Fraser Surrey Docks LP Consideration to Amend Permit No. 2012 – 072 Direct Transfer Coal Facility Consultation Summary Report Prepared by: Kirk & Co. Consulting Ltd. June 2015 Public Comment Period May 4 – May 19, 2015
Fraser Surrey Docks LPConsideration to Amend Permit No. 2012 – 072
Direct Transfer Coal Facility
Consultation Summary Report
Prepared by:
Kirk & Co. Consulting Ltd.
June 2015
Public Comment Period May 4 – May 19, 2015
About Kirk & Co. Consulting Ltd. Kirk & Co. is a recognized industry leader in designing and implementing comprehensive public and stakeholder consultation and engagement programs. Utilizing best practices, consultation and engagement programs are designed to maximize opportunities for input. Kirk & Co. independently analyzes and reports on public and stakeholder input.
The views represented in this report reflect the priorities and concerns of respondents. They may not be representative of the views of the public and other stakeholders as a whole because respondents self-selected into the public comment period, and therefore do not reflect a random sample.
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Table of Contents
1. Introduction ...............................................................................................................................4
1.1. Consideration to Amend Permit No. 2012 – 072 Direct Transfer Coal Facility ............................. 4
2. Public Comment Period – May 4 – 19, 2015 .................................................................................4
2.1 Purpose – Public Comment Period ............................................................................................... 4
2.2 Notification ................................................................................................................................... 4
2.3 Participation .................................................................................................................................. 6
2.4 Methods ........................................................................................................................................ 6
2.4.1 Discussion Guide and Feedback Form .................................................................................. 6
2.4.2 Agency Meeting .................................................................................................................... 7
3. Results .......................................................................................................................................8
3.1 Key Themes – Feedback Form, Written Submissions and Local Government Submissions ......... 8
3.2 Key Themes – Agency Meeting ................................................................................................... 24
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1. Introduction
1.1. Consideration to Amend Permit No. 2012 – 072 Direct Transfer Coal Facility
On August 21, 2014, Fraser Surrey Docks LP was granted a permit by Port Metro Vancouver that gives it conditional approval to build and operate a Direct Transfer Coal Facility within its existing lease area.
Fraser Surrey Docks (FSD) is considering applying to amend its existing permit. The proposed amendment would allow FSD to load coal directly from the facility to ocean-going vessels (OGVs). Using OGVs would allow FSD to eliminate or reduce the number of barges required. The proposed amendment to the existing permit would have no impact on the volume of coal permitted to be shipped through FSD, which is 4 million metric tonnes per year.
More information about FSD’s consideration to amend Permit No. 2012 – 072 can be found at www.fsd.bc.ca/amendment.
2. Public Comment Period – May 4 – 19, 2015
2.1 Purpose – Public Comment Period
The purpose of the public comment period, held May 4 to May 19, 2015, was to provide an opportunity for the public and stakeholders to review the proposed changes to the existing permit, and specifically for FSD to seek comments on the proposed scope of the studies associated with the amendment under consideration.
These studies included the Human Health Risk Assessment (HHRA), Environmental Impact Assessment (EIA), Air Quality Assessment (AQA), Marine Risk Assessment, Environmental Management Plan (EMP), Water Management Plan, Fire Safety Plan, and Spill Response Plan.
The input received during the public comment period has been summarized in this report and will be considered by FSD, along with information provided by technical experts, as part of the consideration to apply for an amendment to the existing permit.
Should FSD submit an application to amend the existing permit, a second round of public consultation will be undertaken. Round 2 Public Consultation would focus on the proposed project design associated with the submitted amendment application for Permit No. 2012 – 072 and the results of the studies.
2.2 Notification Notification of opportunities to participate in the public comment period included the following:
• Notification Emails: 115 emails were sent to stakeholders (local governments, environmentalorganizations, health authorities, MLAs and others) on May 4, 2015, with information about thepublic comment period.
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• Phone Calls: Phone calls were made to stakeholders (local governments, environmentalorganizations, health authorities, MLAs and others) to inform them of the public commentperiod, as follow-up to the email notification.
• Newspaper Advertising: Advertisements ran in the following community newspapers betweenMay 6 and May 14, 2015:
• Online Advertising: Online notification advertisements ran from May 4 to May 19, 2015, on thefollowing sites, with the following results:
• Surrey Leader: 9,904 ad impressions• New Westminster Record: 6,446 ad impressions
• Postcard Mailer: 9,077 households in Surrey and New Westminster received a postcard thatinformed recipients of ways to participate in the public comment period. The postcards weresent during the week of May 4, 2015, to households near FSD.Maps illustrating where the postcards were delivered can be found in Appendix A.
• Website: Notification of the public comment period and a button linked to the Discussion Guideand online Feedback Form were displayed on Fraser Surrey Docks’ home page (www.fsd.bc.ca)from May 4 – 19, 2015; a link to a page with information about the amendment(www.fsd.bc.ca/amendment) was also displayed on the home page.
Publications Dates • Surrey Leader• New Westminster
NewsLeader• Burnaby Now• New Westminster Record• Delta Optimist
Wednesday, May 6 and Wednesday, May 13
• Surrey Now• Richmond News• Peace Arch News
Thursday, May 7 and Thursday, May 14
Publications Circulation per insertion Burnaby Now 45,526 New Westminster Record 15,735 Delta Optimist 17,050 New Westminster NewsLeader 61,261 Richmond News 46,728 Surrey Now 117,720 Surrey Leader 82, 530 Peace Arch News 37,510
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• Social Media: Notification was sent from FSD’s Twitter account (@FSDocks) beginning May 4,2015, and at relevant times throughout the public comment period to remind the public andstakeholders of the opportunity to submit feedback.
• Information Bulletin: On May 4, 2015, an information bulletin was sent to regional andprovincial media to advise them of the public comment period.
2.3 Participation
A total of 51 submissions were received during the public comment period. A summary of the input received can be found starting on page 8.
• Online Feedback Form: 23 received• Written Submissions: 22 received• Local Government Submissions: 5 received• Agency Meeting: 1 meeting
2.4 Methods
Materials, including the Discussion Guide and Feedback Form, and the scope and rationale documents specific to each study, were made available online at www.fsd.bc.ca/amendment beginning on May 4, 2015. Feedback was collected through the following methods:
2.4.1 Discussion Guide and Feedback Form A Discussion Guide provided an overview of the proposed changes to the existing permit. The Discussion Guide and Feedback Form invited comment from the public and stakeholders regarding the proposed scope of eight key studies relevant to the amendment:
• Human Health Risk Assessment• Environmental Impact Assessment• Air Quality Assessment• Marine Risk Assessment• Environmental Management Plan• Water Management Plan• Fire Safety Plan• Spill Response Plan
The Discussion Guide was available for download, and an online version of the Feedback Form was
available at www.fsd.bc.ca/index.php/amendment during the public comment period.
A copy of the Discussion Guide and Feedback Form can be found in Appendix B.
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2.4.2 Agency Meeting
A meeting was requested by the Fraser Health Authority and was held on May 15, 2015.
Representatives of FSD attended the meeting, along with a meeting recorder from Kirk & Co. Prior to and during the meeting, agency representatives were provided with the Discussion Guide and the scope and rationale documents for each study, and were encouraged to submit input during the public comment period. Representatives of FSD provided information about their consideration to apply for an amendment, focusing on the proposed scope of studies relevant to the amendment. Agency representatives were invited to ask questions and provide feedback during the meeting. Key themes from this meeting are summarized in Section 3.2 on page 24.
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3. Results
The following provides a summary of the key themes from submissions received from online feedback forms, written submissions (emails and letters), and the agency meeting during the public comment period from May 4 to 19, 2015. As much as possible, the language expressed by respondents has been retained in the key themes.
3.1 Key Themes – Feedback Form, Written Submissions and Local Government Submissions
The results received through the online Feedback Form, written submissions and local government submissions are categorized according to Feedback Form questions shown below. This summary of key themes reflects the comments provided by respondents. The accuracy of the information in the comments below has not been confirmed. FSD will respond to the comments provided by respondents through a consideration memo, which will be posted prior to or concurrent with an amendment application, if FSD chooses to proceed.
The number of respondents commenting on a key theme is noted in brackets. The number of comments may exceed the total number of respondents commenting, as respondents may have commented on more than one topic.
1. Human Health Risk Assessment (HHRA), which will be completed by SNC-Lavalin Inc. (Environment& Water)
An overview of the proposed scope of this study can be found on page 7 of the Discussion Guide, andthe original study can be found at www.fsd.bc.ca/amendment.
Please provide comments on the proposed scope of the Human Health Risk Assessment associatedwith Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:
Respondents provided the following comments related to the proposed scope of the HumanHealth Risk Assessment:
• The HHRA is too narrow; all potential adverse impacts included in this study must beaddressed for the entire transport route and FSD’s site, including: (9)
o The route of ocean-going vessels (OGVs), at least out to the open oceano The entire route that coal trains would travel from the U.S. border to FSDo Project-related emissions from equipment on-siteo The cumulative impacts of industry in the area, including newly approved and
pending projects that will impact the South Arm of the Fraser River
• There are concerns about air pollution and poor air quality from airborne pollution and coaldust, and its impacts on human health, including: (7)
o Concern regarding allergies, asthma, and cancero Potential impacts on the environment, plants, animals and homes
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• Economic, health and quality of life impacts from noise or traffic associated with increasedrail transport and increased activity at the terminals should be considered (4)
Respondents also stated the following related to the proposed scope of the Human Health Risk Assessment:
• That there has not been a Human Health Risk Assessment that has reviewed the cumulativehealth risks of industry in the area (1)
• Support for the proposed scope of the study (1)• That the review of the study by multiple experts is good (1)• That Golder Associates identified a number of minor errors throughout the HHRA
document; these errors should be corrected in the updated HHRA (1)• That it would be appropriate to re-evaluate conservative assumptions about the hazard
quotient and recalculate risks, or to identify these elevated predictions as an item thatshould be addressed in the AQA (1)
• That the air quality and noise impact areas for the HHRA require amendment to includeRichmond residential areas and a redefinition of air quality parameters specific to marinevessel operations in the South Arm of the Fraser River (1)
• That the updated HHRA should include input from the health authorities (1)
Respondents also provided the following comments, not directly related to the scope of the Human Health Risk Assessment, for the amendment under consideration:
• There are known health risks associated with the loading and shipping of coal (2)• This proposal will increase open-car coal train traffic through residential communities, which
raises concerns about the health impacts of coal dust, diesel exhaust, and nighttime noisefrom train whistles, as well as the potential impacts of vibration from heavy coal trains tohomes closest to rail lines (2)
• Concerns about the impacts on public health (1)• The supporting documents for the original project permit regarding operational noise and
vibration were dismissed (1)
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2. Environmental Impact Assessment (EIA), which will be completed by SNC-Lavalin Inc.(Environment & Water)
An overview of the proposed scope of this study can be found on page 8 of the Discussion Guide,and the original study can be found at www.fsd.bc.ca/amendment.
Please provide comments on the proposed scope of the Environmental Impact Assessment(EIA) associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No.2012 – 072:
Respondents provided the following comments related to the proposed scope of theEnvironmental Impact Assessment:
• The environmental impacts associated with the shipment of coal from FSD need to bere-evaluated with broader scope, including impacts on areas outside of the immediateenvironment, including: (9)
o Fish habitato Wetlandso Forestso Threatened or endangered specieso The shorelineo The greater cumulative carbon impacts of burning coal
• There are concerns about a potential increase in operational and construction noise relatedto the proposed amendment, and respondents stated that noise impacts from trains andships should be considered in the updated studies and in mitigation commitments (7)
• Risks associated with the cumulative increase in shipping traffic in the region should beconsidered, including: (5)
o Risks of accidents and oil and/or coal spills, threatening listed endangered species,fishing, tourism and recreation industries, Friday Harbor Marine BiologicalLaboratories and property values
o Impacts to recreational boaterso Threats to endangered salmon and orca (including noise impacts)o Impacts to recreational and commercial shellfish fisherieso Invasive species introduced through increased ballast water dischargeso Damage to wetlands and waterways from construction and developmento Ocean acidification
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Respondents also stated the following related to the proposed scope of the Environmental Impact Assessment:
• Support for the proposed scope of the study (1)• Impacts from contaminant spills of the coal product may include: (1)
o Smotheringo Toxicity from polycyclic aromatic hydrocarbons (PAHs)o Substrate changeo Accumulation
o
Water quality degradation• The EIA should be made available to the public and should be written in lay terms (1)• There should be an analysis of the following activities related to the proposed amendment:
(1)Anchoring for queuing and/or bunkeringVessel traffic related to tug assists and any bunkering-related vessel traffic
• Concerns that FSD has stated that no reassessment is required, and concerns that, without acloser look at the impacts on these areas and others, there is no confidence in FSD’sconclusions (1)
• The current areas of impact for the EIA require amendment to include Richmond’sforeshores and the provincially designated wetlands that constitute the South Arm IslandsWildlife Management Area (1)
• The air quality parameters for the EIA must be redefined specific to increased marine vesseloperations in the South Arm of the Fraser River (1)
• The EIA must take into account cumulative impacts of newly approved and pending projectsthat will impact the South Arm of the Fraser River; further accessory effects of increaseddredging (if required) to accommodate the large OGVs must also be included (1)
• A clear definition of types of coal and sources must be included in the EIA and PMVcertificate, and should clearly outline the Proponent responsibilities and tasks to amend thecommodity type or source (1)
Respondents also provided the following comments, not directly related to the scope of the Environmental Impact Assessment, for the amendment under consideration:
• Concerns that, although FSD has stated that “the project is not likely to cause significantadverse environmental effects, the words “not likely” and “significant” are cause forconcern. This respondent stated that any degree of impact is unacceptable (1)
• Any coal in FSD’s facility will impact the environment (1)
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o
o
3. Air Quality Assessment (AQA), which will be completed by Levelton Consultants Ltd.
An overview of the proposed scope of this study can be found on page 9 of the Discussion Guide,and the original study can be found at www.fsd.bc.ca/amendment.
Please provide comments on the proposed scope of the Air Quality Assessment (AQA)associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 –072:
Respondents provided the following comments related to the proposed scope of the AirQuality Assessment:
• There are concerns about the impacts of poor air quality on human health, such as allergiesand asthma, from airborne pollution and coal dust, and from impacts on the environment,including climate change and pollution (6)
• Air quality impacts associated with releases of coal dust from trains transferring andtransporting coal in the region, from terminals, or from OGVs should be considered in thescope of the study (4)
• The proposed scope of the Air Quality Assessment should: (3)o Include information on how many cars form each traino Include information on where coal will be stored if not loaded immediately onto a
ship; this is an air quality concerno Link to the Environmental Impact Assessmento Consider upstream and downstream impacts
Respondents also stated the following related to the proposed scope of the Air Quality Assessment:
• The AQA should include data from Westshore Terminals, which loads directly to ships (1)• There needs to be more attention paid to the air quality and the coal dust created when
railcars offload (1)• Support for the proposed scope of the study (1)• Performance-based measures and ongoing monitoring must be included in the dust control
measures on-site and in adjacent areas. Particulate, NOx, VOC, CO and CO2 analysis relatedto OGV power sources (while in transit and while docked) must be included in the analysis,and put into context of regional cumulative impacts of other approved and proposedprojects in the lower Fraser River (1)
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Respondents also provided the following comments, not directly related to the scope of the Air Quality Assessment, for the amendment under consideration:
• FSD should handle commodities that they have experience with, especially because thermalcoal can spontaneously combust if stockpiled, which could release toxic smoke that cancause serious and immediate health impacts (2)
• There are concerns about air quality impacts from: (2)o Coal dusto The consumption of coal abroad
• As the volume of coal shipped through FSD will stay the same, there is no change to theissue of coal dust (1)
• Loading coal directly to ships instead of barges will reduce problems with coal dust (1)• Results from ongoing dust monitoring conducted by terminals and municipalities are
encouraging and demonstrate that the industry’s continuing efforts at dust mitigation areworking (1)
• FSD should consider the health and safety of residents of Annieville and Royal Heights (1)• Agricultural goods loaded/unloaded in the same port are liable to be contaminated with
coal dust (1)
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4. Marine Risk Assessment, which will be completed by DNV (Det Norske Veritas)
An overview of the proposed scope of this study can be found on page 10 of the DiscussionGuide, and the original study can be found at www.fsd.bc.ca/amendment.
Please provide comments on the proposed scope of the Marine Risk Assessment associatedwith Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:
Respondents provided the following comments related to the proposed scope of the MarineRisk Assessment:
• The proposed scope of the Marine Risk Assessment is inadequate and flawed, because ofthe inability to mitigate constant cumulative industrial impacts on the marine environment,including: (2)
o Increased ballast water discharges and associated risk of introducing invasivespecies
o Oil spillso Vessel noise (especially as it affects the southern resident killer whales)o Anchoring for queuing and/or bunkeringo Vessel traffic related to tug assists and any bunkering-related vessel traffic
• The permit should include a rigorous review of the risk and consequences of all accidentsand spills of any kind along the route and potential adverse impacts, including a discussionof: (2)
o The owners, operators and crews of project vesselso An assessment of the risk of all types of project-related vessel accidentso The types and volumes of propulsion fuel that would be carried by project-related
OGVso The safety-communication systems and equipment that would be on board each
project-related vessel and how it would be maintainedo Rescue protocols and maritime accident response infrastructure along the route to
open oceano Operational discharges of oil from project-related vesselso Who would pay costs for all impacts resulting from a project-related accidento Increases in the number of vessels transiting through the Salish Seao The introduction of additional bunker-fuelled Panamax vessels to the Fraser River
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Respondents also stated the following related to the proposed scope of the Marine Risk Assessment:
• Support for the proposed scope of the study (1)• Questions about the impacts of deep water vessels anchoring, including: (1)
o Impacts on shellfish, crab and nursery fish throughout the whole project areao The diameter of impact on and damage to the sea flooro The current anchorage patterns are for all oil tankers, tar sands bitumen ships, and
proposed coal shipso Impacts on fisheries throughout the anchoring area if the sea floor is often displaced
• New marine risk models must include cumulative impacts of newly approved and pendingprojects that will impact the South Arm of the Fraser River, including the recently certifiedVAFFC Jet Fuel Terminal project, the George Massey Tunnel Replacement project, and LNGterminal expansion at Tilbury (1)
• Any dredging of the Fraser River or other seaway modifications must be identified in theMarine Risk Assessment, and in turn be referred to in the EIA (1)
• Request for more information regarding the ultimate limits on OGV size that can beaccommodated at FSD, including questions about: (1)
o The factors (draught, basin size, river dynamics, etc.) that limit the ability toaccommodate ships larger than Panamax (i.e., 12 m draught, 32 m beam, 290 mlength)
o Any further modifications of the Fraser River required, particularly at the GeorgeMassey Tunnel location, to accommodate Panamax vessels, or larger vessels beingcontemplated
o Current or future plans to dredge the Fraser River to a depth of 18 metres• The study needs to completely re-evaluate impacts (1)
Respondents also provided the following comments, not directly related to the scope of the Marine Risk Assessment, for the amendment under consideration:
• The use of OGVs rather than barges is safer because it will decrease vessel movements andtherefore decrease risk of an accident, and because OGVs will require pilots, which will adda level of marine safety (6)
• The destruction of our food chain and of the marine environment would have a huge globalimpact; investments should instead be made into clean energy projects (2)
• The safety record of deep sea marine traffic on the Fraser River is exemplary (1)
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5. Environmental Management Plan (EMP), which will be completed by Soleil EnvironmentalConsultants Ltd.
An overview of the proposed scope of this study can be found on page 11 of the DiscussionGuide, and the original study can be found at www.fsd.bc.ca/amendment.
Please provide comments on the proposed scope of the Environmental Management Plan(EMP) associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No.2012 – 072:
Respondents provided the following comments related to the proposed scope of theEnvironmental Management Plan:
• The scope of the Environmental Management Plan should be broader to include: (2)o Analysis beyond the proposed loader to see if there is something that would better
reduce coal dusto The cumulative impacts of newly approved and pending projects that will impact
the South Arm of the Fraser River, as they relate to the new type of Panamax vesselbeing proposed
• There should be containment and catch basins on the dock face (1)
• Support for the proposed scope of the study (1)
Respondents also provided the following comments, not directly related to scope of the Environmental Management Plan, for the amendment under consideration:
• The Environmental Management Plan is flawed because: (2)o Mitigation statements to manage risk are unable to mitigate global environmental
impactso The proposed project would ensure that public dollars are used to construct a
flawed project• The project is close to environmentally sensitive areas like Burns Bog (1)• There is a lack of confidence in Environmental Management Plans and the ability to
adequately manage emergencies, given the oil spill in English Bay in 2015 (1)• There are concerns about the impacts on the environment (1)• There are concerns about the potential effects on marine life and wildlife (1)
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6. Water Management Plan, which will be completed by Omni Engineering Inc.
An overview of the proposed scope of this study can be found on page 11 of the DiscussionGuide, and the original study can be found at www.fsd.bc.ca/amendment.
Please provide comments on the proposed scope of the Water Management Plan (WMP)associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 –072:
Respondents provided the following comments, not directly related to the scope of the Water Management Plan, for the amendment under consideration:
• Support for the proposed scope of the study (2)
• The scope of the Water Management Plan should be widened, because: (2)o It neglects to deal with FSD’s contribution to the destruction of the environment,
including damage to air, the river system and human healtho It should include a review of submissions received during Metro Vancouver’s public
comment period related to FSD’s waste discharge permit application
• The study needs to completely re-evaluate impacts (1)
• A request for further information regarding the feasibility for treatment of FSD’s sitewastewater through Metro Vancouver’s Annacis Island Wastewater Treatment Plant (1)
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Respondents provided the following comments related to the proposed scope of the WaterManagement Plan:
7. Fire Life Safety Plan, which will be completed by Hatch Mott MacDonald
An overview of the proposed scope of this study can be found on page 12 of the DiscussionGuide, and the original study can be found at www.fsd.bc.ca/amendment.
Please provide comments on the proposed scope of the Fire Life Safety Plan associated withFraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:
Respondents provided the following comments related to the proposed scope of the Fire LifeSafety Plan:
• Support for the proposed scope of the study (2)
• The Fire Life Safety Plan is flawed because we are unable to mitigate such risks to the environment, and because the plan will not be effective in stopping fires and preserving life/safety (1)
• The revision of the Fire Life Safety Plan is good; however, there are outstanding questions,including: (1)
o Whether Delta and Surrey Fire Departments will assist in fire responseo Whether a more accessible route will be provided for emergency access to FSD
Respondents also provided the following comments, not directly related to the scope of the Fire Life Safety Plan, for the amendment under consideration:
• FSD should not stockpile thermal coal, due to problems with spontaneous combustion (1)• Concerns about potential impacts to the environment from a fire, including pollution (1)
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8. Spill Response Plan, which will be completed by Fraser Surrey Docks LP
An overview of the proposed scope of this study can be found on page 12 of the DiscussionGuide, and the original study can be found at www.fsd.bc.ca/amendment.
Please provide comments on the proposed scope of the Spill Response Plan associated withFraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:
Respondents provided the following comments related to the proposed scope of the SpillResponse Plan:
• There is a lack of confidence in the Spill Response Plan because: (2)o It is unable to mitigate spillso The containment of the oil spill in English Bay in 2015 was inadequate
• Impartial experts, especially those who have experience with larger port management,should assist with the review (1)
• The plan must now account for the handling of bunker fuels typically used by Panamaxvessels, any accessory activities (such as bunkering of docked ships), and impacts over theentire length of the South Arm of the Fraser River (1)
• The plan must account for an increase in vessel movements of up to 80 return-trip vesselmovements and the greater consequence of a potential marine accident involving OGVs,rather than tug and barge (1)
• The risk and response evaluations must be put into context of other newly approved andpending projects in the South Arm of the Fraser River that will result in a significant increasein OGV transits (1)
Respondents also provided the following comments, not directly related to the scope of the Spill Response Plan, for the amendment under consideration:
• Increased shipping and its accompanying risk of a major rail or marine spill could adverselyimpact the environment, economy and quality of life of the Salish Sea (3)
• There is a lack of confidence in this kind of plan’s effectiveness (1)• All OGVs are required to have an agreement with WMRCC who will respond to any incident
involving a release of fuel oil; there have been no fuel oil releases that the Pilotage Authorityis aware of while under the conduct of a Fraser River Pilot (1)
• If there were no use of coal, there would be no spill (1)
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9. Additional Comments
Please provide any additional comments on the proposed application to amend Permit No.2012 – 072:
Respondents provided the following comments:
• Opposition to the project (23)o General opposition to the projecto Concerns that the facility would be built in a densely populated areao Opposition to export of coal in several U.S. stateso Concerns that the facility will only benefit producers and customers of coal, not the
local communityo Local municipalities and Metro Vancouver are opposed to the export of coal in the
Fraser River area
• Concern regarding the coal industry’s impacts on the environment, including carbonemissions, climate change and pollution, and the fact that it is an industry that is already indecline (11)
• Concern with the process, including the approval process, and a lack of meaningful publicconsultation, including: (7)
o Concerns about the short notice for the public comment period (which includeda major holiday weekend)
o Concerns that the notification postcard was not received by many residents of thearea
o Requests for a longer consultation period on the permit amendment application inorder to review material
o A need for FSD to properly consult the Mayor and Councillors of New Westminstero Concerns that the solicitation of public comments occurred before all of the studies’
updates have been completedo General concerns about the permit processo A request that an independent Medical Health Officer be involved in the final
decisiono Concerns about the lack of public input and the lack of a public health assessment of
American thermal coalo Concerns that, once the studies are complete, Port Metro Vancouver and FSD
should conduct a public information meeting on the amendment application toensure the public has the opportunity to fully understand the implications of theproposal
• Opposition to the proposed amendment (6)o General opposition to the proposed amendmento Concerns that the final project will be monstrous compared to the original
considerations (e.g., larger volumes of coal and greater impacts on the surroundingenvironment) despite supporting the original application
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• Support for the proposed permit amendment (3)
• Reiterated original support for the project, due to: (3)o The substantive and comprehensive research and professional reviews of the project
planso The changes related to the amendment that will reduce marine traffic, reduce dust
impacts, improve the industrial footprint and reduce water runoff from theoperation
• Concern whether FSD will listen to concerns raised in this comment period (3)
• The monetary benefits of FSD’s Direct Transfer Coal Facility do not offset the cost to theenvironment or communities (2)
• Concerns about having more coal and ships near the Fraser River and on FSD’s site (2)
Respondents also provided the following comments expressing concern about the environmental impacts of the project: • If George Massey Tunnel is replaced with a bridge, FSD will begin exporting larger volumes
of coal on bigger vessels, which will mean increased adverse impacts from more coal trains through communities, more noise, diesel exhaust and coal dust, and more ship traffic in the Salish Sea (1)
• Tourism is a very valuable industry in San Juan County, and there are concerns aboutimpacts on the Salish Sea’s human residents and thousands of different species (1)
• People should use clean energy like solar or wave power (1)• Concern regarding tailings ponds; also, having a transfer facility on the Fraser River should
not be allowed (1)
Respondents also provided the following comments related to health concerns: • The project will have significant physical and mental health risks from light and noise
pollution (1) • Concerns about the health risks of coal dust (1)• The project seems to be a short-term decision that rests on the illusion of economic benefit,
while diminishing health and well-being of the community and increasing costs for thehealth care system (1)
June 2015 Fraser Surrey Docks LP Consideration to Amend Permit No. 2012 – 072 Consultation Summary Report 21
Respondents also provided the following comments related to coal dust: • From the perspective of a resident of New Westminster, the project should not proceed,
and coal dust travelling from FSD across the Fraser River and into the home is undesirable(1)
• The efficacy of techniques for minimizing coal dust is questionable, especially given theinability to contain dust from other export goods and there are concerns that suchtechniques are very costly and unlikely to be implemented (1)
• The increased risk of fire from the amount of coal dust is too great (1)• FSD should pick whichever method minimizes coal dust (1)• There are concerns about air quality from airborne pollution and coal dust, and potential
impacts of poor air quality on human health, such as allergies and asthma (1)
Respondents also provided the following comments related to the project and the proposed amendment:
• Proposals to ship coal from ports along the U.S. west coast have met resistance, and it isquestionable that this project would be permitted in B.C. (1)
• Concerns about the potential impacts on property values (1)• Concerns about long-term impacts on residents, including quality of life concerns (1)• Coal is important because it is a major economic driver in British Columbia, and it powers
homes, businesses and communities in 40% of the world (1)• Rail is the most fuel-efficient means of transporting goods and commodities; coal trains are
treated to ensure that coal dust is contained as trains pass (1)• Any proposed changes to the existing permit must clearly identify the number and size of
OGVs, since it is unclear whether the Discussion Guide identifies the project as having thepotential for 80 OGVs (160 vessel movements/transits) or 40 OGVs (80 vesselmovements/transits) (1)
• A full and complete study should be required that covers the environmental impacts andhealth concerns related to the project in consideration of the amendment (1)
• The risks to public health, the environment, and water quality are not in the public interest(1)
• Concern about railcar topping agent in FSD’s wastewater that will be discharged to thesewer system (1)
• If there is an accident at FSD, other ports will suffer (1)• Cutting down marine traffic from 8 barges to 1 OGV is misleading (1)• This seems like a bait-and-switch technique (1)• B.C. businesses face opposition based primarily on aversion to carbon-based products, but
these groups do not heed the fact that coal is a legal, legitimate product that has been safelyshipped through B.C. ports for decades (1)
• The direct transfer from train to OGVs presents an increased logistical risk related to thetiming of coal arrival and ship availability; this respondent stated opposition to thestockpiling of coal at this facility (1)
• If coal must be transported, the United States should transport their own product (1)
June 2015 Fraser Surrey Docks LP Consideration to Amend Permit No. 2012 – 072 Consultation Summary Report 22
• Supportive of FSD’s ongoing commitment to further air, water and human health studiesand expressed confidence in FSD’s ability to meet or exceed Port Metro Vancouver’s criteria (1)
• Request for access to the same details provided to the various contractors (like SNC-Lavalin)about the specifics of the amendment, as more information would be helpful to the publicin giving more feedback on the scope of the studies (1)
• Opposition to the original application for proposed expansion of coal exports at FSD until:(1)
o An independent third-party Health Impact Assessment has been completedo Port Metro Vancouver holds formal public hearings regarding the proposed project
at FSD• A report (as an appendix to the respondent’s submission) outlines concerns with FSD’s
original proposal, including the scope of the environmental impact assessment, stormwatermanagement, dust control, noise control, erosion and sediment control, flood risk, healthimpact assessment and consultation with staff (1)
• The Port Authority lacked the authority to issue the Permit to FSD or to make adetermination under s.67(a) of the Canadian Environmental Assessment Act (1)
• With or without an amendment to the permit, a key outstanding requirement is thedevelopment of a final Air Quality Management Plan and the submission of a final MetroVancouver Air Quality Permit application (1)
• Request to Metro Vancouver for the involvement of the Independent Interagency ReviewCommittee in this process (1)
June 2015 Fraser Surrey Docks LP Consideration to Amend Permit No. 2012 – 072 Consultation Summary Report 23
3.2 Key Themes – Agency Meeting
The following are key themes from FSD’s meeting with the Fraser Health Authority on May 15, 2015. As much as possible, the language expressed by participants was retained in the key themes.
Meeting Key Themes Fraser Health Authority May 15, 2015 9:15 a.m. to 10:15 a.m.
ATTENDEES • Chief Medical Health Officer, Fraser
Health Authority (FHA)• Medical Health Officer, Fraser Health
Authority• President and CEO, Fraser Surrey Docks
LP (FSD)• Senior Project Specialist, SNC-Lavalin
Environment (SNC)
NOTE TAKER • Kirk & Co. (Meeting Recorder)
Agency representatives noted the following:
• That the concerns expressed by the Fraser HealthAuthority are not specifically related to the proposedamendment, but rather to the overall scope of thestudies that have been undertaken
• That the original Human Health Risk Assessment (HHRA)was satisfactory, and that the scope of study beingundertaken for the HHRA in consideration of theproposed amendment is acceptable, but that a fullHealth Impact Assessment is recommended
• That a Health Impact Assessment would be mutuallybeneficial, in terms of looking at all factors, identifyingpotential future risks and mitigation, and providing abalanced approach for moving forward
• That a project such as this could have impacts beyondthe scope of the footprint, and without that dataavailable, it is difficult to reassure community concerns
• That Fraser Surrey Docks is studying what is within thescope set out by Port Metro Vancouver
• That the Fraser Health Authority was interested inreviewing the assessment of ocean-going vessels as partof the consideration to apply for an amendment, interms of both marine risk and emissions
• That the Fraser Health Authority would consult withMetro Vancouver for their opinion on the adequacy ofthe air quality monitoring undertaken
June 2015 Fraser Surrey Docks LP Consideration to Amend Permit No. 2012 – 072 Consultation Summary Report 24
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Taylor P l
Path
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Pl
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er S
t
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E E ig hth Ave
Access Rd
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lumb
ia S
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Manzani ta Pl
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Cre s
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yal A
ve
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Hil l Ave
1 0th Ave E
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on S
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Hamilt on S t
Ames
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10 th Ave
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110 Ave
125
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Park Cres
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4th S t
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on S
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1 5 th Ave
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Sequo ia Rd
Er in Ave
109 Ave
Mona A ve
Cher
r y S t
Crai
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y S t
Ches
tnu t
St
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Rd
Garre
t t St
C anfo r Ave
124
St
125A
St
Mu sq ueam Dr
Qua ys id e D r
E Six th A v
e
Agnes S t
Bra id St
Fron t StTenth St
Ri ch mo n d St
Rich
mond
St
Fu rness S t
N orth Arm
Fraser
River BridgeviewPark
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SappertonPark
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George DerbyConservation Area
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SS1
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Rd Hwy 1
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SS7
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To
Q uee nsborough Bridge
Front St
19th Ave
Marlb
orou
gh A
ve
Graham Ave
Elgin
Ave
Audley Blvd
Twenty-Second S t
Irmin St
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Humphries Ave
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Duncan St
Nordel Crt Modesto Dr
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South
Fras
er Way
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tford
Ave
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McBrid e Blvd
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83 Ave
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Wood St
Bryant St
Stanley St
80 Ave
Main St
Sixteen th S t
2nd St
Balmoral St
Griffi
ths A
ve
Trapp Ave
Salis
bury
Ave
Chester Rd
Stride Ave
18th AveThird St
108 S
t
Eleventh St
Meadow Ave
Beresford St
Brooke Rd
Sper
ling A
ve
Dubl in St
Seventh St
Mary Ave
Carnarvon St
Riverbend Dr
Hwy 91A
11th Ave
Dunlop Rd86 Ave
Willard St
17th Ave
Annaci
s Pky
Cl inton St
Dyke Rd
Thirteenth St
Nanaimo St
Cumbe rland S t
Elwell St
6th St
Hamilton S t
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Fifth St
Mar ine Way
Byrne Rd
Nevi lle St
Westminster Hwy
Fraserwood Way
Seventh Ave
13th Ave
South
Fras e
r Per im
i ter Rd
Queens Ave
Southridge Dr
Second St
Firs t St
Salter St
London St
82 Ave
14th Ave
84 Ave
Fourth AveFifth Ave
South Dyke Rd
River Rd
Fourth St
North F raser Way
Edmonds St
Edinburgh St
Ewen Ave
Gille
y Ave
12th Ave
Cliveden Ave
Derwent Way
South Fraser Perimiter Road
87 Ave
Lake
view
Ave
Duffe
rin A
ve
River Dr
Olive
r Dr
McGr
egor
Ave
Dock
RdWiggins St
Walth
am A
ve
MacP
herso
n Ave
Quayside Dr
E Sixth
Ave
114
St
Agnes St
Boun
dary
Rd
Belgrave Way
Wil tshi re Blvd
4th St
Walker Ave
Bulle
r Ave
10th Ave Tenth St
116
St
G lenb roo k Dr
Third Ave
Kendale View
Rowl
ing
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Delsom Cres
Quayside Dr
Surrey
Delta
Burnaby
Richmond
NewWestminster
96 Ave
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88 Ave
80 Ave
Stewardson Way
Rumble St
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Eighth Ave
Marine Dr
Marine Way
River Rd
112 S
t
Roya
l Oak
Ave
Nordel Way
McBride Blvd
10th AveKingsway
Hwy 91
Queensborough Bridge
Hwy 91
Hwy 91
Hwy 91 A
North Arm
Anna
cis Channel
Gund
ersen
Sloug
h
Fraser Rive
r
SS91
Froggers CreekRavine Park
Methews CreekRavine Park
KisbeyPark MalvernPark
QuennsParkPowerhousePark
Byrne CreekRavine Park
Ron McLeanPark
AlbertCrescent
E WoodlandsVegetation Study A
AnnievillePark
NorthDelta ParkSunburyPark
WillardPark
MackiePark
RoyalHeights Park
Burnaby FraserForeshore Park
Delta NatureReserve
EastburnKelvin
West End
GlenbrookeNorthMiddlegate
Queensborough
ConnaughtHeights
NorthDelta
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BCFSA / RTA: V3M
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Audley Blvd
To
Qu eens b or ough Bridge
Southpoint Dr
Twenty-Second S t
Elwell St
Ho lt R d
97 Ave
Duncan St
Q uee
n Mary Blvd
Boyne St
103A Ave
St Andrews Dr124 St
103 Ave
122 S
t
P ark Dr
143A
St
Indus
tr ial R
d
Howes St
111 Ave
Alaska
Way
121 S
t
Ol d Yale Rd
109 Ave
128A
St
138 S
t
123A
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105 Ave
101 Ave
Semiahmoo Rd
130 S
t
108 Ave
139 S
t
107 Ave
127 S
t
Salis
bury
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141 S
t
106 Ave
98 Ave
94 Ave
Eighteenth St
90 Ave89A Ave
Br idgeview Dr
K indersley Dr
McBride Blvd
Pembina St
Ash St
Ninth St
Timberla
nd
Rd
Southridge Dr
110 Ave
96A Ave
Wood St
106A Ave
112 Ave
115A Ave
Tannery Rd
136 S
t
18th Ave
Mary AveSixteenth St
11th Ave
105 Ave
107A Ave
Cumberland St
Chester Rd
129 S
t
158 S
t
115B AveStrid
e Ave
Third St
116A Ave
Eleventh St
113 Ave
91 Ave
Marine Way
Westm inster Hwy
98 Ave
Dublin St
114 Ave
Seven th S t
Carnarvon St
105A Ave
Hwy 91A
102 Ave
112 Ave
Annaci
s Pky
Thirteenth St
Nanaimo St
103A Ave
Edmonds S t
Hamil ton St
Four teenth St
Fifth St
16th Ave
Grace Rd
90 Ave
150
St
S eventh Ave
116 Ave
South
Fras
er Way
Queens Ave
12th Ave
First St
Second St
Salter St
London St
14th Ave
144 S
t
115 Ave
Fourth Ave
99 Ave
Nordel Way
Fifth Ave
South Dyke Rd
Wha
lley
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Four th St
Cliveden Ave
South Fraser Pe rimiter
Road
Edinburgh St
100 AveSouth
Fras
er Peri
miter R
dEwen Ave
92 Ave 92 Ave
100 Ave
148 S
t
157 S
t
Front St
87 Ave
129A
St
Green Timbers Way
123 S
t
Gle n Avon Dr
F le etwood W
a y
118
St
Carluke Cres
142A St
Surrey Rd
River Dr
125A
St
143 S
t
142 S
t14
2A S
t
146 S
t
151 S
t
Dock
Rd
125 S
t
R ich mo nd St
126A
St
Ro xburgh Rd
Musqueam Dr
Quayside D r
146 S
t
114
St
Agnes St
Boun
dary
Rd
Belgrave Way
124 S
t
City
Pky
156 S
t
154 S
t
South Frase r Perimiter Rd
Prince Charles Blv d
Universi ty Dr
10th Ave
126 S
t
Tenth St
134
St
116
St
115A St
140 S
t
132 S
t
96B Ave
Third
Ave
G ing e r Dr
King Rd
Derwent Way
Quayside Dr
Surrey
Coquit lam
Delta
PortCoquit lam
Burnaby
NewWestminster
Scott R
d
Boyd St
Nordel Way
112 S
t
Twentieth St
Griffiths Dr
E Colum
bia St
Derwent Way
Sixth St
Sixth Ave
River Rd
Eighth Ave
108 Ave
104 Ave
96 Ave
120 S
t
Twelfth St
Grosvenor Rd
128 S
t
King
George Hwy
Kingsway10th Ave
Fraser Hwy
King George Blvd
Hwy 91
Hwy 91
Hwy 1
Hwy 91 A
Hwy 91A
North Arm
Annacis ChannelFra
ser River
SS91
SS1
LowerEllendale Park
VictoriaPark
RoyalKwantlen Park
HollandPark
Green TimbersUrban Forest
HawthornePark
HjorthRoad Park
HollyPark
RichmondPark
QuennsPark
WillardPark
DelviewPark
RoyalHeights Park
InvergarryPark
QueensParkEastburn
WhalleyPortMann
Kelvin
JohnsonHeights
West End
GlenbrookeNorthMiddlegate
Queensborough
ConnaughtHeights
NorthDelta
Bridgeview
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FSA MapCarte de RTA
Copyright © Canada Post Corporation, 2015 - This map is provided for the sole use of Canada Post customers in preparing their mail. Any other use, including resale and the use of the map as a component of another product or service, is strictly prohibited. The map is provided "as is" and Canada Post disclaims any warranty whatsoever. The map must be used only during the validity period noted and must be destroyed following the expiry of such validity period. If no validity period is indicated on the map, the map must be destroyed 30 days from the date you obtained the map from Householder Counts & Maps. All rights not expressly granted are reserved by Canada Post and its licensors.Tous droits réservés © Société canadienne des postes, 2015 - L'utilisation de cette carte est réservée exclusivement aux clients de Postes Canada pour la préparation de leur courrier. Toute autre utilisation, y compris la revente ou l'utilisation de la carte comme complément à un autre produit ou service, est strictement interdite. La carte est fournie « telle quelle » et Postes Canada décline toute garantie de quelque nature que ce soit. La carte ne peut être utilisée que pendant la période de validité susmentionnée et doit être détruite après l'expiration de ladite période de validité. Si aucune période de validité n'est indiquée sur la carte, la carte doit être détruite dans les trente jours suivant la date où vous l'avez obtenue par Nombre de chefs de ménage et cartes. Tous les droits qui ne sont pas expressément accordés dans le cadre des modalités d'utilisation sont réservés à Postes Canada et à ses concédants.
The Delivery Mode names that have an asterisk (*) indicate Modes that are split between more than one (1) FSA.Les noms des modes de livraison avec un astérisque (*) indiquent des modes partagés entre plusieurs RTA.
H al l Pl
Brandy D r G re e nh i l l Pl
10 9B St
115
St11
5 St
Da ly Pl
76 Ave
119
St
114A
St
71 Ave
Gi roday PlWh itb y Pl
94 Ave
113
St
8 8A A ve
Sterl ing Cr t
Arbou r P l
Shea
ves C
rt
Evans P l
T urne
r Pl
G i l m our C res
78 Ave
S ta m ford
Pl
V i sta P
l
Bo yn ton P l
Sunse t D r
Daws on P l
117B
St
76A Ave
74B Ave
Hw y 91
111B
St
Knudson Rd
Wadham Dr
82A Ave
84B Ave
79 Ave
83 Ave
85B Ave
Aud ley B lvd
83A Ave
G lenb rook Pl
83 Ave
118B
St
Bever l y D r
75B Ave
84A Ave
Hardy P l
112A
St
85A Ave
M alt o n Dr
Queens Pl
114A
St
90A Ave
Tron
dhei
m D r
118A
St
113B St
Ebor
Rd
Fir cr
est Dr
Royal Cres
Parkw
ood P l
Nechako Dr
1 18A
St
112A
St
111A
St
S u l livan P l
120A
St
79 Ave
Taylo r Way
Carl is le Rd
Car v
er Cres
76A Ave
Ke nd ale Pl
93A Ave
84 Ave
11 0A St
115A
St
113A
St
9 2A Ave
Alaska
Rd
118A
St
Ba rk ley D r
River W
ay
Larson Rd
87 Ave
93A Ave
86A Ave
Princess D r
Iv e r son C res
Cund
y Ave
111
St
Skagi t Dr
Crow n Cr es
120A
St
M odes to P l
Wi l tsh ire P l
Warwick Rd
M i nster Dr S
93 Ave
96 A ve
118A
St
R iver R
d
114
St
Hea th Cres
74 A ve
116A S t
Ram ona Way
De lc res t D r
Pa tr ic ia Dr
91 Ave
Fu lle r C res S
83A Ave
Gle nr ose D r
78 Ave
74A Ave
80A Ave
98 Ave
110
St
78B Ave109A
St
Bu rbank Dr
E le va tor Rd
Brem
r idge
Dr
114A St
He rmosa D r
91 Av e
77A Ave
115
St84B Ave
82B Ave
78B Ave
94A Ave
95 Ave
82A Ave
79A Ave
Fairfie ld P l
112B
St
115
St
Shepherd Way89A Ave
Gunde
rson R
d
78A Ave
113B
St
117B
St
117
St
118
St
Made r Lane
116
St
81A Ave
71A Ave
75 Ave
97A Ave
Swen
son
Way
Nich
olso
n Rd
W estv
i ew D r
Yor k C res
79A Ave
Hard
y Rd
118
St
Ca ldew S t
85B A ve
Fu ll er Cres N
120A
St
Norde l Way
De lv is ta Dr
Westsi de Dr
114A
St
81A Ave
86A Ave
117A
St
Co l l ings Way
No rum
Rd
81 Ave
Norde l Cr t
85 Ave
A ldf
ord
Ave
79A Ave
B r id l i ng ton Dr
Garre tt Dr
Pemb
erto
n Cr
es
119
St
7 2A Ave
112
St87A Ave
111 St
77 Ave
73 Ave
Terrace D r
81 Ave
110
St
Cent re S t
Dawson Cres
R obso
n Rd
Rus sell Dr
89 Ave
111B
St
Kenda le Way
South F ras
er P eri
mi t er Rd
89A Ave
Holt Rd
72A Ave
D elwo od Dr
92 A Ave
94 Ave
84A Ave
73A Ave
97 Ave
119A
St
M ode sto Dr
115A
St
85A Ave
Garfie ld Dr
M on roe Dr
Alaska
Way
114
St
C l iveden Ave
96A Ave
83 Ave
Santa Monica Dr
80 Ave
Main St
B a rr ymo re Dr
Brooke Rd
Dunl op Rd
75A Ave
92 A ve
90 A ve
115
St
No rde l Way
86 Ave
82 Ave
84 Ave
South F ras er Per im i ter Road
117
St
Bat e
s Rd
Wa lkw ay
80A Ave
120 A St
Watson Cr t
119B St
Jam e s Pl
119
St
118
St
Fe rn Way
Cow ley D r N
116A
St
Sunbu ry Pl
Byro
n Rd
113A
St
F iley Dr
Brew
ster
Dr E
Stegav ik C rt
A rp e Cr es
Canyon Cres
Mins
ter D
r E
112A
St
115A
St
Dels om Wa y
N orum C r es
110A
St
108
St
117A
StMi
tch e
ll Way
112A
St
Mins
t er D
r W
B rews ter Dr W
Don cas t
er Cr
es
8 6A Ave
De lnova Dr
Blake Dr
Watson D r
Har rog ate Dr
117A
St
Sheaves Rd
Suncrest Dr
S wa n
son D
r11
3 St
Sca rbo r ough Dr
119A St
McAdam Rd
87 Ave
74 A ve
118
St
116A
St
Be lg rave Way
D elsom Cres
114
St
117
St
118
St
108
St
W il t sh i re B l vd
116 St
116B
St
85 Ave
95 Ave
95A Ave
119A
St
113B
St
78 Ave
95A Ave
88A Ave
116A
St
Craw
ford
Dr
Der w
ent W
ay
Kend ale View
Ann acis Chan nel
Gunde
rsen S
lough
Fraser Rive
r
KennedyPark
AnnievillePark
NorthDelta Park
MackiePark
DelviewPark
RoyalHeights Park
Delta NatureReserveChalmersPark GundersonPark
90 Ave
Regal Dr
88 Ave
96 Ave
80 Ave
72 Ave
Nordel W
ay
River Rd
112 S
t
120 S
t
Hwy 91
Surrey
Delta
NorthDelta
SS91
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V3V
V3M
V4E
V3W
V4G
V4C
LB0001
LB0001
DR0000
0 0.25 0.5 0.75 10.125 km ±
BCFSA / RTA: V4C
FSA MapCarte de RTA
Copyright © Canada Post Corporation, 2015 - This map is provided for the sole use of Canada Post customers in preparing their mail. Any other use, including resale and the use of the map as a component of another product or service, is strictly prohibited. The map is provided "as is" and Canada Post disclaims any warranty whatsoever. The map must be used only during the validity period noted and must be destroyed following the expiry of such validity period. If no validity period is indicated on the map, the map must be destroyed 30 days from the date you obtained the map from Householder Counts & Maps. All rights not expressly granted are reserved by Canada Post and its licensors.Tous droits réservés © Société canadienne des postes, 2015 - L'utilisation de cette carte est réservée exclusivement aux clients de Postes Canada pour la préparation de leur courrier. Toute autre utilisation, y compris la revente ou l'utilisation de la carte comme complément à un autre produit ou service, est strictement interdite. La carte est fournie « telle quelle » et Postes Canada décline toute garantie de quelque nature que ce soit. La carte ne peut être utilisée que pendant la période de validité susmentionnée et doit être détruite après l'expiration de ladite période de validité. Si aucune période de validité n'est indiquée sur la carte, la carte doit être détruite dans les trente jours suivant la date où vous l'avez obtenue par Nombre de chefs de ménage et cartes. Tous les droits qui ne sont pas expressément accordés dans le cadre des modalités d'utilisation sont réservés à Postes Canada et à ses concédants.
The Delivery Mode names that have an asterisk (*) indicate Modes that are split between more than one (1) FSA.Les noms des modes de livraison avec un astérisque (*) indiquent des modes partagés entre plusieurs RTA.
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015
Public Comment PeriodConsideration to Amend Permit No. 2012 – 072 Direct Transfer Coal Facility
May 4 – 19, 2015
Discussion Guide and Feedback Form
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 20151
Consideration to Amend Permit No. 2012 – 072 Direct Transfer Coal Facility On August 21, 2014, Fraser Surrey Docks LP (FSD) was granted a permit by Port Metro Vancouver that gives it conditional approval to build and operate a Direct Transfer Coal Facility within its existing lease area.
FSD is considering applying to amend its existing permit. The proposed amendment would allow FSD to load coal directly from the facility to ocean-going vessels (OGVs). Using OGVs would allow FSD to eliminate or reduce the number of barges required. The proposed amendment to the existing permit would have no impact on the volume of coal permitted to be shipped through FSD (4 million metric tonnes per year).
This Discussion Guide outlines aspects of the existing permit FSD is considering applying to amend, and seeks comments on the proposed scope of studies associated with the potential amendment to Permit No. 2012 – 072.
How Can I Provide Feedback?
• Provide a written submission• Submit your Feedback Form:
• Online• By email• By mail
Reporting
• Community and stakeholder feedback willbe summarized and posted online atwww.fsd.bc.ca/amendment
Correspondence and Inquiries
• Telephone: 604 - 891-1695
• Web: www.fsd.bc.ca/amendment
• Email: [email protected]
• Mail: PO Box 2233 Vancouver Main, Vancouver, BC V6B 3W2
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 2
Port Metro Vancouver Permit Process Port Metro Vancouver is the permitting authority for the proposed amendment.
On August 21, 2014 Port Metro Vancouver issued a Project Permit to Fraser Surrey Docks LP (FSD)for the development of a Direct Transfer Coal Facility to handle up to 4 million metric tonnes of coal, per year.
The permitting process considered environmental and technical information, as well as First Nations, municipal, agency, and community input.
In completing its federal environmental review, and as per Section 67 of the Canadian Environmental Assessment Act 2012 (CEAA 2012), Port Metro Vancouver considered the information and the proposed mitigation measures provided by FSD, along with other relevant information. Port Metro Vancouver concluded that, with the implementation of proposed mitigation measures and subject to the conditions of the permit, the project is not likely to cause significant adverse environmental effects.
Round 1Public Comment PeriodConsideration to Amend Permit No. 2012 – 072
Review of proposed changes to the existing permit and proposed scope of studies.
May 4 – 19, 2015
Round 2Public ConsultationIf FSD submits the proposed amendment, the public will be provided with an additional opportunity to review and comment on changes to the project design and on the final results of the studies.
Fraser Surrey Docks LP (FSD) is the largest employer on the Fraser River waterfront, with more than 300 full-time employees. FSD has been a major employer and contributor to local communities for over 50 years, handling over 3 billion dollars-worth of goods annually. FSD has directly contributed over 280 million dollars to B.C. communities over the last 5 years through wages, taxes and buying of local goods and services.
There will be two opportunities to provide input regarding the proposed amendment. FSD will consider your input, along with information provided by technical experts, as part of its consideration to apply for an amendment to the existing permit.
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 20153
Overview of Changes Under ConsiderationConsideration to Amend Permit No. 2012 – 072 Direct Transfer Coal Facility
Fraser Surrey Docks LP (FSD) is considering applying to amend its existing permit (Permit No. 2012 – 072) that gives it conditional approval to build and operate a Direct Transfer Coal Facility within its existing lease area.
The application to amend the existing permit would have no impact on the volume of coal permitted to be shipped through FSD (4 million metric tonnes per year).
The proposed amendment would allow FSD to load coal directly from the facility to ocean-going vessels (OGVs) and would allow FSD to eliminate or significantly reduce the number of barges required. One loaded Panamax size OGV can carry approximately four train loads of coal, and the same volume as eight loaded barges (i.e. 1 OGV = 8 barges).
• The proposed amendment under consideration by FSD would increase the current size and height of the loader,allowing for direct loading to OGVs.
• Use of OGVs would replace most or all barges. If approved, FSD plans to replace all barges with OGVs, but wouldretain barging as a potential secondary option.
• It is anticipated that the use of OGVs would further mitigate the potential for fugitive dust, as coal would betransported in a closed hatch.
• The conveyance system, receiving pit and rail tracks would be shifted on site to accommodate the larger vesselloader.
• The footprint of the facility area would decrease, which would reduce the amount of rain water runoff collected.
Ocean-going Vessel
Ocean-going vessels would eliminate or reduce the number of barges required.One ocean-going vessel holds the same volume as eight barges.
1 8 Barges
=
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 4
The following are potential shipping scenarios based on 4 million metric tonnes per year:
* Numbers represent return-trip vessel movements.
Potential Shipping Scenarios Loaded Trains / Year Loaded OGVs / Year* Loaded Barges / Year*
Current permit approval 320 0 640
25% shift to OGVs (with proposed amendment)
320 20 480
50% shift to OGVs (with proposed amendment)
320 40 320
75% shift to OGVs (with proposed amendment)
320 60 160
100% shift to OGVs (with proposed amendment)FSD’s preferred operational scenario
320 80 0
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 20155
Potential Modifications to Original Project Design:
To accommodate a larger vessel loader, the conveyance system, receiving pit and rail tracks would be shifted in order to achieve proper angles and elevations. Primary changes would be as follows:
Project Features Approved Permit Proposed Amendment Application
Volume of coal shipped 4 million metric tonnes / year No change
Mode of shipping 1,280 barge movements / year based on 640 barge return trips
Use of OGVs to replace some or all barges
Marine Vessel Loader 14.3 metre (m) outreach (length of boom) from the edge of the berth and a maximum height of 15.0m
27.4m outreach from the edge of the berth and a maximum height of 36.2m
Receiving pit and building A fabric building spanning a 17m-in-length bottom discharge pit with 125 tonne surge bin
Metal-clad building; shifted 12m east and 16m south
Receiving building and pit dimension stay the same
Wastewater settling basins A two-stage primary and secondary settling basin with an approximate capacity of 300 m3
Shifted 37m west and rotated 90 degrees counter clockwise
Dimensions for settling basins stay the same
Also included is a 560,000 litre tank for contingency storage purposes for storm events
Basins would reside under the Out Feed Conveyor for more effective use of space and water management practices
Dust mitigation Dust mitigation measures meet regulatory standards
Additional dust mitigation through use of closed hatches on OGVs, spraying of empty outbound railcars
Overall water catchment area (Facility footprint)
5,340 m2 Decreased to 3,680 m2
Estimated to reduce water runoff by 10 -15%
Rail tracks Relocation of the front gate Adjustments to the rail loop; removal of Shed 4 and no relocation of the front gate
Jobs Estimated 20-25 full-time jobs An increase of up to 20 additional full-time jobs (total of up to 40- 45 new full-time jobs) due to extra shifts required to load OGVs (based on 100% shift to OGVs)
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 6
Studies Fraser Surrey Docks LP (FSD) is working with consultants, who are subject-matter experts, to update studies that were undertaken for the existing permit (Permit No. 2012 - 072). The updated studies will identify and analyze any potential impacts of the proposed amendment.
Studies to be updated with respect to the proposed amendment include:1. Human Health Risk Assessment (HHRA) – SNC-Lavalin Inc. (Environment & Water)
2. Environmental Impact Assessment (EIA) – SNC-Lavalin Inc. (Environment & Water)
3. Air Quality Assessment (AQA) – Levelton Consultants Ltd.
4. Marine Risk Assessment – DNV (Det Norske Veritas)
5. Environmental Management Plan (EMP) – Soleil Environmental Consultants Ltd.
6. Water Management Plan – Omni Engineering Inc.
7. Fire Life Safety Plan – Hatch Mott MacDonald
8. Spill Response Plan – prepared by Director of Engineering, Fraser Surrey Docks LP
Updated studies, as listed above, would be reviewed by Port Metro Vancouver, the regulating authority, as part of an application to amend Permit No. 2012 - 072.
FSD anticipates that Port Metro Vancouver will contract a third-party reviewer, Golder Associates Ltd., to assist in the review of the following studies:
• Human Health Risk Assessment (HHRA)
• Environmental Impact Assessment (EIA)
• Air Quality Assessment (AQA)
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 20157
1. Human Health Risk Assessment (HHRA) – SNC-Lavalin Inc. (Environment & Water)
A Human Health Risk Assessment (HHRA) was undertaken for the original project design. Port Metro Vancouver referred the HHRA for review by an independent third party (Golder Associates Ltd.), prior to the approval of Permit No. 2012 – 072.
In consideration of the proposed amendment, SNC-Lavalin will undertake a review of the HHRA (July 2014) to understand the impact of the proposed amendment on health risks. Human health risk assessments are tools used to determine if people will be safe if they are exposed to substances that are in the environment, food, or consumer products. The review of the HHRA will look at a comprehensive list of substances which may be present in emissions that could arise from the proposed amendment.
The HHRA will be updated, in part, based on the results of the Air Quality Assessment (AQA) conducted by Levelton Consultants Ltd. (Levelton) for the proposed amendment. A comprehensive list of emission sources will be evaluated in the AQA including the proposed coal operations at Fraser Surrey Docks LP (FSD) (i.e. emissions from marine vessels, and fugitive dust generated from material transfer points, as well as during coal unloading and loading), and in-transit emission sources (including emissions from marine vessels on the Fraser River).
SNC-Lavalin has reviewed the HHRA and based on their understanding of the proposed amendment, determined that the following areas of the report that will require further analysis:
• The HHRA will be updated to reflect Levelton’s AQA results;
• Exposure Point Concentrations (EPCs) will be interpreted based on the updated Levelton AQA results. EPCs areused to estimate exposures to fugitive dust and combustion emissions at specific geographic locations; and,
• Risk estimates associated with exposures to the emissions will be re-calculated based on updated EPCs, and theresults of the HHRA will be reviewed and updated as necessary.
The remaining sections of the HHRA require only minor edits as they are accurately described and remain applicable with respect to the proposed amendment, such as the scope of the HHRA, project location, baseline and rail corridor EPCs and associated risk estimates.
To facilitate an update of the proposed amendment application, SNC-Lavalin will revise the July 2014 HHRA report, and summarize the revisions in a technical memorandum.
SNC-Lavalin will:
• Review the description of refinements to the project associated with the proposed amendment;
• Review the extent to which the HHRA accurately estimates human health risks, taking into account the refinementsto the project associated with the proposed amendment;
• Describe and discuss the refinements to the project associated with the proposed amendment which are materialto the HHRA; and,
• Review and analyze the extent to which mitigation measures should be updated, where applicable.
The original Human Health Risk Assessment (July 2014), and the scope and rationale documents (April 2015) provided by SNC-Lavalin in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 8
2. Environmental Impact Assessment (EIA) – SNC-Lavalin Inc. (Environment & Water)
An Environmental Impact Assessment (EIA) was undertaken for the original project design. Port Metro Vancouver referred the EIA for review by an independent third party (Golder Associates Ltd.), prior to the approval of Permit No. 2012 – 072.
In consideration of the proposed amendment, SNC-Lavalin will undertake a review of the EIA (November 2013) to update the environmental impacts and proposed mitigation measures associated with loading coal directly onto OGVs as opposed to barges.
SNC-Lavalin has reviewed the EIA and, based on their understanding of the proposed changes to the project, have determined that the following sections will require further investigation or analysis:
• Project Description
• Consultation
• EIA Methodology
• Air Quality
• Surface Water and Groundwater
• Fish and Fish Habitat
• Vegetation and Wildlife
• Lighting
• Vessel Traffic
• Recreational and CommercialFishing
• Human Health
• Cumulative effects
• Environment Management Plans
• Summary of Project Effects,Mitigation Measures andResidual Effects
• Conclusion
SNC-Lavalin will prepare a technical memorandum that will review and analyze the changes to each of the relevant sections in the EIA. The technical memorandum will discuss environmental effects and provide additional mitigation measures relevant to the proposed amendment which are not currently covered in the EIA, if applicable.
SNC-Lavalin will:
• Review the description of refinements associated with the proposed amendment to the project;
• Review the extent to which the EIA adequately describes the potential environmental impacts, taking into accountrefinements associated with the proposed amendment to the project;
• Describe and discuss the refinements associated with the proposed amendment to the project which are materialto the EIA; and,
• Review and analyze the extent to which the potential impacts and mitigations should be updated, whereapplicable.
The original Environmental Impact Assessment (November 2013), and the scope and rationale documents (April 2015) provided by SNC-Lavalin in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 20159
3. Air Quality Assessment (AQA) – Levelton Consultants Ltd.
An Air Quality Assessment (AQA) was undertaken for the original project design. Port Metro Vancouver referred the AQA for review by an independent third party (Golder Associates Ltd.), prior to the approval of Permit No. 2012 – 072.
In consideration of the proposed amendment, Levelton will update the air quality study by conducting a review of the AQA submitted for the original permit (June 2014) to evaluate the potential impacts from the proposed project changes. A comprehensive list of emission sources will be evaluated related to the refinements associated with the project in the AQA, including the proposed coal operations at Fraser Surrey Docks LP (FSD) (i.e. emissions from marine vessels, and fugitive dust generated from material transfer points, as well as during coal unloading and loading), and in-transit emission sources (including emission from marine vessels on the Fraser River).
Levelton has reviewed the AQA and, based on their understanding of the proposed amendment, determined that the following areas of the report will require further analysis:
• Source Emissions Estimation
• The key revisions will reflect the differences in the project components associated with the change from abarge loader to a ship loader, vessel emissions, and additional mitigation measures implemented for FSD’sagricultural goods handling operation.
• Modelling Methodology
• Revisions will reflect the differences in the project components associated with the change from a bargeloader to a ship loader, and changes to FSD’s agricultural goods handling operation.
• Air Dispersion Modelling Results
• Key revisions will reflect the differences in the project components associated with the change from a bargeloader to a ship loader, vessel emissions, and changes to FSD’s agricultural goods handling operation, whichwill be used to assess the potential impacts from emissions.
• In-Transit Analysis
• Revisions of combustion and fugitive dust emissions from transport on the Fraser River will be required toreflect the changes in the project components associated with the change from a barge loader to a shiploader, vessel emissions, and additional mitigation measures implemented for the agricultural goods handlingoperations. The analysis is to be re-conducted to determine potential impacts.
• Combustion Volatile Organic Carbons (VOC) Speciation
• Revisions to this section will be required to reflect the changes to combustion emission sources. The analysisis to be updated for consideration in the HHRA (SNC-Lavalin).
To facilitate an update of the proposed amendment application, Levelton will revise the June 2014 AQA report, and summarize the revisions in a technical memorandum.
Levelton’s scope of work in updating the AQA study will include the following:
• A review of the description of the refinements to the project associated with the proposed amendment;• A review of the extent to which the AQA provides a representative assessment of the potential air quality impacts,
considering the refinements to the project associated with the proposed amendment;• A description and discussion of the refinements to the project associated with the proposed amendment which
are material to the AQA; and,• A review and analysis of the extent to which the potential impacts should be updated, including changes to the
assessment methodology, where applicable.
The original Air Quality Assessment (June 2014), and the scope and rationale documents (April 2015) provided by Levelton Consultants in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 10
4. Marine Risk Assessment – DNV (Det Norske Veritas)
A Marine Risk Assessment was undertaken for the original project design prior to the approval of Permit No. 2012 – 072 by Port Metro Vancouver.
In consideration of the proposed amendment, DNV will undertake a review of the Marine Risk Assessment to review the marine vessel movement and navigation risks associated with the proposed amendment of loading directly to OGVs as opposed to barges. The Marine Risk Assessment will review the navigational impacts associated with changing from barges to OGVs.
DNV has reviewed the Marine Risk Assessment and, based on their understanding of the proposed amendment, identified the following areas of the report that may require further analysis:
• Fraser Surrey Docks LP (FSD) Coal Barge Operations
• This section will be redrafted to accurately describe the Panamax size vessels that are being considered foroperations.
• Methodology and Approach
• The methodology for calculating marine accident risk remains accurate with the exception of the casedefinitions. The cases described in this section are no longer accurate based on the refinements associatedwith the proposed amendment as they describe barge movements. The new cases that are proposed foranalysis will be updated to include OGV movements.
• Risk Model Results
• A new analysis will be conducted for the operations described in the proposed amendment. Because theenvironmental and traffic data for the Fraser River is still valid for the proposed amendment, the incidentfrequency results will be adjusted based on the number of OGV movements.
The traffic data (of vessels not associated with FSD) and the environmental data and assumptions from the original risk assessment will be utilized in the updated assessment. A complete re-model of the study area is not considered necessary due to the fact that the only parameter that would be altered is the number of vessels transiting the Fraser River.
The findings of the Marine Risk Assessment review, as outlined by DNV’s scope below, will be summarized in a technical memorandum. In addition, mitigation measures will be revised to reflect the refinements associated with the proposed amendment to the project.
DNV’s scope will include the following:
• Update the potential vessel accident frequency, consequence and risk from the previous projected activity of640 barge movements to 80 OGV movements, and a range of scenarios in between;
• Linear adjustment of the accident frequency, based on the updated number of vessel movements; and,
• An update to the marine risk assessment based on the updated frequency of OGVs compared to barges.
The original Marine Risk Assessment (September 2014), and the scope and rationale documents (May 2015) provided by DNV in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 201511
5. Environmental Management Plan (EMP) – Soleil Environmental Consultants Ltd.
An Environmental Management Plan (EMP) was undertaken on the original project design prior to the approval of Permit No. 2012 – 072 by Port Metro Vancouver.
In consideration of the proposed amendment, Soleil Environmental Consultants Ltd. will undertake a review of the current EMP and, with Fraser Surrey Docks LP (FSD), update the plan where required. The EMP previously prepared for the original permit will be revised to reflect the proposed amendment to the permit to use OGVs.
As part of the review, Soleil Environmental Consultants Ltd. will consider if any of the proposed changes will impact the environment relative to the originally approved permit. For example, it is anticipated that a change to a taller ship loader with a covered telescoping chute will reduce the potential for fugitive coal dust. The proposed relocation of some infrastructure will require the production of new drawings for inclusion into the revised EMP.
Revisions to the current EMP will be completed and a new draft document produced for review, comment and approval by FSD with subsequent submission for review and approval to Port Metro Vancouver.
The original Environmental Management Plan (June 2013), and the scope and rationale documents provided by Soleil Environmental Consultants in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment
6. Water Management Plan – Omni Engineering Inc.
A Water Management Plan (WMP) was undertaken on the original project design prior to the approval of Permit No. 2012 – 072 by Port Metro Vancouver.
In consideration of the proposed amendment, Omni Engineering Inc. will undertake a review of the Water Management Plan (August 2014, WMP) to confirm the relevance of the water management impacts due to the proposed project changes.
The updated Water Management Plan will review:
• Updated wastewater containment area and associated water volumes;
• Re-location and re-sizing of the wastewater settling capacities accordingly;
• Minor modification to the out feed conveyor spill trays; and,
• Review of vessel loading dust mitigation technology strategies.
Results of the WMP review will be summarized in a revised WMP, covering the topics within the scope of work described above.
The original Water Management Plan (August 2014), and the scope document provided by Omni Engineering Inc. in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 12
7. Fire Life Safety Plan – Hatch MottMacDonald
A Fire and Safety Plan was undertaken on the original project design prior to the approval of Permit No. 2012 – 072 by Port Metro Vancouver.
In consideration of the proposed amendment, Hatch Mott MacDonald (HMM) will undertake a review of the Fire and Safety Plan (August 2014) to confirm the relevance of the fire and safety management impacts described to the proposed project changes. Further to this, HMM will conduct a full operational review to update the existing plan as a whole, bringing all aspects of the plan to relevance, and develop a Fire Life Safety Plan.
Review of the Fire and Safety Plan will:
• Undertake a complete revision of the existing Fireand Safety Plan for the proposed coal operations atFSD. The review will take into consideration:
• Planned revisions to the proposed operation(barge loader to ship loader)
• Revised operations of the loading vessels
• Summarize the requirements and regulatoryframeworks for a coal handling facility;
• Describe the hazards and consequent risks; and,
• Detail the planned design mitigation and operationalcontrols contained within the design.
Results of the Fire and Safety Plan review will be summarized in a revised Fire Life Safety Plan, covering the topics within our scope of work described above.
The original Fire and Safety Plan (RKMS, September 2012), and the scope document provided by Hatch Mott MacDonald in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment
8. Spill Response Plan – Fraser SurreyDocks LP
A Spill Response Plan for FSD’s terminal and FSD’s berth corridor was undertaken on the original project design prior to the approval of Permit No. 2012 – 072 by Port Metro Vancouver.
In consideration of the proposed amendment, Fraser Surrey Docks LP (FSD) will undertake an internal review of its existing Spill Response Plan to confirm the relevance of loading dry bulk ocean-going vessels (OGVs) described to the proposed project changes. The review will be led by Fraser Surrey Docks LP Director of Engineering and Terminal Development, with guidance from the Director of Operations and Health and Safety Officers. As FSD is a deep sea marine terminal with over 50 years of experience, no significant impacts or changes are anticipated to the existing Spill Response Plan, though this will be confirmed through a detailed review.
Results of the Spill Response Plan review will be summarized in an updated Spill Response Plan.
The original Spill Response Plan (January 2013), and the scope document prepared by FSD in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 201513
Frequently Asked Questions (FAQs)
1. Why is Fraser Surrey Docks LP (FSD) building a Direct Transfer Coal Facility?
• FSD is a major, multi-purpose marine terminal thatfacilitates shipping of a variety of goods includinggeneral cargo, steel, forest products, agriculturalproducts and containers.
• FSD has the capacity to handle a portion of the38 million metric tonnes of coal that are transportedthrough Port Metro Vancouver annually, and hasbeen permitted to do so following a thorough reviewprocess (completed August 2014).
2. Why is FSD considering applying to amend its existing permit to build a Direct Transfer Coal Facility?
• The proposed amendment would allow FSD to loadcoal directly from the facility to ocean-going vessels(OGVs), reducing the need for barges. OGVs havemore capacity than barges. One loaded OGV cancarry four train loads and the same amount as eightloaded barges.
• The proposed application to amend the existingpermit would have no impact on the permittedvolume of coal shipped through FSD (4 million metrictonnes per annum).
• Due to changes in commercial conditions, FSDanticipates shipping most or all of its volume byOGVs. The use of OGVs would reduce the number ofmarine vessel movements.
3. What changes would the proposed amendment include?
• The proposed amendment would increase thecurrent size and height of the barge loader, allowingfor direct loading to OGVs.
• Use of OGVs would replace most or all barges. Ifapproved, FSD plans to replace all barges by OGVs,but would retain barging as a potential secondaryoption.
• It is anticipated that the use of OGVs would furthermitigate the potential for fugitive dust, as coal wouldbe transported in a closed hatch.
• The conveyance system, receiving pit and rail trackswould be shifted on site to accommodate the largervessel loader.
• The footprint of the loading area would decrease,which may reduce water runoff.
4. Will this change the volume of coal that FSD is permitted to transport through the facility?
• The proposed amendment to the permit would nothave any impact on the amount of coal that FSDis permitted to transport through the facility. Theexisting permit is for 4 million metric tonnes of coal (4MMT) per year, and anything over this amount wouldrequire a new project review.
5. How would the proposed amendment change vessel movements on the Fraser River?
• The proposed amendment would allow FSD to loadcoal directly from the facility to OGVs, reducing theuse of barges and reducing the number of vesselmovements from the original project permit. An OGVcan carry the volume of 4 trains. In comparison, 8barges would be required to carry the same amount(1 ship = 8 barges).
• FSD anticipates shipping coal mostly or entirely byOGVs, while retaining barging as a secondary option.
6. What type of vessels would be used with the proposed amendment?
• Any vessel accommodated at FSD would be inaccordance with current size limitations for the FraserRiver. The ship loader being proposed would be ableto accommodate Panamax class vessels that wouldnot exceed 11.5 metre draft when loaded.
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 14
7. Why is it necessary for the height of the vessel loader to be increased?
• Vessels sit much higher in the water than barges andthe loader must be able to reach over the side of thevessel into the hatch. This height will allow the vesselloader the appropriate reach to load coal directly intothe specific vessel hatch it is loading.
• The vessel loader would require a maximum heightof 36.2 metres to load coal directly into OGVs.By comparison, the gantry cranes used to movecontainers onsite at FSD are 55 metres high with theboom down, and are 82 metres high with the boomup.
8. How does this proposed amendment affect the studies that were completed for the original permit application?
• The following studies (available at www.fsd.bc.ca/amendment) will be reviewed and updated asnecessary with a supplementary technical memo orreport:
• Human Health Risk Assessment (HHRA) –SNC-Lavalin Inc. (Environment & Water)
• Environmental Impact Assessment (EIA) –SNC-Lavalin Inc. (Environment & Water)
• Air Quality Assessment (AQA) – LeveltonConsultants Ltd.
• Marine Risk Assessment – DNV (Det NorskeVeritas)
• Environmental Management Plan (EMP) – SoleilEnvironmental Consultants Ltd.
• Water Management Plan – Omni Engineering Inc.
• Fire Life Safety Plan – Hatch Mott MacDonald
• Spill Response Plan – prepared by Director ofEngineering, Fraser Surrey Docks LP
• The public will have the opportunity to review andprovide comments on the scope and results of thestudies.
• For further information on how toprovide feedback, please visitwww.fsd.bc.ca/amendment
9. What does this proposed permit amendment application mean with respect to the recent wastewater permit application to Metro Vancouver?
• The waste discharge permit application submitted toMetro Vancouver is for a maximum volume dischargerate of 5 litres per second of treated wastewater, andthis would not change as a result of the amendment.Overall, FSD’s treated wastewater would be 9,000tonnes (0.0001%) of the 172 million tonnes of regionalwastewater flowing through the Annacis Islandfacility every year, which includes a number of otherindustrial users, undergoing similar treatment.
• Wastewater from the proposed facility would first betreated onsite and discharged directly to the AnnacisIsland Treatment Facility via Metro Vancouver’s NorthSurrey Interceptor Sewer, which runs directly underthe FSD facility. As such, wastewater would be treatedto meet or exceed Metro Vancouver’s rigorousstandards protecting water quality.
10. How many OGVs currently berth at FSD per year?
• Approximately 275 OGVs called at FSD in 2014.
11. What is being done to reduce coal dust from railcars?
• The coal will be sprayed with a binding agent atthe mine site during loading to railcars. Once therailcars are loaded, a topping agent is applied to thecoal in each railcar. In addition, Burlington NorthernSanta Fe (BNSF) is constructing a re-spray station atPasco, Washington to mitigate dust. This will provideadditional dust mitigation for coal shipments enroute to FSD.
• Although FSD is not responsible for the movementof products by rail, we are working closely with themines and our rail partners to ensure dust mitigationstrategies are consistently applied.
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 201515
Reference Documents The following supporting documents for the original project permit are available on the Project Updates page at www.fsd.bc.ca/amendment:
• Direct Transfer Coal Facility Project Application
• Human Health Risk Assessment (HHRA)
• Air Quality Assessment (AQA)
• Environmental Impact Assessment (EIA)
• Phase 1 Community Engagement Summary Report
• Phase 2 Engagement Summary Report
• Marine Risk Assessment
• Coal Transfer Facility Fire Safety Plan
• Preliminary Environmental Management Plan
• Air Dispersion Modelling Assessment
• Spill Response Plan
• Water Management Plan (WMP)
The following supporting documents for the original project permit are available at www.portmetrovancouver.com/en/projects/OngoingProjects/Tenant-Led-Projects/FraserSurreyDocks.aspx:
Decision Documents, including:
• Project Review Report – August 2014
• Environmental Review Decision Statement –August 2014
• Human Health Risk Assessment Third PartyReview (Golder Associates)
• Fraser Surrey Docks Direct Transfer Coal FacilityMitigation Strategy Description
• Backgrounder – About This Project and DecisionProcess
• Port Metro Vancouver Project Review Process
• Human Health Risk Assessment (HHRA)(July 2014)
• Environmental Impact Assessment PublicComments Response Memo
• Documents Referenced in the EnvironmentalReview Decision Statement (includingcorrespondence)
• Environmental Impact Assessment PublicComments Response Memo
• Fraser Surrey Docks Environmental ImpactAssessment Public Agency Comments
DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 16
Feedback Form
This feedback form seeks your input regarding the scope of the preliminary studies being undertaken by Fraser Surrey
Docks LP (FSD) as part of its consideration to amend Permit No. 2012 - 072. The proposed amendment would be
made to its existing permit that gives it conditional approval to build and operate a Direct Transfer Coal Facility within
its existing lease area.
1. Human Health Risk Assessment (HHRA) completed by SNC-Lavalin Inc. (Environment & Water).
An overview of the proposed scope of this study can be found on page 7 in this discussion guide and the original
study can be found at www.fsd.bc.ca/amendment
Please provide comments on the proposed scope of the Human Health Risk Assessment (HHRA)associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:
2. Environmental Impact Assessment (EIA) completed by SNC-Lavalin Inc. (Environment & Water).
An overview of the proposed scope of this study can be found on page 8 in this discussion guide and the original
study can be found at www.fsd.bc.ca/amendment
Please provide comments on the proposed scope of the Environmental Impact Assessment (EIA)associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:
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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 201517
3. Air Quality Assessment (AQA) completed by Levelton Consultants Ltd.
An overview of the proposed scope of this study can be found on page 9 in this discussion guide and the original
study can be found at www.fsd.bc.ca/amendment
Please provide comments on the proposed scope of the Air Quality Assessment (AQA) associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:
4. Marine Risk Assessment – DNV (Det Norske Veritas)
An overview of the proposed scope of this study can be found on page 10 in this discussion guide and the original
study can be found at www.fsd.bc.ca/amendment
Please provide comments on the proposed scope of the Marine Risk Assessment associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:
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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 18
5. Environmental Management Plan (EMP) completed by Soleil Environmental Consultants Ltd.
An overview of the proposed scope of this study can be found on page 11 in this discussion guide and the original
study can be found at www.fsd.bc.ca/amendment
Please provide comments on the proposed scope of the Environmental Management Plan (EMP)associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:
6. Water Management Plan – Omni Engineering Inc.
An overview of the proposed scope of this study can be found on page 11 in this discussion guide and the original
study can be found at www.fsd.bc.ca/amendment
Please provide comments on the proposed scope of the Water Management Plan (WMP) associated withFraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:
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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 201519
7. Fire Life Safety Plan - Hatch Mott MacDonald
An overview of the proposed scope of this study can be found on page 12 in this discussion guide and the original
study can be found at www.fsd.bc.ca/amendment
Please provide comments on the proposed scope of the Fire Life Safety Plan associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:
8. Spill Response Plan – Fraser Surrey Docks LP
An overview of the proposed scope of this study can be found on page 12 in this discussion guide and the original
study can be found at www.fsd.bc.ca/amendment
Please provide comments on the proposed scope of the Spill Response Plan associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:
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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 20
9. Please provide any additional comments you may have regarding the proposed application to amendPermit No. 2012 - 072:
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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 21
Please submit your feedback form by May 19, 2015.
Fraser Surrey Docks LP (FSD) will consider your input, along with information provided by technical experts, as part of its consideration to apply for an amendment to Permit No. 2012 - 072.
Please provide your contact information (optional):
Name:
Organization (if applicable):
Role: (if applicable):
Address:
Postal Code:
Email:
Phone:
Any personal contact information you provide to Fraser Surrey Docks LP on this form is collected and protected in accordance with the Freedom of Information and Protection of Privacy Act. If you have any questions regarding the consideration to amend Permit No. 2012-072 Direct Transfer Coal Facility or Fraser Surrey Docks LP and/or the information collection undertaken on this form, please contact Fraser Surrey Docks LP at [email protected].
The deadline to submit feedback is May 19, 2015
You can return completed feedback forms:
Online: www.fsd.bc.ca/amendment
By email: [email protected]
By mail: PO Box 2233 Vancouver Main, Vancouver, BC V6B 3W2
For general project information:
www.fsd.bc.ca/amendment
Phone: 604 - 891-1695
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