Jurgen Franke P. Eng., Director, Engineering & Terminal Development. Review and rationale for changes to Environmental Management Plans

Transcription

1 Soleil 342 Rosehill Wynd Tsawwassen, BC V4M 3l9 29 April 2015 Fraser Surrey Docks Limited Partnership Elevator Road Surrey, BC, Canada V3V 2R7 Attention: Jurgen Franke P. Eng., Director, Engineering & Terminal Development Re: Review and rationale for changes to Environmental Management Plans Dear Sir: The following document summarizes proposed changes to the preliminary Construction and Operational Environmental Management Plans (CEMP, and OEMP, respectively) for the amended Project as described in the Proposed Permit Amendment to the Direct Transfer Coal Facility Executive Summary prepared by Fraser Surrey Docks (dated march 18, 2015). Some of the proposed changes will reflect reassessment required as a result of the proposed design changes to the Project. It should be noted the original EMPs were prepared as a single document, and the revised CEMP and OEMP will be prepared as two separate documents. Separating the single EMP into two separate documents will necessitate some duplication of text between the two plans (e.g. project description sections). However, it also makes practical sense since some plans or mitigation measures are relevant to both plans, others are only applicable to the operational or construction phase of the project. The original EMP document provides a framework for identifying and managing changes in the scope of the project, and the need to incorporate information from other assessments, and to elaborate on effective mitigation measures, based on best management practices (BMPs) and guidelines applicable at the time of construction. In addition, it is anticipated some sections will be expanded to provide additional information/clarification about roles and responsibilities, and the document could continue to be adapted as contractors are hired, responsibilities defined and construction techniques finalized. In summary, this review provides a number of revisions and changes to the original document and it should be stressed that some of these changes and revisions are part of a normal process of updating and finalizing the CEMP and the OEMP. 1

2 Section Reference 1.0 Introduction Action required Rationale 1.0 Introduction 1.1 Project Description Revisions recommended to update reference to background documents and assessments forming the basis of the EMP. amendments to the project description. No new assessment 1.2 System Components amendments to the project description. No new assessment 2.0 Construction Program 2.0 Construction Program 3.0 Environmental Setting NEW Section Add New section amendments to the project description. No new assessment Section 3.0 to be changed to Section 4.0 Revision to insert a new section describing the environmental setting, and summarizing how construction activities might impact the ecological components. This section will summarize vegetation and wildlife as well as aquatic habitats in the project area. In addition this section will summarize expected impacts to the environment from the project. Conduct field survey to confirm local site conditions relative to revised project design, and reduced footprint impact. 3.0 Construction Environmental Management Plans change to section 4.0 Note: The numbering of all subsequent sections will also be changed from 3 to Surface Water Quality and Sediment Control Plan Revisions required to reflect mitigation measures outlined in the environmental impact assessment (EIA) and/or other background assessments completed for the project. 2

3 3.1.1 Watercourse Adjacent to Elevator road 3.2 Environmental Monitoring Plan 3.3 Hazardous Materials Management and Spill Response Plan (HMMSRP) Move (including sub sections) Information in this section will be moved and incorporated into the new Section 3.0, which will provide an expanded discussion about the environmental setting. Revisions to describe the role and responsibilities of the environmental monitor in more detail and ensure consistency with mitigation measures in other background assessments, primarily the EIA. Revisions in multiple sub-sections of 3.3, to provide more information about management strategies and responsibilities, and to ensure consistency with mitigation measures in other background assessments, primarily the EIA. Where applicable references to other BMPs or guideline documents will also be added, updated or checked. Revisions will also be made to include a new sub-section covering spill prevention and containment as part of the HMMSRP. This does not require any new assessments as the materials contemplated for use in the project remain the same Spill Preparedness Change to subsection 3.4 Move edit and Revisions to move spill preparedness and spill response to a separate management plan/strategy. Revisions will also ensure consistency with mitigation measures in other background assessments, primarily the EIA. Where applicable references to other BMPs or guideline documents will also be added, updated or checked. No new assessments required, the nature of the products and activities have not changed Spill Response Move and edit As described above for Section move to new separate section and revise. 3.4 Soils Management Plan (SMP) Managing Known or Suspect Contaminated Soils Revisions to incorporate additional information and Revisions to incorporate additional information and 3

4 3.5 Air Quality Management Plan 3.6 Noise Management Plan Revisions to incorporate additional information and assessments and documents. Incorporate information from other disciplines as available. assessments and documents. Incorporate information from other disciplines as available. 3.7 Pile Driving Plan 3.8 Vegetation and Wildlife Protection Plan Revisions to incorporate differences in environmental impact from design changes near Elevator Road and assessments and documents. Conduct field survey to confirm local site conditions relative to revised project design. Re-evaluate habitat balance, based on reduced footprint impact of new design on local watercourses. 4.0 Operational Environmental Management Plan As noted elsewhere in this document the OEMP is being prepared as a separate document from the CEMP, therefore some of the required revisions will include incorporating or duplicating information for the Introduction section of the CEMP. The actual management plans for various activities will then start in Section 2. In addition, the OEMP will be prepared as a draft document and be finalized following construction. This will allow all design changes required or incorporated during construction to be considered and incorporated into the operational plan as applicable. 1.0 Introduction 1.1 Project Description Revisions recommended to update reference to background documents and assessments forming the basis of the EMP. amendments to the project description, incorporating 4

5 1.2 System Components 4.0 Operational Environmental Management Plans Re-number accordingly as Section Air Quality Management Plan Weather Monitoring amendments to the project description incorporating Revisions to identify and document the current applicable version of any system guiding documents prepared for and in effect at Fraser Surrey Docks. These documents would form the basis of the OEMP and would be complemented by mitigation measures specific to the DTCF project outlined in various background assessments for the project. No new assessments documents, (e.g. FSD Anti Idling Policy). Incorporate documents. Incorporate information from other disciplines as available Dust Monitoring documents. Incorporate information from other disciplines as available Dust Mitigation Measures documents. Incorporate information from other disciplines as available. 4.2 Runoff Management Plan Revisions required to incorporate additional information and ensure consistency with final designs and applicable permits Water Treatment Revisions required to incorporate additional information and ensure consistency with final designs and applicable permits Water Quality Monitoring Revisions required to incorporate additional information and ensure consistency with final designs and applicable permits. 5

6 4.3 Emergency Response Plans assessments and documents, (e.g. FSD Terminal Safety Management System, fire safety plans and emergency procedures). No new assessments Combustion assessments and documents, (e.g. FSD Terminal Safety Management System, fire safety plans and emergency procedures). No new assessments Spill Prevention and Response New Section documents, (e.g. FSD Terminal Safety Management System, fire safety plans and emergency procedures). No new assessments New section proposed to provide information on recommended procedures for site maintenance. Would include reference to FSD safe work procedures (SWPs), product stewardship policy and sustainable procurement policy. 4.4 Lighting Plans 4.5 Noise Management Plans 5.0 References and Information Sources (including sub sections) As described above revisions to incorporate applicable information and ensure consistency with other background assessments and documents. Incorporate Applicable to CEMOP and OEMP Revisions required to update references and ensure accurate citation of background documents, assessments, current BMPs and applicable regulatory guidelines or legislation. Should you have any questions regarding the above described review and rationale for revisions 6

7 please feel free to contact the undersigned at or Peter Frederiksen at Sincerely, Soleil Environmental Consultants Ltd. POLARIS Environmental Consultants Ltd. Tom A. Watson, Ph.D., R.P.Bio. (BC), P. Biol. (AB) Senior Environmental Scientist President Peter Frederiksen, CPESC, DipT Senior Environmental Specialist President 7