CONTAMINATION IDENTIFICATION AND ASSESSMENT PLAN FOR THE TRANS MOUNTAIN PIPELINE ULC TRANS MOUNTAIN EXPANSION PROJECT NEB CONDITION 46 August 2017 REV 4 687945 01-13283-GG-0000-CHE-RPT-0036 R4 DRAFT for Review Trans Mountain Pipeline ULC Kinder Morgan Canada Inc. Suite 2700, 300 – 5th Avenue S.W. Calgary, Alberta T2P 5J2 Ph: 403-514-6400 Trans Mountain Pipeline ULC Contamination Identification and Assessment Plan Trans Mountain Expansion Project 687945/August 2017 TABLE OF CONCORDANCE National Energy Board (NEB) Condition 46 is applicable to the following legal instruments: OC-064 (CPCN), AO-003-OC-2 (OC2), AO-002-OC-49 (OC49), XO-T260-007-2016 (Temp), XO-T260-008-2016 (Pump 1), XO-T260-009-2016 (Pump 2), XO-T260-010-2016 (Tanks) and MO-015-2016 (Deact). Table 1 describes how this Plan addresses the Condition requirements applicable to Project activities. TABLE 1 LEGAL INSTRUMENT CONCORDANCE WITH NEB CONDITION 46: CONTAMINATION IDENTIFICATION AND ASSESSMENT PLAN OC-064 AO-003-OC-2 (OC2) AO-002-OC-49 XO-T260-007-2016 XO-T260-008-2016 XO-T260-009-2016 XO-T260-010-2016 MO-015_2016 NEB Condition 46 (CPCN) (OC49) (Temp) (Pump1) (Pump2) (Tanks) (Deact) Trans Mountain must file with the NEB for approval, at least 4 months prior to Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan Sections 4.0 and 5.0 of this Plan commencing construction, a Contamination Identification and Assessment Plan that includes: a) a description of the procedures that have been implemented to-date, and that will be implemented prior to or during construction, to identify and assess pre-existing solid, liquid or gaseous contamination that could be disturbed by, or affect, the Project, including whether site investigations have been or will be undertaken; b) a demonstration of the adequacy of the procedures in a) with reference to Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this Section 4.0, 5.0 and 7.0 of this relevant standards, guidelines, and best practices, including how historical Plan Plan Plan Plan Plan Plan Plan Plan land use has been taken into account and discussion of the potential for chemicals of concern to not be detectable by smell or by sight; c) the information that has been or will be reported by Trans Mountain, Section 6.0 of this Plan Section 6.0 of this Plan Section 6.0 of this Plan Section 6.0 of this Plan Section 6.0 of this Plan Section 6.0 of this Plan Section 6.0 of this Plan Section 6.0 of this Plan including to whom and when, concerning the pre-existing contamination; d) a summary of its consultation with Appropriate Government Authorities, Section 2.0 of this Plan Section 2.0 of this Plan Section 2.0 of this Plan Section 2.0 of this Plan Section 2.0 of this Plan Section 2.0 of this Plan Section 2.0 of this Plan Section 2.0 of this Plan potentially affected Aboriginal groups and affected landowners/tenants. In its summary, Trans Mountain must provide a description and justification for how Trans Mountain has incorporated the results of its consultation, including any recommendations from those consulted, into the plan; and e) confirmation that Trans Mountain will update the relevant Environmental Section 1.0 of this Plan Section 1.0 of this Plan Section 1.0 of this Plan Section 1.0 of this Plan Section 1.0 of this Plan Section 1.0 of this Plan Section 1.0 of this Plan Section 1.0 of this Plan Protection Plan(s) to include any relevant information from the Contamination Identification and Assessment Plan. 01-13283-GG-0000-CHE-RPT-0036 Page i Trans Mountain Pipeline ULC Contamination Identification and Assessment Plan Trans Mountain Expansion Project 687945/August 2017 EXECUTIVE SUMMARY The Contamination Identification and Assessment Plan (the Plan) was prepared to meet National Energy Board (NEB) Condition 46 regarding the Trans Mountain Expansion Project (“the Project” or “TMEP”). This Plan was completed to ensure appropriate handling of contamination to protect workers, public and the environment and demonstrates Trans Mountain Pipeline ULC’s (Trans Mountain’s) commitment to mitigate potential risk from exposure to pre-existing contamination from disturbed soil and/or water that could be disturbed by, or affect, the Project. This Plan outlines the identification and assessment of pre-existing areas of potential contamination within the Project Footprint, including procedures for managing contamination identified in the additional searches completed to update the preliminary inventory of potentially contaminated sites (TERA Environmental Consultants [TERA] 2013a) (CIPCS). Relevant standards, guidelines, and best practices to be followed during the construction works are included in this Plan. In conjunction with the preparation of this Plan, additional works were completed to update the CIPCS and to create an updated inventory of potentially contaminated areas located within, or immediately adjacent to the Project Footprint. Properties reviewed were characterized as resulting in a low, moderate, or high risk for encountering contamination within the Project Footprint. A total of 40 areas were classified as moderate risk and four areas were classified as having a high risk. In order to determine if adequate characterization information was available for areas ranked as high risk, previously collected data was evaluated for specific properties, where available. The four high risk areas include portions of the Project Footprint which crosses through the former University of Alberta Ellerslie Waste Management Facility in Edmonton (KP 26.3 to KP 26.8) in Alberta (AB), Kamloops Airport (KP 840.9 to KP 841.5), Surrey/Langley area (KP 1154.8 to KP 1157.9) and City of Coquitlam (KP 1168.7 to KP 1173.1) in British Columbia (BC). Through this data review, it was determined three individual properties within the identified high risk areas require subsurface intrusive investigation prior to construction to develop construction mitigation plans. These three properties are located in the Surrey/Langley area (two properties) and City of Coquitlam (one property). A Contamination Resource Specialist (Resource Specialist) will ensure the appropriate response and mitigation is carried out during construction in high risk areas. When working in areas of moderate risk, the Environmental Inspector will ensure workers are aware of the potential to encounter contamination. In the event unexpected contamination is encountered the Contamination Discovery Contingency Plan (Appendix B of the Environmental Protection Plans [EPPs]) will be initiated, and a Resource Specialist will direct response activities. The Project will be constructed along several third-party properties with various current and historical activities, which may have resulted in impacts to soil, groundwater, vapour, and/or sediments. Trans Mountain will notify the NEB and the owner of the property should impacts in these areas be identified prior to, or during, construction works. Trans Mountain will ensure contaminated waste material encountered during construction within the pipeline construction footprint is tracked and managed appropriately. Should impacts be identified on Trans Mountain properties, Trans Mountain will address them according to the guidance provided in the NEB Remediation Process Guide (2011). Trans Mountain has initiated consultation and will continue to work with Appropriate Government Authorities, landowners, and any potentially affected Aboriginal groups to ensure issues concerning contamination are addressed. Trans Mountain has also provided responses to Information Requests (IRs) on issues related to potential contamination as a result of the NEB hearing process. This Plan is part of the Environmental Management Plans (Section 3.0 of Volume 6 of the Environmental Plans) to ensure that the applicable procedures for managing contamination are followed, and where necessary, the applicable mitigation measures are implemented. In addition, pertinent information from this Plan will be used to update the Project-specific EPPs (Volumes 1 through 5, 9 and 10 of the Environmental Plans). 01-13283-GG-0000-CHE-RPT-0036 Page ii Trans Mountain Pipeline ULC Contamination Identification and Assessment Plan Trans Mountain Expansion Project 687945/August 2017 TABLE OF CONTENTS Page TABLE OF CONCORDANCE ........................................................................................................................ i EXECUTIVE SUMMARY ............................................................................................................................... ii 1.0 INTRODUCTION .............................................................................................................................. 1 1.1 Project Description .............................................................................................................. 1 1.2 Objectives ........................................................................................................................... 2 1.3 Links to other Trans Mountain Environmental Plans .......................................................... 2 1.4 Commitments Management ...............................................................................................