Responses to TERMS OF REFERENCE FOR THE PREPARATION OF A FOCUS REPORT Regarding the Canso Spaceport Facility Proposed by Maritime Launch Service Ltd. March 2019 Responses To Terms of Reference for the Preparation of a Focus Report Canso Spaceport Facility Proposed by Maritime Launch Services, Ltd. LIST OF ACRONYMS AND ABBREVIATIONS °C degrees Celsius ADEC Alaska Department of Environmental Conservation ADR Agreement concerning the Carriage of Dangerous Goods by Road AFI USAF Instruction AFTOX US Air Force Toxic Chemical Dispersion Model AST Office of Commercial Space Transportation BMP best management practice BRRC Blue Ridge Research and Consulting, LLC CAA Clean Air Act CAP Collection Accumulation Point CCAFS Cape Canaveral Air Force Station CCEMP Consolidated Comprehensive Emergency Management Plan CCME Canadian Council of Ministers of the Environment CCOHS Canadian Centre of Occupational Health and Safety CCR California Code of Regulations CEPA Canadian Environmental Protection Act CERCLA Comprehensive Environmental Response, and Liability Act CFR Code of Federal Regulations CO carbon monoxide CO2 carbon dioxide CWA Clean Water Act dBA A-weighted decibels DEQ Department of Environmental Quality dm3 cubic decimeter DNL day-night average sound level DoD US Department of Defense DOT Department of Transportation DSL Domestic Substances List EA Environmental Assessment EIS Environmental Impact Statement EPA US Environmental Protection Agency EPC Emergency Preparedness Canada EPP Environmental Protection Plan EQS Environmental Quality Standard ESA European Space Agency FAA Federal Aviation Administration FAC Florida Administrative Code FDEP Florida Department of Environmental Protection ft feet g grams GCIFA Guysborough County Inshore Fisherman’s Association GSFC Goddard Space Flight Center ha. Hectares HNO3 nitric acid ICAO International Civil Aviation Organization ICP Integrated Contingency Plan IMDG International Maritime Dangerous Goods i March 2019 Responses To Terms of Reference for the Preparation of a Focus Report Canso Spaceport Facility Proposed by Maritime Launch Services, Ltd. LIST OF ACRONYMS AND ABBREVIATIONS (continued) ISO International Organization for Standardization kg kilograms KLC Kodiak Island Launch Complex km kilometers kN kilonewton kPa kilopascal KSC Kennedy Space Centre l litre LOX liquid oxygen m metres m3 cubic metres MARS Mid-Atlantic Regional Spaceport mg milligrams MLS Maritime Launch Services, Ltd mm millimetres MMH monomethylhydrazine MPC maximum permissible concentration MSDS Material Safety Data Sheet N2O nitrogen oxide N2O4 nitrogen tetroxide NAAQS National Ambient Air Quality Standards NaGISA National Geography In-Shore Areas NASA National Aeronautics and Space Administration NDMA Nitrosodimethylamine NDSL Non-Domestic Substances List NEF Noise Exposure Forecast NO nitric oxide NO2 nitrogen dioxide NOx nitrogen oxides NPDES National Pollution Discharge Elimination System permits NPR NASA Procedural Requirement NPS non-point source NSE Nova Scotia Environment NTO Dinitrogen Textroxide OPlan Operation Plan PEIS Programmatic Environmental Impact Statement PM10 particulate matter 10 micrometers or less in diameter PM2.5 particulate matter 2.5 micrometers or less in diameter ppm parts per million QA quality assurance QC quality control RCRA Resource Conservation and Recovery Act RfD reference dose RID Agreement concerning the Carriage of Dangerous Goods by Rail RP-1 Refined petroleum-1 RTS Reagan Test Site RWQCB Regional Water Quality Control Board ii March 2019 Responses To Terms of Reference for the Preparation of a Focus Report Canso Spaceport Facility Proposed by Maritime Launch Services, Ltd. LIST OF ACRONYMS AND ABBREVIATIONS (continued) SAU single-action unit SBCAPCD Santa Barbara County Air Pollution Control District SDO State Design Office SO2 sulfur dioxide TLV threshold limit value TNSC Tanegashima Space Center TSCA Toxic Substances Control Act UDMH unsymmetrical dimethyl hydrazine UES USAKA Environmental Standards UIC Union of Railways UPC United PARADYNE Corporation US United States USAF US Air Force USAKA US Army Kwajalein Atoll VAC Commonwealth of Virginia Administrative Code VAFB Vandenberg Air Force Base VPDES Virginia Pollution Discharge Elimination System permits WFF Wallops Island Flight Facility LIST OF APPENDICES Appendix A Resumes Appendix B Material Safety Data Sheets Appendix C United PARADYNE Corporation Emergency Response Plan Appendix D N-Nitrosodimethylamine (NDMA) Appendix E Hydrazine and NDMA Analysis Appendix F EPA Method 1625 Revision B: Semivolatile Organic Compounds by Isotope Dilution GC/MS Appendix G Maritime Launch Services Insurance Summary iii March 2019 Responses To Terms of Reference for the Preparation of a Focus Report Canso Spaceport Facility 1.0 Project Description Proposed by Maritime Launch Services, Ltd. 1.0 PROJECT DESCRIPTION 1.1 Provide an updated description of the Project, including clarification of the following: o It is understood the site operator will be Maritime Launch Services Ltd. Provide further information on responsibility for managing the launches; The implementation of the Cyclone-4M program will be carried out by Maritime Launch Services Ltd. (MLS), Halifax, Nova Scotia, Canada, together with leading Ukrainian space enterprises Yuzhnoye State Design Office (SDO), PA Yuzhmash Machine-Building Plant and American United PARADYNE Corporation (UPC). Table 1.1 lists the responsibilities for each organization. Figure 1.1 shows a launch team organizational chart. Table 1.1 Cyclone-4M Program Management and Responsibilities Organization Responsibilities MLS Responsible for overall management of the Cyclone-4M program for all phases of Space Launch System development and its operation, including: • Obtaining necessary licenses, permits, etc. • Ensuring safety of operations at the launch complex • Organization and coordinating work on preparation and conduct of the launch vehicle launches • Development of design and construction documentation for launch site • Construction of the launch site and support GSE Yuzhnoye SDO • Design and construction of the launch vehicle • Design of SLS ground infrastructure including ground support equipment • Spacecraft integration with Cyclone-4M space launch system and preparation of necessary launch information; • Participation in prelaunch processing and launch of the launch vehicle PA Yuzhmash • Production of Cyclone-4M space launch system components Machine- • Assembly and preparation of the launch vehicle for launch Building Plant • Participation in launch UPC • Maintenance supply of propellant, compressed and liquefied gases • Operation and maintenance of propellant facilities, their engineering systems and equipment 1-1 March 2019 Responses To Terms of Reference for the Preparation of a Focus Report Canso Spaceport Facility 1.0 Project Description Proposed by Maritime Launch Services, Ltd. Figure 1.1 Cyclone-4M Launch Team Organizational Chart 1.1 Provide an updated description of the Project, including clarification of the following: o Clarify how many launches are expected annually. There is inconsistency in the EA Registration Document in this regard. The Cyclone-4M will ramp up to a maximum of eight (8) launches per year over the first five (5) of operation. It is anticipated there would be one launch in the first year (2021) and an increasing number of launches each year up to a maximum of eight (8) by approximately 2026. The total number of launches under this project (2021-2030) is estimated to be 159. 1-2 March 2019 Responses To Terms of Reference for the Preparation of a Focus Report Canso Spaceport Facility 1.0 Project Description Proposed by Maritime Launch Services, Ltd. 1.2 Given the highly toxic properties of hydrazine related chemicals (e.g., unsymmetrical dimethyl hydrazine, hydrazine and monomethylhydrazine), the following information requests are required as part of the Focus Report: o A jurisdictional review on where hydrazine related chemicals are used for similar spaceport facilities in developed countries, and a list of spaceports in developed countries where hydrazine related chemicals are used currently; Historically, the primary use of hydrazine was as a rocket propellant. In the United States (US), 73% of hydrazine consumed in 1964 was used for this purpose. By 1982, the use profile for hydrazine had diversified: 40% of hydrazine was used in the manufacture of agricultural chemicals, 33% for chemical blowing agents, 15% in boiler water treatment as a corrosion inhibitor, 5% as rocket propellant and 7% for other purposes. Hydrazine was not manufactured in Canada in 2006 (the data collection year for the Canadian Environmental Protection Act [CEPA] Domestic Substances List [DSL] Assessment) above the reporting threshold of 100 kg. The quantity of hydrazine imported into Canada in 2006 was in the range of 10000–100000 kg. Most of these imports were as aqueous solutions of hydrazine, the form of the product commonly found on the market. In 2006, 123 kg and 1,865 kg of hydrazine were reported to have been released to the atmosphere and hydrosphere, respectively. In addition to environmental releases of hydrazine, 1,076 kg were transferred to hazardous waste facilities for disposal in 2006 (EC/HC 2011a). In addition to use as fuel for many rockets and spacecraft, including the space shuttle, Northrop Grumman’s (Formerly Orbital ATK) Cygnus capsule, SpaceX’s Dragon Capsule, and the MAC-200 satellite bus manufactured by Magellan Aerospace for the RADARSAT Constellation, hydrazine