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Kiewit Ledcor TMEP Partnership TRANS MOUNTAIN EXPANSION PROJECT 2115 COMMISSIONER STREET PROJECT SUPPORT SITE PORT OF VANCOUVER PROJECT PERMIT SUBMISSION CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN (CEMP) Revision Date Remarks 0 July 24, 2017 Prepared for: Prepared by:

TRANS MOUNTAIN EXPANSION PROJECT - Port of … · Installation of 280 m of 1.8m high standard chain link fence, with barb wire above the top bar. iv. Installation of a 10m wide, double

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Kiewit Ledcor TMEP Partnership

TRANS MOUNTAIN EXPANSION PROJECT

2115 COMMISSIONER STREET – PROJECT SUPPORT SITE

PORT OF VANCOUVER PROJECT PERMIT SUBMISSION

CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN (CEMP)

Revision Date Remarks

0 July 24, 2017

Prepared for:

Prepared by:

2115 Commissioner Street – Project Support Site: Vancouver Fraser Port Authority

Construction Environmental Management Plan

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TABLE OF CONTENTS

List of Tables ...................................................................................................................................... iv

List of Figures ..................................................................................................................................... v

1 INTRODUCTION ..................................................................................................................... 7

2 PROJECT INFORMATION ..................................................................................................... 8

2.1 Location .......................................................................................................................... 8

2.2 Project Description ......................................................................................................... 8

2.3 Project Schedule .......................................................................................................... 10

2.4 Site Description ............................................................................................................ 12

2.4.1 Habitat Assessment .......................................................................................... 13

2.4.1.1 Aquatic ...................................................................................................... 13

2.4.1.2 Terrestrial .................................................................................................. 14

2.4.2 Desktop Review of Archaeological Potential .................................................... 14

3 CONTACTS AND RESPONSIBILITIES ................................................................................ 14

3.1 Environmental Roles and Responsibilities ................................................................... 15

3.1.1 Contractor Environmental Manager .................................................................. 15

3.1.2 Environmental Coordinator ............................................................................... 16

3.1.3 Environmental Discipline Specialists ................................................................ 17

3.1.4 Construction Staff Responsibilities ................................................................... 17

4 RELEVANT ENVIRONMENTAL LEGISLATION .................................................................. 18

5 PROJECT MITIGATION MEASURES AND ENVIRONMENTAL SPECIFICATIONS ......... 23

5.1 Temporary Construction Lands and Infrastructure EPP .............................................. 23

5.2 General Practices ......................................................................................................... 23

5.2.1 Work Plans........................................................................................................ 24

5.2.2 Environmental Training ..................................................................................... 24

5.2.3 Environmental Monitoring ................................................................................. 24

5.2.4 Environmental Reporting .................................................................................. 25

5.3 Site Access, Mobilization and Laydown Areas ............................................................ 25

5.3.1 Site Laydown .................................................................................................... 25

5.3.2 Site Access ....................................................................................................... 25

5.4 Air Quality ..................................................................................................................... 26

5.5 Noise and Vibration ...................................................................................................... 28

5.6 Machinery and Equipment ........................................................................................... 29

5.7 Erosion and Sediment Control ..................................................................................... 30

5.7.1 Best Management Practices ............................................................................. 31

5.7.1.1 Water Management ................................................................................... 31

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5.7.1.2 Erosion Prevention and Control ................................................................ 31

5.7.1.3 Sediment Control ...................................................................................... 32

5.8 Contaminated Soil and Groundwater Management ..................................................... 33

5.8.1 Recognition and Response ............................................................................... 33

5.8.1.1 Identification of Contamination .................................................................. 33

5.8.1.2 Notification Framework ............................................................................. 33

5.8.1.3 Health and Safety ...................................................................................... 33

5.8.2 Interim Mitigation .............................................................................................. 34

5.8.3 Contamination Management Requirements ..................................................... 34

5.9 Vegetation and Wildlife Management .......................................................................... 35

5.9.1 Vegetation ......................................................................................................... 35

5.9.2 Wildlife .............................................................................................................. 35

5.10 Marine Works ............................................................................................................... 36

5.11 Heritage Resources ..................................................................................................... 37

5.11.1 Archaeological Training .................................................................................... 38

5.11.2 Heritage Resources Discovery Contingency Plan ............................................ 38

5.11.2.1 Human Remains Discovered During Construction ................................... 39

5.12 Sensitive Habitat Features and Species ...................................................................... 39

5.12.1 Species at Risk ................................................................................................. 39

5.12.2 Mitigation Measures .......................................................................................... 40

6 EMERGENCY RESPONSE ................................................................................................... 40

6.1 Purpose and Scope ...................................................................................................... 40

6.2 Response Organization................................................................................................ 41

6.3 Contractor Responsibilities .......................................................................................... 41

6.4 Equipment .................................................................................................................... 42

6.5 Initial Assessment ........................................................................................................ 42

6.6 Recovery ...................................................................................................................... 42

6.7 Detailed Assessment ................................................................................................... 42

6.8 Remediation ................................................................................................................. 42

6.9 Closure ......................................................................................................................... 42

6.10 Emergency Communication ......................................................................................... 43

7 FUEL MANAGEMENT PLAN ............................................................................................... 43

7.1 Refueling Procedures ................................................................................................... 43

7.1.1 Onshore Works ................................................................................................. 43

7.1.2 Refueling Marine Equipment ............................................................................ 44

7.1.3 Jerricans ........................................................................................................... 44

8 WASTE MANAGEMENT PLAN ............................................................................................ 45

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8.1 Guiding Principles ........................................................................................................ 45

8.2 WASTE CHARACTERIZATION ................................................................................... 45

8.3 PREVENTION AND MITIGATIVE MEASURES .......................................................... 46

8.3.1 General Requirements ...................................................................................... 47

8.3.2 Training ............................................................................................................. 47

8.3.3 Non-Hazardous Wastes (including Camp Wastes) .......................................... 48

8.3.4 Hazardous Waste and Chemical Handling ....................................................... 48

8.3.5 Hazardous Waste and Chemical Storage ......................................................... 48

8.3.6 Waste Disposal ................................................................................................. 49

8.3.7 Documentation and Record Keeping ................................................................ 49

H-1 APPENDIX A………………………………………………………EMERGENCY CONTACTS

H-1 APPENDIX B………………………………………………………….CONTINGENCY PLANS

H-1 APPENDIX C………………………………………………MARINE CONTINGENCY PLANS

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List of Tables

Table 1: Key Project Construction Personnel .................................................................................... 14

Table 2: Environmental Legislation and Legal Requirements ........................................................... 18

Table 3: Key Emergency Contact Phone Numbers ........................................................................... 43

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List of Figures

Figure 1: Project Location .................................................................................................................... 8

Figure 2: Site Plan ............................................................................................................................... 9

Figure 3: Site Access ......................................................................................................................... 26

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1 INTRODUCTION

This Construction Environmental Management Plan (CEMP) is the primary document to guide overall

environmental best management practices to be implemented by the construction team for the 2115

Commissioner Street – temporary Project Support Site (the Project) to reduce or eliminate effects on the

environment and meet regulatory requirements.

The general objectives of the CEMP are:

To protect valued ecological components and socio-economic features along within the Project area

during the design and construction phases of the project;

to ensure compliance with the conditions of environmental approvals from regulatory authorities;

and

to reduce potential environmental liabilities.

Construction management of the Project recognizes that human safety, traffic management and other

factors are also important during design and construction planning; an overall environmental benefit can be

achieved by expeditious completion of the contract (i.e., minimizing the duration of disturbance). It is the

Contractor’s goal to complete the construction activities associated with the setup of this site in a safe and

efficient manner and to protect and enhance environmental and socioeconomic resources.

It is important to note that the CEMP and its component plans may need periodic revisions when further site-

specific information becomes available or as Project conditions change. At a minimum, the CEMP will be

reviewed prior to the start of construction to ensure mitigation measures within the CEMP are appropriate for

the scheduled construction activities at the Project site. It is acknowledged that Vancouver Fraser Port

Authority (VFPA) will make the final determination on the suitability, completeness and adequacy of the

CEMP and any future revisions.

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2 PROJECT INFORMATION

2.1 Location

As indicated in Figure 1, the Project will be located at 2115 Commissioner in the western end of the East

Vancouver Port Lands region. The site is bounded by the Burrard Inlet to the North and the Canadian

National Railway to the South.

Figure 1: Project Location

2.2 Project Description

The 2115 Commissioner Street – Project Support Site includes site preparation and construction of a new

trestle dock, Construction of the Project site will include:

General site preparation and grading, including any necessary upgrades to the existing ground to make suitable for the operation of a 300T Crawler Crane.

Assembly of a 300T Crawler Crane.

Installation of a trestle dock and dolphin piles, to facilitate material transfer from barges, legal trucks and the laydown yard. This may also be used as an access point for crews to board water taxis to be transported to the Westridge Marine Terminal;

Setup of temporary construction offices, lunchrooms, washcars and storage containers.

Installation of temporary lighting, fences, gates and other measures to secure the site for the duration of the Project.

Layout of internal access roads, vehicle parking locations, bus staging areas and security access points.

A plan drawing showing the proposed site layout is provided in Figure 2.

2115 Commissioner Street

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Figure 2: Site Plan

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2.3 Project Schedule

The construction activities planned for this site will be split into three sections based on Permit Applications

filed with VFPA as follows.

1) Site Investigations (Category A permit)

This covers the entire 2115 Commissioner Street Site.

This will include:

i. - Mapping and locating of all utilities onsite – Sites 1 & 2

ii. - Where any ground disturbance is planned in proximity of any utilities,

physically verifying

iii. the location of utilities by hand or using a hydro-vac – Site 1 only

iv. - Site survey and layout – Sites 1 & 2

v. - Geotechnical investigations, as shown in Appendix A, including;

vi. o Two ~30m deep CPT bore holes

vii. o Four 3-4m deep test pits or auger hole

viii. o Actual depths will be determined by the onsite Geotechnical Engineer.

ix. The site will be restored to its previous condition after tests are conducted.

This work commenced on July 20th, 2017 and will take approximately 4-6 weeks to

complete.

2) Setup for Parking, Busing and Water Taxi

This is Specific to Site 2, as shown on Figure 2.

This will include:

i. - Minor clean-up and site grading including:

Removal of any debris left onsite

Filling in of pot holes

Removal of shrubs and bushes

ii. - Installation of 150m of 1.8m high standard chain link fence, with barb wire

above the top bar.

iii. - Installation of a 10m wide, double swing gate for vehicle access and a 1.2m

wide man-gate for personnel access.

iv. - Placement of 60m of precast concrete barricades to delineate the Original

Wharf.

v. - Delineation of approximately 80 parking spots and two street side bus staging

areas.

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vi. Installation of a flexi-float dock and engineered access ramp, for worker access

to water taxi.

The flexi-float dock would be secured to the seabed using two – 600mm

diameter spud’ piles, connected to the dock. The preliminary

dimensions for the flexi-float is 40’ x 20’ x 7’ with a 77’ engineered

access ramp.

Appendix B shows a representative flexi-float configuration, as planned

for this site.

Appendix C shows a sample design for the access ramp from a

previous project. A new engineered design will be completed for the

ramp on this site prior to installation.

vii. Following removal of the temporary access ramp and flexi-float dock

(anticipated to occur in December 2017), marine riparian vegetation will be

replanted within the affected area.

This work will take approximately 4 weeks to complete, commencing upon the receipt of

the project permits; anticipated in September 2017. After the construction is complete,

the site will enter its operational phase which will last until the end of the TMEP project,

approximately two years later.

3) Setup of Marine Service Yard.

This is Specific to Site 1, as shown on Figure 2.

This will include:

i. Minor clean-up and site grading including:

Removal of any debris left onsite

Filling in of pot holes

ii. Upgrades to existing ground, as required to support a 300T crawler crane. This

may include:

Milling of existing asphalt.

Temporary removal of the top 300-600mm of gravel.

Placement of Geotextile grid or fabric

Replacement, compaction and grading of gravel previously removed.

Import and placement of additional gravel required to achieve design

capacity and grade.

iii. Installation of 280 m of 1.8m high standard chain link fence, with barb wire

above the top bar.

iv. Installation of a 10m wide, double swing gate for vehicle access and a 1.2m

wide man-gate for personnel access.

v. Placement of 55m of precast concrete barricades to delineate the Original

Wharf.

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vi. Placement of mobile office trailers, washroom trailer and connex storage

containers.

vii. Layout of approximately 50 parking stalls for onsite and offsite staff.

viii. Construction of a Temporary Trestle consisting of:

A 30’ x 115’ Access Trestle

A 48 x 180’ Main Trestle

25 ea – 600mm diameter pipe piles

28 ea – 900mm diameter pipe piles

ix. Installation of temporary mobile small boat dock made up of 3 flexi-float barges.

x. Installation of temporary lights on the existing wooden poles along

Commissioner Street, as shown in Appendix I.

These lights will designed and installed based on the PER Guidelines

for Lighting.

Specifically, they will be installed to improve safety and security on the

site, without creating nuisance lighting for the neighbouring community

or marine vessels.

The detailed site lighting plan will be prepared by a qualified lighting

professional prior to the installation of lights on site.

We will coordinate this with BC Hydro and necessary approvals and

permits will be obtained prior to any installations.

This work will take approximately 8-12 weeks to complete, commencing upon the

receipt of the project permits; anticipated in December 2017. After the construction is

complete, the site will enter its operational phase which will last until the end of the

construction of the TMEP project, approximately two years later.

As part of the Design - Build process, the establishment of demolition and construction schedules is a key

and evolving process as preliminary design drawings are developed. As the design for this site is still in the

preliminary stages, it is possible for the construction schedule to evolve The Project team will continue to

work with VFPA staff throughout the permitting process to address outstanding issues and how they may

impact the overall schedule of the works.

2.4 Site Description

The site at 2115 Commissioner Street is located 8 km west of the Second Narrows Bridge in Vancouver,

British Columbia. The lot is located on a previously disturbed, level industrial site and the ground at the site

is currently bare gravel. The site can be accessed via Commissioner Street and no temporary access is

required.

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2.4.1 Habitat Assessment

Detailed biophysical assessment reports of the existing aquatic and terrestrial habitat have been completed

for the Project. Summaries of the finding in those reports are provided below.

2.4.1.1 Aquatic

The 2115 Commissioner Street site is located in the inner harbor of the Burrard Inlet approximately 12 km

west of the Westridge Marine Terminal, which is located in the Central Harbour of Burrard Inlet. Similar fish

species and habitats are present at both the sites and a DFO Important Area for Pacific salmon overlaps

with these two sites. The installation and operation of the temporary trestle, access trestle and small flexi-

float dock is not expected to result in lasting deleterious effects to existing intertidal and subtidal habitats or

species. Shading of vegetated rocky habitats is expected to be partial and vary throughout the day under the

access trestle and small boat dock. Although some sessile or slow moving benthic invertebrates (e.g.,

painted anemone, giant plumose anemone, sea stars, and orange sea-pen) may be crushed during

installation of piles, the number affected is expected to be negligible given the expected abundance of these

species across subtidal benthic habitats in the Inner Harbour of Burrard Inlet. Further, these species are

likely to quickly repopulate the affected areas when the piles are removed. No long-term or irreversible

residual effects are expected with respect to the sustainability or productivity of local invertebrate and fish

populations. Potential effects to marine mammals, birds and/or fish from underwater noise, artificial lighting,

or vessel movement are expected to be effectively mitigated during operation of the proposed infrastructure

and associated marine traffic. Following removal of the temporary infrastructure, intertidal and subtidal

habitats are expected to return to pre-construction conditions within several months or less. For further

information regarding the Aquatic Bio-Physical Assessment, refer to Appendix B.

The following key mitigation measures will be implemented to avoid or reduce potential adverse effects to

species and habitats resulting from in- and near-water construction activities at the site and operation of the

temporary infrastructure.

• Mooring piles and piles to support the temporary trestle and access platform will be installed during

the DFO least-risk work window for Burrard Inlet (August 16–February 28). • A bubble curtain will be

installed around piles during impact-hammer pile driving.

• Underwater noise monitoring will be conducted during impact-hammer pile driving to verify that

pressure levels do not exceed 30 kPa (fish injury threshold; BC Marine and Pile Driving Contractors

Association 2003) outside of the bubble curtain.

• A marine mammal monitor will be onsite to monitor marine mammal exclusion areas during impact-

hammer pile driving: 150 m radius around piles for harbour seals; 1,000 m initial radius around piles

for cetaceans and marine mammal species at risk, adjusted to meet the 160 dB (marine mammal

behavioral disturbance threshold; National Oceanic and Atmospheric Administration [NOAA] n.d.)

based on underwater noise monitoring conducted during impact hammer pile driving. Further details

of this measure are provided in the Environmental Monitoring section below.

• Impact-hammer pile driving will be restricted to daylight hours to facilitate effective visual

monitoring of the 150-m harbor-seal zone and 1,000 m cetacean and marine mammal species at

risk zone.

• Construction crews will maintain a 100-m separation distance between the marine environment

and fuel or hazardous material storage sites, and oil change and refueling areas, unless otherwise

approved by an environmental inspector.

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• During periods of bird migration and/or during extreme weather events, bird strike warnings will be

issued to marine construction vessels with a request to reduce deck lighting.

• Project-related vessels) will travel at slow speeds (less than 10 knots) and avoid rapid acceleration

to limit the intensity of acoustic emissions (both above and below the water surface) and to

decrease the likelihood of striking marine mammals, infrastructure or other vessels.

• Appropriate erosion and sediment control measures (e.g., coir logs, erosion control matting,

sediment fence and crushed gravel) will be implemented in accordance with a site-specific erosion

and sediment control plan during near-water construction activities to limit sediment runoff into the

marine environment.

2.4.1.2 Terrestrial

A site visit was conducted on July 10, 2017 to assess existing vegetation and site characteristics. The site

substrate is entirely anthropogenic in nature. The previous tenant has removed all buildings and structures,

left some paved portions of the site and regraded the remainder of the site with ¾ inch crushed gravel. The

area that is proposed to be utilized for equipment parking and materials storage/handling has been denuded

of all vegetation by the previous tenant. A 2m wide strip of vegetation (primarily Himalayan blackberry

[Rubus armeniacus] and young cottonwood [Populus balsamifera] along the western edge of the property on

the bank upslope from Burrard Inlet will be left intact. For further details, please refer to the Terrestrial Bio-

Physical Assessment in Appendix C.

2.4.2 Desktop Review of Archaeological Potential

A desktop review of archaeological potential was conducted for the site in June 2017. The tidal and sub-

tidal (offshore) area that is to be developed for the Project has been subject to numerous dredging and

infilling activities in the past that have significantly altered native sediment and soils. As the site is entirely on

a man-man landform, it is assessed as having low potential for unrecorded archaeological sites. No further

archaeological work is recommended.

3 CONTACTS AND RESPONSIBILITIES

The successful implementation of the Project environmental program is a coordinated team effort that

includes input and review by Project Management, Project environmental team, VFPA representatives, field

staff and construction craft workers. Project personnel involved with the planning and implementation of

Project construction and the Project environmental program are provided in Table

1. Further details on the roles and responsibilities of key personnel are provided below in Section 3.1.

Table 1: Key Project Construction Personnel

Name Role Organization Phone #

Lorne Caley Project Director Kiewit 604-315-1152

Barry Pihowich Construction Manager Kiewit 780-691-4029

Andrew Allan Contractor Environmental

Manager

Kiewit 604-317-6886

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TBD Environmental Coordinator Kiewit

TBD Environment, Health and Safety

Burnaby

Trans Mountain 1-604-268-3008

TBD Environmental Inspector Trans Mountain

TBD Senior Compliance Advisor Trans Mountain

TBD Environmental Lead VFPA

3.1 Environmental Roles and Responsibilities

3.1.1 Contractor Environmental Manager

The Contractor Environmental Manager will plan, administer and authorize the use of resources to run an

effective environmental program. The Contractor Environmental Manager will be a qualified environmental

professional (R.P.Bio) and will utilize the services of the Environmental Coordinator at their discretion.

Responsibilities of the Contractor Environmental Manager include, but are not limited to the following:

Overall environmental management of the Project;

Implementation of environmental policies and procedures;

Coordinate environmental input to construction planning;

Supervise Environmental Coordinators as necessary to ensure that the environmental goals and

objectives of the Project are met in a timely and effective manner;

Communicate and train on the requirements of this CEMP to project staff and construction craft

workers;

Preparation of environmental documentation in support of environmental permitting/agency

acceptance;

Authority to stop Project work in the event of an environmental non-compliance or potential non-

compliance;

Conduct regular meetings with the construction team and Environmental Coordinator to ensure

environmental compliance;

Final review of the Construction Environmental Management Plan (CEMP) and any the

development of any revisions throughout the construction period;

Overall responsibility for effective implementation of the CEMP;

Review and quality control of material generated by the Environmental Coordinator and

environmental specialists;

Ongoing review of all environmental documentation to evaluate relevance and effectiveness;

Development and implementation of environmental training activities;

Liaise with the VFPA and other regulatory agencies on environmental matters, as required;

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Producing weekly environmental reports;

Maintaining complete inventory of all environmental records (e.g., reports, photographs, analytical

results, incident reports, etc.) relating to the environmental program;

Participate as required in community consultations on environmental matters; and,

Identification of resource requirements and project environmental budgeting.

3.1.2 Environmental Coordinator

Environmental Coordinators will verify compliance with the CEMP through surveillance (field) monitoring,

under supervision of the Environmental Manager. The Environmental Coordinator will be qualified internal

or external, 3rd party resource. The Environmental Coordinators’ duties will include, but not be limited to, the

following:

Ensuring that construction staff are aware of the environmental policies and requirements;

Verifying that all required permits, licenses, and approvals are obtained prior to the start of the

applicable construction activity;

Train field staff and construction craft workers of the implementation of mitigations measures used

to protect the environment, as require by the Environmental Manager;

Be onsite as per the schedule established by the Environmental Manager and Construction

Management prior to project start;

Advise project members if project activities have caused or are likely to cause an environmental

incident and make recommendations for corrective action;

Liaise directly with project members and provide technical advice for the purpose of resolving

situations that may impact the environment as they arise;

Reviewing the work schedule and procedures with regard to present and future construction

activities;

Regularly monitoring fuel delivery and refueling procedures;

Regularly checking all equipment and vehicles on site for hydrocarbon leaks;

Ensuring that emergency spill and fire equipment caches are adequately supplied and dated;

Checking the condition and operational efficiency of all water and sediment retention measures;

Providing technical assistance on environmental matters to the VFPA, construction staff and

regulatory agencies;

Inspecting all activities during construction, especially in-water works, to ensure compliance with

terms and conditions of this CEMP, permits and approvals and the protection of sensitive habitats;

Documenting construction activities by field notes and photographs;

Supporting the Contractor Environmental Manager in the production of weekly environmental

compliance reports;

Has the modifying or Halting work authority to ensure that appropriate mitigation measures are in

place to protect the environment; and

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Monitoring water and effluent within the project area in accordance with the Water Quality Program,

and increasing observations and/or sampling as necessary when activities occur around sensitive

areas.

3.1.3 Environmental Discipline Specialists

Specialized environmental consultants will provide environmental services as needed to support

environmental management of construction activities. It is anticipated that the following discipline

consultants may be needed to support construction of the Project:

Contaminated sites consultant (e.g., to develop a protocol for managing possible encounters with

previously unknown contamination, provide or review contaminated site assessments, coordinate

remediation, and other tasks);

Fisheries and aquatic consultant (e.g., to assess permanent and temporary impacts on aquatic

species and habitat under the Fisheries Act);

Wildlife/vegetation consultant (e.g., to provide vegetation/wildlife surveys, define special mitigation

and monitoring programs);

Archaeological/heritage consultant (e.g., to provide assessment as necessary and define

procedures in the event that previously undisclosed cultural materials are encountered during

construction);

Noise consultant (e.g., to provide specialized monitoring, noise modeling or technical information in

support of the community relations program); and

Air quality consultant (e.g., to provide air quality monitoring or prepare technical documentation

needed to resolve air quality complaints).

3.1.4 Construction Staff Responsibilities

A key component for the implementation of a successful environmental program is an understanding by field

crews and supervision of how construction activities impact the environment and mitigations measures to

reduce or eliminate those impacts. This CEMP is provides guidance to field supervision on those mitigation

efforts. Environmental responsibilities of the construction management and field supervision include:

Becoming familiar with the CEMP, aspects of their work that could have a negative impact on the

environmental and implementing appropriate mitigation measures to reduce or eliminate those

impacts;

Ensure the field staff and subcontractors are familiar with the CEMP and mitigation measures that

are to be used for the construction activities they are responsible for;

Understand the role of, and be able to take direction from the Project environmental team with

respect to environmental protection measures;

Compliance with all Project permits and approvals; and,

Report all environmental incidents, in a timely manner, to the Project environmental team and be

involved in the corrective actions to prevent re-occurrence of those incidents.

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4 RELEVANT ENVIRONMENTAL LEGISLATION

Table 2 provides a list of the relevant environmental legislation and legal requirements applicable to the

Project. This table will be revisited and updated as necessary throughout the life of the Project to capture

any changes in environmental legislation or changes in construction activities that may trigger any additional

regulatory requirements.

Table 2: Environmental Legislation and Legal Requirements

Act,

Regulation or

Bylaw

Description Applicability Approval or Permit in

Place/Forthcoming; or

Requirements Met

Federal

Fisheries Act

(FA -

administered by

Department of

Fisheries &

Oceans (DFO)

and

Environment

Canada)

The FA is the main

federal legislation

providing protection for

fish, fish habitat and

water quality in Canada.

Also, the FA also

prohibits the deposit of

deleterious substances

to water frequented by

fish.

The work requires

pile installation

below the high water

mark (HWM). Also,

stormwater will be

generated during

construction.

QEP has consulted with DFO and

has been advised to complete a

self-assessment to determine if the

Project will cause serious harm to

fish that support a commercial,

recreational or aboriginal fishery.

The QEP has also decided to

submit a Request for Review to the

DFO for this project. The QEP self-

assessment has been initiated and

can be provided to VFPA, upon

request, once completed. An

Erosion and Sediment Control Plan

that outlines the mitigation

measures that will be implemented

to prevent the release of sediment

laden water to Burrard Inlet is

provided in Section 5.6 of this

CEMP. Protection measures for

marine fish and mammals is

covered in Section 5.12 Sensitive

Habitat Features and Species of

this CEMP.

Canada

Shipping Act,

National Spill

Response

Protocol

The Canada Shipping Act

is Transport Canada’s

regulatory framework

surrounding marine

pollution and its

enforcement. In the case of

a report of pollution in the

water, including oil or fuel

spills, Canada operates

under the National Spill

Response Protocol, which

The Project has the

potential for

hydrocarbon spills to

Burrard Inlet.

An Environmental Emergency and

Spill Response Plan has been

developed for the construction

phase of the Project and is

provided in Section 6.2 of this

CEMP.

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Act,

Regulation or

Bylaw

Description Applicability Approval or Permit in

Place/Forthcoming; or

Requirements Met

specifies that the Canadian

Coast Guard is responsible

for all spill response and

recovery in the marine

environment.

Navigation

Protection Act

(NPA -

administered by

Transport

Canada)

The NPA is the main

federal legislation that

protects the public right

to free and unobstructed

passage over navigable

waters.

The Project includes

the construction of a

new trestle dock

facility and mooring

dolphins.

The project will be required to

submit a ‘Notice of Works’ to the

Navigation Protection Program

(NPP). Depending on the NPP

review, an ‘Application for Approval’

may be also required. An

‘Application for Approval’ will have

conditions that need to be followed

to ensure compliance with the

approval.

Migratory Birds

Convention Act

(MBCA)

The MBCA is the main

federal legislation that

protects migratory birds,

eggs and nests.

The work does not

require vegetation

clearing

Clearing activities will be conducted

outside on the bird breeding

season (April 1 to July 31).

Buildings to be demolished will be

surveyed for swallow nests prior to

demolition. An ongoing swallow

nesting monitoring program will be

in place throughout project

construction.

Species At Risk

Act (SARA)

SARA is in place to

prevent wildlife species

in Canada from

disappearing, to provide

for the recovery of

wildlife species that are

extirpated, endangered,

or threatened as a result

of human activity, and to

manage species of

special concern to

prevent them from

becoming endangered

or threatened.

Various construction

activities may impact

some SARA listed

species or their

habitats.

A list of SARA listed species is

provided in the Project Biophysical

Report. The risk to those species

will be evaluated and appropriate

mitigation efforts are provided in

the Project Biophysical Reports.

VFPA Non-

Road Diesel

The NRDE fee recovers

costs associated with

The NRDE Fee is

applicable to all

Responsible parties must not

introduce non-road diesel engines

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Act,

Regulation or

Bylaw

Description Applicability Approval or Permit in

Place/Forthcoming; or

Requirements Met

Emissions

(NRDE)

Regulation

managing air quality and

reducing diesel

particulate matter

emissions

parties granted the

right by VFPA to

occupy lands owned,

managed, or

administered by

VFPA.

that are “non-certified” (Tier 0) or

certified as “Tier 1” without prior

written approval from VFPA.

Provincial

Spill Reporting

Regulations of

the

Environmental

Management

Act (EMA -

administered by

the Ministry of

Environment)

The regulation

establishes a protocol

for reporting the

unauthorized release of

substances into the

environment as well as a

schedule detailing

reportable amounts for

certain substances for

sites having Provincial

jurisdiction. The same

protocol will be used for

the 2115 Commissioner

Street site (Federal

jurisdiction) with the

reports going to VFPA

Substances (e.g.,

hydrocarbons) that

may be harmful to

the environment will

be used during the

construction period

of the Project.

A comprehensive emergency and

spill response plan has been

developed for this CEMP (see

Section 6). All spills over the limits

specified in the regulation will be

reported to the VFPA

Contaminated

Sites and

Hazardous

Waste

Regulations of

the EMA

These regulations

govern the handling,

storage, transportation,

treatment and disposal

of contaminated material

and hazardous waste.

Unexpected

previously

contaminated

material may be

found within Project

boundaries.

Hazardous waste

(e.g., used oil) will be

generated during

construction.

A hazardous waste and

contaminated material

management plans are contained

within this CEMP (Sections 8 and

5.88, respectively). A BC Waste

Generator number will be obtained

for the life of construction.

Wildlife Act The Wildlife Act protects

a bird or its eggs, the

nest of eagle, peregrine

falcon, gyrfalcon,

osprey, heron or

The work does not

require vegetation

clearing

Clearing activities will be conducted

outside on the bird breeding

season (April 1 to July 31). A pre-

construction nest survey will be

conducted to determine the

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Act,

Regulation or

Bylaw

Description Applicability Approval or Permit in

Place/Forthcoming; or

Requirements Met

burrowing owl and the

nest of a bird when the

nest is occupied by a

bird or its egg.

presence of any eagle, peregrine

falcon, gyrfalcon, osprey, heron or

burrowing owl nest.

BC Heritage

Conservation

Act

The Heritage

Conservation Act

provides for the

protection of British

Columbia’s

archaeological

resources

The site is

considered to have

low archaeological

potential and

conflicts with

archaeological sites

in considered

unlikely. A Heritage

Resources

Discovery

Contingency Plan is

in place in the

unlikely event that

potential

archaeological

materials are

encountered during

construction

If additional archaeological work is

necessary, that work will conform to

the terms of the relevant Heritage

Conservation Act permit and will be

documented in the final report to be

reviewed and approved by the BC

Archaeology Branch (MFLNRO). .

Regional

Metro

Vancouver

Municipal Solid

Waste and

Recyclable

Material

Regulatory

Bylaw #181,

1996

Metro Vancouver

administers and

enforces the disposal of

solid waste and

recyclables that are

received at their transfer

stations and landfills.

The Project will be

generating solid

waste and

recyclables during

construction.

To minimize the production of solid

waste from construction, all waste

will be segregated on site and

recyclables (e.g., wood, metal, and

organic waste) will be transported

to an appropriate facility. A Waste

Management Plan is provided in

Section 8 of this CEMP.

Municipal

City of

Vancouver (CV)

Noise

Control Bylaw

1987 #6555

The CV Noise Bylaw

restricts the continuous

sound levels of

construction equipment

and the hours of

construction activities.

Heavy construction

equipment will be

used during

construction of the

Project

Construction activities will comply

with CV Noise bylaw that limits

construction activities between the

hours of 7:30 am to 8:00 pm

Monday through Friday and 10:00

am to 8:00 pm Saturday unless an

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Act,

Regulation or

Bylaw

Description Applicability Approval or Permit in

Place/Forthcoming; or

Requirements Met

exemption has been provided by

the CV.

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5 PROJECT MITIGATION MEASURES AND ENVIRONMENTAL SPECIFICATIONS

5.1 Temporary Construction Lands and Infrastructure EPP

The purpose of the Temporary Construction Lands and Infrastructure EPP is to communicate Trans

Mountain’s environmental procedures and mitigation measures to Project construction and Inspection

personnel in a clear, concise format. These potential environmental procedures and mitigation measures are

to be implemented during construction of temporary construction lands and infrastructure to avoid or reduce

potential adverse environmental effects. Specifically, the Temporary Construction Lands and Infrastructure

EPP:

• identifies mitigation measures to be implemented during development of the temporary

construction lands and infrastructure;

• provides instructions for carrying out construction activities in a manner that will avoid or reduce

adverse environmental effects; and

• serves as reference information to support decision-making and provides direction to more detailed

information (e.g., resource-specific mitigation measures, management and contingency plans).

This Temporary Construction Lands and Infrastructure EPP is intended to be a comprehensive compilation

of all environmental protection procedures, mitigation measures and monitoring commitments, as set out in

Trans Mountain’s Application, its subsequent filings, or as otherwise committed to during the NEB

proceedings. Trans Mountain confirms its intention to implement all of its commitments pursuant to NEB

Conditions 2 and 6.

5.2 General Practices

For this Project, environmental process, practice and risk management will be based on the concepts of

“avoidance of impacts”, “continual improvement” and “check and act” throughout the duration of the Project.

The first step in environmental risk management is the “avoidance of impacts” during design. Should

avoidance in design not be feasible, then a feedback loop starts and input by the environmental team is

applied in order to minimize impacts. The revisiting of these impacts at the various design stages creates an

adaptive management feedback loop aimed at “continual improvement”.

The concept of “continual improvement” requires sequencing of tasks whereby Project team members are

assigned the responsibility of “checking and acting” upon construction features that may impact the

environment. Key stages in the “check and act” portion of the process during construction are

environmental monitoring and reporting. Monitoring and reporting provides further opportunity for continual

improvement during construction where environmental mitigation measures can be revisited and refined to

provide the required environmental protection goals. Environmental monitoring and reporting identify the

mitigation/avoidance strategies to ensure that goals and objectives set out in the CEMP, VFPA permit and

applicable regulatory legislation are addressed.

Task sequencing for each stage in the process will aid in preventing lengthy delays in environmental review,

regulatory permitting, day-to-day construction activities, and subsequent cost increases (i.e., risk

management). This process facilitates environmental issue resolution while providing the mechanism for

continual improvement.

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To ensure the successful application of this procedure will depend on the execution of four general

environmental processes: planning, training, monitoring and reporting.

5.2.1 Work Plans

It is critical that environmental protection and mitigation strategies developed by the Environmental Team

are appropriately conveyed to the field staff, in a timely manner. The development of activity and or site

specific environmental protection measures in the work plans for implementation in the field is an important

step in communicating these measures to field crews. The Construction Team will develop specific

construction work plans that identify and incorporate environmental constraints, regulatory commitments and

mitigation strategies. The environmental input section is a component of the construction work plan and is a

summary of the environmental mitigation measures related to the construction work being performed.

Once the work plan is complete, it will be reviewed by the Environmental Team and site superintendent to

ensure that environmental compliance is achieved. The final version of the work plan will be presented at

the pre-activity meeting with the Environmental Team and construction staff in attendance.

5.2.2 Environmental Training

Environmental training, education and awareness of all Project personnel form the cornerstone of a strong

environmental program. The Construction Team provides training for its workers, including subcontractors

as applicable, designed to:

Increase employee awareness and appreciation of the environment and the natural resources likely

to be affected during construction activities; and

Familiarize workers with the negative impacts their actions can have on the environment and how

these can best be avoided or minimized.

The training program is intended to facilitate worker understanding of the environmental context of the

Project and clarify the role of the trainees in achieving at least minimum environmental requirements of the

Project. Training is intended to increase environmental accountability of individual workers respecting

protection of the environment; therefore environmental training is mandatory for all personnel.

The environmental training and awareness program consists of three levels, each targeting a different

audience:

Advanced Training on the CEMP conditions, VFPA Permit requirements and applicable guidelines

for construction managers as well as site supervisors;

Basic Training for all other site workers (e.g., as part of more general Site Orientation); and

Tailgate training sessions for individual crews to address specific construction methods or

environmental issues.

Records will be kept for Advanced and Basic Training that summarize the objective or purpose of the

training, the type of material covered, attendance, as well as minutes/notes where appropriate.

5.2.3 Environmental Monitoring

Environmental monitoring is a key step in environmental process and risk management for the Project. Not

only is environmental monitoring used to review, observe and report on environmental impacts resulting

from construction activities, it is also a critical tool in assessing potential risk during pre-construction

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planning. To reduce environmental risk, environmental monitoring needs to anticipate potential impacts and

identify mitigation/avoidance strategies to ensure that goals and objectives set out in the CEMP and

regulatory agency approvals are addressed during all project phases.

Monitoring of construction activities in sensitive areas or in-water works will be on a full-time basis. For the

other activities, the intensity of environmental monitoring depends upon their sensitivity and potential

impacts and will be set by the Environmental Manager in consultation with the VFPA and Construction

Management Team. For example, environmental monitoring will be on a full time basis during vegetation

clearing.

Further details on the environmental monitoring roles and responsibilities of the Contractor Environmental

Team are provided in Section 3.1 of this CEMP.

5.2.4 Environmental Reporting

A large component of the environmental management for the Project is the production of effective

environmental reports. These reports facilitate the transfer of information between the Construction Team,

VFPA, and regulatory agencies. Clear, concise reporting during all Project phases and activities will form the

basis for environmental issue identification, resolution, and compliance auditing. The Construction Team will

implement an environmental reporting structure that addresses activities during Project construction as

follows:

Environmental incident and corrective action reports for each environmental incident;

Weekly environmental monitoring reports; and,

Environmental specialist reports (e.g., noising monitoring) specific to an activity or environmental

feature.

All these reports will be submitted to the VFPA and the applicable regulatory agency(s), if required.

5.3 Site Access, Mobilization and Laydown Areas

Our mobilization plan will capitalize on existing site conditions. Minimizing impacts to permanent features

and setting up temporary facilities in strategic locations will result in a safe, efficient construction site. Three

important aspects to a successful mobilization and effective construction site are office locations, laydown

areas, and site access.

5.3.1 Site Laydown

Site laydowns will be located in areas that remain undisturbed for the majority of the project duration.

The laydown will be located at the SW portion of the site. It consists of connex storage containers, officer

trailer, lunch trailer, wash cars, and vinyl shelter. This area has suitable access for off-loading materials and

the perimeter of the property will be contained with chain link fencing for added security.

5.3.2 Site Access

Commissioner street will primary be used to gain access to both the NE and SW portion of the 2115

Commissioner Street site.

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In the NE section, the lot is primary occupied by parking stalls and temporary trestles to transport marine

workers. This site can be accessed by the man gate and double vehicle gate on Commissioner Street. The

layout and configuration of the lot is unlikely to change throughout the duration of the project.

In the SW section, the lot is primary used for equipment and material laydown combined with office site

trailers. The configuration of this area is likely to change depending on the phase of the project. A crane will

be stationed at the temporary trestle to help load and off-load material from barges. To ensure the safety

and stability of the crane, an engineered crane pad will be constructed using granular fill in area where the

crane may operate. Similar to the NE site, the lot can be accessed through the double vehicle gate and man

gate on Commissioner Street.

Access to the old wharf section located between the NE and SW sites will be restricted due to the existing

conditions. The perimeter of the site will secured with chain link fence and concrete barriers to minimize the

possibility of unauthorized access.

Figures 3a and 3b: 2115 Commissioner Street – Site Access Options

Figure 3: Site Access

5.4 Air Quality

Construction related impacts are generally of short-term duration but may still cause adverse air quality

impacts. Air pollutants generated during construction generally fall into one of two categories – airborne

dust and vehicular exhaust emissions.

Airborne and fugitive dust can be generated during dry periods and arise from disturbances of soil and

construction aggregates, vehicular traffic on temporary unpaved roads, and wind erosion of stockpiles.

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Fugitive dust and airborne particulates will be controlled and minimized by implementing best management

practices including:

Notify landowners and/or occupants of the potential to be affected by emissions from construction activities prior to commencement of these activities in proximity to lands owned by the respective landowners and/or occupants.

Restrict the duration that vehicles and equipment are allowed to sit and idle to less than 1 hour, unless air temperature is less than 0°C.

Establish speed limits, approved by Trans Mountain, on the pipeline construction footprint and

access roads. Post signs stating the applicable speed limits for construction traffic to avoid wildlife

injury and mortality, maintain soil structure and reduce dust.

Apply only water or non-toxic and non-persistent chemical products approved by an Environmental Inspector or designate to access roads for dust control at park locations or resource-specific features including agricultural crop production areas, especially berry crops.

Do not apply dust control chemicals to roads during windy conditions or within 300 m of a watercourse, wetland or lake or sensitive agricultural crops (e.g., berries, nurseries and organic farms). Dust control chemicals are to be approved by an Environmental Inspector, or designate, in advance of application.

Site Preparation

o • Grade the construction site in phases.

o • Stabilize surfaces of completed earthworks with vegetation, if appropriate.

o • Compact distributed soil.

Storage Piles and Material Handling

o Minimizing the handling of soils and aggregates (e.g., by avoiding double handling of spoil,

covering truckloads of fine-grained materials during hauling);

o Minimize generation of road dust (e.g., minimize the time that unpaved surfaces are

exposed and use watering or sweeping);

o During dry conditions and when necessary, control dust sources (e.g., minimize the time

that unpaved surfaces are exposed, water or cover potential dust sources, sweep paved

surfaces);

o As necessary, use environmentally acceptable dust suppressants, approved by the

Environmental Inspector, or water to control dust on access roads, laydown areas, work

areas, and disposal areas;

o Prefer the use of water, with consideration for water conservation, drainage and sediment

control where appropriate;

o No burning of oils, rubber, tires and any other material will not take place at the site;

o Stationary emission sources (e.g. portable diesel generators, compressors, etc.) should be

used only as necessary and turned off when not in use;

o Track out best management practices of vehicles leaving the site will be used to reduce the

dispersion materials and debris from the site;

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o Compact disturbed soils;

o Reduce activities that create fugitive dust during windy conditions;

o Manage storage piles (e.g., by shaping them, installing enclosures or coverings around

piles, conducting storage pile activities downwind of sensitive receptors);

o Control mud and dirt track-out from construction sites; and,

o Minimize drop height at material transfer locations (e.g., when loading soil onto haul trucks).

Construction equipment and processes that generally result in sizable non-fugitive emissions include drills,

excavators, crawler tractors, loaders, graders and marine vessels. BMPs that will be used to mitigate

adverse air quality effects from construction include:

Implement a vehicle/equipment anti-idling policy for construction equipment and vehicles;

Make use of legislated best available technologies and practices to reduce emissions;

Control point-source emissions e.g., by implementing applicable measures recommended by Metro

Vancouver and Fraser Health Authority;

Minimize cold starts and operate equipment at and within load tolerances and rating;

Maintain all equipment in good working order and used at optimal loads to minimize emissions; and,

Perform routine checks of the exhaust system of all equipment to identify actual or potential

deficiencies (daily visual inspection by operator, 500hr preventative maintenance performed by

maintenance department).

A qualitative air quality monitoring program (i.e., visual observation of air quality) will be implemented on an

ongoing basis to guide the implementation of BMPs and check on their success or failure. Qualitative

monitoring will focus on activities that have the greatest potential impact to air quality. All non-road diesel

equipment will be in compliance with the VFPA Non-Road Diesel Engine Regulatory Program.

5.5 Noise and Vibration

The goal of the Noise Management Program is to guide measures that minimize community impacts and

also achieve community acceptance of unavoidable demolition, construction and operational noise. An

Operational Noise Study including mitigation measures is provided in a separate report submitted to the

VFPA. Noise complaints will be handled as per the community response plan.

Project construction will primarily entail the following noise generating activities:

Sub-excavation of soils (e.g., using excavators);

Trucking of materials along haul routes to and from site;

Ground improvement pile driving (e.g., using drill rig, vibratory hammer, impact hammer),

Grading and sub-base construction (e.g., using dozers, excavators, rollers and compactors);

Some construction materials could come in by barge; and,

Local contractor adjacent to site may be used for pile driving activities and material delivery.

Mitigation measures will include the preparation and implementation of noise management procedures, best

efforts to target noise emission levels of equipment, and selection and implementation of activity and

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location specific BMPs to control demolition and construction noise emissions. Examples of key noise

mitigation measures are as follows:

Project-related vessels will be maintained in good working condition to reduce acoustic emissions (both above and below the water surface).

Use vibratory methods of pile installation, to the extent feasible (e.g., where geophysical conditions

allow). Limit in-water impact pile driving to daytime only.

Construction activities will be primarily conducted from Monday to Saturday between 7:00 am and

8:00 pm. However, some construction activities may need to be conducted outside of these hours

in which case a variance request will be made to the VFPA prior to the start of these activities;

Affected community and CV will be notified of any particular noisier activities that may be

forthcoming. These activities may need to require monitoring to ensure compliance with the local

noise bylaw;

Maintain construction equipment in good working condition;

Operate equipment at or within load tolerances and ratings;

Focus maintenance on lubrication, replacement of worn parts, exhaust deficiencies;

When practical, shut down heavy equipment not in active use;

Avoid unnecessary engine revving and use of engine brakes;

Minimize use of back-up beepers providing in compliance with WorkSafe regulations;

Select travel routes to avoid noise-sensitive receptors;

Relocate or reorient stationary equipment so as to engage natural noise screening/dampening

features;

Use special measures such as temporary noise barriers for noisier demolition and construction

activities;

Communicate with the public regarding work procedures and scheduling of noisy activities and,

Train all personnel on noise mitigation strategies within the noise mitigation plan.

5.6 Machinery and Equipment

A variety of equipment and machinery will be used on site during construction of the Project. Examples may

include crawler cranes, rubber tired loaders, bull dozers, articulated dump trucks, track and rubber tired

excavators, etc. A number of small pieces of equipment such as fork lifts, generators, pick-up trucks and

light plants will also be used during construction. A list of all equipment and machinery to be used during

construction will be provided to the VFPA prior to construction. In addition, all non-road diesel equipment

will be subject to the VFPA Non-Road Diesel Emissions (NRDE) Program which prohibits the addition of Tier

1 and older diesel engines without prior Port Authority approval. As such, the Construction Team will

complete and submit the NRDE Annual Reporting Tool for applicable equipment once construction

commences.

A small, u-dome type equipment maintenance facility will be situated within the Project boundaries. This

facility will be used for minor preventative maintenance and repairs such as oil and fluid changes, hose

changes, tire replacement, etc. All major equipment maintenance repairs will be done off site.

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The implementation of some basic mitigation measures will avoid or minimize impacts resulting from

operation and storage of equipment during construction. These include:

Inspection of all equipment prior to mobilization to site to ensure they are in good operating order

and maintained free from leaks, excess oil and grease invasive species and noxious weeds;

All equipment will undergo a preventative maintenance (PM) program Preventative maintenance is

typically scheduled for every piece of equipment on the project after a defined number of hours

(typically every 250 or 500 hours). During these “PMs” the entire equipment is thoroughly checked

and worn parts (though not defective) will be replaced. Preventative maintenance is carried out by

qualified maintenance personnel.

All construction equipment (including pick-up trucks) will have a spill containment kit onboard at all

times;

Refueling will only occur as outlined in the Fuel Management Plan in this CEMP (Section 7);

All equipment will undergo a documented daily inspection performed by the operator. These

inspections can identify potential spill sources (e.g. defective hoses or fittings) at the start of each

shift. These inspection forms are reviewed by the maintenance department and the observations by

the operator will be addressed; and,

When practical, light spill from light plants or temporary light poles will be minimized by directing

lights downward and placing task lights as close to the operation as possible.

5.7 Erosion and Sediment Control

This Erosion and Sediment Control Plan describes the general approach that will be implemented so that

water that flows, or is discharged, from construction sites complies with applicable water quality standards.

For the purpose of this plan, construction water is defined as run-off that is produced as a result of various

construction activities (e.g. from dewatering work sites, excess water from drilling and ground densification)

and surface run-off from rain events.

The details will be included in the specific Work Plans for each area and the functionality of the control plan

is confirmed by the Environmental Team during the Pre-Activity Meetings and it is the duty of Field

Supervisors to ensure the work is completed as per the plan.

Construction water emanating from the site will be monitored to confirm compliance prior to discharge to the

natural environment. Measures will be implemented onsite to remedy deficient water quality induced by

construction. The Plan also provides general and site specific measures for controlling sediment laden flows

emanating from disturbed areas or from dewatering. It focuses on prevention and correction of potential

erosion and sediment issues relating to preload and surcharge placement, vegetation removal and stripping,

grade construction, cut faces, fills, ditching, and other areas requiring temporary disturbance of potentially

erodible materials.

Construction affected surface water will meet specifications prior to discharging to the receiving waters.

Adaptive management will be used to correct measures that fail to redress water quality deficiencies. The

Construction Team’s strategy is:

Prepare site specific Sediment and Drainage Management Plans (SDMPs) in tandem with

development of Work Plans and Work Methods with input from the Environmental Team;

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Identify requirements for additional water quality monitoring prior to and during construction to

ensure preventative and mitigation measures can be taken as appropriate, to avoid impacts to water

quality;

Identify potential water quality contaminants of concern generated by construction activities and

associated preventative and mitigation measures;

Identify areas prone to sedimentation in more detailed, site specific plans or work methods, as

applicable;

Check that implemented BMPs are functioning as designed and that corrective actions are being

taken when required. BMP implementation and maintenance checks are to be conducted at least

weekly and after major rainfall events. These checks will be documented in the Weekly Monitoring

Reports;

Apply federal water quality guidelines and objectives in evaluation of the water quality samples

collected before, during and after construction;

Monitor levels of suspended sediments, using turbidity as a field measure, in accordance with

applicable water quality objectives using federal methodologies for turbidity monitoring; and,

Comply with environmental requirements and BMPs in order to avoid impacts to water quality.

5.7.1 Best Management Practices

The selection and implementation of environmental best practices will consider such factors as: the size of

work sites; activity associated with particular construction sites; proximity to environmentally sensitive

features such as fish-bearing watercourses; work site gradient; nature of disturbed soil material, predicted

discharge volumes and flow rates; and other factors. Measures will be adjusted in response to changing

conditions or to correct environmental protection deficiencies.

BMPs will be implemented mainly in the following contexts:

To manage drainage and storm flows in and around work sites;

To prevent discharge to the environment of water that may be produced as a result of various

construction activities (e.g., from dewatering work sites, excess water from drilling, etc.);

To prevent erosion at discharge points e.g., by maintaining or reducing existing flow velocities

and/or by providing dissipation measures; and

To maintain water quality and flow volume at discharge points.

5.7.1.1 Water Management

Water discharged from a construction site into watercourses, ditches or stormwater drainage systems will be

monitored to confirm that suspended solids, pH and other water quality parameters meet required

environmental performance indicators. Water quality monitoring frequency and parameters requirements will

follow the applicable permits and environmental legislation.

5.7.1.2 Erosion Prevention and Control

Best management practices for erosion prevention and control include, but are not limited to, the following:

Minimize the area disturbed by construction, e.g. by minimizing clear and grub areas;

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Minimize soil disturbance and soil compaction;

Minimize the volume of overland flow entering, or flowing through, construction areas;

Regardless of the proximity to watercourses, applicable BMPs for surface water quality and

sediment and erosion control will be implemented;

Divert surface water around disturbed construction areas, stockpiles or lay down areas. Diversion

should avoid significant alteration of pre-existing down slope drainage;

Roughen the surfaces of compacted, disturbed and exposed soils to increase infiltration to ground

and break up or slow down sheet flows (e.g., implement “cat tracking”);

Minimize soil stockpile areas and volumes, where possible, particularly during inclement weather

and/or when working in environmentally sensitive areas;

Avoid placing soil stockpiles on sloped terrain;

Stockpile soils as far away as possible from watercourses or other flowing conveyances that have

direct hydraulically connection to sensitive receiving waters;

Minimize slopes of disturbed areas and stockpiled material; maintain the natural angle of repose;

Ensure that sufficient filter cloth, rock, seed, drain rock, culverts, staking, and other materials used

for erosion prevention or control are readily available on site;

When installing or relocating utilities, minimize the length of trench exposed at any given time;

Check erosion control measures regularly (at least once a week), with frequency based on weather

conditions, risk, and sensitivity of the area, and correct deficiencies without delay;

Minimize vehicle access routes into working areas;

Discharge points have dissipation measures implemented; and,

Maintain or reduce existing flow velocities to stop erosion at discharge points, by roughening the

surface, (e.g. by placing boulders and rocks at hose outlets to disperse flow, or have hoses

discharge under water; for channel flow velocity reduction place check dams).

5.7.1.3 Sediment Control

The construction team will implement appropriate sediment controls to achieve water quality requirements

for discharge to local watercourses, drainage ditches or storm sewers. As required, guidance on sediment

control implementation will be provided by the Environmental Manager, Environmental Coordinator or other

suitably qualified personnel. Measures include, but are not limited to, the following measures:

Silt fencing around stockpiled spoils or disturbed areas as necessary;

Check-dams or gravel berms in drainage channels;

Covering erodible materials with tarp or other appropriate impervious material;

Storm drain inlet protection (e.g., using catch basin screens or filter socks);

Temporary sediment control ponds or traps, or storm water interceptors;

Undertake wheel washing primarily in centralized median locations to remove sediment from

transportation vehicles and prevent offsite tracking of sediment

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Infiltration galleries around dewatering pumps to remove sediment; and

Street sweeping to remove loose sediment from impervious or paved surfaces.

5.8 Contaminated Soil and Groundwater Management

In all situations, contaminated soil and groundwater will be handled, transported, disposed of and

documented in accordance with the provincial Environmental Management Act including the Contaminated

Sites Regulation and Hazardous Waste Regulation. A qualified environmental professional in contaminated

sites management will oversee all contaminated soil and water activities.

5.8.1 Recognition and Response

5.8.1.1 Identification of Contamination

Soil, surface water and groundwater contamination can generally be recognized by one or more of the

following:

• unusual, hydrocarbon or chemical odor;

• visual sheen;

• visual free product (oil or other product);

• visual staining. and/or

• high soil vapour concentrations.

Stop work in the immediate area where contamination is identified during the construction phase of the

Project to allow an assessment to be undertaken of the contaminated area.

5.8.1.2 Notification Framework

Upon the identification of contamination, work in the area will cease immediately and the Environmental

Inspector will be notified. The Environmental Inspector will immediately notify the Senior Compliance Advisor

of the discovery. The Senior Compliance Advisor will ensure the timely notification to the NEB and other

Appropriate Government Authorities.

A Contaminated Sites Resource Specialist with experience in contaminated sites will be contacted and

required to be present at the identification site to verify the indications of potential soil and groundwater

contamination (i.e., sheen and adjacent soil staining) and assist in monitoring and mitigation.

5.8.1.3 Health and Safety

Upon discovery of contamination, the health and safety of personnel and the public is the first priority.

Contractors and personnel on-site will suspend all work in the area, shut equipment down and immediately

notify the Construction Manager or designate and an Environmental Inspector. Appropriate personal

protective equipment, will be worn and all reasonable measures will be taken to ensure that health and

safety of anyone in the immediate area is preserved. Personnel and Contractors will employ all measures

and requirements outlined in Construction Health and Safety Management Plan as well as any other

measures or requirements.

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5.8.2 Interim Mitigation

The Environmental Inspector and Contaminated Sites Resource Specialist must be consulted when

determining the necessary mitigation measures that are to be implemented when it is safe to do so. In all

instances, the migration of the contamination from the disturbed area must be minimized. Mitigation

measures may include:

• segregating contaminated soil for later sampling and/or analysis and disposal;

• placing contaminated soil onto an impermeable surface;

• covering contaminated soil with an impermeable cover in cases where precipitation may cause

runoff;

• constructing berms to control runoff, in cases where runoff is imminent;

• stopping contaminated water discharge;

• storing contaminated water in tanks for later sampling and/or analysis and disposal; and

• if sampling is required, laboratory analytical parameters for soil and groundwater should be based

on site history and land use. Potential contaminants of concern are outlined in the Contamination

Identification and Assessment Plan (Volume 6 of the Environmental Plans).

5.8.3 Contamination Management Requirements

Excavations in which contaminated soil and/or groundwater has been discovered must not be backfilled until

authorization has been given by the Construction Manager and Environmental Inspector. Soil brought on-

site to fill excavations must be approved by the Environmental Inspector prior to use.

Contaminated soil and water must not be transported off-site or disposed of until analytical results have been

received as per applicable federal and provincial regulations and as outlined in the Contamination

Identification Assessment Plan (Section 3.0 of Volume 6 of the Environmental Plans). The Construction

Manager and the environmental Inspector will provide notification as to when excavations can be backfilled.

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Trans Mountain Expansion Project REV D September 2016/664818

5.9 Vegetation and Wildlife Management

Given the historic industrial use of the Site impacts to terrestrial habitats and wildlife are deemed to

be very low. The site is predominantly paved or graveled with sparse row of vegetation. The

terrestrial habitat biophysical assessments for the project provides further detail on the species

composition and maturity of this strip of vegetation. The following key mitigation measures will be

implemented to avoid or reduce potential adverse effects to species and habitats. These measures

include:

5.9.1 Vegetation

Keep vegetation clearing at a minimum with particular attention near watercourses and

Environmentally Sensitive Areas (ESAs);

No vegetation will be felled into a watercourse;

Stage clearing to provide maximum erosion protection while still allowing construction to

proceed.

Conduct pre-clearing surveys for any rare or sensitive species;

Prepare a clearing and grubbing plan in consultation with the Environmental Manager;

Mark the clear and grub, “No Disturbance”, and “Vegetation to Remain” boundaries on the environment construction drawings;

Flag or sign “No Disturbance” and “Vegetation to Remain” areas (e.g. 30 m buffer around designated watercourses and ESAs) in the field prior to clearing and inspect weekly;

Maintain the appropriate ESA-specific buffer zones for clear and grub around designated watercourses (30 meters) and ESAs (e.g. 30 meters for songbirds) during clear and grub activities until ready to proceed with earthwork and stabilization (i.e., staged approach);

Do not fell timber into a watercourse unless safety considerations dictate otherwise or unless

approved by Environmental Coordinator;

The Construction Team will notify the Environmental Manager upon the discovery of rare or

sensitive species – the Environmental Manager will in turn notify the VFPA;

If wood waste is stored on site, store it in a well-drained location, free of standing water, and

All invasive plant species will be disposed of in accordance with the local municipal Green

Waste Program and at a facility equipped to handle invasive plant waste.

5.9.2 Wildlife

All vegetation clearing will be conducted outside of the bird breeding season (April 1 to July

31);

Maintain all construction sites free of wildlife attractants such as food, garbage, petroleum

products or other materials with a strong odor;

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It is noted that birds may nest in construction equipment (e.g., on cranes, formwork,

machinery, temporarily stored materials and other construction infrastructure). Inspection of

work areas will occur regularly throughout the bird breeding season to identify birds

attempting to nest as early as possible. Should breeding behavior be identified, a specific

management plan will be developed by a qualified specialist and in consultation with the

VFPA and appropriate regulatory agencies to ensure compliance with the Migratory Birds

Convention Act;

Where garbage containers are required, ensure containers are inaccessible to wildlife; and,

Do not discharge concrete truck wash water directly to ground. Capture and remove wash

water for treatment and disposal at an approved offsite facility (albeit small quantities of

wash water can be treated onsite).

5.10 Marine Works

A temporary trestle dock is required to support the marine off-loading facility and laydown yard for

the project. The construction of the dock will include in-water piles to support and the temporary

trestle and engineered access ramp.

The following mitigation measures will be utilized for marine construction activities:

Conduct pile installation activities in accordance with applicable permits and/or approvals.

Use a vibratory method of pile installation preferentially over an impact hammer, where feasible, and in accordance with engineering design criteria, to reduce the intensity of underwater noise and pressure emitted to the marine environment.

Where an impact hammer is required for pile installation, deploy a bubble curtain around the full wetted length of the pile to reduce underwater noise and pressure levels.

Upon commencement of impact pile installation or recommencement of such activities after a delay of 30 minutes or more, conduct a pile installation ramp-up procedure starting with less frequent impact strikes of lower force.

Monitor underwater noise and pressure levels outside of the bubble curtain throughout impact pile driving. If monitoring indicates an exceedance of 30 kPa (≈ 209.5 dB re 1 µPa [peak]) during the DFO least risk window for Burrard Inlet (August 16 to February 28) or 22.5 kPa (≈ 207 dB re 1 µPa [peak]) outside of the DFO least risk window for Burrard Inlet (March 1 to August 15), or a fish kill is observed, stop impact pile driving immediately and review and modify methods, as appropriate, in consultation with DFO.

Prior to the commencement of impact pile driving, conduct visual monitoring (by trained, qualified personnel) for cetaceans and marine mammal species at risk within an initial marine mammal exclusion zone, set to a radius of 1 km from active locations of impact pile driving. Conduct simultaneous visual monitoring within a harbour seal-specific exclusion zone, set to a radius of 150 m. Impact pile driving may only commence if no marine mammals are observed within their respective exclusion zones for 30 minutes prior to the start of the activity. The exclusion zone for cetaceans and marine mammal species at risk will encompass the area within which underwater noise levels exceed 160 dB re: 1 µPa. Underwater noise level field verification will be conducted during the first several days of impact pile driving to define the radius of this zone.

Conduct field verification of underwater noise levels when there are changes to impact pile driving equipment (e.g., hammer size and pile size) or substantial changes to pile locations to allow for adjustments to the radius of the cetacean and marine mammal species at risk exclusion zone.

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Conduct constant visual monitoring of the marine mammal exclusion zones during impact

pile driving. If a cetacean or marine mammal species at risk, or a harbour seal, is observed

within its respective exclusion zone, temporarily suspend impact pile driving (or reschedule if

deemed necessary) until the marine mammal(s) has left the exclusion zone or does not

reappear within 30 minutes.

Pile-driving in open water will occur during the window of least risk for impacts to fish and

fish habitat (August 16 to February 28) unless previously approved by DFO (VFPA will be

notified prior to construction for any determination in this regard);

The area of pile removal will be surrounded by a containment boom during pile removal, and

an oil boom will be placed within the containment boom;

Barges or other vessels will not ground on the foreshore or river/seabed or otherwise disturb

the foreshore or river/seabed (including disturbance as a result of vessel propeller wash);

No equipment will operate on the intertidal foreshore; and

A marine based large spill clean-up kit including sufficient booms to contain a major spill will

be on site during all marine operations.

Discuss marine mammal issues that are identified during construction, with the Environmental Inspector, the Marine Resource Specialist and the appropriate regulatory authorities.

Implement marine mammal-specific mitigation measures outlined under relevant activities (e.g., impact pile installation above).

Implement the Onshore or Marine Wildlife Species of Concern and Discovery Contingency

Plan (see Appendix B of the EPP, which now also applies to marine wildlife species), in the

event of encountering a marine mammal species of concern.

Monitoring reports for in-water activities will be provided by the monitor to Environmental Manager

and forwarded onto the VFPA on a monthly basis unless noted otherwise in the Marine Mammal

Monitoring Plan.

5.11 Heritage Resources

The 2115 Commissioner Street sites have been subject to an archaeological overview assessment

(AOA). Results of the AOA concluded that there is no need for further archaeological surveys at

these sites. Provincial Heritage Register indicates there are no known archaeological sites within the

proposed boundaries of the temporary construction lands and infrastructure sites.

A desktop review of archaeological potential has been conducted to evaluate the archaeological

potential of the proposed site and to provide recommendations regarding the appropriate scope of

further archaeological work.

The desktop review concluded that as the site is entirely on a man-made landform, it has low

potential for unrecorded archaeological sites and no further work is recommended.

The general strategy for managing potential discovery of Heritage Resources includes:

Pre-construction desktop review of archaeological potential;

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Targeted delivery of training in archaeological material recognition; and

Implementation of a Heritage Resources Discovery Contingency Plan to manage possible

chance finds.

5.11.1 Archaeological Training

Archaeological education and awareness includes training in how to recognize cultural materials

(e.g., artifacts, burial sites) and how to implement the Heritage Resources Discovery Contingency

Plan that has been developed to manage possible encounters with archaeological materials during

construction. The protocol includes procedures for stopping work and notifying supervisory

personnel in the event suspicious materials are encountered.

The archaeological training program includes two main components. Basic training on Project

obligations respecting archaeological management will be delivered to all construction personnel as

part of the basic site orientation. The basic training will be designed to deliver awareness that

Heritage Resources are protected under provincial legislation (Heritage Conservation Act) and these

may be encountered during construction. Specialized Training will be delivered by qualified

archeologist to construction personnel who are about to construct in areas that have high potential

for encountering archaeological materials. The training will focus on site recognition and on the

Heritage Resources Discovery Contingency Plan that will be implemented in the event previously

unknown or undisclosed archaeological resources are discovered during the course of the work.

5.11.2 Heritage Resources Discovery Contingency Plan

The following procedure will be implemented to manage possible encounters with previously unknown or undisclosed Heritage Resources.

In the event that suspected heritage resource sites are discovered during construction, implement the measures listed below.

Prohibit the collection of any historical, archaeological or paleontological resources by Project personnel except for qualified Heritage Resource Specialists acting as authorized by the appropriate regulator/permit.

Suspend work immediately in the vicinity (i.e., within 30 m) of any newly identified archaeological, paleontological or historical resource sites (e.g., modified bone, pottery fragments and fossils). Work at that location may not resume until the measures below are implemented. Clearly mark the site using fencing and flagging to secure avoidance where appropriate.

Notify the Environmental Coordinator, who will notify the Construction Manager, the Contractor Environmental Manager, the Heritage Resource Specialist and, if warranted, the local police and appropriate government authority.

As and where required, a qualified Heritage Resource Specialist will develop, if warranted, an appropriate mitigation plan in consultation with the Contractor, Environmental Inspector, the Construction Manager, the appropriate government authority, as well as the applicable Aboriginal communities. The mitigation measure options available include those measures

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for site avoidance, systematic data recovery and monitoring/surveillance as described above.

5.11.2.1 Human Remains Discovered During Construction

In the event that suspected human remains are discovered during construction, implement the mitigation measures listed below.

Suspend work immediately in the vicinity of the newly identified human remains. Work at that location may not resume until the measures below have been implemented.

Notify the Environmental Coordinator, who will notify the Construction Manager, the Contractor Environmental Manager, the Heritage Resource Specialist and, if warranted, the local police and appropriate government authority.

If there is potential for disturbance to the site due to trafficability or high public visibility, assign employees to stand watch until the local police and Heritage Resource Specialist arrives.

Stake or flag off the location to secure avoidance.

Cover any exposed remains with clean plastic sheeting, tarpaulin, blanket or other covering until the local police and Heritage Resource Specialist is present.

Do not backfill. If excavated fill has been loaded into a truck, empty the excavated fill at a nearby secure location for the local police and Heritage Resource Specialist to inspect.

Work will only resume in that area once the archaeological and forensic studies are complete, clearance has been granted by the local police and appropriate government authority, and direction has been advised that work can continue.

5.12 Sensitive Habitat Features and Species

5.12.1 Species at Risk

The aquatic biophysical survey report indicated that site conditions within the assessment area are

not considered conducive to the presence of federally or provincially listed species at risk. The only

listed species with the potential to occur at the Project location is northern abalone Northern abalone

(provincially Red-listed; designated Threatened by COSEWIC, 2000; designated Threatened under

SARA Schedule 1, 2003) occurs in rocky habitats from the low intertidal to 100 m below sea level but

is usually found in water less than 10 m deep. In BC, northern abalone distribution is patchy and

typically located along open coastline. This species was not detected during either survey. The

probability of this species occurring at the Project location is considered low due to the protected

nature of the area under the wharf.

The terrestrial biophysical survey report concluded the site conditions are not conducive to use by

federally or provincially listed species at risk within the Assessment Area.

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5.12.2 Mitigation Measures

Burrard Inlet is considered sensitive habitat features that has the potential to be impacted during

construction. Mitigation measures related to the protection of riparian habitat, terrestrial habitat and

the prevention of off-site migration of sediment laden run-off to these features with provided the

Vegetation and Wildlife Management and Erosion and Sediment Control the sections in this CEMP

(Sections 5.8 and 5.6, respectively). The following mitigation measures will also be employed:

Verify that mitigation measures associated with onshore and marine wildlife species at risk

are communicated to Project personnel.

Report sightings of sensitive species or species at risk immediately to the Environmental

Inspector. Implement the Wildlife Species of Concern and Discovery Contingency Plan, as

appropriate. The Environmental Inspector will record the location in the daily reports.

Discuss marine fish and fish habitat issues that are identified during construction with the

Environmental Inspector, the Marine Resource Specialist and the appropriate regulatory

authorities.

Barges will be anchored or spudded in appropriate areas where potential for effects to

intertidal and subtidal marine habitats is limited. Grounding is prohibited, unless authorized

by VFPA. Avoid sensitive marine habitats, where feasible.

Have the Environmental Inspector report immediately to DFO if the extent or nature of permanent alteration or

destruction of fish habitat during any marine construction phase is outside of the scope defined in permits and

approvals or if there is an occurrence of unpermitted serious harm to fish, or an increase in the risk of serious

harm to fish.

6 EMERGENCY RESPONSE

The Marine Spill Contingency Plan has been prepared for construction activities being completed at

the 2115 Commissioner Street Sites. This plan demonstrates that KLTP has appropriate response

capabilities and measures in place to effectively address potential releases during construction at the

2115 Commissioner Street Sites.

6.1 Purpose and Scope

Spill reporting procedures are applicable to all Trans Mountain construction activities. These

procedures are specific to the 2115 Commissioner Street Sites and will be followed in the event of a

spill or release, within this facility or contamination of coastal waters during construction activities

associated with the Project.

The purpose of this plan is to provide direction on how to quickly, safely and effectively respond to a

construction phase marine spill at the 2115 Commissioner Street Sites to allow for the protection of

the public, employees and Contractors, the environment and company property. In addition, this plan

will facilitate the reporting of releases of hazardous materials to the appropriate authority, as

required. As a federally regulated company, Trans Mountain is responsible for reporting any volume

of spill at the 2115 Commissioner Street Sites to the NEB. This Marine Spill Contingency Plan

identifies the lines of authority and responsibility, establishes proper reporting and communication

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procedures and outlines an action plan, to be implemented in the event of a marine spill. This Marine

Spill Contingency Plan applies to fuel, hydrocarbons, chemicals and other potentially harmful

substance released at the 2115 Commissioner Street sites.

Construction-specific activities may result in spills, such as:

• spills from on-land construction vehicles/equipment that drain into the ocean;

• spills from vessels engaged in construction activities (e.g., tugs and workboats); and

• spills from construction equipment on barges (e.g., pile drivers).

6.2 Response Organization

Spills into or threatening a body of water are considered reportable through the Emergency

Response Line process, as a reportable incident, to the Senior Compliance Advisor. The Senior

Compliance Advisor must report any incident of a spill or release at the 2115 Commissioner Street

Sites directly to the NEB, as soon as practical, and take appropriate measures to remediate the

contamination. The NEB also requires notification of the contamination, in writing, to the Secretary of

the Board (NEB 2011).

Emergency spill response equipment will be located, as a responsibility of the contractor, in the

TMEP 2115 Commissioner Street Sites Oil Spill Containment and Recovery location. The location

and contents of the emergency spill response equipment will be discussed intermittently during daily

safety meetings. Further information regarding this equipment can be obtained from the Contractor.

Prompt notification of a spill to the 2115 Commissioner Street Sites Supervisor is crucial. Contact

local emergency response providers in the event of a spill involving danger to human life. For marine

pollutant or spills in Vancouver harbour, call Vancouver Traffic VHF 12/11/74/16 immediately.

For a spill to the marine environment, immediate notification to Canadian Coast Guard Marine

Communications and Traffic Services (MCTS) is required (see http://www.ccg-gcc.gc.ca/e0003876).

All accidental over side discharges should be reported immediately to the Operations Centre (1-604-

6659086).

If the discharges contain oil or other deleterious substances, the vessel must immediately notify the

MCTS and activate its pollution response plan. The Port Information Guide (VFPA 2016) provides

more information and clarification regarding reporting requirements (see

http://www.portvancouver.com/wp-content/uploads/2015/03/Port-Information-Guide-12-Port-

ofVancouver-August-2016-amended.pdf).

6.3 Contractor Responsibilities

KLTP will be responsible for prevention, preparedness, response and reporting on their work sites

during the construction phase of the Project. KLTP will maintain an up-to-date inventory and location

knowledge of response materials at the worksite. KLTP will provide training, prior to work, and

implement regular emergency response exercises to enable workers and subcontractors to perform

their designated emergency responsibilities. It will be KLTP’s responsibility to immediately inform the

Site Supervisor, Contractor Environmental Manager, VFPA Environmental Lead, Environmental

Inspector, TMEP management and the Senior Compliance Advisor in the event of a spill or release.

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6.4 Equipment

Emergency response equipment and materials will be stored on-site, as close to the area of work as

feasible. These materials will include, but are not be limited to: booms; skimmers and other collection

devices; sea-water pumps; hoses; sorbents; fire nozzles; containment vessels; spill kits; and

personal protective equipment. Any concerns regarding additional response equipment should be

directed to the 2115 Commissioner Street Sites Supervisor, who will be able to source

supplementary equipment through local service providers in the area.

6.5 Initial Assessment

In the event of any incident, the location and circumstances will be assessed to determine the safety

hazards, human and environmental resources at risk of adverse effect and potential of the incident

escalating into a greater incident. This assessment will be conducted by the Environmental Inspector

or the Site Supervisor, depending on the circumstances. The priorities of the Environmental

Inspector in the event of a release incident are to:

• protect people and environment;

• stop the source, if safe to do so; and

• contain the release.

6.6 Recovery

After the initial assessment is complete, recovery of free product or materials with high

concentrations of spilled product should be performed as soon as feasible to reduce the extent of

effects to the shoreline, sediment and water.

6.7 Detailed Assessment

After the initial assessment and recovery activities are complete, a detailed assessment of effects

resulting from the spill is required. This assessment will: investigate the effects to the shoreline,

sediment, water and wildlife in detail; provide comparisons of concentrations of parameters of

concern with applicable guideline concentrations; and provide recommendations for remedial

activities, if warranted.

6.8 Remediation

Remedial activities recommended in the detailed assessment should be implemented as soon as

feasible following the spill to bring sediment and water conditions into compliance with regulations.

Long-term monitoring may be required as a result of certain spills. A remediation report is required to

be submitted to the appropriate bodies.

6.9 Closure

Once the site has been brought back into compliance with applicable regulations and monitoring

activities are complete, a closure report is required to be submitted to the appropriate bodies.

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6.10 Emergency Communication

Emergency communication is outlined in the Project Communication Plan. It is important to note that

quick and clear communication is essential to minimize potential impacts to workers, the public,

property and the environment in emergency situations. The VFPA will be contacted for any release

of a dangerous goods (as defined in the BC Spill Reporting Regulation) to water or any amount to

land that is over the volume for the listed in the Schedule of the BC Spill Reporting Regulations. In

addition, the Canadian Coast Guard will be contacted for any spill of hazardous material to Burrard

Inlet. The phone numbers of key emergency responders are provided in Table 3.

Table 3: Key Emergency Contact Phone Numbers

Authority/Company Name Phone Number

Emergency Services 911

VFPA Operations Centre 604-665-9086

Local Non-emergency police 604-985-1311

Local Non-emergency fire 604-980-5021

Vancouver General Hospital 604-875-4111

Emergency Management BC (formerly PEP) 1-800-663-3456

DFO Radio Room 604-666-3500

Canadian Coast Guard 604-775-8881

Tri-Arrow Industrial Recovery Inc. (3rd party spill response) 604-682-2751

HazCo Emergency Response (3rd party spill response) 1-800-667-0444

Safety-Kleen Emergency Response (3rd party spill response) 1-888-375-5336

7 FUEL MANAGEMENT PLAN

7.1 Refueling Procedures

The following best management practices will be following for all refueling operations. All

construction personnel involved with refueling will undergo specific training on these practices.

7.1.1 Onshore Works

General measures include:

Deliver fuel to construction site by approved mobile refueling tanks (either to on-site refueling

tanks or directly into the equipment);

All dispensing or transferring of fuel will be attended for the duration of the operation;

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The attendant will be trained in fueling procedure;

Refuel excavators and other large tank capacity machines away from a water body and

other ESAs (minimum 100 m unless otherwise reviewed and accepted by the Environmental

Inspector);

When transferring fuel from mobile tank to large machines, place sorbent material around

the fuel inlet prior to dispensing, and use pumping equipment, an approved hose and top-fill

nozzle;

Verify that there is a proper connection between the fuel fill hose and the fill pipe of the tank,

mobile refueling tank or the equipment being filled, and verify that the fill valve is open;

Do not overflow the receiving tank;

While refueling, suspend operation of moving equipment in the immediate vicinity of the

refueling; and,

Maintain regular inspections of fuel systems and their components (check for leakage,

deterioration or damage).

7.1.2 Refueling Marine Equipment

Refueling procedures specific to marine based equipment used for construction of the piles

and wharf structure will be developed and provided by the marine subcontractor(s) as part of

marine Work Methods.

7.1.3 Jerricans

Smaller equipment can be refueled using CSA approved jerrican(s); and,

When not in use, jerricans should be placed in portable secondary containment rather than

placed directly on the ground;

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8 WASTE MANAGEMENT PLAN

The Plan has been prepared to provide guidelines for dealing with the generation of Project waste,

and to provide guidelines for dealing with the procurement, storing and handling of hazardous

materials and chemicals required for the Project.

This Plan outlines specific measures to be followed by all employees and contractors involved with

the construction of the Project. The Plan is designed to ensure that chemicals and wastes are

procured, handled, stored and disposed of in an environmentally responsible manner, thereby

maintaining ecological and cultural integrity. This Plan will reduce the likelihood of an accidental

release of potentially hazardous waste products into the environment during construction.

This Plan applies to all employees, contractors and consultants who conduct work on during

construction of the Project. All employees, contractors and consultants will abide by all federal,

provincial and local requirements for the storage, handling, transport, disposal and release reporting

requirements of all products and waste materials that are potentially hazardous to human health and

the environment.

The Contractor Environmental Manager Environmental Inspector are responsible for ensuring

compliance with Trans Mountain’s Environmental Guidelines and all applicable codes, regulations

and industry standards for waste management and handling chemicals. Where a discrepancy

occurs, the most stringent requirements apply. In the event of a release (i.e., spill), the Spill

Contingency Plan (see Appendix B of the Pipeline EPP) will be implemented. The Spill Contingency

Plan sets forth the lines of communication and procedures to follow in order to facilitate containment

and clean-up should a release occur.

8.1 Guiding Principles

KLTP and Trans Mountain are committed to performing its activities in an environmentally

responsible manner. The following general guiding principles have been incorporated into this plan:

reasonable preventative measures will be taken to avoid the release of wastes and

hazardous materials into the environment;

all waste and hazardous material releases must be reported to the Environmental Inspector,

and to the appropriate authorities, if warranted;

all waste and hazardous material releases will be cleaned up promptly and thoroughly; and

waste and hazardous materials will, to the extent feasible, be recycled, disposed of or

moved to an approved area as required.

8.2 WASTE CHARACTERIZATION

The starting point for effective waste management begins with accurate waste classification. Potential project related wastes have been divided into two categories, namely hazardous waste and non-hazardous waste, for discussion of storage, handling and disposal procedures. Waste characterization should follow the proper guidelines (e.g. BC Hazardous Waste Legislation Guide) and ensure compliance with proper transportation and disposal procedures.

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Nonhazardous Wastes – include garbage and debris generated through the activities of personnel during construction and construction footprint reclamation that are nontoxic in nature and can be disposed in approved industrial landfills or solid waste landfills (non-secure landfills in BC). These include, but are not necessarily limited to:

food wastes on footprint, office areas and camps;

camp black and grey water;

recyclable materials (e.g., paper, tin);

pipe tape and coating;

spent welding rods;

pipe end shavings;

grinder pads;

styrofoam and plastics;

wood (e.g., skids, survey stakes);

wire;

cut and collected invasive plants;

flagging tape;

used geotextile;

construction and demolition debris;

contaminated soil (below the acceptable limit); and

metal strapping.

Hazardous Wastes – wastes with any of the properties described in Schedule 1 but does not include those wastes defined in the BC Hazardous Waste Regulation. Generally speaking, hazardous waste include wastes and products generated or used during construction that may contain toxic substances in the form of residues. These wastes have to be disposed in approved secure landfills in BC. These include, but are not necessarily limited to:

used lube filters;

spent grease cartridges;

Naturally Occurring Radioactive Materials (NORMs) (e.g., radon);

spent cleaning products and associated materials (e.g., rags);

used batteries (i.e., automotive or equipment);

herbicides, pesticides and their containers;

de-icers;

fuels (gasoline, diesel, propane);

used oils and lubricants (e.g., engine oil, transmission/drive train oil, hydraulic oil, gear oil, lubricating grease);

used antifreeze/coolants (i.e., containers/cans of ethylene glycol, propylene glycol);

paints and solvents, brushes with residues of these materials;

Polychlorinated Biphenyl (PCB); and

glues (including epoxy and urethane coating products) and cements

8.3 PREVENTION AND MITIGATIVE MEASURES

All employees, contractors and consultants of Trans Mountain will be required to comply with applicable regulations for the containment, handling, storage, use and disposal of wastes and chemicals. The following are minimum requirements.

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8.3.1 General Requirements

Following are some of the guidelines for hazardous waste storage (Hazardous Waste Storage Guidelines, AEP 1988; Hazardous Waste Legislation Guide, BCMOE 2016)

1. Siting requirements for construction yards and staging areas that are designated as hazardous waste storage areas:

The facility shall be readily accessible for fire-fighting and other emergency procedures.

The location is not subject to flooding caused by a 24 hour, 10 year storm.

The location shall be chosen to minimize the potential for environmental damage, including any threats to the quality of surface water and groundwater, and to the health of humans, animals and plants from the normal operation of the facility and from any other causes.

2. Safety requirements for hazardous wastes storage areas

A storage facility for hazard waste shall be designed, constructed and operated such that it complies with the requirements stipulated in the provincial occupational health and safety (OHS) legislation and the Canada Labour Code.

A storage facility for hazardous waste shall comply with the requirement for safety equipment stipulated by the regulations (e.g. Alberta Fire Code under the Fire Prevention Act).

Access to a hazardous waste storage facility shall be limited to employees who have been trained in respect of normal and emergency procedure.

A storage facility shall have signage indicating that hazardous wastes are stored therein.

Incompatible waste must be stored in such a manner that contact in the event of an accidental release is not possible.

3. Operational requirements for hazardous wastes storage areas:

Secondary containment must meet regulatory requirements

Ventilation rate must meet regulatory requirements

4. The KLTP will register with the appropriate provincial government department with respect to hazardous materials (to obtain a hazardous waste generator number or equivalent) and shall, at that time, provide detailed manifest information regarding the location of the staging areas, the types of waste that will be produced, and the transport vehicles that will be collecting the waste for disposal.

8.3.2 Training

1. All Project staff with waste management and hazardous materials responsibilities will be educated in accordance with regulatory requirements specific to the Project. All personnel shall understand their responsibilities for proper handling, identification, documentation and storage of wastes and hazardous materials.

2. All Project staff will possess valid WHMIS training [Section 7.0 General Pipeline Construction Mitigation Measures].

3. All fuel truck drivers, and drivers transporting waste or chemicals will have current Transportation of Dangerous Goods (TDG) certification.

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8.3.3 Non-Hazardous Wastes (including Camp Wastes)

1. An appropriate number and gender of portable toilets shall be made available to ensure each crew has ready access to washroom facilities. The number of toilet facilities will meet regulatory requirements. Generally speaking, the number of toilets is depending on the number of employee for that sex. The facilities will be serviced and cleaned regularly and will be adequately secured. All site personnel are to use portable toilets as provided. Sewage and greywater will be hauled to approved facilities for disposal [Section 7.0 General Pipeline Construction Mitigation Measures].

2. An appropriate number of waste and recycling receptacles will be made available during construction. Each construction site will be equipped with adequate garbage receptacles for solid non-hazardous wastes and debris. All garbage and food waste will be regularly transported to the nearest bear-proof transfer station or landfill for proper disposal.

3. While working on organic farms, waste containers will accompany each working unit.

4. Secured non-hazardous materials (e.g., skids, geotextiles, survey stakes) that pose no threat to the surrounding ecosystem will be neatly stockpiled in locations along the right-of-way for disposal. The disposal frequency is dependent upon the type of material stockpiled and the plan for storage will be approved by the Waste Management Coordinator.

5. All garbage will be stored in wildlife-proof containers when potential wildlife/human conflicts may occur [Section 7.0 General Pipeline Construction Mitigation Measures].

8.3.4 Hazardous Waste and Chemical Handling

1. During waste and chemical handling activities, employees and/or contractors will use appropriate personal protective equipment to prevent any contact with material.

2. Procedures for safe loading and unloading of products will be followed:

service vehicles will be equipped with automatic shut-off valves;

brakes will be set;

the vehicle will be grounded if the product is flammable;

the operator will observe loading and unloading activities at all times; and

when complete, the operator will examine all outlets for leakage and take corrective action if warranted.

3. Material Safety Data Sheets (MSDS) will be kept onsite for all chemicals handled.

8.3.5 Hazardous Waste and Chemical Storage

1. While working on organic farms, hazardous waste containers will accompany each working unit.

2. Designated hazardous waste storage areas at a facility shall be designed to meet all applicable federal and provincial regulations.

3. Hazardous materials will be stored in designated storage area(s). Short-term hazardous material storage on the pipeline construction footprint may be designated with approval of the Environmental Inspector, if required for specific tasks.

4. Hazardous materials wastes will be stored greater than 100 m from a wetland, watercourse or waterbody, where feasible.

5. Designated storage areas will be clearly identified and secured. Waste stored in any containers must be clearly labelled to comply with the TDG Act and WHMIS regulations.

6. Hazardous wastes will be separated by type.

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7. Secondary containment may be required depending on the location, type, volume and duration of the waste or chemical being stored. Secondary containment will be in accordance with applicable federal, provincial and municipal requirements.

8. Containment devices will be constructed from suitable metallic or non-metallic materials capable of containing the stored product. Liners used for secondary containment shall be placed and maintained to ensure their effectiveness and intended use.

9. Secondary containment areas not protected from the elements will be monitored regularly to ensure that ice, snow, or rainwater have not decreased the volumetric capacity for storage of a release to be less than 110% of the aggregate storage volume of the containment area. Water accumulated within a secondary containment structure may be removed if authorized by the Environmental Inspector. If there is visible hydrocarbon sheen, the water will be collected for proper storage and disposal.

10. Containers and tanks will be closed when not in use. Drain valves will be locked to prevent accidental or unauthorized releases.

11. Visually inspect fuel tanks on a regular basis as well as when the tank is refilled. Maintain inspection records for each tank, where warranted. Take remedial action as soon as a crack, dent or leak is detected [Section 7.0 General Pipeline Construction Mitigation Measures]

12. The Contractor will remove all secondary containment structures at the end of the construction phase, and return the impoundment area to its original contours and appearance, including establishing appropriate drainage patterns and vegetation cover.

8.3.6 Waste Disposal

1. All waste materials will be disposed of in accordance with federal and provincial legislation and municipal/regional regulations as required.

2. The Contractor will plan for disposal and will obtain approval and liaise with the Waste Management Coordinator for use of pre-approved waste facilities and to determine options for Project-related waste disposal.

3. Waste disposal facilities are audited on a regular basis to ensure environmental, regulatory, and financial compliance. Only approved facilities are permitted to accept waste. Solid non- hazardous wastes and debris will be collected as required and disposed of at approved locations.

4. Used oil and oil filters will be placed in sealed containers and delivered for disposal by a qualified service contractor.

5. Receptacles for recycling various products (e.g., paper and tin) will be available at Project construction yards and camps and will be hauled to appropriate recycling depots.

6. NORMs will be transferred to approved locations by a qualified contractor for final disposal.

7. Facilities for disposal or treatment of PCB must be pre-approved by Trans Mountain. This includes third party waste brokers, consultants and contractors. PCB concentration must be thoroughly characterized prior to special treatment or disposal.

8.3.7 Documentation and Record Keeping

1. MSDSs will be available for each product stored at a particular construction yard or staging area. Copies will be provided to the Lead Environmental Inspector and Waste Management Coordinator.

2. The Contractor will maintain a record of the routine inspections performed on the industrial

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waste storage area(s). The Contractor will provide these records for the construction office with any and all inspection reports monthly and will forward these to the Waste Management Coordinator.

3. Provincial manifest will be reviewed by an authorized Trans Mountain representative with current TDG certification when waste is transferred from a temporary storage facility for transport to a final disposal location. In Alberta, the generator must complete Part A, the carrier complete Part B, and the receiver complete Part C of the manifest.

4. The Waste Management Coordinator will be provided with copies of waste manifests. Provincial manifest records must be reconciled within six weeks of initial shipment date. Until notification that the waste has been received at its final disposal location, the waste is the responsibility of Trans Mountain.

5. Copies of manifest records must be kept in a central location for a minimum of two years after the waste has arrived at its final disposal location.

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H-1 APPENDIX A

EMERGENCY CONTACTS

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TABLE A-1

EMERGENCY CONTACTS

Contact Location Phone Number FEDERAL NEB Canada 1-800-899-1265 Department of Fisheries and Oceans Observe, Record and Report Hotline

Alberta and BC 1-800-465-4336

ALBERTA RCMP/Police

Edmonton Stony Plain Edson Hinton

911 or 1-780-412-5424 1-780-968-7200 1-780-723-8822 1-780-865-2455

Alberta Health Services: Emergency Medical Services (Ambulance)

Gateway EMS Station (Edmonton) West View Health Centre (Stony Plain) Edson Healthcare Centre (Edson) Hinton Healthcare Centre (Hinton)

911 or 1-780-342-1172 1-780-968-3600 1-780-723-3331 1-780-865-3333

Hospital/Clinic University of Alberta Hospital (Edmonton) Royal Alexandra Hospital (Edmonton) West View Health Centre (Stony Plain) Edson Healthcare Centre (Edson) Hinton Healthcare Centre (Hinton)

1-780-407-8822 1-780-735-4111 1-780-968-3600 1-780-723-3331 1-780-865-3333

Fire Edmonton Stony Plain Edson Hinton

911 or 311 1-780-442-5445 1-780-963-3551 1-780-723-3178 1-780-865-6020

AER 24-hour Emergency Line Energy/Environmental Emergency & Operational Complaint Number

1-800-222-6514

Alberta Environment and Parks- 24-Hr Emergency Hotline Edmonton 1-800-222-6514 WCSS Oil Spill Co-operative – 24-Hr Emergency Alberta 1-866-541-8888

Forest Fires Alberta 310-FIRE (3473) Trans Mountain – Environmental, Health and Safety Management System (EHS)

Edmonton 1-780-449-5903

Trans Mountain Operations Supervisor Stoney Plain/Edmonton 1-780-449-5980 Trans Mountain – 24-hour Emergency Line Alberta 1-888-876-6711 BC RCMP/Police

Valemount Clearwater Barriere Kamloops Merritt Hope Abbotsford Burnaby

911 or 1-250-566-9800 1-250-674-2237 1-250-672-9918 1-250-828-3000 1-250-378-4262 1-604-869-7750 1-604-859-5225 1-604-294-7922

Emergency Medical Services (Ambulance) Valemount Clearwater Barriere Kamloops Merritt Hope Abbotsford Burnaby

911 or 1-250-566-4703 1-250-674-3344 1-250-672-9244 1-250-828-4770 1-250-378-5912 1-604-869-5112 1-800-461-9911 1-604-872-5151

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TABLE A-1 Cont'd

Contact Location Phone Number Hospital/Clinic Valemount Health Centre (Valemount)

Dr. Helmcken Memorial Hospital (Clearwater) Barriere Community Health Centre (Barriere) Royal Inland Hospital (Kamloops) Nicola Valley Health Centre (Merritt) Fraser Canyon Hospital (Hope) Abbotsford Regional Hospital (Abbotsford) Burnaby Hospital (Burnaby)

1-250-566-9138 1-250-674-2244 1-250-672-9731 1-250-374-5111 1-250-378-2242 1-604-860-7732 1 604-851-4700 1-604-434-4211

Fire Valemount Clearwater Barriere Kamloops Merritt Hope Abbotsford Burnaby

911 1-250-566-9800 1-250-674-3733 1-250-672-9711 1-250-372-5131 1-250-378-5626 1-604-869-5671 1-604-853-3566 1-604-294-7190

BC MOE 24-hour Spill Line BC 1-800-663-3456 BC MOE Spill Response BC 1-877-952-7277 BC OGC 24-hour Incident Reporting BC 1-800-663-3456 Conservation Officer Service BC 1-250-356-7669 WCSS Oil Spill Co-operative – 24-hour Emergency BC 1-866-541-8888 Forest Fires BC Forest Fires Reporting Centre 1-800-663-5555 Trans Mountain – EHS Burnaby 1-604-268-3008 Trans Mountain – EHS (Kamloops) Kamloops 1-250-371-4017 Trans Mountain Operations Supervisor Burnaby 1-604-268-3040 Trans Mountain Operations Supervisor Sumas 1-604-268-3080 Trans Mountain Operations Supervisor Kamloops 1-604-268-4040 Trans Mountain Operations Supervisor Clearwater 1-250-587-6350 Trans Mountain – 24-hour Emergency Line BC 1-888-876-6711

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H-1 APPENDIX B

CONTINGENCY PLANS

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TABLE OF CONTENTS

Page 1.0 CONTAMINATION DISCOVERY CONTINGENCY PLAN ...........................................................B-3

1.1 Pre-Job Planning ..............................................................................................................B-3 2.0 FIRE CONTINGENCY PLAN ........................................................................................................B-5 3.0 FLOOD AND EXCESSIVE FLOW CONTINGENCY PLAN ..........................................................B-6 4.0 HERITAGE RESOURCES DISCOVERY CONTINGENCY PLAN ...............................................B-7 5.0 RARE ECOLOGICAL COMMUNITIES OR RARE PLANT SPECIES DISCOVERY

CONTINGENCY PLAN .................................................................................................................B-9 6.0 SOIL EROSION AND SEDIMENT CONTROL CONTINGENCY PLAN .....................................B-10 7.0 SOIL HANDLING CONTINGENCY PLAN ..................................................................................B-13 8.0 SOIL/SOD PULVERIZATION CONTINGENCY PLAN ...............................................................B-14 9.0 SPILL CONTINGENCY PLAN ....................................................................................................B-15

9.1 Introduction ....................................................................................................................B-15 9.2 General Measures..........................................................................................................B-16 9.3 Initial Response ..............................................................................................................B-16 9.4 General Spill Containment Procedures..........................................................................B-17

10.0 TRADITIONAL LAND USE SITES DISCOVERY CONTINGENCY PLAN .................................B-19 10.1 Traditional Land Use Sites Identified Prior to Construction ...........................................B-19 10.2 Traditional Land Use Sites Discovered During Construction .........................................B-21

11.0 WET/THAWED SOILS CONTINGENCY PLAN ..........................................................................B-22 12.0 WILDLIFE SPECIES OF CONCERN ENCOUNTER AND DISCOVERY CONTINGENCY

PLAN ...........................................................................................................................................B-24

LIST OF ATTACHMENTS Attachment B1 Spill Scene Checklist......................................................................................................B1-1

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1.0 CONTAMINATION DISCOVERY CONTINGENCY PLAN 1.1 Pre-Job Planning

A list of areas with moderate to high potential risk for contamination is provided in the Contamination Identification and Assessment Plan (Section 3.0 of Volume 6 of the Environmental Plans). In accordance with the Contamination Identification and Assessment Plan, a Contamination Resource Specialist will ensure the appropriate response and mitigation is carried out during construction in the identified 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 that unexpected contamination is encountered, this Contamination Discovery Contingency Plan will be initiated.

Recognition and Response

Identification of Contamination Soil, surface water and groundwater contamination can generally be recognized by one or more of the following:

• unusual, hydrocarbon or chemical odor;

• visual sheen;

• visual free product (oil or other product);

• visual staining. and/or

• high soil vapour concentrations.

Stop work in the immediate area where contamination is identified during the construction phase of the Project to allow an assessment to be undertaken of the contaminated area.

Notification Framework Upon the identification of contamination, work in the area will cease immediately and the Environmental Inspector will be notified. The Environmental Inspector will immediately notify the Senior Compliance Advisor of the discovery. The Senior Compliance Advisor will ensure the timely notification to the NEB and other Appropriate Government Authorities.

A Contaminated Sites Resource Specialist with experience in contaminated sites will be contacted and required to be present at the identification site to verify the indications of potential soil and groundwater contamination (i.e., sheen and adjacent soil staining) and assist in monitoring and mitigation.

Health and Safety Upon discovery of contamination, the health and safety of personnel and the public is the first priority. Contractors and personnel on-site will suspend all work in the area, shut equipment down and immediately notify the Construction Manager or designate and an Environmental Inspector. Appropriate personal protective equipment, will be worn and all reasonable measures will be taken to ensure that health and safety of anyone in the immediate area is preserved. Personnel and Contractors will employ all measures and requirements outlined in Construction Health and Safety Management Plan as well as any other measures or requirements.

Interim Mitigation The Environmental Inspector and Contaminated Sites Resource Specialist must be consulted when determining the necessary mitigation measures that are to be implemented when it is safe to do so. In all instances, the migration of the contamination from the disturbed area must be minimized. Mitigation measures may include:

• segregating contaminated soil for later sampling and/or analysis and disposal;

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• placing contaminated soil onto an impermeable surface;

• covering contaminated soil with an impermeable cover in cases where precipitation may cause runoff;

• constructing berms to control runoff, in cases where runoff is imminent;

• stopping contaminated water discharge;

• storing contaminated water in tanks for later sampling and/or analysis and disposal; and

• if sampling is required, laboratory analytical parameters for soil and groundwater should be based on site history and land use. Potential contaminants of concern are outlined in the Contamination Identification and Assessment Plan (Volume 6 of the Environmental Plans).

Contamination Management Requirements Excavations in which contaminated soil and/or groundwater has been discovered must not be backfilled until authorization has been given by the Construction Manager and Environmental Inspector. Soil brought on-site to fill excavations must be approved by the Environmental Inspector prior to use.

Contaminated soil and water must not be transported off-site or disposed of until analytical results have been received as per applicable federal and provincial regulations and as outlined in the Contamination Identification Assessment Plan (Section 3.0 of Volume 6 of the Environmental Plans). The Construction Manager and the Environmental Inspector will provide notification as to when excavations can be backfilled.

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2.0 FIRE CONTINGENCY PLAN The Prime Contractor(s) will develop a Fire Contingency Plan (Volume 4C, Section 5.2.7) and a Fire Prevention Plan (Volume 4C, Section 5.2.8) as part of their Emergency Response Plan (ERP) that will include, at a minimum, the guidelines provided in the TMEP Health and Safety Management Program and associated Emergency Management Program. Specifically, the following fire prevention and contingency measures will be incorporated into the Prime Contractor(s) ERP.

In the Event of a Wildfire The following response measures will be implemented, as warranted, in the event of a fire.

• Commence fire suppression measures immediately upon detection of a fire provided that current fire behaviour allows personnel to safely proceed.

• Initiate the Emergency Response Line (ERL) process as required. The ERL process can be found in the Project Construction Health and Safety Management Plan.

• Report location of fire as well as size, wind direction, fuels burning and immediate values at risk to the Fire Boss.

• The Fire Boss will report all wildfires immediately and relay general fire information to the Senior Compliance Advisor who will advise the appropriate provincial, municipal or federal authorities.

• All equipment and personnel shall be made available to control the fire. Suppression efforts will take into consideration fire behaviour, safety, training and fitness of personnel as well as equipment availability.

• The Fire Boss will inspect the fire as soon as possible and take charge of directing suppression measures until relieved by a responding authority official.

• Moveable material, particularly explosive or flammable materials and/or vehicles will be promptly moved to a safe location whenever there is a possibility of being endangered by fire.

• Fire suppression efforts shall continue until the fire is extinguished, until it is no longer safe for Project personnel to respond to the fire, or until otherwise notified by the appropriate jurisdictional authority (i.e., AEP, BC MFLNRO).

• The Fire Boss will ensure that all burning embers are extinguished and will monitor burn area for smouldering material. If available, employ infrared scanning equipment to detect any residual hot spots.

To Report a Wildfire Alberta: 310-FIRE (3473)

BC: 800-663-5555 (or *5555 on most cellular networks)

General Fire Information When a fire is encountered on or adjacent to the temporary construction lands or infrastructure site, make note of the following fire and site conditions prior to reporting the fire:

• crew contact information;

• location of the fire;

• fuel the fire is burning in (e.g., trees and grass);

• approximate size of the fire;

• how quickly the fire is spreading;

• colour of the smoke; and

• values at risk (lives, property and structures)

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3.0 FLOOD AND EXCESSIVE FLOW CONTINGENCY PLAN Notify the Environmental Inspector or the Construction Manager that contingency measures have been initiated as a result of flooding or excessive stream flow so that a record of the location, timing and reason for implementation of the contingency plan is maintained. The Senior Compliance Advisor must be notified, who will notify the Appropriate Government Authorities (i.e., AEP, BC MOE and NEB), as warranted and as soon as practical, that contingency measures are being/have been implemented (see Contacts provided in Appendix A of this EPP).

Weather conditions will be monitored by the Environmental Inspectors on a daily basis. If a major storm is predicted or occurs, watercourse crossings where construction is in progress or has been completed will be monitored to determine whether any preventative or corrective actions need to be implemented.

If the potential for increased sediment concentrations, or sedimentation in a watercourse due to Contractor activity is predicted, the Soil Erosion and Sediment Control Contingency Plan (see Section 6.0 of this appendix) will be implemented. At watercourses where an isolated crossing method is preferred, the isolation crossing techniques may not be feasible during periods of excessive flow or unusually wet seasons. Excessive flows are flows that are greater than the seasonally expected normal range based on existing and predicted flow data, and the ability of the isolation method to accommodate those flows.

The following contingency measures will be implemented progressively or individually, as warranted, if excessive flow or flood conditions, heavy precipitation or snowmelt events are anticipated prior to commencing watercourse crossing construction.

• Assess the capability to handle the forecasted flow rate for the duration of the instream works, with the crossing method being used.

• Defer instream work for the watercourse crossing construction to a later time when flows have subsided, or weather related threat has passed.

The following contingency measures will be implemented progressively or individually, as warranted, if excessive flow or flood conditions should occur during watercourse crossing construction.

• Withdraw all equipment or tanks containing fuel, oil or other hazardous materials from potential flood areas.

• Relocate all topsoil/root zone material piles as approved by the Environmental Inspectors.

• Relocate spoil storage piles, to the extent feasible, to a position above the anticipated high water level.

• Remove all stationary and mobile equipment deployed at the crossing site to a safe area above the anticipated high water level.

• Remove any instream flume or dam equipment that may impede stream flow, if safe work conditions allow.

• Restrict the use of bridges and other vehicle crossing structures until it is determined whether adequate free-board is present on bridges and adequate capacity is available in culverts.

• Take corrective measures, if warranted, to avoid flooding of adjacent lands.

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4.0 HERITAGE RESOURCES DISCOVERY CONTINGENCY PLAN **Note: Personnel are NOT permitted to collect and/or keep any heritage resources.

The following procedures provide contingency measures for the discovery of heritage resources prior to and during construction of the Project.

Heritage Resource Discovery during Construction In the event that suspected heritage resource sites are discovered during construction, implement the measures listed below.

• Notify the Environmental Inspector, who will notify the Construction Manager, Trans Mountain Environment, who will determine if the services of a qualified Heritage Resource Specialist may be necessary, and the Senior Compliance Advisor, who will notify the appropriate regulatory authority as required.

• Determine the need for Contractor security personnel to secure the site pending approval from the Appropriate Government Authority.

• Prohibit the collection of any historical, archaeological or palaeontological resources by Project personnel except for qualified Heritage Resource Specialists acting as authorized by the appropriate regulator/permit.

• Suspend work immediately in the vicinity (i.e., within 30 m) of any newly identified archaeological, palaeontological or historical resource sites (e.g., modified bone, pottery fragments and fossils). Work at that location may not resume until the measures below are implemented. Clearly mark the site using fencing and flagging to secure avoidance where appropriate.

• As and where required, a qualified Heritage Resource Specialist will develop, if warranted, an appropriate mitigation plan in consultation with the Contractor, Environmental Inspector, the Construction Manager, the appropriate government authority, as well as the applicable Aboriginal groups. The mitigation measure options available include those measures for site avoidance, systematic data recovery and monitoring/surveillance as described above.

Human Remains Discovered During Construction In the event that suspected human remains are discovered during construction, implement the mitigation measures listed below.

• Suspend work immediately in the vicinity (i.e., within 30 m) of the newly identified human remains. Work at that location may not resume until the measures below have been implemented.

• The Environmental Inspector will notify the Construction Manager, the Chief Activity Inspector, Trans Mountain Environment, who will determine if the services of a qualified Heritage Resource Specialist may be necessary, and the Senior Compliance Manager who will, if warranted, notify the local police and appropriate regulatory authorities.

• Determine the need for Contractor security personnel to secure the site pending approval from the Appropriate Government Authority.

• If there is potential for disturbance to the site due to trafficability or high public visibility, assign employees to stand watch until the local police and Heritage Resource Specialist arrives.

• Stake or flag off the location to secure avoidance.

• Cover any exposed remains with clean plastic sheeting, tarpaulin, blanket or other covering until the local police and Heritage Resource Specialist is present.

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• Do not backfill. If excavated fill has been loaded into a truck, empty the excavated fill at a nearby secure location for the local police and Heritage Resource Specialist to inspect.

• The Contractor will only resume work in that area once the archaeological and forensic studies are complete, clearance has been granted by the local police and appropriate government authority, and Trans Mountain has been advised that work can continue.

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5.0 RARE ECOLOGICAL COMMUNITIES OR RARE PLANT SPECIES DISCOVERY CONTINGENCY PLAN

Field studies for rare ecological communities and rare plant species will be completed prior to construction, and known locations and mitigation are included in the Resource-Specific Mitigation Tables (Appendix D of this EPP). In the event that previously unidentified potential ecological communities or rare plants (vascular plant or bryophyte including moss or liverwort or lichens) are discovered on or within 30 m of the temporary construction lands and infrastructure site prior to or during construction, Contractor personnel will follow the measures outlined below.

• Note the location of the potential rare plant or ecological community relative to the construction footprint.

• Notify an Environmental Inspector. The Environmental Inspector will contact Trans Mountain Environment to discuss the need for a Vegetation Resource Specialist.

• Send a photograph of the potential rare element and any additional details (e.g., habitat characteristics) regarding the element and the site to the Resource Management Specialist to provide to the Vegetation Resource Specialist.

• Avoid further disturbance within 10 m of the location until the Vegetation Resource Specialist has been consulted.

• If warranted, the Vegetation Resource Specialist will be required to visit the site and will determine if site-specific mitigation measures are required.

• The Vegetation Resource Specialist will develop an appropriate site-specific mitigation plan based on the Rare Ecological Community and Rare Plant Population Management Plan (see Section 5.0 of Volume 6 of the Environmental Plans); this site-specific plan will be developed in consultation with the Environmental Inspector.

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6.0 SOIL EROSION AND SEDIMENT CONTROL CONTINGENCY PLAN Where soil erosion by wind or water is evident during construction, all necessary Contractor equipment and personnel will be made available to control the erosion. The Environmental Inspector in consultation with the Construction Manager or designate, Environmental Manager will determine appropriate procedures to be implemented to control soil erosion and other soil handling problems that may be encountered. The Senior Compliance Advisor must be notified, who will notify the Appropriate Government Authorities (i.e., AEP, BC MOE and NEB), as required and as soon as practical, that contingency measures are being/have been implemented (see Contacts provided in Appendix A of this EPP). A record will be made of the location, timing, reason for implementation and measures implemented.

One or more of the following erosion control options listed below will be implemented, as warranted, where soil erosion is observed. Similar procedures to control erosion will be followed during the operational phase.

Soil Erosion by Water

• Temporarily shut-down construction at the location where erosion is occurring until the risk of erosion has been reduced or conditions improve; the decision to shut-down construction will be made following a discussion involving the Contractor, the Construction Manager or designate and an Environmental Inspector.

• Install sediment fences near the base of slopes if adjacent to watercourses.

• Construct and/or install temporary berms of subsoil, logs, timber, coir logs, or sandbags on slopes where the risk of erosion is high during construction.

• Implement the following measures if regrading:

- salvage topsoil/root zone material and store away from the area to be regraded;

- construct temporary berms to direct water flow off the footprint if practical;

- regrade rills and gullies; and

- replace salvaged topsoil/root zone material.

• Implement one or a combination of the following long-term mitigation techniques:

- construct cross ditches or berms, decreasing the spacing on steeper slopes or on more erodible soils;

- armour the upslope face of berms with geotextile, logs or sandbags;

- apply erosion control blanket, mulch or tackifier to hold soil; and

- reseed and hand rake an annual cover crop, hydroseed or apply seed, install erosion control blankets.

Soil Erosion by Wind

Topsoil/Root Zone Material

• Temporarily shut-down construction at the location where erosion is occurring until the risk of erosion has been reduced or conditions improve; the decision to shut-down construction will be made following a discussion involving the Contractor, the Construction Manager and an Environmental Inspector.

• Consider using the following techniques if soil erosion by wind of the topsoil/root zone material windrow is of concern:

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- apply water or tackifier (at rate recommended by the distributor) the topsoil/root zone material windrow; or

- tamp the topsoil/root zone material windrow with suitable equipment.

Consider using one or a combination of the following techniques if soil erosion by wind is of concern after topsoil/root zone material replacement:

• seed with an annual or biannual cereal or short-lived perennial grass cover crop species;

• conduct straw crimping (straw to be sourced prior to construction, contact Agricultural Fieldman or Crop Specialist in Alberta or the BC Ministry of Agriculture Representative in BC for local, high quality straw suppliers); apply hydromulch or tackifier;

• use a packing roller (e.g., Accuroller) to lightly compact sandy or pulverized soils;

• import small diameter woody slash, spread out and walk down with equipment;

• apply locally available manure (sourced or approved by the landowner) and cultivate; or

• install wind fences.

Soil Erosion/Sedimentation at Streambanks Depending on the rate of flow, water will transport particles of varying size and quantity. The faster the flow, the larger the size of the particle and the greater the amount of particles transported. Particles are deposited when the particle load is excessive for the level of flow, causing sedimentation.

In the Event of Potential Sedimentation to a Waterbody An Environmental Inspector will communicate that contingency measures have been initiated and will maintain a record of the location, timing and reason for implementation of the contingency measures. The Senior Compliance Advisor will notify the NEB as soon as practical that contingency measures have been implemented. In the event that unacceptable levels of sedimentation of a watercourse or wetland is occurring during water crossing construction or in-water work, suspend construction activities and review the measures presented in the Water Crossing Construction Monitoring Management Plan (see Section 9.0 of Volume 6 of the Environmental Plans).

Should an extreme precipitation and/or stream flow event threaten, or other circumstances occur that may render the existing erosion and sediment control measures inadequate, the procedures outlined below will be implemented progressively or individually, as warranted.

• Prohibit the operation of construction equipment close to the banks of watercourses where there is a risk of bank sloughing, failure of the vehicle crossing, flooding of the work area or damage to sensitive aquatic species and/or habitat.

• Install additional sediment fencing to prevent sediment-laden water from entering watercourses.

• Excavate cross ditches to divert runoff away from watercourses, wetlands and/or lakes.

• Construct berms of subsoil, sandbags, rock, timber, straw/hay bales or coir logs on approach slopes and/or banks to divert runoff from the construction footprint and onto well-vegetated lands or sediment retention ponds. The location and method of erosion and sediment control will be approved by an Environmental Inspector.

• Install erosion control blanket or coir matting on disturbed areas such as the banks and approach slopes to assist in the control of erosion and potential for sedimentation of watercourses, wetlands and/or lakes.

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• Import sandbags and place strategically to help stabilize and add height to the banks in order to prevent flooding of nearby areas, especially where vegetation has been removed.

• Implement additional erosion and sedimentation control measures provided in the Flood and Excessive Flow Contingency Plan (Section 3.0 of this appendix).

• Implement one or a combination of the following mitigation techniques for long-term protection measures:

- plant rooted stock plants in the spring or fall;

- transplant dormant shrubs and trees from areas adjacent to or within the vicinity of the crossing location (see Shrub Staking and Transplanting Dwg. 2 in Appendix C of this EPP);

- apply erosion control blanket following seeding; and

- reconstruct the stream profile to remove scour holes or instream obstructions.

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7.0 SOIL HANDLING CONTINGENCY PLAN The following soil handling related problems may arise during construction, which may result in loss of soil productivity if not addressed. Mitigation measures are suggested that may lessen the effects associated with construction.

Little or no Topsoil on Cultivated Lands • Salvage to colour change or to 15 cm, whichever is greatest.

Little or no Topsoil on Native Grassland, Tame Pasture or Hay • Salvage to colour change or to 15 cm, whichever is greatest

Stony Subsoils or Topsoil/Root Zone Material • Attempt to use conventional equipment (e.g., dozers) to salvage topsoil/root zone material. Employ

excavators with clean-up buckets, if dozers are ineffective.

Uneven Boundary between Topsoil/Root Zone Material and Subsoil • Utilize equipment capable of fine depth adjustments when salvaging topsoil/root zone material. Avoid

overstripping and admixing of topsoil/root zone material with subsoil.

Soil Pulverization • Refer to the Soil/Sod Pulverization Contingency Plan (Section 8.0 of this appendix).

Uneven Surface on Native Grassland, Hay or Tame Pasture • Salvage topsoil from the spoil pile area on hay and tame pasture.

• Consider salvaging topsoil from the spoil storage area on native grasslands where the surface is uneven.

• Minimize scalping of the sod layer by:

- using equipment with fine depth control, such as a clean-up bucket or fly swatter, to backfill spoil that was stored directly on top of the sod layer; and

- considering use of a prairie protector rubber blade on a clean-up bucket.

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8.0 SOIL/SOD PULVERIZATION CONTINGENCY PLAN The NEB will be notified as soon as practical after the implementation of soil/sod pulverization contingency measures.

Criteria for Implementation Pulverization may occur on unsalvaged, well-sodded lands, and on cultivated lands with silt or clay-textured soils. The Soil/Sod Pulverization Contingency Plan will be implemented where sod integrity on hay and/or tame pasture lands or topsoil has been disturbed to the extent that the soil/sod will not infill naturally within the same time frame as the adjacent soil, or there is an unacceptably high risk of soil erosion by wind.

The following contingency measures will be implemented where pulverization is occurring and topsoil was not fully salvaged from the working area of the Project Footprint. Locations where these measures apply will be determined by an Environmental Inspector in consultation with the landowner and/or occupant or the applicable Crown land authority.

• Provide alternative access to the construction footprint to avoid areas prone to soil/sod pulverization.

• Minimize traffic, particularly rubber-tired vehicles, in areas where pulverization is prone to occur.

• Use equipment with low-ground pressure tires/tracks (e.g., wide pad tracks) during salvaging and replacement of topsoil.

• Salvage a wider area of topsoil from the Project Footprint.

Salvage topsoil from all travel areas in silty soil.

• Implement other suitable mitigation measures depending on conditions encountered during construction (e.g., availability of extra TWS, soil moisture levels and land use).

Implement the following measures during clean-up and reclamation activities along portions of the construction footprint where soil/sod pulverization occurred prior to contingency measures being implemented.

• Lightly cultivate the affected areas in two directions with a spike cultivator or a scarifier.

• Cultivate an area approximately 1 m wider than the disturbed area.

• Harrow the area to prepare a seedbed.

• Drill or broadcast seed the area, as appropriate, and lightly harrow the area again to incorporate seed and compact the seedbed, if broadcast.

• Straw crimp, if deemed necessary by an Environmental Inspector, on erosion prone soils.

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9.0 SPILL CONTINGENCY PLAN 9.1 Introduction

Guidelines for the safe handling, storage, use and disposal of potentially hazardous materials as well as spill prevention measures and guidelines for the refuelling and servicing of equipment are provided in Trans Mountain’s Waste Management Plan (Section 3.0 of Volume 6 of the Environmental Plans).

The timeline in which the reporting is to take place is dependent on the size of the spill. An immediately reportable spill is defined as a release of a substance that is likely to be an imminent environmental or human health hazard and/or meets or exceeds reportable volumes listed below, with more information provided in the Compliance Management Plan (Volume 10 of the Environmental Plans). Such spills will be immediately reported to the appropriate federal and/or provincial authorities. Spills with volumes that are not immediately reportable or the substance is not likely to be an imminent environmental or human health hazard are not required to be reported to the applicable federal and/or provincial authorities. Rather, these spills will be tracked and documented by the Environmental Inspectors and submitted to Trans Mountain operations for inclusion in their spill-tracking databases.

If there is any doubt that the quantity spilled exceeds reportable levels, the spill will be treated as a reportable spill. The Trans Mountain Regulatory and Compliance Team will determine if the spill should be reported to the appropriate provincial and/or federal authorities (refer to the NEB Incident Report provided in the CMP [Volume 10 of the Environmental Plans]). Crucial information that will be provided to Trans Mountain Management via the Environmental Inspector includes name and telephone number of the caller, date and time of the call, material(s) spilled, location of the spill, estimated quantity spilled, cause of spill, actions taken to-date, assistance required, injuries and weather conditions (KMC 2017).

In Alberta, a reportable spill is defined by the Alberta Environmental Protection and Enhancement Act as:

• the release has caused, is causing or may cause impairment of or damage to the environment, human health or safety, or property;

• the amount exceeds the quantities or emission levels set out for the substance (see MSDS and Trans Mountain’s Environmental Compliance Plan);

• the release is into a watercourse or into the groundwater or surface water in any quantity; and/or

• the release is 200 L or more (Transport Canada 1992 immediate reporting quantity for flammable liquids [class 3]) (see Attachment B1).

In BC, a reportable spill is defined by the BC Environmental Management Act as:

• a release of 100 L or more of: hydraulic oil, engine/lube oil, gasoline, diesel or solvents;

• a release of 25 L or more of waste oil;

• a release of 5 L or more of engine coolant;

• a release of 25 kg or more of contaminated soils; and/or

• any release to a waterbody or watercourse (see Attachment B1).

Spill reporting in BC must be completed in accordance with the Spill Reporting Regulation under the Environmental Management Act.

All spills no matter what size or type material will be reported by the worker discovering the spill to Environmental Inspector, Environmental Manager and Chief Activity Inspector

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Any sites contaminated by a spill will be assessed, remediation will be designed and disposal sites will be identified in accordance with the NEB Remediation Process Guide (NEB 2011). This document will be provided to the Construction Manager or designate, the Environmental Inspector as part of the Environmental Education Program. Emergency contacts are presented in Appendix A of this EPP.

9.2 General Measures

The following general measures are to be adhered to during construction of the TMEP.

• Maintain appropriate spill equipment at all work sites based on risk. The risk potential for site-specific spills will be used to determine the appropriate type of response equipment to be stored on-site and suitable location for storage.

• Post specific instructions regarding applicable contacts and appropriate response actions to be taken in the event of a spill in the field construction offices.

9.3 Initial Response

The following actions will be taken upon detection of a construction spill specific to the TMEP.

• Ensure personal safety and the safety of others on-site and don appropriate personal protective equipment.

• The first person on the scene will execute the actions presented in the Spill Scene Checklist (Attachment B1).

• Report the spill to an Environmental Inspector, Environmental Manager and Chief Activity Inspector.

• When notified of a reportable spill, an Environmental Inspector or designate will immediately ensure that the following actions are taken, where applicable:

- action is taken to ensure safety of workers and the public;

- an on-site Emergency Response Coordinator is designated;

- the necessary equipment and personnel are mobilized, and measures are being implemented to stop the source of the spill, if safe to do so, and commence clean-up; and

- Trans Mountain Management are immediately notified of the spill; and

- Trans Mountain Management notifies the Senior Compliance Advisor, who will immediately notify the applicable provincial and federal agencies, and the NEB of the spill if it meets the reporting threshold.

• The Contractor will make all resources available to contain and clean-up the spill.

In the event of an oil spill associated with the existing TMPL, the Contractor must immediately notify Trans Mountain via the 24-Hour Control Center Emergency Line (1-888-876-6711). In addition, the following actions will be taken:

• ensure action is taken to ensure safety of workers and the public; and

• attempt to contain the spill to the greatest possible extent without endangering the welfare of workers as directed by Trans Mountain until TMPL emergency spill responders arrive.

The Contractor will make all resources available to TMPL emergency spill responders to facilitate the containment and clean-up the spill.

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In the event of a spill associated with a third party foreign pipeline, the Contractor must immediately notify Trans Mountain via the 24-Hour Control Center Emergency Line (1-888-876-6711). In addition, the following actions will be taken:

• ensure action is taken to ensure safety of workers and the public;

• coordinate the containment of the spill to the greatest possible extent without endangering the welfare of workers until the third party pipeline owner’s emergency spill responders arrive.

The Contractor will, upon request of the third party pipeline owner, make resources available to facilitate the containment and clean-up the spill.

9.4 General Spill Containment Procedures

The successful containment of a spill on land or water depends on a variety of factors including: ground cover and topography; hydrogeology; solubility of the material; viscosity of the liquid; water currents; soil permeability; and weather conditions.

The following general guidelines will be followed for containment of spills of hazardous materials.

• Ensure personal safety and safety of others on-site. The first person on the scene will execute the actions listed in the Spill Scene Checklist. This includes a review of the MSDS sheets.

• Assess the safety hazards of the situation and don appropriate personal protective equipment.

• Remove sources of ignition, if safe to do so.

• Identify the product, stop source and physically contain spill as soon as safe to do so.

• Avoid use of water or fire extinguishing chemicals on non-petroleum product spills since many chemicals react violently with water and chemical extinguishing agents may release toxic fumes. In addition, chemicals may be soluble in water and dispersal makes containment and clean-up more difficult.

• Minimize traffic on contaminated soils.

• Use berms constructed with materials and equipment in proximity to the site to physically contain a spill on land. Deployment of booms will be necessary to contain a spill and prevent contamination spread on water.

• Clean-up will not be attempted without advice from the Environmental Inspector and Trans Mountain.

9.4.1 Spot Spills

Effects from small spot spills can generally be minimized and will not result in the suspension of activities if the appropriate actions listed below are promptly implemented. All small spills of fuels or hazardous materials must be contained, cleaned up and reported immediately to an Environmental Inspector.

• An Environmental Inspector will approve methods to remove or reclaim contaminated soils, in consultation with a qualified specialist if warranted. Heavily contaminated soil and vegetation will be disposed of at an approved facility as outlined in the Waste Management Plan (Section 3.0 of Volume 6 of the Environmental Plans).

• Locations where spot spills occur are to be recorded.

• In lightly contaminated soil areas where in situ restoration is feasible; soil will be fertilized, incorporated by hand or cultivated to a depth below the depth of contamination. Repeat or apply other approved remedial measures, as necessary.

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9.4.2 Spills Occurring During On-site Transportation

The general guidelines listed below will be followed for the containment of materials spilled during transportation.

• Contain spilled product.

• Pump tanker truck or transportation vessel dry (into appropriate containers or alternative tanker truck).

• Remove tanker truck or transportation vessel from the site.

• Recover spilled product.

• Clean up contaminated area.

• Dispose of sorbent pads, heavily contaminated soil and vegetation at an approved facility in accordance with the Waste Management Plan (Section 3.0 of Volume 6 of the Environmental Plans). On lightly contaminated soil areas where remediation is feasible, add amendments, sample soil and seed as appropriate. Repeat or apply other approved remedial measures, as necessary.

9.4.3 Spills Adjacent to or into a Watercourse or Wetland

The general guidelines listed below will be followed for spills adjacent to or into a watercourse or wetland.

• Construct berms and/or trenches to contain spilled product prior to entry into a watercourse or wetland.

• Deploy booms, skimmers and/or sorbents, if feasible, to contain and recover spilled material from a watercourse or wetland.

• Collect spilled product.

• Clean up contaminated area including downstream shorelines.

• Dispose of heavily contaminated soil and vegetation at an approved facility. On lightly contaminated soil areas consider in situ remediation where feasible; fertilize and then cultivate beyond depth of contamination. Repeat or apply other approved remedial measures, as necessary.

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10.0 TRADITIONAL LAND USE SITES DISCOVERY CONTINGENCY PLAN 10.1 Traditional Land Use Sites Identified Prior to Construction

In the event that TLU sites are identified during supplemental studies with Aboriginal groups prior to construction for the Project, the sites will be assessed and appropriate mitigation measures will be determined. Newly discovered TLU sites will be assessed based on the following criteria:

• the location of the TLU site with respect to the area of development;

• the relative importance of the TLU site to the applicable First Nation community; and

• the potential for an alteration of construction activities to reduce or avoid sensory disturbance.

The mitigation measures listed below have been successful in mitigating effects on TLU sites. Alternative site-specific mitigation strategies may also be recommended by Aboriginal groups, or the Aboriginal Monitor(s) for the construction area. The mitigation measures that may be implemented will be dependent on the type of site identified and its proximity to the temporary construction lands and infrastructure site.

Hunting Hunting and wildlife sites are areas where large mammals such as elk, moose, deer, caribou and bear are commonly harvested. Key wildlife species are identified both in community discussion and by observed game ambushes, blinds and hunting stands, dry meat racks and butchered animal remains. Furthermore, locales where game can be expected, such as mineral licks, calving areas and well-used game trails, are typically prized hunting areas.

Successful and accepted mitigation measures for hunting sites may include:

• adhering to species-specific timing constraints, to the extent feasible; and

• limiting or restricting the use of chemical applications to control invasive vegetation.

Trapping Aboriginal individuals continue the practice of trapping and snaring for food and pelts. These traps and snares may or may not be located within registered trap lines.

To avoid accidental damage where the temporary construction lands or infrastructure contacts a trap line, mitigation measures may include:

• maintaining access to the trap line during construction; and

• moving of trap line equipment by the trapper prior to construction.

Fishing The practice of traditional fisheries relates to the species harvested, fishing techniques and the nature of specific reaches of lakes and rivers. Fishing methods may include but are not limited to angling, gigging, spear-fishing, dip netting, gill netting and the construction and use of fish traps and weirs. While fishing activities vary with changes in seasonal water flow and variation in fish stocks, fisheries often exhibit habitual repeated use. Fishing areas include waterbodies that are often in proximity to staging areas and/or access points to the waters. Secondary fishing activities relate to the processing of harvests, and may include processing yards, smokehouses, drying racks and fish-grease rendering features.

Standard and effective mitigation measures for fishing areas may include:

• recording and mapping of fishing locales; and

• strict adherence to the regulations, standards and guidelines set by provincial and federal government authorities for watercourse crossings.

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Plant Gathering Many Aboriginal individuals harvest medicinal, ceremonial and food source plants. Plants are gathered in a variety of environments, which include old forests along watercourses and in rugged or mountainous areas. Detailed information regarding medicinal plants is passed down from the Elders and is considered proprietary by the communities.

To avoid the disruption of plant gathering activities, mitigation measures include:

• limiting or restricting the use of chemical applications to control invasive vegetation;

• replacement of plant species during reclamation; and/or

• avoidance of the site.

Habitation Sites Habitation sites include traditional campsites, cabins and settlements. Campsites typically have defined hearths (fire rings), de-limbed trees, tent frames and/or miscellaneous cached or discarded camping supplies and equipment. Cabin structures represent a more permanent occupation of the land and include central log or timber-framed structures, traditional activity areas such as drying racks and smoking tents, and ancillary equipment storage areas. A group of cabins or campsites may signify a long-term or intermittent occupation. A settlement may have been used seasonally or throughout the year, depending on location or necessity. The relative size and nature of habitation sites continuously evolve based on how families and communities grow and often expand from campsites to cabins and possibly to settlements.

Successful and proven mitigation measures for habitation sites include:

• avoidance of the site;

• detailed mapping and a photographic recording of the location; and/or

• detailed recording and controlled excavations may be implemented.

Gathering Places Aboriginal people often gather to share in ceremonial activities, exchange items of trade, arrange and celebrate marriages, and for other activities. Additionally, indigenous grave sites are sometimes recorded in the general area of large gathering places. Such gathering places have historical, ceremonial, cultural and economic significance to Aboriginal groups.

Potential effects on gathering places may be mitigated through:

• avoidance of the site; and

• detailed recording and mapping.

However, the visual effect will be assessed in the field and site-specific mitigation measures will be refined and optimized, as warranted.

Sacred Areas Sacred areas include burials, vision quest locations, rock art panels, birth locations and ceremonial places, among others. A particular element is often only a small component of a larger spiritual complex, which can encompass topographic features and may, by its very nature in the context of Aboriginal spirituality, be inestimable and irreplaceable.

Mitigation measures for sacred areas may include:

• avoidance of the site; and

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• detailed recording and mapping.

However, additional site-specific mitigation measures will be refined and optimized in the field and through community discussions, as warranted.

10.2 Traditional Land Use Sites Discovered During Construction

In the event that TLU sites are identified during construction of the pipeline, the following measures will be implemented, as warranted.

• Flag or fence off the previously unidentified TLU site. Work at that location may not resume until the measures below are conducted.

• Notify an Environmental Inspector, who will notify the Construction Manager or designate, the Aboriginal Monitor and the Heritage Resource Specialist.

• The Heritage Resource Specialist and the Aboriginal Monitor will assess the site and develop an appropriate mitigation plan using the information listed above.

• The potentially affected Aboriginal group(s) will be informed of the discovery and the mitigation measures to be implemented.

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11.0 WET/THAWED SOILS CONTINGENCY PLAN Trans Mountain will assign Environmental Inspectors with sufficient training and soils-related experience to identify soils that are too wet for a particular activity and when the soils are sufficiently dry to allow the activity to resume. The decision to continue or suspend particular construction activities on lands with excessively wet/thawed soils will be made by the Construction Manager in consultation with an Environmental Inspector. A record of the location, timing and reason for implementation of the Wet/Thawed Soils Contingency Plan will be maintained by the Environmental Inspectors. In the event that activities are suspended, the Environmental Inspectors will notify the Senior Compliance Advisor as soon as practical, who will notify the NEB, if warranted.

The Environmental Inspectors will be responsible for monitoring ground conditions and ensuring that all suitable protection measures are implemented. Trans Mountain believes that it is critical to maintain effective communication between the Contractor, the Environmental Inspectors, and the regulators (i.e., the NEB, via the Senior Compliance Advisor). A meeting will be held in the field to ensure that all parties involved mutually understand the concerns associated with working in wet/thawed conditions.

Soils will be considered to be excessively wet when the planned activity could cause damage to soils either due to rutting through the surface material into the subsoil; soil structure damage during soil handling; or compaction and associated deformation of surface material due to heavy traffic.

Contingency measures will be implemented, as warranted, if one of the following indicators occurs:

• rutting of topsoil/root zone material to the extent that admixing may occur;

• soil becomes deformed;

• excessive wheelslip;

• excessive build-up of mud on tires and cleats;

• formation of large puddles; and/or

• excessive tracking of mud as vehicles leave the pipeline construction footprint.

Where construction activities have the potential to, or are causing the aforementioned issues, the Construction Manager, in consultation with an Environmental Inspector and the Contractor, will suspend that phase of the construction activity until soil conditions dry out/freeze, or effective mitigation procedures have been implemented.

In order to avoid terrain disturbance and soil structure damage through rutting, deformation, or compaction due to wet/thawed soil conditions, construction alternatives will be employed, when warranted, in the event of thawed soils during frozen conditions and/or an excessively wet surface during non-frozen conditions. The contingency measures listed below will be implemented individually or in combination, as necessary, based on site-specific conditions.

Wet Soil Contingency Measures • Temporarily modify or shut-down construction activities at the location with wet soil conditions until

the conditions improve; the decision to modify or shut-down construction will be made following a discussion involving the Contractor, the Construction Manager and an Environmental Inspector.

• Restrict construction traffic, where feasible, to equipment with balloon tires or wide pad tracks.

• Prevent rubber-tired traffic from driving along the construction footprint.

• Postpone work in highly sensitive areas and restrict work efforts to low sensitivity or non-problem areas (e.g., well drained soils) until conditions improve.

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• Install matting in problem areas.

• Implement drainage controls (shallow ditching and/or pumping) to prevent puddling and expedite drying, where practical.

Recommencement of suspended work at any given location must be authorized by the Construction Manager, in consultation with an Environmental Inspector once conditions are acceptable.

Thawed Soil Contingency Measures

• Restrict construction traffic, where feasible, to equipment with low-ground-pressure tires or wide pad tracks.

• Prevent rubber-tired traffic from driving on or along the construction footprint where there is unsalvaged topsoil.

• Restrict work to non-problem areas, such as frozen or well-drained soils, until conditions improve.

• Limit construction activities and traffic, if thawed ground conditions are encountered, to the evening or early morning when the ground is frozen.

• Install matting in problem areas.

• Employ frost inducement measures such as snow packing or plowing to increase the load-bearing capacity of thawed ground as a temporary measure.

• Suspend construction activities and traffic in areas with thawed soils until the soils dry out or refreeze.

If the indicators of excessively wet/thawed soil conditions previously noted above are not evident, soils will be considered dry enough to resume activity.

Partial Suspension of Construction Activities and Traffic The primary concern during wet/thawed soil conditions is the potential for rutting, compaction and loss of soil structure (deformation) of the topsoil/root zone material. Some construction activities may be conducted and traffic allowed during wet/thawed soil conditions while others are suspended.

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12.0 WILDLIFE SPECIES OF CONCERN ENCOUNTER AND DISCOVERY CONTINGENCY PLAN

12.1.1 Wildlife Species of Concern

The following procedures provide contingency measures for the discovery of wildlife species of concern (i.e., with conservation status) prior to and during construction. Wildlife species with conservation status refer to those species listed as Special Concern, Threatened or Endangered federally on Schedule 1 of the SARA and/or by the Committee on the Status of Endangered Wildlife in Canada, and provincially designated as Endangered, Threatened or Special Concern in Alberta or Red or Blue-listed in BC or listed as Threatened or Endangered under the BC Wildlife Act.

Wildlife Species of Concern Discovery Prior to Construction In the event that wildlife species of concern or their site-specific habitat are discovered during wildlife or other studies along the construction footprint or other associated components (e.g., storage sites), the discovery will be assessed and appropriate mitigation measures will be determined by an Environmental Inspector in consultation with Trans Mountain Environment and a Wildlife Resource Specialist as necessary. The review of the wildlife species observation or habitat feature will consider the following:

• The wildlife species, its conservation status and specific habitat needs relative to the area of development.

• The location of the wildlife habitat feature (e.g., stick nest) relative to the area of development and in consideration of the recommended setback distances as provided by regulatory guidelines, where applicable.

• The presence of topographic features or vegetation to effectively screen the wildlife habitat feature from construction activities.

• The timing of construction versus the timing windows/sensitive periods for the wildlife species as provided by regulatory guidelines, where applicable.

• The potential for an alteration of construction activities to reduce or avoid direct and/or sensory disturbance.

The mitigation measures to be implemented will be determined by a qualified Wildlife Resource Specialist and may include the following.

• Abide by seasonal timing windows and the recommended setback distances (as provided by regulatory guidelines, where feasible).

• Abide by daily timing restrictions on construction activities, where feasible.

• Reduce the area of disturbance and protect the site using fencing or clearly mark the site using flagging.

• Inform all users of access restrictions in the vicinity of flagged or fenced sites.

• Realign the route (i.e., micro-routing) or shift the development (i.e., access road, ancillary site, etc.) within the staked boundaries to avoid the site. Refer to the MOC process provided in the CMP (Volume 10 of the Environmental Plans).

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- Ensure the appropriate provincial permit is obtained for the salvage and relocation of wildlife species or the removal of a nest protected by the BC Wildlife Act. Note, habitat enhancement measures or a replacement nest may be needed dependent on the conditions of the permit; Ensure a SARA Section 73 Permit is obtained on Federal lands (e.g., Indian Reserves), if the Project will affect species listed as extirpated, endangered or threatened on Schedule 1 of SARA and will contravene SARA’s general or critical habitat prohibitions (i.e., no person shall kill, harm, harass, capture or take a wildlife species; damage or destroy the residence of one or more individuals of a wildlife species; or destroy any part of the critical habitat of any endangered, threatened or extirpated species).

The locations of important wildlife and wildlife habitat encountered along the construction footprint or associated components and appropriate mitigation to be implemented are identified in the Resource-Specific Mitigation Tables (Appendix D).

Wildlife Species of Concern Discovery during Construction Wildlife species of concern and their habitat that have the potential to occur along the construction footprint or associated components, as well as the locations of provincially identified wildlife areas (e.g., Key Wildlife and Biodiversity Zones, and Ungulate Winter Ranges) will be identified through the Environmental Compliance and Education Program. The Environmental Inspectors will be provided with detailed information on identifying wildlife species of concern and their site-specific habitat.

In the event of an observation of a wildlife species of concern, the mitigation will vary depending on the species. For example, observations of songbirds and/or large mammals, where no associated habitat feature (e.g., active nest or mammal den) is present, may not warrant mitigation given their ability to move away from the construction area. For other species such as amphibians that may be restricted to a discrete area, mitigation measures (e.g., salvage of individuals in compliance with appropriate permit) will be reviewed and implemented as required.

In the event that wildlife species of concern or their site-specific habitat is discovered during construction, the discovery will be assessed and appropriate mitigation measures will be determined. Upon discovery of a wildlife species of concern or habitat feature during construction, the following should occur.

• Suspend work immediately in the vicinity of any newly discovered wildlife species of concern. Do not resume work at that location until the measures below are implemented.

• Notify an Environmental Inspector who will notify the Construction Manager.

• The Environmental Inspector will assess the discovery and either allow construction to resume or, in the event of a confirmed or potential discovery, proceed by notifying:

- Trans Mountain’s Regulatory and Compliance Team; and

- a Wildlife Resource Specialist.

A qualified Wildlife Resource Specialist will assess the discovery and determine the appropriate mitigation measures to be implemented in consultation with an Environmental Inspector, the Construction Manager and the appropriate regulatory authority. The Wildlife Resource Specialist will visit the site, if warranted.

12.1.2 Wildlife Encounter Contingency Plan

In the event of an encounter with wildlife during construction either at the construction site or on the commute to and from the construction site, follow the measures provided below.

• Report any incidents (e.g., aggressive behaviour, nuisance behaviour, obtained food or garbage) with wildlife to an Environmental Inspector who will immediately notify the appropriate regulatory authority and, if warranted, the local Fish and Wildlife detachment (see Appendix A of this EPP).

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• Report any trapped, injured or dead animals on-site to an Environmental Inspector who, if warranted, will notify Trans Mountain’s Regulatory and Compliance Team so the Appropriate Government Authority can be contacted to consult on appropriate action.

• Report the location and details of collisions with wildlife to an Environmental Inspector, who will notify the Appropriate Government Authority and the local conservation officer, if applicable (see Appendix A of this EPP).

• Once the preceding contacts have been made, the Environmental Inspector will communicate the information to the Construction Manager.

• The Environmental Inspectors will document all wildlife encounters during construction in a detailed record. This record will include, at a minimum: date; weather conditions; location; wildlife species encountered; the type of encounter (e.g., passive, aggressive, etc.); and, if applicable, any actions taken by Project staff to address the situation. Wildlife encounter records will be kept on file by Trans Mountain and provided to the Appropriate Government Authority and Aboriginal groups upon request.

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Wildlife Sighting Information

Name of Observer: ___________________________ Date of Observation: _____________________

Location of Observation (KP): ____________ Location Name (if applicable):_____________________

UTM Zone: _________ Easting: ___________________ Northing: ______________________________

Wildlife Observation:

Species Observation Type (i.e., visual, heard animal, observed sign such as tracks, scat, etc.)

Age (adult, young, unknown)

Sex (male, female, unknown)

Number observed (include numbers of males/females if known)

Habitat Description (e.g., forested, grasslands, agriculture)

Behaviour of Animal (describe what the animal was doing)

Aggressive Behaviour (Yes or No; if yes describe)

Additional Comments

Name of Environmental Inspector Card Submitted To: __________________________________________________ Date of Submission: _________________________

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ATTACHMENT B1

SPILL SCENE CHECKLIST

Note: The following activities will be taken by the first person on the scene of a hazardous material spill or release or a spill of other potentially deleterious material into a watercourse or wetland or environmentally sensitive area, if feasible.

(a) Ensure personal safety and safety of others on-site and don appropriate personal protective equipment. ________

(b) If possible without further assistance, assess the safety hazards of the situation, ensure the safety of workers and the public, and identify the composition (see Spill Report Form - next page) of the spilled material via the SDS sheets that are available for each controlled substance. ________

(c) If feasible and safe to do so, remove any sources of ignition, cut off the source of the spill and initiate a release response plan (i.e., control, contain and clean up). While efforts have been initiated to contain the spill, immediately notify the Construction Manager, or designate and an Environmental Inspector. If the Senior Compliance Advisor, or designate, cannot be immediately contacted, notify Trans Mountain’s 24-hour Emergency Line. These people will, as required, contact the appropriate authority as well as applicable federal and provincial agencies and the NEB. ________

(d) Once the source has been cut off, attempt to contain the spilled material. Seek qualified assistance if necessary. ________

(e) Take note of details such as time, location, material, volume, corrective actions, etc., for reporting criteria. ________

(f) In Alberta, Trans Mountain will submit a written report directly to the Monitoring Division of the AER within 7 days of verbally reporting an unrefined or refined product release, if the release has caused, is causing, or may cause adverse effect on the environment. If the release is fully contained on-site, or there are no adverse effects, then a written report is not required. In Alberta, a spill of 200 L or greater must be reported for all Class 3 (Flammable Liquids) spills. ________

(g) In BC, Trans Mountain will provide an immediate verbal report to the BC MOE 1-800-663-3456 (24-hour emergency line). Where requested to do so by an environment officer, a written report shall also be filed with the department. In BC, a spill of 100 L or greater must be reported for all Class 3 (Flammable Liquids) spills. ________

2115 Commissioner Street – Project Support Site: Vancouver Fraser Port Authority

Construction Environmental Management Plan

Rev.0

H-1 APPENDIX C

MARINE CONTINGENCY PLANS

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MARINE SPILL CONTINGENCY PLAN Introduction The Marine Spill Contingency Plan has been prepared for construction activities being completed at the VersaCold Sites. This plan demonstrates that Trans Mountain has appropriate response capabilities and measures in place to effectively address potential releases during construction at the VersaCold Sites.

Purpose and Scope Spill reporting procedures are applicable to all Trans Mountain construction activities. These procedures are specific to the VersaCold Sites and will be followed in the event of a spill or release, within this facility or contamination of coastal waters during construction activities associated with the Project.

The purpose of this plan is to provide direction on how to quickly, safely and effectively respond to a construction phase marine spill at the VersaCold Sites to allow for the protection of the public, employees and Contractors, the environment and company property. In addition, this plan will facilitate the reporting of releases of hazardous materials to the appropriate authority, as required. As a federally regulated company, Trans Mountain is responsible for reporting any volume of spill at the VersaCold Sites to the NEB. This Marine Spill Contingency Plan identifies the lines of authority and responsibility, establishes proper reporting and communication procedures and outlines an action plan, to be implemented in the event of a marine spill. This Marine Spill Contingency Plan applies to fuel, hydrocarbons, chemicals and other potentially harmful substance released at the VersaCold sites.

Construction-specific activities may result in spills, such as:

• spills from on-land construction vehicles/equipment that drain into the ocean;

• spills from vessels engaged in construction activities (e.g., tugs and workboats); and

• spills from construction equipment on barges (e.g., pile drivers).

Response Organization Spills into or threatening a body of water are considered reportable through the Emergency Response Line process, as a reportable incident, to the Senior Compliance Advisor. The Senior Compliance Advisor must report any incident of a spill or release at the VersaCold Sites directly to the NEB, as soon as practical, and take appropriate measures to remediate the contamination. The NEB also requires notification of the contamination, in writing, to the Secretary of the Board (NEB 2011).

Emergency spill response equipment will be located, as a responsibility of the contractor, in the TMEP VersaCold Sites Oil Spill Containment and Recovery location. The location and contents of the emergency spill response equipment will be discussed intermittently during daily safety meetings. Further information regarding this equipment can be obtained from the Contractor.

Prompt notification of a spill to the VersaCold Sites Supervisor is crucial. Contact local emergency response providers in the event of a spill involving danger to human life.

For marine pollutant or spills in Vancouver harbour, call Vancouver Traffic VHF 12/11/74/16 immediately. For a spill to the marine environment, immediate notification to Canadian Coast Guard Marine Communications and Traffic Services (MCTS) is required (see http://www.ccg-gcc.gc.ca/e0003876). All accidental over side discharges should be reported immediately to the Operations Centre (1-604-665-9086). If the discharges contain oil or other deleterious substances, the vessel must immediately notify the MCTS and activate its pollution response plan. The Port Information Guide (VFPA 2016) provides more information and clarification regarding reporting requirements (see http://www.portvancouver.com/wp-content/uploads/2015/03/Port-Information-Guide-12-Port-of-Vancouver-August-2016-amended.pdf).

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VersaCold Sites (Waterlots 1 and 2) Contractor Responsibilities VersaCold Sites Contractors will be responsible for prevention, preparedness, response and reporting on their work sites during the construction phase of the Project. VersaCold Sites Contractors must maintain an up-to-date inventory and location knowledge of response materials at the worksite. The Contractor must provide training, prior to work, and implement regular emergency response exercises to enable TMEP workers and subcontractors to perform their designated emergency responsibilities. It will be the Contractor’s responsibility to immediately inform the VersaCold Sites Supervisor, TMEP management and the Senior Compliance Advisor in the event of a spill or release.

Equipment Emergency response equipment and materials will be provided to VersaCold Sites Contractors and are to be stored on-site, as close to the area of work as feasible. These materials will include, but are not be limited to: booms; skimmers and other collection devices; sea-water pumps; hoses; sorbents; fire nozzles; containment vessels; spill kits; and personal protective equipment. Any concerns regarding additional response equipment should be directed to the VersaCold Sites Supervisor, who will be able to source supplementary equipment through local service providers in the area.

Initial Assessment In the event of any incident, the location and circumstances will be assessed to determine the safety hazards, human and environmental resources at risk of adverse effect and potential of the incident escalating into a greater incident. This assessment will be conducted by the Environmental Inspector or the VersaCold Sites Supervisor, depending on the circumstances. The priorities of the Environmental Inspector in the event of a release incident are to:

• protect people and environment;

• stop the source, if safe to do so; and

• contain the release.

Recovery After the initial assessment is complete, recovery of free product or materials with high concentrations of spilled product should be performed as soon as feasible to reduce the extent of effects to the shoreline, sediment and water.

Detailed Assessment After the initial assessment and recovery activities are complete, a detailed assessment of effects resulting from the spill is required. This assessment will: investigate the effects to the shoreline, sediment, water and wildlife in detail; provide comparisons of concentrations of parameters of concern with applicable guideline concentrations; and provide recommendations for remedial activities, if warranted.

Remediation Remedial activities recommended in the detailed assessment should be implemented as soon as feasible following the spill to bring sediment and water conditions into compliance with regulations. Long-term monitoring may be required as a result of certain spills. A remediation report is required to be submitted to the appropriate bodies.

Closure Once the site has been brought back into compliance with applicable regulations and monitoring activities are complete, a closure report is required to be submitted to the appropriate bodies.