a vulnerable location as the portal on Nimbus Mountain to the east. The areas logging road bridge needs to be. outlined in yellow are estimated avalanche, rockfall, and/or debris collection areas and their deposition 44.2) The directional drill method has been selected zones. as a preferred crossing method on a preliminary basis subject to additional investigations and design. Based on the preliminary design, the ends of the directional drill hole will be on high ground far from Hunter Creek and the pipeline will be up to 50 m below the creek. 44.2) The proponent has expressed a desire to pass This will put the pipeline in a location where it is far the proposed pipelines under Hunter Creek in a below the creek and the ends of the crossing will also horizontal directional drill, or HDD. Core samples from be on high ground well away from the stream. As drilling at Hunter Creek have revealed highly fractured indicated, zones of highly fractured rock may be rock which could make a HDD impossible. The encountered. While this may increase the difficulty, contingency crossing method of Hunter Creek there are methods such as grouting that may be suggested to the proponent by their consultant(s) will considered if mud support is not sufficient in the be discussed later in this document. fractured rock. In the event that directional drilling is not feasible based on further work, other crossing methods that will provide suitable protection to the pipeline will be used.
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Evidence from Douglas Channel Watch Response
45.1) The newest Hunter Creek Bridge. According to a 45.1) As stated previously, the crossing design for feasibility assessment prepared for the proponent by Hunter Creek will provide for safe crossing conditions AMEC Earth & Environmental, "It is reported that a for the pipelines. A deeply buried pipeline crossing is former logging road bridge across Hunter Creek was far different from the much more vulnerable low destroyed in a flood prior to 2006 and local elevation bridge for a logging road. observation suggests that there were likely previous problems with the bridge or road washing out. During the pre-2006 event, most of the flow in Hunter Creek relocated to a channel along the north edge of the Kitimat Valley adjacent to the toe of the slope. An active subchannel formed along the east bank and an abandoned subchannel was visible along the west bank downstream of the bridge. This is not expected to be a stable situation over time and further avulsion of the channel is likely." (emphasis mine) http://www.ceaa.gc.ca/050/documents_staticpost/cearref_2179 9/2293/PG-HU.pdf
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 35 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
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Evidence from Douglas Channel Watch Response
46.1 and 46.2) The presently considered alternative crossing method for Hunter Creek is an isolated trenched crossing. This may be revised during detailed design. Contrary to the impression given in the discussion by Douglas Channel Watch, a trenched crossing, if used, would extend far beyond the edges of the present creek channel to allow for future avulsion of the channel. The depth of installation of the pipe would be deeper than the depth of scour erosion and would be designed so that even in the event that the channel is plugged or the bridge 46.1) The arrow in photograph 46 indicates the washes out, the pipeline would remain undamaged eastern abutment of the former Hunter Creek bridge below the depth of erosion and channel changes. which was washed away as referenced in 45.1 above. 46.2) The new bridge was built several metres 46.3) Most of the coastal streams have a double peak upstream of the old bridge, at approximately the same with high flows in May/June and again in elevation above the creek bed. Even if the bridge isn't September/October/November. The second peak is a washed away by another flood event, it could still be result of high precipitation and may also include warm involved in damaging the proposed pipelines. During a rain on wet snow events. The high flows can move major flooding event on Sept 29th, 1988, a significant amounts of debris including gravel and Government of BC document states, "The new bridge boulders as well as trees. It is, therefore, not at Hunter Creek in the Upper Kitimat Valley plugged surprising that the relatively low clearance bridge up. The creek diverted down the new grade for over opening may become plugged. 500 m, totally destroying the grade." (emphasis mine) 46.4 and 46.5) The avulsion potential at Hunter Creek http://www.env.gov.bc.ca/wsd/public_safety/flood/pdfs_word/flo is recognized and avulsion has occurred several times ods_landslides_north.pdf in the recent past. If the alternative crossing method 46.3) I hope the significance of the above reference to is used, the pipelines will be at sufficient depth over a the plugging of Holt Creek under the Hunter Creek sufficient depth and length to avoid exposure during bridge in the month of September is not lost on the an avulsion or erosion event. The ends of the HDD Panel. As there would probably not have been enough would be located on high ground well removed from accumulations of snow in September to cause the stream and would not be affected. significant avalanches in the Hunter Creek Valley, this would leave only landslide and/or the remains of forested slopes brought down by debris slides which would be capable of plugging the creek under the bridge. 46.4) If the contingency crossing method at Hunter Creek is used, a similar flood event could expose the proponents pipelines to lateral loading for a distance of 500 metres, or more if the creek followed the disturbed soils in the trench the pipelines would be buried in. The entry and exit points of a HDD, and the pipelines which emerge from them, could be impacted as well.
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 36 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response 46.5) Hunter Creek was also effected during the major flood event of October 6 to 14, 1991, when the Kitimat River rose 17 feet in 30 hours. "Major washouts at km 13 and at Hunter Creek, on the Upper Kitimat FSR totalled $220,000 damage." http://www.env.gov.bc.ca/wsd/public_safety/flood/pdfs_word/flo ods_landslides_north.pdf
47.1) The upper Hunter Creek Valley is subject to 47.1 to 47.5) An intense storm event producing heavy massive avalanches. Photograph 47 shows warm rain on wet snow is an event that typically approximately 250 metres of the approximately 5.5km produces high flows that may result in debris flows. of avalanche paths (as measured along both banks of The accumulation of debris in the channel is an the creek) which terminate into Hunter Creek. This additional factor required for debris flows. Avalanches photograph was not taken in mid-winter or early spring may facilitate debris flows by depositing debris into when much larger amounts of snow would be present. the channel. Jökulhlaup events, if applicable will also The arching brown shapes on the opposite side of the be allowed for. As stated previously, debris flows, creek could indicate the normal deposition depth of avulsion events and high flows are known events at Hunter Creek and other coastal mountain streams. avalanches left by late spring. The hazards will be allowed for in the pipeline ) From the headwaters of Hunter Creek to 4.5km 47.2 crossing design. The pipeline crossing design at downstream, both sides of the creek are almost Hunter Creek will be robust and the preliminary design continuous avalanche slopes which deposit directly method of directional drilling would result in the into the creek. pipeline crossing being far below the stream, unlike 47.3) From the 4.5km mark mentioned in 47.4, to the the forestry road which is vulnerable to the every high proposed contingency pipeline crossing downstream, flow event, debris flow or avulsion. there are an additional 1km of avalanche paths which empty into Hunter Creek. This totals 5.5km of The geohazards that occur due to the high flows, avalanche chutes and paths which deliver snow, ice, debris flows, avulsion and similar hazards are not rock, talus, soil, and woody material directly into unique and have been satisfactorily mitigated on other Hunter Creek. pipelines through the Coast Mountains such as the 47.4) The mountains on either side of Hunter Creek Vancouver Island Gas Pipeline. rise over 3000 feet above the creek, amassing large amounts of snow with an increased propensity to avalanche: "Many maritime storms have highly variable freezing levels and often bring precipitation in
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 37 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response the form of rain to lower slopes and as snow above the freezing level (i.e., the elevation of the 0°C isotherm). In maritime snow environments, the mountain snowpack accumulates as a series of stacked wedges" (emphasis mine) http://www.for.gov.bc.ca/hfd/pubs/docs/Lmh/Lmh55part1.pdf 47.5) James W. Schwab, Geomorphologist, states, "Anecdotal information suggest that jökulhlaup or glacial outburst floods have originated in the headwaters of the Kitimat watershed in the late 1970s, late 1980s and as recently as February 2011. These glacial outburst floods have sent a sediment plume down the Kitimat River to tide water. They may occur catastrophically and may contribute to lateral and catastrophic channel movement on the upper Kitimat." http://bvcentre.ca/files/research_reports/11- 03Schwab_Pipeline-geomorphology_Sept2011.pdf ) The avalanche assessment and other 47.6) An Avalanche Consultant employed by AMEC to 47.6 assessments that have been carried out at Hunter assess the avalanche risks to the proponents Creek were undertaken to provide information for the proposed buried pipelines in the Coast Mountains design of the pipeline crossing. The Avalanche stated, "Hunter Creek is a very steep sided valley with Report the hazards and additional information is numerous productive avalanche paths. AMEC wishes contained in the Overall Geotechnical Report and to evaluate the danger of snow avalanche debris Geotechnical Hazard Report as well as in other damming the creek with significant flooding resulting." reports. As stated in the various filed materials, The Avalanche Consultant's report also states, "The additional investigations will be undertaken. The most significant damming is to be expected with purpose of this comprehensive work is to design and relatively narrow, small streams and large avalanche operate a safe crossing. deposits. Both these factors are pronounced in Hunter Creek". (emphasis mine) http://www.ceaa.gc.ca/050/documents_staticpost/cearref_2179 9/3085/09_Att_4-2.pdf
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 38 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response
48.1 and following): We are in basic agreement with the observations outlined to the left which are similar to those outlined in the various filed documents. The stream is not viewed as “inconsequential”. As stated above, the crossing method will allow for the avulsion and debris flow events at the crossing. The crossing design will be robust so that the pipeline is protected from the expected future events at this site. As discussed previously, the pipeline crossing will not be vulnerable to debris flows and avulsion events in the way that infrastructure such as a logging road or a logging road bridge are.
48.1) Hunter Creek's alluvial fan is disproportionately large for the length and size of the creek, evidencing the frequency and size of flooding events from this valley. The fan extends 1.5km downstream from the bridge near the head of the fan, and the fan is 1km wide at its terminus. The fan has permanently pushed 48.C) To be clear, protection by an existing bridge the Kitimat River to the opposite side of the valley, to abutment would not be considered to be adequate the base of the distant mountain in the photograph. protection for the pipeline facilities at Hunter Creek. 48.2) This photograph, taken in October, 2011, from mid-span on the current Hunter Creek bridge, illustrates the destructive potential of this seemingly inconsequential creek. 48.A) These young alder trees grew on newly exposed gravel since the last flood event, which was probably earlier in the spring of 2011, judging from their height. 48.B) These alders and cottonwoods survived this years flood, but judging from their height they started growing on freshly exposed gravel from a flood event in 2010. 48.C) These alder and cottonwoods, protected by the bridge abutment, appear from their size, to have started growing on newly exposed gravel after a flood event 4 to 5 years ago. 48.D) These large cottonwoods began growing on newly exposed gravel as well. They are of an age where hemlock, spruce, and cedar trees now growing in the cottonwoods protective understory, will soon be overtaking them to become a mature stand of evergreens. 48.E) This is a mature stand of evergreens. It may be one major flood event away from being a newly exposed gravel bar, with young alder as in 48.A growing in their stead.
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 39 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
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Evidence from Douglas Channel Watch Response
49.1) A trenched crossing is not the “probable contingency plan” – it is the presently considered contingency crossing and will be considered further during detailed design. If the trenched crossing contingency method is used, it will be suitably engineered and installed to provide a safe crossing that will not be affected by future debris flows, scour or avulsion.
49.2) As discussed above, there are potential methods such as grouting that can be considered to mitigate the low RQD values. Further investigations are anticipated and if directional drilling does not appear to be a favourable crossing method, other trenchless methods may be considered.
49.3) See above. 49.1) The above 3 photographs illustrate the probable contingency plan winter crossing method of Hunter 49.4) The use of the word “resigned” and the Creek (if a HDD crossing proves impossible) as connotation that a less than adequate design solution recommended in feasibility reports for the proponent will be recommended are not correct. As by both Worley Parsons Resources & Energy, and professionals with expertise in the investigation and AMEC Earth & Environmental. design of stream crossings, the final recommended design following detailed investigation and design will 49.2) AMEC Earth & Environmental drilled exploratory allow for the considerable lateral channel movement core samples at Hunter Creek and found that, "Rock and scour erosion that may occur at this site. If a
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 40 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response Quality Designation (RQD) values were extremely trenched crossing is used, the crossing will need to be variable, ranging from 0 to 100%. For both core relatively long and deep to provide adequate recovery and RQD, there was no discernable protection to the pipeline. The final design will also improvement of the rock competency with depth. depend on the location of the crossing. Instead, the rock appeared to vary from good quality to poor and back again at intervals along the core. The zones of low competency appear to be located in 49.5) The finally chosen crossing method and areas of closely fractured rock, possibly as a result of contingency methods will be subject to approval by local faulting." various regulatory agencies as part of the regulatory http://www.ceaa.gc.ca/050/documents_staticpost/cearref_2179 process. Other trenchless methods may also be 9/2293/PG-HU.pdf considered depending on the results of further investigations. 49.3) Worley Parsons Resources & Energy reached the same conclusion as AMEC Earth & Environmental about contingency plans for crossing Hunter Creek, agreeing that the highly fractured rock found in exploratory core samples could make a HDD impossible. http://www.ceaa.gc.ca/050/documents_staticpost/cearref_2179 9/2293/PA-HU.pdf 49.4) A possible indication of AMEC being resigned to following the contingency plan of burying the proposed pipelines in trenches across Hunter Creek can be found in the Avalanche Consultant's report employed by AMEC to assess the avalanche risks to the proponents buried pipelines, where he states, "AMEC is concerned about flash floods affecting the buried pipeline as it crosses the fan of the confluence of Hunter Creek..." http://www.ceaa.gc.ca/050/documents_staticpost/cearref_2179 9/3085/09_Att_4-2.pdf 49.5) As if these geologic and environmental difficulties weren't problematic enough for the proponent, in the Department of Fisheries and Ocean's written evidence, section 3.2.8, # 2, "DFO recommends that the Proponent employ a trenchless crossing method for all stream crossings that have a risk category of medium to high, all stream crossings where there is no LRP and where important anadromous fish habitat occurs." https://www.neb- one.gc.ca/ll- eng/livelink.exe?func=ll&objId=777411&objAction=browse (Volume 2, Part 2)
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Evidence from Douglas Channel Watch Response
50.1) Response by Enbridge personnel. The projected extent in question is a modelled extent for an unmitigated spill of a volume considered beyond the maximum credible potential volume loss at Hunter Creek (Application, Volume 7B, Section 9.5). Hunter Creek will be crossed by the pipelines right-of-way as a directional drill, which will serve to further reduce the probability of a spill at this location. 50.1) The projected extent of spill damage after a dilbit spill into Hunter Creek, provided by the proponent, 50.2) Response by Enbridge personnel. The which indicates a spill into Hunter Creek would pollute Application (Volume 7B, Section 9.5) states that almost the entire length of the Kitimat River, its diluted bitumen “could potentially move as surface estuary, and the head of Douglas Channel. recoverable hydrocarbons from KP 1098.8 to the estuary at the north end of Kitimat Arm (past KP 1160) within four to ten hours.” The Application (Volume 7B, Section 9.5) also states that “[t]he estimated response 50.2) Please refer to File No. A2K0Y8, paragraphs 49 time for containment [defined as mobilization at site] is through to 49.f, for a description of the proponents two to four hours from the initial incident, depending estimate for a spill into Hunter Creek reaching the on location, so It would be necessary to deploy Kitimat River estuary during flood conditions in as little containment booms simultaneously at key locations in as 4 hours, and their misguidedly optimistic estimated the system (e.g., Kitimat River estuary, control points containment time of said spill taking 4 hours as well. on Kitimat River).” Hunter Creek is characterized by a large alluvial fan before entering the Kitimat River and is, as such, not considered an appropriate containment and recovery site. Northern Gateway has filed reply evidence providing preliminary site-specific
response tactics within the Kitimat drainage, which
includes a number of sites downstream from Hunter Creek.
50.3) Clearly, the onerous accumulation of hazards in 50.3) Response by Enbridge personnel. Northern this area is not lost on the proponent, who in putting as Gateway has not made such a statement. For the positive a proposal before the Panel as possible, flat correct context please refer to the Application (Volume out admits it could at least double the record of a liquid 7B, Section 9.5). petroleum product spill into a Canadian river in history, and that over 90% of that river would be polluted before they maintain they could contain the spill site.
AMEC File: EG0926008 2100 100 G:\PROJECTS\Other Offices\EG-Edmonton\EG09260 - Enbridge Gateway\2100 - Hearings\Douglas Channel Watch\Geotechnical Response to Douglas Channel Watch (photo evidence of M Minchin)_17July12_FINAl.doc Page 42 7054206_2|CALDOCS Attachment 5 to Northern Gateway Reply Evidence
Northern Gateway Pipelines Geotechnical Response to Photographic Evidence of Douglas Channel Watch Proposed Northern Gateway Pipelines July 17, 2012
Evidence from Douglas Channel Watch Response
51.1) The upper Kitimat Valley is not as confined as 51.1) The conditions along the upper Kitimat are Hoult Creek, but would present its own severe discussed in the Overall Geotechnical Report and are geologic hazards toward liquid petroleum pipelines further discussed in the Geotechnical Hazard and access issues stemming from its glacial history, Assessment. The pipeline system will be designed to large scale clearcut logging practices of the past, and accommodate the conditions that are present the mountains rising 5,000 precipitous feet above, including the conditions presented by the large areas from both the north and south banks of the river. that have been logged in the past.
51.2) According to a land management handbook 51.2 and 51.3) Avalanche initiation and deposition is published by the BC Ministry of Forests, many of these not a major concern with respect to the pipeline itself, slopes above and immediately adjacent to the upper which will be buried. This is in direct contrast to the Kitimat River may never have been clearcut had there facilities discussed in the quote from the Avalanche been linear infrastructure such as pipelines present Handbook which refers to watersheds or fisheries. when active logging was occurring. The concerns discussed are related to sedimentation. 51.3) Concerning avalanches, the handbook states, The Handbook does not discuss pipelines. "When downslope transportation corridors (eg. highways or railways), facilities (eg. occupied or unoccupied structures) essential resources (eg. registered community, domestic, or commercial watersheds or important fisheries), or other concerns may be affected by avalanche initiation from logging, the acceptable risk must be more conservative than if timber resources alone are affected."(emphasis mine) http://www.for.gov.bc.ca/hfd/pubs/docs/Lmh/Lmh55part2.pdf
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52.1) The Northern Gateway Pipeline will not be constructed along the Kitimat River Forest Service Road. Instead, an optimal route will be chosen taking into account the terrain, geohazards such as debris flows and lateral erosion by the Kitimat River and other facilities existing at the time of construction. In most locations, the road is well above the river and the locations where the river migrates laterally. There 52.1) The access into the upper Kitimat River is on a are a few locations where the road corridor may be logging road approximately 100 metres above the subject to lateral erosion by the Kitimat River. In valley floor, and it is proposed that the pipelines are to these areas, the preliminary route has been located follow this road. The Kitimat River occupies the whole farther from the river. The final route design will allow of the valley floor, as it changes course regularly from for lateral erosion and will incorporate sufficient bank to bank during major flooding events. clearances so that it will not be subject to lateral 52.2) Just as in the Hoult Creek Valley, routing of the erosion. proponents pipelines will be compromised by the 52.2) At the time of writing, the route of the Pacific Pacific Trail Pipelines natural gas pipeline having been Trails Pipeline is not clear. The best overall solution constructed first. The Pacific Trail Pipelines will be would be for both pipeline projects to cooperate so choosing the safest route through this terrain, leaving that the routes of both can be jointly optimized. The NGPLP few options in an already demanding Northern Gateway Project has requested such landscape. cooperation. However, if it does not occur, the Northern Gateway Project can still be constructed safely, although possibly with increased costs and increased Project footprint. The safety of the Northern Gateway Pipeline will not be compromised and
suitable engineering designs will be used taking
account of the actual location in which the pipelines are constructed. 52.3) Buried pipelines are much less prone to damage 52.3) There are 24 creeks perpendicular to the from debris flows than surface structures such as proposed pipelines path in the upper Kitimat River logging road bridges. Suitable design measures Valley between Hunter Creek and Chist Creek, each including depth of cover and possibly additional of which being capable of large debris slides or protection will be employed at all debris flow sites. avalanches. Compounding the likelihood of debris The increased potential for debris flows due to logging slides in these creeks is the extensive clearcut logging is recognized and will be allowed for in the design. practised in the upper Kitimat Valley in the past.
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53.1) The geotechnical engineers are well aware of 53.1) Access can be problematic, particularly after the potential problems posed by snags running storms when trees or snags fall across the road. This downhill. The same gouging effect has been snag gouged out a deep path as it came down the successfully mitigated during the design of other slope above, creating a channel for the development pipelines through mountainous areas where large of a future debris slide. timber occurs.
54.1) Much of the access road into the upper Kitimat 54.1) The photo shows an oversteepened road cut in Valley is built in lateral moraine material left by the glaciofluvial sand and gravel. This is not a moraine. valleys retreating glacier. Much of it is very near the The slope angles at the location, while steep, are less angle of repose, or the steepest angle at which it can than the angle of repose. The material that has fallen be piled and remain in place, unsupported. off the oversteepened cut is roughly at the angle of 54.2) The road through these lateral moraines are repose. The pipeline RoW would not be left with typically 20 feet wide, and suffer greatly from the oversteepened cuts since they would ravel back resulting cutback upslope degrading, as well as the uphill, as is occurring in this photo. lower slope eroding away due to erosion and the moraine material having been disturbed during 54.2 and 54.3) Detailed design of the cuts and fills for
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Evidence from Douglas Channel Watch Response construction. the Northern Gateway Pipeline grades through the 54.3) Constructing a dual pipeline through this terrain, Hoult and Kitimat Valleys will be carried out prior to forced as it is to be located between the river below construction so that oversteepened and unsupported and the too steep slopes above, particularly when cuts are not left behind. The ravelling of the cuts does Pacific Trail Pipelines will have already occupied the not pose any hazard to the pipeline but is undesirable safest and least problematic route, puts the since it may result in increased sediment generation. proponents proposed pipelines at considerable risk. Mainline pipelines are not constructed in fill except under very unusual circumstances and will not be placed where erosion of fill or the edge off a grade may erode. However, as with the cut side, the fills will be designed in detail so that erosion and sliding are controlled.
55.1) In addition to the 24 creeks on this section of 55.1) This appears to be a groundwater blow-off the proposed pipelines path, debris slides can occur failure as discussed in Cavers, D.S. (2003). at any point along this 20 kilometre section of the Groundwater Blow-Off and Piping Debris Flow Failures. Conference Proceedings, 3rd Canadian access road. This debris slide originated in an old Conference on Geotechnique and Natural Hazards. 8 logging clearcut and required heavy equipment to pages). Several such slides have been noted along clear the road. The rivulet the slide followed is 15cm the Kitimat Forest Service Road in the bedded wide, and scoured the slope to an approximate glaciofluvial sediments. Similar slides are generally depth of 2 metres. not capable of damaging the pipeline to the point where a leak would occur. Mitigating methods include groundwater drainage, depth of cover and additional protection for the pipeline as discussed in the Overall Geotechnical Report.
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The Project is well aware that heavy snow 56.1) occurs in the Coast Mountains and is planning for it ) Access into the upper Kitimat River Valley during 56.1 relative to construction, operational and emergency winter will be extremely difficult. One metre snowfalls access. in Kitimat are not uncommon, and snow has been in the fields of Kitimat without melting away for as long as 6 consecutive months. When Kitimat receives an average of 4.15 metres of snow, and the Coast Mountains in this area receive over 12 metres, one can only imagine how much snow will be falling on the upper Kitimat River and Hoult Creek logging roads, and the difficulties that would create regarding access whether in emergencies or not.
57.1) The average night time low temperature in 57.1) Northern Gateway does not dispute this Kitimat is below freezing 5 months of the year, and is assumption. only one degree above freezing in one other month. One can assume then, that in the upper Kitimat River
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Evidence from Douglas Channel Watch Response Valley, the night time average low temperature is below freezing for at least one half the year.
57.2) Should a spill occur into Hoult Creek, Hunter 57.2) Response by Enbridge personnel. This Creek, the Wedeene Rivers, or the Kitimat River, the comment is firstly based on the assumption that the proponent, as evidenced by their clean up attempts of watercourses in question will either entirely or to a the Kalamazoo River, would not be able to clean large extent freeze over. While this may be the case submerged dilbit from salmon spawning gravels for with Hoult Creek, Hunter Creek and the upper large portions of the year. stretches of the Wedeene Rivers and the Kitimat River, this is unlikely to be the case for downstream
sections of the drainage. Given ice and snow cover the migration of hydrocarbons will likely be restricted and winter response techniques would be implemented.
57.3) According to the United States Environmental 57.3) Response by Enbridge personnel. The Protection Agency, as of November, 2011, in a suspension in question, occurring during a period of statement regarding ongoing attempts to find and low water and sediment temperatures, was over a clean submerged dilbit from the bottom of the year and three months following the incident and Kalamazoo River, they state, "Submerged oil recovery following extensive cleanup operations. work has been suspended for the winter due to low water and sediment temperatures." (emphasis mine) http://www.epa.gov/enbridgespill/
58.1) This is a photograph of an oil spill in Prudhoe 58.1 and 58.2) Response by Enbridge personnel. Bay, Alaska. When conditions do allow flying into the Leak rates below 178,000 litres per hour are upper Kitimat Valley, a not so frequent occurrence as detectable by Enbridge's comprehensive and the Panel has discovered, oil spills can be completely overlapping leak detection approaches, which invisible from above. includes the Material Balance System ("MBS"). In 58.2) Considering the proximity of the pipeline to the response to JRP IR 3.12f), Northern Gateway Kitimat River, and the proponents admission that their indicated that the preliminary theoretical leak Edmonton control centre cannot detect leaks below detectability for the oil pipeline will be 1.5 - 3% of 178,000 litres per hour, it is conceivable that there nominal flow in a 2 hour alarm window and between could be a 1 million litre per day spill into the Kitimat 11 - 22% of nominal flow in the 5 minute alarm River. The proponent wouldn't even know it was window. Assuming a rate of 525,000 bpd, any leak
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Evidence from Douglas Channel Watch Response happening until the dilbit finally reached Kitimat rates above 104 - 209 cubic meters in 2 hours (or approximately 90km downstream and somebody 52,000 - 105,000 litres in one hour) would trigger the 2 phoned the control centre. https://www.neb-one.gc.ca/ll- hour MBS alarm and 32 to 63 cubic meters in 5 eng/livelink.exe?func=ll&objId=774696&objAction=browse&redi minutes would trigger the 5 minute alarm. rect=3 Enbridge is actively investigating and testing a number of leak detection technologies that are complimentary to the current leak detection system and if performance was proven acceptable, would plan to implement on the Northern Gateway pipeline to further improve leak detection performance.
59.1) Incredibly, as we are so far into this document and now approximately 33km from the proposed Nimbus Mountain west tunnel portal in the Hoult Creek 59.1 to 59.C) Response by Enbridge personnel. The Valley, this is the first boom location identified response locations provided in the River Controls by the proponent and/or its consultant(s) on the Points Technical Data Report (Polaris 2010) were Kitimat River. preliminary, indicative and are not considered http://www.ceaa.gc.ca/050/documents_staticpost/cearref_2179 comprehensive of all potential response sites within 9/2213/Volume7/Volume_7B.pdf the Kitimat drainage. Northern Gateway has filed reply 59.A) The river current here is fast at all times of the evidence providing preliminary site-specific response year. tactics within the Kitimat drainage. Response site 59.B) The arrow indicates the great height at which would be further investigated during detailed design. paint has been scraped from the bridge support by trees and other debris carried downstream during major flood events. 59.C) A log deposited by previous flooding. The log and the woody debris below it represent a serious threat to any booms deployed during floods.
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Response by Enbridge personnel. 60.A) Currents below the bridge are fast at all times of 60.A) to 60.1) Northern Gateway has filed reply evidence providing the year. preliminary site-specific response tactics within the 60.B) Arrow 60.B indicates the leafy debris deposited Kitimat drainage. Accessibility to sites along the upper at the high water mark on the banks of the Kitimat Kitimat River is considered within this piece. Access River after a flood in late September, 2011. would be further investigated during detailed design. 60.1) Choosing this location as the proponents first boom location on the Kitimat River patently displays the limited access issues into the upper Kitimat River Valley. There are no other access points to the north bank of the Kitimat River upstream of this location because the logging road was built with tower logging in mind, where logs could be hauled from the steep mountainsides below and above the road.
61.1 and 61.2) The Onion Lake “Flats” are not an esker, but are in fact a glaciofluvial delta. Eskers are long often sinuous ridges deposited by flowing glacial meltwater under or in the glacier, whereas the Onion Lake Delta is a very large glaciofluvial delta.
The Chist Creek crossing location shown is incorrect – the centreline of the Project Assessment Area is located close to the existing forestry bridge well 61.1) The arrows above indicate the Onion Lake Flats upstream of the large eroding slopes shown in the esker being eroded by Chist Creek. Eskers are formed background of the photo and close to the location of when retreating glaciers leave large deposits of the photo.
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Evidence from Douglas Channel Watch Response eroded material in wide, flat plains. 61.3) Soft glaciomarine clay is not expected to be 61.2) The forested section above the letter A in the encountered in this area based on three investigative photograph above, is the approximate location of the holes that have been drilled near Chist Creek that proposed horizontal bore crossing of Chist Creek. encountered sand and gravel overlying bedrock with 61.3) It is in this area that the proposed pipelines will one hole encountering a thin layer of glacial till. first encounter the glaciomarine clay deposits in the main Kitimat Valley. These unstable clay deposits The earthflows that have occurred in the Kitimat have been a key factor in many earthflows found Valley are not located along the proposed pipeline between this location, and where the proposed tank route. For example, see the Glaciomarine Clay Report. farm is to be located.
63.1) Like the previous case, this is not an esker, but is the south facing slope of the glaciofluvial terrace on 63.1) This image is of a stable esker, 18km to the which Terrace airport is located. northwest of the south face of the Onion Lake Flats esker.
63.1) The erosion and instabilities on the south face of the Onion Lake Delta (not an esker) at “A” are not a single massive earthflow but there is widespread erosion and smaller slides on the south face off the delta in the area noted. These instabilities are discussed in the Glaciomarine Clay report and consist of a combination of surface erosion, groundwater piping erosion and smaller scale instabilities along various channels eroded into the face. The pipeline was routed well to the north of this area. The pipeline route shown in the illustration is incorrect. The actual route is farther north (farther away from the crest of the slope) as shown on the illustration below taken
63.1) Arrows A indicate the massive earthflow on the from the Glaciomarine Clay Report. The blue area southern face of the Onion Lake Flats esker upon corresponds to glaciomarine deposits. The small orange lines show individual slide locations. which the proposed pipelines, indicated in red, are to
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Evidence from Douglas Channel Watch Response pass. The Chist Creek crossing location in photograph 61 is in the upper right of the image.
63.2) The proponent is fully aware of the dangers of 63.2) The distribution of glaciomarine clays are shown glaciomarine clay deposits at this location and other in blue in the illustration above (part of a much larger locations in the main Kitimat Valley. "Extensive plan shown in the Glaciomarine Clay Report). deposits of clay in a marine (salt water) environment are present at lower elevations in the Kitimat Valley.
Some of this material is sensitive and the strength of this material can drop significantly, possibly resulting in slides. The pipeline route was selected to avoid these deposits in most locations. (emphasis mine) http://www.ceaa.gc.ca/050/documents_staticpost/cearref_2179 9/2213/Volume3/Vol_3_Main_Report.pdf
63.3) The pipeline route avoids all areas of known 63.3) It is important to remember the potential for glaciomarine clay slides. Previous glaciomarine clay ground shaking effects in the Kitsumkalum-Kitimat landslides are located in specific areas including west Trough as discussed below image 29 of this document of the Airport Delta (Mink Creek Slide) and in the while reading Geomorphologist Marten Geertsema's Lakelse area. These areas have been avoided during assertion that, "We could examine the possible the routing of pipelines. The distribution and connection of the dated earthflows with past seismic considerations of glaciomarine clays are discussed in activity by dating liquefaction features in the Kitimat the Glaciomarine Clay Report. Further investigations River delta, or tsunami deposits in local tidal marshes. of the distribution of glaciomarine clay and the Establishing whether a connection exists is a key step potential for seismic events to trigger movements will in the risk assessment of these potentially devastating be carried out during detailed design. Based on the landslides."http://www.for.gov.bc.ca/rni/research/Extension_n available information at this point, the potential effects otes/Enote20.pdf of the glaciomarine clay can be adequately mitigated. 63.4) To acquire an understanding of the massive, 63.4, 63.5 and 63.6) A large slide, such as the Mink long reaching potential for earthflows being capable of Creek slide, could indeed result in substantial damage completely wiping out hundreds of metres of the to a pipeline. However, as discussed previously, the proponents pipelines in a single event, please refer to areas where such slides have occurred have been the link below, where Geomorphologists Marten avoided. It is worth emphasizing that large Geertsema and James Schwab present a glaciomarine clay slides do not occur everywhere in photographic overview of a recent earthflow. In it, they the Kitsumkalum Trough as discussed in the state, "Sometime between mid- December and Glaciomarine Clay Report. Further checks on the 1993 distribution of marine clays relative to possible stability early January 1994, 23 ha of glaciomarine sediment issues are planned, as indicated above. flowed and slid rapidly into Mink Creek, near Terrace, British Columbia. The landslide occurred when a zone of sensitive clay suddenly liquefied, probably after a small creek bank failed. This initiated a complex
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Evidence from Douglas Channel Watch Response sequence of flowing and sliding along gently dipping failure planes. The landslide was retrogressive, although a central portion of the failure may have occurred as a monolithic flakeslide. Landslide debris filled the incised valley of Mink Creek and extended downstream for one kilometre." http://www.for.gov.bc.ca/hfd/pubs/docs/rr/rr08.pdf 63.5) Please also refer to James W. Schwab's report describing in great detail the past and recent history of earthflows in the Kitsumkalum-Kitimat Trough. http://bvcentre.ca/files/research_reports/11- 03Schwab_Pipeline-geomorphology_Sept2011.pdf 63.6) It gives little peace of mind then, when the proponent claims, "The pipeline route is located further to the north and west onto the Onion Lake delta and generally avoids areas where marine clays appear to be present."(emphasis mine) http://www.ceaa.gc.ca/050/documents_staticpost/cearref_2179 9/2213/Volume3/Vol_3_Main_Report.pdf
64.1) This is the proponents second boom location on 64.1) and 64.2) Response by Enbridge personnel. the Kitimat River, 5km below the first boom location in Response tactics will be dependent on local the upper Kitimat Valley, at the bridge on Highway 37 environmental conditions at the time of an incident, which is located at the base of the Onion Lake Flats such as discharge, and would be adapted as required. esker. 64.2) Note the trees stuck on the bridge abutment, brought downriver by a recent flood. As mentioned earlier, the Kitimat River wanders extensively between the steep mountains which confine it. Large numbers of trees carried downstream during floods, up to and including fully mature spruce trees, would make attempts at successfully placing booms across the
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Evidence from Douglas Channel Watch Response Kitimat River for any appreciable length of time, essentially useless. Darkness for up to 16 hours during long winter nights would further complicate attempts at placing and maintaining booms.
65.1) Highway 37 meets the Kitimat River in several 65.1 and 65.2) Response by Enbridge personnel. locations downstream of the bridge at the base of the Gravel bars are a good location for boom deployment. Onion Lake Flats esker, and these are being Deployment conditions will depend on local conditions considered as potential boom locations. such as water elevations and may be varied as 65.2) This is the point on the Kitimat River referenced required. in 2.3.e of this document where, "Two kilometres south of the Kitimat River bridge, a one-lane section of 150 m of highway disappeared into the river." The lateral movement of the Kitimat River during major flooding events therefore brings into question the adequacy of these locations as safe boom sites.
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Evidence from Douglas Channel Watch Response
66.1) Response by Enbridge personnel. Again, as discussed above, boom deployment methods and 66.1) Another of the proponents potential boom sites. locations would depend on local conditions and would This section of highway 37 was almost washed away be adjusted as required. in a flood which occurred in late September, 2011.
67.1) This is a view downstream from the same 67.1 and following) Response by Enbridge vantage point in photograph 66 above. personnel. Discussed above. The locations of booms 67.A) Just a small representation of the total number and related spill activities and planning will depend on of mature trees brought downstream over the 98km local conditions and will vary as conditions change. length of the Kitimat River during one flood. Considering the likelihood of pipeline ruptures would Response tactics will be dependent on local increase in the Kitimat River watershed during major environmental conditions at the time of an incident, flood events, such trees would make mitigation efforts such as discharge, and would be adapted as required. through booming nearly impossible. Northern Gateway is well aware that many sections of 67.B) This is a new river channel, which the river the lower Kitimat River are highly dynamic and that opened up during flooding in recent years. The old response tactics should be considered as indicative river channel was at the base of the large cottonwoods and adapted based on environmental conditions and on the right. The forest which previously occupied the watercourse character at the time of an incident.
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Evidence from Douglas Channel Watch Response new channel was carried downstream by flood waters. 67.C) Rocks placed during the flood. These may, or may not remain in place during the next major flood. 67.2) The first of Kitimat's residential neighbourhoods, the Cablecar Subdivision, is 6km downstream of this location.
68.1) This is a location on the River locally known as 68.1) Response by Enbridge personnel. Northern Coho Flats. It is accessed by a 2km remnant section Gateway has filed reply evidence providing of a Haisla First Nations trail thousands of years old, preliminary site-specific response tactics within the with many examples of culturally modified cedars Kitimat drainage. Included in the piece are a number along route. It is still used to this day as an access trail of potential response sites upstream of the Coho Flats for fishing, and as an important location for the site on the Kitimat River. passing generations of Kitimat residents to connect with our natural environment.
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Evidence from Douglas Channel Watch Response
69.1) Response by Enbridge personnel. Response 69.1) The proposed boom location at Radley Park in tactics will be dependent on local environmental Kitimat, where current speeds remain fast at all times conditions at the time of an incident, such as of the year. discharge, and would be adapted as required.
70.1) The abutment on the bridge several metres 70.1 and 70.2) Response by Enbridge personnel. It is upstream of the Radley Park boom location. Note the expected that the Kitimat and other major rivers that years of accumulated woody debris jammed against are tending to erode laterally will carry significantly the bridge abutment brought downstream during years amounts of woody debris. of successive flood events. 70.2) There are residences a few hundred metres from Should an incident occur during a period of flood this location. when a large amount of debris is carried by the river, response focus would shift primarily to upstream sites where there is greater potential for effective containment and recovery.
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Evidence from Douglas Channel Watch Response
71.2 – 71.4) Comments quote Northern Gateway’s 71.1) The western half of the Kitimat River estuary. response to Douglas Channel Watch IR 1 and the Between this location and Radley Park is where the contents of Table A-6 (Volume 7A) of the Application Kitimat River Hatchery is located. entirely out of context. Northern Gateway does not 71.2) If a dilbit spill reaches the Kitimat River estuary state that it, without condition, “recommends” in-situ and becomes entrapped in the estuary grasses, the burning of estuary grasses in ether the Application of proponent admits it would recommend setting fire to IR responses. Subject to a Net Environmental Benefit the estuary. In response to Douglas Channel Watch IR Analysis and approval from regulators, Northern No. 1 - A2I9I1 regarding mitigation techniques Gateway would consider in-situ burning as an anticipated for the Kitimat River estuary, the proponent alternative response in wetlands. In any case, in-situ states, "If a controlled burn were appropriate in certain burning would only be undertaken if it is considered to circumstances, the response team may recommend result in the greatest net environmental benefit of all such an action." the available response options including natural 71.3) The proponent also claims that in-situ burning of attenuation. oil spills will be recommended in wetlands, or in the Kitimat River estuary, "To reduce hydrocarbon when other techniques are unsuitable or cause more damage to an area," and would be, "Used in areas where heavy equipment would cause environmental damage" http://www.ceaa.gc.ca/050/documents_staticpost/cearref_2179 9/2213/Volume7/Volume_7A.pdf
71.4) The estuary is 2km away from both the Haisla community of Kitamaat to the south, and the townsite of Kitimat to the north. 71.5) Northern Gateway is aware of filed evidence 71.5) Other interveners, particularly the Haisla and the referenced. Kitimat Valley Naturalists, have detailed the ancient cultural and environmental importance of the Kitimat River estuary, and of the cumulative impacts from current and past industrial activities upon the estuary in their submissions to the Panel.
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Evidence from Douglas Channel Watch Response Conclusion
C.1) The proponents past history of liquid petroleum product spills into the environment, totalling 26 million C.1) No matter what the size or location of a spill, litres from 1999 to 2010 alone, is of great concern. Enbridge takes every incident very seriously and Their inability to simply locate a 3.8 million litre spill for treats it as a top priority. Northern Gateway’s 14 hours in the flat farming country of Alberta east of goal is to prevent all spills, leaks and releases, the Rockies does little to bolster confidence in their and to safely and rapidly respond to any incident claim of a 4 hour containment time in the Coast and minimize the consequences. Additional Mountains of British Columbia. information on spill response is contained in various filed documents and evidence. C.2) Another great concern is the proponent's and the U.S. Environmental Protection Agency's difficulty in C.2) Enbridge’s experience at the Marshall spill was locating and cleaning up spilled dilbit in the Kalamazoo that water temperature was a factor in the ability to river that has sunken into the riverbed, and deciding, recover submerged oil using an agitation and re- "Submerged oil recovery work has been suspended floatation technique. Warmer temperatures did for the winter due to low water and sediment increase the potential for submerged oil to resurface, temperatures." Winters on BC's north coast are where it would then be recovered. There are many considerably longer. factors which affect the ability to recover submerged oil including, among others, water temperature, depth,
characteristics of the submerged oil and submerged oil concentration. Northern Gateway believes C.3) Specifically to this project, the major concerns detection and recovery in colder temperatures would are; still be possible, but likely at reduced efficiency.
C.3.a) The entire proposed west tunnel portal slope on Nimbus Mountain is made of rockfall material, and C.3.a) The west portal of the Hoult Tunnel is trees there show evidence of recent avalanches discussed above in Sections 7 to 26. The West Portal and/or rockfall, of the Hoult Tunnel is located on a ridge with glacial till/morainal materials on the lower part of the slope C.3.b) The proposed aerial crossing of Hoult Creek is and some possible minor rock fall despots on the below the avalanche and/or rockfall prone proposed upper part of the slope. Farther to the north, there is tunnel portal slope of Nimbus Mountain,C.3.c) The an active avalanche slope, but the portal area itself is mountains rise over 4700 precipitous feet above the not subject to major avalanches. A portal structure will proposed pipelines path in the Hoult Creek Valley, likely be used to protect the portal area from possible local rock fall. C.3.d) Mount Hoult's slopes, where the proposed pipelines are to pass, are deeply cut by very active C.3.b) See Section 31.1. The crossing of Hoult Creek avalanche, rockfall and debris chutes is outside the major avalanche area and beyond the area that could potentially be affected by rock fall.
C.3.d) See Sections 37 to 40 above. The hazards ) Hunter Creek will have extremely large flood C.3.e are recognized and will be suitably mitigated using events, possibly including avalanche debris induced methods including depth of cover and additional winter flash floods. The Hunter Creek bridge has been protection. Buried pipelines are much easier to washed away in the past, and has had debris caught protect against geohazards such as avalanches, rock under it, diverting the creek, which then washed away fall or debris flow than facilities on the surface such as a one half Kilometre section of road beside which the logging road bridges. proposed pipelines are to be buried, C.3.e) See Sections 44 to 49. The proposed crossing method Hunter Creek is a Directional Drill which
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Evidence from Douglas Channel Watch Response C.3.f) The proponent admits a spill into Hunter Creek would put the pipeline well below and well beyond the will at least double the record for a liquid petroleum potential effects of erosion and high flow events. If product spill into a Canadian river, and that they will directional drilling is not feasible, the crossing method not contain the spill before the dilbit has reached the used will put the pipelines well below and beyond the Kitimat River estuary, thereby polluting almost the vertical and lateral scour zones. entire length of the Kitimat River, C.3.f) See Northern Gateway’s response to C.3.g) The upper Kitimat Valley's steep slopes have Section 50. been clearcut, making them prone to avalanche and debris slides,
C.3.g) See Section 51. Avalanche and debris slides (actually these are normally termed debris flows) will C.3.h) The Pacific Trail Pipelines (PTP) natural gas be satisfactorily mitigated so that the pipelines will not pipeline will be constructed first, and will have first be affected. The pipelines will be designed so that the choice of the safest route through the demanding slides will be able to run over top or deposit on top of Hoult Creek and upper Kitiimat River Valleys. the pipeline alignments so that the buried pipelines PTP's willingness to share that route is weak, as remain unaffected. proven by the proponents claim that, "Northern Gateway has been attempting to engage the C.3.h) See Section 52. While it would be desirable for proponents of the Pacific Trail Pipelines for an the various Projects to cooperate to best utilize the extended period of time regarding collaboration on existing terrain, the Northern Gateway Project can be routing, construction and access management, and safely constructed if this route optimization does not will continue to do so in the future." occur.
C.3.i) Lateral moraines in the upper Kitimat River Valley will suffer heavy erosion if dual pipelines are constructed through them, C.3.i) See Section 54. The features discussed are mostly glaciofluvial terraces composed of sand and gravel. The oversteepened forestry road cuts are retrogressing as would be expected for an C.3.j) Incredibly, the first boom location on the Kitimat oversteepened cut. The final pipeline right of way River is approximately 33km below where Hunter cuts will be designed and constructed so that they are Creek enters the Kitimat River, and approximately not oversteepened and the potential for adverse 43km from the tunnel portal, erosion and retrogression is controlled.
C.3.k) Booms will be useless in flood waters carrying C.3 j-k) See Northern Gateway’s responses to mature trees with their root wads attached Sections 59 and 70. downstream,
C.3.l) The Kitsumkalum-Kitimat Trough has incompletely defined seismicity hazards. This raises serious concerns regarding the significant glaciomarine clay deposits in the main Kitimat Valley, C.3.l) See Sections i.4, 2.1. The seismicity hazards in and how Topographic Amplification may increase the trough are as well defined as most other locations avalanches, rockfall and debris slides in the Hoult in western Canada. There is nothing that indicates a Creek and upper Kitimat River Valleys, higher hazard along this valley alignment than nearby areas. Topographic amplification is well known. Avalanches, rock falls and debris slides in the Hoult Creek area and other areas are known, are discussed in the filed materials and can be successfully
mitigated. While a seismic event might trigger local C.3.m) An earthflow in the main Kitimat Valley could
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Evidence from Douglas Channel Watch Response potentially carry away hundreds of metres of the slides, they would be in locations where the potential proposed pipelines in a single event, for such failures have been and will be identified and where mitigation measures will be provided.
C.3.m) See Sections 61 to 63. The statement that the pipelines would be adversely affected by large earthflows is correct which is why a lot of effort is being applied so that the pipelines will NOT be constructed in areas prone to large earthflows. The portion of the main Kitimat Valley in which the
pipelines are routed is not prone to large earthflows
and no large earthflows near the pipeline route have C.3.n) Boom locations in the main Kitimat Valley on been identified. Further work on glaciomarine clay Highway 37 have suffered washouts from floods in the distribution and properties is planned and additional recent past. Floods have raised the level of the Kitimat mitigative measures will be undertaken if required. River 17 feet in 30 hours, C.3.n) See Northern Gateway’s response to section C.3.o) The western side of the Coast Mountains in the 70. Kitimat vicinity draw over a metre of rain per year from weather systems piling in from the Pacific Ocean, and the mountains adjacent to the Kitsumkalum-Kitimat Trough have up to 12 metres of snow per year. This can have devastating effects on any form of linear C.3.o) See Northern Gateway’s response to section infrastructure, 56.
C.3.p) The proponent admits they may recommend burning the Kitimat River estuary after spills.
C.3.p) See Northern Gateway’s response to section 71. C.5) It is definitely in the proponent's investors best C.5) Northern Gateway has filed reply evidence interest to see this project through to completion, providing preliminary site-specific response tactics particularly when they will never have to suffer the within the Kitimat drainage. stench of millions of litres of dilbit in their valley, watch their estuary burn, or be made to release a good percentage of past dividend cheques to help efforts in cleaning any spills, or to support local residents whose food sources and/or livelihoods have been destroyed. C.7) Allowing 25 years for a generation, 7 x 25 = 175. C.7) A First Nations lady spoke at one of the events From a geotechnical perspective, we typically work to surrounding this proposal in Kitimat, and shared that at least this level, but many of the features we are within her culture they consider the implications of considering are far older than this. The geotechnical serious decisions 7 generations into the future. I perspective is very long and we are used to working to submit that the Panel members adopt such a mindset long time perspectives. in terms of timescale, and that they consider their moral duty to represent the interests of the north coast of British Columbia environment, the people who live and derive their sustenance or incomes from it, and the economic effects of exporting such massive C.8) As practicing geotechnical professionals we are
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Evidence from Douglas Channel Watch Response amounts of unrefined product on out of work required to be members of the Association of Canadians. Professional Engineers and Geoscientists of British C.8) A moral duty is defined as, "When someone Columbia. The following quote is from the preamble recognizes a duty, that person commits himself or and first point of the Association’s Code of Ethics: herself to the cause involved without considering the self-interested courses of actions that may have been Members and licensees shall act at all times with relevant previously". fairness, courtesy and good faith to their associates, employers, employees and clients, and with fidelity to the public needs. They shall uphold the values of truth, honesty and trustworthiness and safeguard human life and welfare and the environment. In keeping with these basic tenets, members and licensees shall: (1) hold paramount the safety, health and welfare of the public, the protection of the environment and promote health and safety within the workplace;
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3.0 LIMITATIONS AND CLOSURE
Recommendations and evaluations presented herein are based on preliminary data and are considered preliminary. In general, detailed on-ground site evaluations have not been done at many locations. It is expected that further investigations will be undertaken for the areas discussed in this report during detailed engineering for design and construction. Other more detailed reports have been prepared for some aspects of the project and these reports should be referenced as applicable. If conditions other than those reported are noted during subsequent phases of the project, AMEC Earth & Environmental should be notified and be given the opportunity to review and revise the current recommendations, if necessary.
This report has been prepared for the exclusive use of Northern Gateway Pipelines Inc. for specific application to the area within this report. Any use which a third party makes of this report, or any reliance on or decisions made based on it, are the responsibility of such third parties. AMEC Earth & Environmental accepts no responsibility for damages, if any, suffered by any third party as a result of decisions made or actions based on this report. It has been prepared in accordance with generally accepted geotechnical engineering practices. No other warranty, expressed or implied, is made.
Respectfully submitted,
AMEC Earth & Environmental, a division of AMEC Americas Limited Reviewed by:
Per D. S. Cavers, M.Eng., P.Eng.(AB&BC), P.Geo. (BC) P. Barlow, M.Sc., P.Eng. (AB&BC) Principal Engineer Principal Engineer
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REFERENCES
AMEC (2010) Overall Geotechnical Report on the Pipeline Route Rev. R for the Enbridge Northern Gateway Project, Bruderheim, Alberta to Kitimat, BC, prepared by AMEC Environmental and Infrastructure for Northern Gateway Pipelines.
Atkinson, G.M. 2009. Preliminary Seismic Evaluation of Enbridge Northern Gateway Pipelines Project. Report prepared for AMEC Earth & Environmental.
Dietzfelbinger, C. (2009). Location and properties of avalanche paths that affect the proposed northern gateway pipeline alignment through the Coast Mountains. Prepared by Bear Enterprises Ltd for AMEC Earth & Environmental, August 2009.
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