Content Copy Of Original

Size: px
Start display at page:

Download "Content Copy Of Original"

Transcription

1 Content Copy Of Original Ministry of the Environment and Climate Change Ministère de l Environnement et de l Action en matière de changement climatique Imperial Oil Limited 1 Duncan Mill Road, Room 1061 Toronto, Ontario M3B 1Z2 Site Location: Sarnia Products Pipeline Pumping Station 100-5th Concession Road East Waterdown Hamilton City ENVIRONMENTAL COMPLIANCE APPROVAL NUMBER 3098-A7QT7F Issue Date: April 5, 2016 You have applied under section 20.2 of Part II.1 of the Environmental Protection Act, R.S.O. 1990, c. E. 19 (Environmental Protection Act) for approval of: - One (1) horizontal well air sparging and soil vapour extraction system to treat soil and groundwater impacted by petroleum hydrocarbons, equipped with two (2) vapour phase granular activated carbon filters having a minimum removal efficiency of 95%, discharging to the air at a maximum volumetric flowrate of 0.2 cubic metre per second through a stack having an exit diameter of 0.10 metre and extending 2.44 metres above grade; - One (1) vertical well air sparging and soil vapour extraction system to treat soil and groundwater impacted by petroleum hydrocarbons, equipped with a catalytic oxidizer having a minimum removal efficiency of 98%, discharging to the air at a maximum volumetric flow rate of 0.26 cubic metres per second through a stack having an exit diameter of 0.20 metre and extending 3.66 metres above grade; - Two (2) 1.2 metre diameter durable polyethylene holding tanks located inside two air sparging and soil vapour extraction system enclosures, one servicing the Property Line Area and one for the Subsystems 1, 2, 3 Area, each having a capacity of approximately 2,000 litres and equipped with an audible and visual high level alarm system on a level control sensor that shuts the system down, a raised berm around its perimeter that directs water to a floor sump equipped with level sensor and alarm that shuts the air sparging and soil vapour extraction system down, and receiving sewage from the moisture separator of the associated vapour extraction and treatment process via a transfer pump rated at 40 L/min at 1.8 metre TDH, and emptied by a licensed waste hauler and hauled to an approved disposal facility; all in accordance with the supporting documents set out in Schedule "A" attached to this Approval. For the purpose of this environmental compliance approval, the following definitions apply: 1. "Acoustic Assessment Report" means the report, prepared in accordance with Publication NPC-233 submitted in support of the application, that documents all sources of noise emissions and Noise Control Measures present at the Facility. "Acoustic Assessment Report" also means the Acoustic Assessment Report dated March 2, 2016, and signed by Martin Meyer and Areg Gharabegian, Parsons Inc.;

2 2. "Acoustic Audit" means an investigative procedure consisting of measurements and/or acoustic modelling of all sources of noise emissions due to the operation of the Facility, assessed to determine compliance with the Performance Limits for the Facility regarding noise emissions, completed in accordance with the procedures set in Publication NPC-103 and reported in accordance with Publication NPC-233; 3. "Acoustic Audit Report" means a report presenting the results of an Acoustic Audit, prepared in accordance with Publication NPC-233; 4. "Acoustical Consultant" means a person currently active in the field of environmental acoustics and noise/vibration control, who is familiar with Ministry noise guidelines and procedures and has a combination of formal university education, training and experience necessary to assess noise emissions from a Facility; 5. "Approval" means this Environmental Compliance Approval, including the application and supporting documentation listed in Schedule "A"; 6. "Director" means any person appointed in writing by the Minister pursuant to section 5 of the EPA as a Director for the purposes of section 9 of the EPA; 7. "District Manager" means the District Manager of the appropriate local district office of the Ministry, where the Facility is geographically located and in operation; 8. "EPA" means the Environmental Protection Act, R.S.O. 1990, c.e.19, as amended; 9. "Equipment" means the wells, blowers, pumps, granular activated carbon filters, catalytic oxidizer, moisture separators, heat exchangers, holding tanks and other equipment described in the Owner's application, this Approval and in the supporting documentation submitted with the application, to the extent approved by this Approval; 10. "Facility" means the entire operation located on the property where the Equipment is located; 11. "Independent Acoustical Consultant" means an Acoustical Consultant not representing the Owner, and not involved in the noise impact assessment or the design/implementation of noise control measures for the Facility/Equipment. The Independent Acoustical Consultant shall not be retained by the consultant involved in the noise/vibration impact assessment or the design/implementation of noise/vibration control measures for the Facility/Equipment; 12. "Licensed Installer" means a person who holds a license under Article of the OBC; 13. "Manual" means a document or a set of documents that provide written instructions to staff of the Owner; 14. "Ministry" means the ministry of the government of Ontario responsible for the EPA and OWRA and includes all officials, employees or other persons acting on its behalf; 15. "Noise Control Measures" means measures to reduce the noise emission from the Facility and/or Equipment including, but not limited to silencers, acoustic louvres, enclosures, absorptive treatment, plenums and barriers. It also means the Noise Control Measures as shown in the Acoustic Assessment Report dated March 2, 2016, prepared and signed by Martin Meyer and Areg Gharabegian, Parsons Inc., including the manufacturers noise control measures for the enclosures and the barriers detailed in Schedule "B" of this Approval; 16. "OBC" means the Ontario Building Code; 17. "Owner" means Imperial Oil Limited and includes any successors and assignees; 18. "OWRA" means the Ontario Water Resources Act, R.S.O. 1990, c. O.40, as amended;

3 19. "Process" means the remediation process as described in the Owner's application, this Approval and in the supporting documentation submitted with the application, to the extent approved by this Approval; 20. "Professional Engineer" means a person entitled to practice as a Professional Engineer in the Province of Ontario under a license issued under the Professional Engineers Act; 21. "Publication NPC-103" means Publication NPC-103, Procedures, August 1978; 22. "Publication NPC-233" means the Ministry Publication NPC-233, "Information to be Submitted for Approval of Stationary Sources of Sound", October, 1995 as amended; 23. "Publication NPC-300" means the Ministry Publication NPC-300, "Environmental Noise Guideline, Stationary and Transportation Sources Approval and Planning, Publication NPC-300", August, 2013, as amended; 24. "Remedial Work Plan" means the overall plan, developed for the Facility, that contains as a minimum the remedial objectives, a description of environmental controls required during the Process, an overview of the extent of contamination at the Facility and closure conditions to remove the Process from the Facility; 25. "Soil, Groundwater and Sediment Standards" means the Ministry publication "Soil, Groundwater and Sediment Standards for Use Under Part XV.1 of the Environmental Protection Act dated April 15, 2011", as amended; 26. "Supporting Documents" means the Ministry publications that accompany the Soil, Groundwater and Sediment Standards including "Guide for Completing Phase Two Environmental Site Assessment under Ontario Regulation 153/04 dated June 2011, as amended; 27. "Target Compounds" means the petroleum hydrocarbons as described in the Owner's application, this Approval, and in the supporting documentation submitted with the application, to the extent approved by this Approval, that the Process is designed to treat as part of the Remedial Work Plan; 28. "Works" means the sewage works described in the Owner's application and this Approval. You are hereby notified that this environmental compliance approval is issued to you subject to the terms and conditions outlined below: TERMS AND CONDITIONS PERFORMANCE REQUIREMENTS 1. The Owner shall, at all times, design and operate the Process with the intent to reduce the soil and groundwater concentrations of the Target Compounds to comply with the appropriate criteria provided in the Soil, Groundwater and Sediment Standards, appropriate worker health and safety criteria or site specific criteria developed in accordance with the Supporting Documents. 2. The Owner shall prepare a Remedial Work Plan for the site. The Owner shall submit a copy of the Remedial Work Plan to the District Manager at least ten (10) working days before the commencement of operation of the Process. AIR 3. The Owner shall ensure that the Equipment is properly operated and maintained at all times. The Owner shall:

4 (1) prepare, not later than one (1) month after commencement of operation of the Equipment, and update as necessary, a Manual outlining the operating procedures and a maintenance program for the Equipment, including: (a) routine operating and maintenance procedures in accordance with good engineering practices and as recommended by the Equipment suppliers; (b) emergency procedures; (c) procedures for any record keeping activities relating to operation and maintenance of the Equipment; (d) all appropriate measures to minimize noise and odorous emissions from all potential sources; and (e) the frequency of inspection and replacement of the filter material in the Equipment; (2) implement the recommendations of the Manual. NOISE 4. The Owner shall: (1) configure the Facility as per Drawings # 3 and 6 from the Acoustic Assessment Report dated March 2, 2016, and signed by Martin Meyer and Areg Gharabegian, Parsons Inc.; (2) implement all Noise Control Measures as outlined in the Acoustic Assessment Report dated March 2, 2016, and signed by Martin Meyer and Areg Gharabegian, Parsons Inc.; (3) ensure at all time that the air sparge and soil vapour extraction enclosures are oriented as depicted in Drawing #6 from the Acoustic Assessment Report dated March 2, 2016, and signed by Martin Meyer and Areg Gharabegian, Parsons Inc.; (4) ensure that the enclosures doors remain fully closed at all time with the exception for entering and exiting; (5) ensure at all time, following fully implementation of the Noise Control Measures including the barriers detailed in Schedule "A", that the noise emissions from the Facility comply with the limits set out in Ministry Publication NPC-300; and (6) ensure that the Noise Control Measures are properly maintained and continue to provide the acoustical performance outlined in the Acoustic Assessment Report. 5. The Owner shall carry out Acoustic Audit measurements on the actual noise emissions due to the operation of the Facility. The Owner: (1) shall carry out Acoustic Audit measurements in accordance with the procedures in Publication NPC-103; and (2) shall submit an Acoustic Audit Report on the results of the Acoustic Audit, prepared by an Independent Acoustical Consultant, in accordance with the requirements of Publication NPC-233, to the District Manager and the Director, not later than three (3) months after the commencement of

5 operations of the Equipment. 6. The Director: (1) may not accept the results of the Acoustic Audit if the requirements of Ministry Publication NPC- 233 were not followed; and (2) may require the Owner to repeat the Acoustic Audit if the results of the Acoustic Audit are found unacceptable to the Director. SEWAGE WORKS 7. General Provisions: (1) The Owner shall ensure that any person authorized to carry out work on or operate any aspect of the Works is notified of this Approval and the terms and conditions herein and shall take all reasonable measures to ensure any such person complies with the same. (2) Except as otherwise provided by these terms and conditions, the Owner shall design, build, install, operate and maintain the Works in accordance with this Approval. (3) Where there is a conflict between a provision of this Approval and any document submitted by the Owner, the conditions in this Approval shall take precedence. Where there is a conflict between one or more of the documents submitted by the Owner, the application shall take precedence unless it is clear that the purpose of the document was to amend the application. (4) Where there is a conflict between the documents listed in the Schedule A, and the application, the application shall take precedence unless it is clear that the purpose of the document was to amend the application. (5) The terms and conditions of this Approval are severable. If any term and condition of this Approval, or the application of any requirement of this Approval to any circumstance, is held invalid or unenforceable, the application of such condition to other circumstances and the remainder of this Approval shall not be affected thereby. 8. The approval issued by this Approval will cease to apply to those parts of the Works which have not been constructed within five (5) years of the date of this Approval. 9. Change of Owner: (1) The Owner shall notify the District Manager and the Director, in writing, of any of the following changes within thirty (30) days of the change occurring: (a) change of address of Owner or operating authority; (b) change of Owner or operating authority or both, including address of new Owner or operating authority, or both; (c) change of partners where the Owner or operating authority is or at any time becomes a partnership, and a copy of the most recent declaration filed under the Business Names Act, R.S.O. 1990, c. B.17 ; and

6 (d) change of name of the corporation where the Owner or operator is or at any time becomes a corporation, and a copy of the Initial Return or Notice of Change filed under the Corporations Information Act, R.S.O. 1990, c. C.39, shall be included in the notification to the District Manager. (2) In the event of any change in ownership of the Works, the Owner shall notify in writing the succeeding owner of the existence of this Approval, and a copy of such notice shall be forwarded to the District Manager. (3) The Owner shall ensure that all communications made pursuant to this condition refer to the number at the top of this Approval. 10. Construction: (1) The Owner shall ensure that the construction of the Works is supervised by a licensed installer or a Professional Engineer. (2) Upon construction of the Works, the Owner shall prepare a statement, certified by a licensed installer or a Professional Engineer, that the Works are constructed in accordance with this Approval, and upon request, shall make the written statement available for inspection by Ministry staff and staff of the local municipality. (3) Upon construction of the Works, as-built drawing(s) showing the Works "as constructed" shall be prepared by the licensed installer or a Professional Engineer. The drawing(s) shall be kept up to date through revisions undertaken from time to time and a copy shall be retained at the Works for the operational life of the Works. 11. Operations and Maintenance: (1) The Owner shall exercise due diligence in ensuring that, at all times, the Works and the related equipment and appurtenances used to achieve compliance with this Approval, are properly operated and maintained. (2) The Owner shall maintain and service the Works in such a manner that leaks and spills are prevented, and shall use best efforts to immediately identify and clean up all spills. (3) In the event a leak is observed from any component of the holding tank, the Owner shall ensure that the sewage discharge to the tank is discontinued and that the incident is immediately reported verbally to the District Manager, followed by a written report within one (1) week. The Owner shall ensure that during the time remedial actions are taking place, the sewage generated at the site shall not be allowed to discharge to a surface water body or to the environment, and safely collected and disposed of through a licensed waste hauler. (4) The Owner shall maintain a logbook and keep the logbook at the site for inspection by Ministry staff. The logbook shall include the following: (a) the results of Operation and Maintenance activities specified in the above sub-clauses; (b) the date, time and volume of the sewage pump out from the holding tank; and (c) observances (including location) of any leaks and/or spills at or around any component of the Works, including recommendations for remedial action and the actions taken to mitigate the

7 situation. 12. Spill Contingency Plan: (1) Upon commencement of operation of the Works, the Owner shall implement a Spill Contingency Plan that outlines procedures as to how to mitigate the impacts of a spill within the area serviced by the Works and/or prevent pollution incidents. The said plan shall include as a minimum, but not limited to: (a) the name, job title and location (address) of the Owner, person in charge, management or control of the Sarnia Products Pipeline Pumping Station at 100-5th Concession Rd. E, Waterdown; (b) the name, job title and 24-hour telephone number of the person(s) responsible for activating the Spill Contingency Plan; (c) a site plan drawn to scale showing the facility, nearby buildings, streets, catch basins & manholes, drainage patterns (including direction(s) of flow in storm sewers) and any features which need to be taken into account in terms of potential impacts on access and response (including physical obstructions and location of response and clean-up equipment); (d) steps to be taken to report, contain, clean up and dispose of contaminants following a spill; (e) a listing of telephone numbers for: local clean-up companies who may be called upon to assist in responding to spills; local emergency responders including health institution(s); and MOE Spills Action Centre ; (f) Materials Safety Data Sheets (MSDS) for each and every hazardous material which may be transported or stored within the area serviced by the Works; (g) the means (internal corporate procedures) by which the Spill Contingency Plan is activated; (h) a description of the spill response and pollution prevention training provided to employees assigned to work in the area serviced by the Works, the date(s) on which the training was provided and to whom; (i) an inventory of response or remedial measures and clean-up equipment available to implement the Spill Contingency Plan, location and date of maintenance/replacement if warranted, including testing and calibration of the equipment; and (j) the date on which the Spill Contingency Plan was prepared and subsequently, amended. (2) The Spill Contingency Plan shall be kept in a conspicuous place near the reception area on site. (3) The Spill Contingency Plan will be amended from time to time as needed by changes in the operation of the Facility, Equipment and/or Works or to reflect updates in the Municipal By-Laws, or improved best management practices by the Owner. 13. Reporting: (1) One week prior to the start up of the operation of the Works, the Owner shall notify the District Manager (in writing) of the pending start up date.

8 (2) In addition to the obligations under Part X of the Environmental Protection Act, the Owner shall, within five (5) working days of the occurrence of any reportable spill as defined in Ontario Regulation 675/98, bypass or loss of any product, by-product, intermediate product, oil, solvent, waste material or any other polluting substance into the environment, submit a full written report of the occurrence to the District Manager describing the cause and discovery of the spill or loss, clean-up and recovery measures taken, preventative measures to be taken and schedule of implementation. MONITORING PLAN 14. The Owner shall, before commencement of operation of the Process, design and implement a Monitoring Plan, in accordance with the Supporting Documents, for the soil and groundwater at the Facility to document that the Performance Requirements outlined above are not exceeded and the Remedial Work Plan objectives are met. The Monitoring Plan shall specify, as a minimum: (1) Objectives; (2) procedures for monitoring groundwater levels in the vicinity of the air sparging and vapour extraction wells and assessing for groundwater mounding; (3) list of analytical parameters; (4) monitoring locations and frequency; (5) sampling methodology and quality assurance and quality control procedures; (6) contingency measures should results exceed the Performance Requirements; (7) Remedial Work Plan objectives for discontinuation of the Process. NOTIFICATION REQUIREMENTS 15. The Owner shall notify the Ministry, immediately by telephone and in writing within five (5) days, if the Process is not operated in accordance with the Performance Requirements, the Manual or the Monitoring Plan outlined above. RECORD KEEPING REQUIREMENTS 16. The Owner shall, for a minimum of five (5) years from the date of their creation, retain all reports, records and information described in this Approval, and shall make these records available for review by staff of the Ministry upon request. The records shall include: (1) the Remedial Work Plan; (2) records on the inspection, maintenance, and repair of the Equipment related to the Process; (3) all monitoring results including any verification sampling to demonstrate that the Remedial Work Plan objectives are met; and (4) records on the environmental complaints; including: (a) a description, time and date of each incident to which the complaint relates,

9 (b) wind direction at the time of the incident to which the complaint relates, (c) a description of the measures taken to address the cause of the incident to which the complaint relates and to prevent a similar occurrence in the future. The Owner shall make these records available for review by staff of the Ministry upon request. Schedule "A" SUPPORTING INFORMATION 1. Environmental Compliance Approval Application for Industrial Sewage Works, submitted by Parsons Canada Ltd., received at the Ministry on November 20, Environmental Compliance Approval Application for Air & Noise signed by Michele Laperriere of Imperial Oil Limited, dated November 18, Emission Summary and Dispersion Modelling Report signed by Arthur Schatz of Parsons Canada Ltd., dated November 16, Acoustic Assessment Report signed by Martin Meyer and Areg Gharabegian of Parsons Inc., dated March 2, Supporting Information and drawings prepared by Parsons Canada Ltd. and dated November 16, Information submitted via by John Halstead of Parsons Inc. on February 4, and March 3, Dispersion modelling files and information submitted via by Arthur Schatz on February 4, Revised drawings prepared by Parsons Inc. and dated February 10, Technical Memo prepared by Parsons Inc. and dated March 10, Schedule "B" NOISE CONTROL MEASURES - BARRIERS Beside all noise control measures (silencers and acoustically lined hoods) implemented by the manufacturer within the enclosures the Owner shall construct following two (2) barriers: 1. Barrier for the Subsystem 1, 2 and 3 Area Enclosure The L-shaped barrier shall be constructed at the north-west corner of the Subsystem 1, 2 and 3 Area enclosure, to reduce its noise impacts towards the receptors to the west and north-west. The barrier shall be constructed with a total length of approximately 29 metres with a minimum height of 2.4 metres above ground level. The barrier shall be located as depicted in the Drawing #6 from the Acoustic Assessment Report dated March 2, 2016, and signed by Martin Meyer and Areg

10 Gharabegian, Parsons Inc. The barrier shall be continuous without any holes, gaps or other penetrations, and have a surface mass of at least 20 kilograms per square metre. 2. Barrier for the Property Line Area Enclosure The L-shaped barrier shall be constructed on the west side of the Property Line Area Enclosure enclosure, to reduce its noise impacts towards the receptors to the west and north-west. The barrier shall be constructed with a total length of approximately 23.5 metres with a minimum height of 2.4 metres above ground level. The barrier shall be located as depicted in the Drawings #6 from the Acoustic Assessment Report dated March 2, 2016, and signed by Martin Meyer and Areg Gharabegian, Parsons Inc. The barrier shall be continuous without any holes, gaps or other penetrations, and have a surface mass of at least 20 kilograms per square metre. The Owner shall implement above noted barriers prior to commencement of operation of the Equipment. The reasons for the imposition of these terms and conditions are as follows: 1. Conditions 1 and 2 are included to outline the minimum performance requirements considered necessary to prevent an adverse effect resulting from the operation of the Process. 2. Condition 3 is included to emphasize that the Equipment must be maintained and operated according to a procedure that will result in compliance with the EPA, the Regulations and this Approval. 3. Condition 4 is included to provide the minimum performance requirement considered necessary to prevent an adverse effect resulting from the operation of the Facility. 4. Condition 5 is included to require the Owner to gather accurate information so that the environmental impact and subsequent compliance with the EPA, the regulations and this Approval can be verified. 5. Condition 6 is included to ensure that the Acoustic Audit is carried out in accordance with procedures set in the Ministry's Noise Guidelines. 6. Condition 7 is imposed to ensure that the Works are built and operated in the manner in which they were described for review and upon which approval was granted. This Condition is also included to emphasize the precedence of Conditions in the Approval and the practice that the Approval is based on the most current document, if several conflicting documents are submitted for review. 7. Condition 8 is included to ensure that, when the Works are constructed, the Works will meet the standards that apply at the time of construction to ensure the ongoing protection of the environment. 8. Condition 9 is included to ensure that the Ministry records are kept accurate and current with respect to approved Works and to ensure that any subsequent Owner of the Works is made aware of the Approval and continue to operate the Works in compliance with it. 9. Condition 10 is included to ensure that the Works are constructed, and may be operated and maintained such that the environment is protected and deterioration, loss, injury or damage to any person or property is prevented. 10. Condition 11 is included to require that the Works be properly operated and maintained such that the environment is protected.

11 11. Condition 12 is included to ensure that the Ministry is immediately informed of the occurrence of an emergency or otherwise abnormal situation so that appropriate steps are taken to address the immediate concerns regarding the protection of public health and minimizing environmental damage and to be able to devise an overall abatement strategy to prevent long term degradation and the reoccurrence of the situation. 12. Condition 13 is included to provide a performance record for future reference and to ensure that the Ministry is made aware of problems as they arise, so that the Ministry can work with the Owner in resolving the problems in a timely manner. 13. Condition 14 is included to require the Owner to gather accurate information so that the environmental impact and subsequent compliance with the EPA, the regulations and this Approval can be verified. 14. Condition 15 is included to require the Owner to notify the Ministry so that the environmental impact and subsequent compliance with the EPA, the regulations and this Approval can be verified. 15. Condition 16 is included to require the Owner to retain records and provide information to the Ministry so that the environmental impact and subsequent compliance with the EPA, the regulations and this Approval can be verified. In accordance with Section 139 of the Environmental Protection Act, you may by written Notice served upon me, the Environmental Review Tribunal and in accordance with Section 47 of the Environmental Bill of Rights, 1993, S.O. 1993, c. 28 (Environmental Bill of Rights), the Environmental Commissioner, within 15 days after receipt of this Notice, require a hearing by the Tribunal. The Environmental Commissioner will place notice of your appeal on the Environmental Registry. Section 142 of the Environmental Protection Act provides that the Notice requiring the hearing shall state: 1. The portions of the environmental compliance approval or each term or condition in the environmental compliance approval in respect of which the hearing is required, and; 2. The grounds on which you intend to rely at the hearing in relation to each portion appealed. The Notice should also include: 3. The name of the appellant; 4. The address of the appellant; 5. The environmental compliance approval number; 6. The date of the environmental compliance approval; 7. The name of the Director, and; 8. The municipality or municipalities within which the project is to be engaged in. And the Notice should be signed and dated by the appellant. This Notice must be served upon: The Secretary* Environmental Review Tribunal 655 Bay Street, Suite 1500 Toronto, Ontario M5G 1E5 AND The Environmental Commissioner 1075 Bay Street, Suite 605 Toronto, Ontario M5S 2B1 The Director appointed for the purposes of Part II.1 of the Environmental Protection Act ANDMinistry of the Environment and Climate Change 135 St. Clair Avenue West, 1st Floor

12 Toronto, Ontario M4V 1P5 * Further information on the Environmental Review Tribunal s requirements for an appeal can be obtained directly from the Tribunal at: Tel: (416) , Fax: (416) or This instrument is subject to Section 38 of the Environmental Bill of Rights, 1993, that allows residents of Ontario to seek leave to appeal the decision on this instrument. Residents of Ontario may seek leave to appeal within 15 days from the date this decision is placed on the Environmental Registry. By accessing the Environmental Registry at you can determine when the leave to appeal period ends. The above noted activity is approved under s.20.3 of Part II.1 of the Environmental Protection Act. DATED AT TORONTO this 5th day of April, 2016 NR/ c: District Manager, MOECC Hamilton - District John Halstead, Parsons Inc. Rudolf Wan, P.Eng. Director appointed for the purposes of Part II.1 of the Environmental Protection Act