SECTION A: INTRODUCTION, BUSINESS NAME AND ADDRESS

FRASER SURREY DOCKS, 1160 ELEVATOR ROAD, SURREY, BC, V3V 2R7 Phone: 604.581.2233 Fax: 604.581.6488 E-mail: [email protected] Website: www.fsd.bc.ca

Reference: 4419

Deputy Sewage Control Manager Nov 19, 2013

Metro Vancouver

Policy and Planning

Regulation & Enforcement Division

4330 Kingsway,

Burnaby, BC

V5H 4G8

Re: Revised application for a temporary discharge permit for treated coal wastewater

from a proposed coal offloading facility at Fraser Surrey Docks (FSD) in Surrey BC

SECTION A: INTRODUCTION, BUSINESS NAME AND ADDRESS

This letter is a revised application for a temporary sanitary sewer discharge permit under

Greater Vancouver Sewerage and Drainage District (GVSD&D) Sanitary Sewer Use Bylaw 299.

The proposed discharge program has changed since the July 2013 submission based on

consultation with Metro Vancouver. Fraser Surrey Docks (FSD) is therefore resubmitting their

application reflective of these changes1.

A.1 PROJECT DESCRIPTION AND APPLICANT INFORMATION

FSD is applying for a permit in support of the periodic discharge of treated coal wastewater

(primarily storm water runoff) to sanitary sewer at a proposed Direct to Barge (DTB) coal

transfer facility2 (reference Section K).

1 Changes outlined in the attached (Attachment 2) October 15, 2013 letter “Addendum (2) to July 2013 sanitary sewer application

for the Fraser Surrey Docks (FSD) temporary coal offloading facility – supporting information” Note the letter has been revised to reflect comments from November 3rd, 2013 meeting with MV and FSD. This includes updated communications received communications from PMV in regards to other discharge options. 2 FSD is proposing to build an onsite, temporary coal offloading facility adjacent to Shed 1 for Powder River Basin (PRB) coal (≤75

mm particle size). The coal will be imported to FSD via BNSF rail. Prior to transport, the coal will be treated with (Soil-cement® Coal

Car Topping) and multiple anti-oxidant / dust suppression compounds (GE Power and Water DUSTREAT DC91482 and DC61093

or similar). On arrival, the coal will be loaded into barges destined for Texada Island. The facility will operate for 5+ years, with

approximately 2 million tonnes barged offsite in Year 1, and 4 million tonnes barged offsite annually in Years 2 through 5. Inbound

trains will arrive every second day in Year 1, and once daily in Years 2 through 5.

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FSD Sanitary sewer discharge permit application Nov 2013

The facility is proposing comprehensive water based dust suppression systems which will

generate site runoff. This runoff will largely be collected, treated (e.g. solids removal) and re-

used in the dust suppression system. Onsite storage capacity will be available in the form of

multiple treatment ponds (Dumper Area Settling Pond and the Loading Area Settling Pond);

however during selected high rainfall events there will be a need for offsite discharge, preferably

to sanitary sewer.

Table 1. Contact information

APPLICATION INFORMATION SUMMARY

Fraser Surrey Docks - Pacific Rim Stevedoring

11060 Elevator Road

Surrey, BC

V3V 2R7

www.fsd.bc.ca

Registration number 00-0293079

CONTACT PERSON FOR THIS APPLICATION

Jurgen Franke, P. Eng

604-495-1184 (office phone)

604-495-1195 (fax)

778.838.7581(mobile)

[email protected]

A.2 RATIONALE FOR PROPOSED DISCHARGE TO SANITARY SEWER

Onsite dust control measures will be implemented to meet the requirements of local permit

granting agencies (e.g. Port Metro Vancouver & Metro Vancouver) and, importantly, to address

stakeholder concerns about coal entering the lower Fraser River from the proposed facility. First

Nations and other stakeholders have expressed concern about coal spills and other

mechanisms for coal to enter the Fraser from the facility. As a result, FSD made a commitment

early in the planning process to avoid an effluent discharge to the Fraser. Similarly, the Port has

raised concerns about the viability of a discharge of treated wastewater to ground onsite (from a

subsurface contamination standpoint) and FSD anticipates clear stakeholder resistance to this

strategy as well. In the contexts of environmental risk management and commitments made to

stakeholders on keeping coal out of the Fraser River, FSD determined a periodic discharge to

sanitary sewer was a more favourable design option than discharge to the Fraser River, or to

ground.

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SECTION B: SITE AND PROCESS DESCRIPTION

FSD services Container, Breakbulk, Project Cargo, Forest Products and Bulk customers. The

FSD property is 52 ha in size and includes the following developed areas (Golder, 2003):

o Paved areas used for cargo storage and parking

o Six (6) warehouses used to store wood pulp and steel

o Service garage for vehicle and equipment repair

o Rail track system – some of which has been temporarily dismantled

o Shipping berths Schematics of the proposed DTB facility are referenced in Section K. Inbound raw coal will be

unloaded from railcars, onto covered conveyors; then reloaded onto barges destined for Texada

Island. Some coal will accumulate on the equipment (conveyors) within the process area where

the drainage system is isolated from the overall site drainage. When the equipment is washed

down, or, when rain falls in the process area, runoff consisting of water and coal particles will be

generated. This runoff (or wastewater) will be collected by the process area drainage system,

gravity settled to reduce the suspended solids content (and otherwise treated as necessary to

meet Schedule B Restricted Waste Criteria) then discharged to the sanitary sewer.

SECTION C: OPERATING PERIOD

FSD is seeking a 5 year operating permit for the facility from Port Metro Vancouver (PMV), and

would require the same term from Metro Vancouver. The coal transfer process is sporadic as is

the wash-down of equipment. The most relevant criterion for determining the discharge pattern

and quantity would be rainfall (Section I).

SECTION D: WASTEWATER SOURCES

1. Washing of Equipment - estimated frequency of once a week with a volume of 45 m3

Annual Volume = 52 x 45 m3 = 2,340 m3

Average Daily Volume = 2,340 / 365 = 6.4 m3

2. Annual Rainfall on Process Area

11,164 m2 x 1.343 m x .9 = 13,494 m3/year

Average Daily Volume = 13,494 / 365 = 36.9 m3/day

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SECTION E: WASTE WATER TREATMENT

1. Flow Diagram

Detailed treatment system design is forthcoming. At this writing however it is anticipated the

main components of the treatment system will consist of gravity settling of the wastewater in a

two cell settling pond located near the Barge Loading Area as illustrated on drawing 2113-

SK002 Rev 5 (Attachment A in Section K of this application). The settling is expected to occur

in the secondary settling cell, which has a nominal area of 165 m2 and a working volume of

approximately 432 m3.

2. Justification of the Works

Section H of this application contains analyses of wastewater samples (600 mg/L suspended

solids concentration) prepared with Powder River Basin (PRB) coal. The laboratory analyses

indicates total metals, phenols, volatile organic compounds (VOC), sulphate, polycyclic

aromatic hydrocarbons (PAH) BOD5, and pH fall within acceptable ranges as specified in

Restricted Waste Criteria (Schedule B – GVS&DD Sewer Use Bylaw No. 299) Consequently,

treatment beyond reducing TSS concentrations ≤600 mg/L is not expected .

The other parameters in Schedule B which have to be addressed (Table A) are:

Total Suspended Solids Maximum concentration of 600 mg/L

Total Oil and Grease Maximum concentration of 150 mg/L

Oil and Grease (Hydrocarbon) Maximum concentration of 15 mg/L Oil and Grease levels are best determined once the facility is in operation. However, FSD

anticipated sources will be limited to lubrication of conveyors. And, possibly a fuel oil spill from

mobile equipment. The issue of a possible fuel spill is dealt with in Section G of this application.

The possibility of significant oil and grease contamination from normal lubrication of equipment

is remote, providing best practices are followed.3

That leaves suspended solids as the main concern. Appendix 3 of this application contains a

detailed design memorandum describing the size and flow rate of the secondary settling cell to

produce an effluent with a suspended solids < 600 mg/L (or ppm). The memorandum contains

both a theoretical analysis and the results of some practical settling tests performed in a

laboratory setting.

3 It is also worth noting that the other two coal terminals operating in the Vancouver area, Neptune and Westshore

Terminals, do not have a problem meeting the 15 mg/L limit.

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In the unlikely event TSS of <600 mg/L could not be attained, the terminal would apply a

chemical coagulant and flocculent to the effluent as it enters the secondary settling cell. Both

Neptune Terminals and Westshore Terminals use this method to reduce the suspended solids

content of their coal wastewater to less than 50 mg/L as required by their respective MOE

permits. The chemical agents and equipment to apply them are well established and reliable.

3. Maintenance Procedures The secondary settling cell will accumulate sediment on the bottom which will have to be

cleaned out during dry weather when the facility is not operating. The cleanout would be

completed with a mobile pump, which will pump the accumulated sediment back into the

primary cell to be pumped back to the dumper area settling pond. (The sediment in the dumper

area settling pond will be periodically removed by a front end loader, dried and loaded onto the

conveyor belt). In addition all flow monitoring and sampling equipment will have to be routinely

inspected and calibrated according to the equipment supplier recommendations.

4. Provisions to Bypass the Treatment Works

There are no provisions to bypass the treatment works (i.e. the loader area settling pond).

SECTION F: SAMPLE POINT LOCATION

The sample point will be located in a container housing the discharge piping from the pump in

the secondary settling cell. There will be a composite sampler which draws a sample from the

discharge flow at programmed intervals. The composite sample will be collected monthly or as

required, and analyzed for suspended solids, oil & grease, and other parameters as determined

with Metro Vancouver. All wastewater discharged to the sanitary sewer will go through this pipe

so the samples taken from this site are considered representative of discharge water quality.

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SECTION G: SPILL PREVENTION AND CONTAINMENT

Routine inspections and maintenance will be performed on all components of the DTB facility,

including mobile machinery (pick-up trucks, skid steer with sweeper, water truck, propane or

electric forklifts, on road diesel tractor/trailer). Vegetable based oils will be used barge loader

and warping equipment and no hazardous materials storage or use will occur in the wastewater

collection area(s). FSD’s Standard Operating Procedures (SOP) for spill response are attached

to this document.

All wastewater discharges will be routed through the Loading Area Settling Pond. The

submersible pump will be fitted with a ‘Hand-Off-Automatic’ button. In the event of a spill, the

‘off’ button would be pushed to prevent the spilled material from being discharged to sanitary.

Although hazardous materials storage will not be permitted in the processing areas,

hydrocarbon spills from operating equipment may occur. Hydrocarbons would generally be

expected to float on the water surface of the Loader Area Settling Pond and personnel could

deploy booms, spill pads etc. in response. The ponds will also be fitted with skimmers to capture

floating hydrocarbons. Finally, the pump can be shut down in the event of such a spill to

eliminate the potential for discharge to sanitary.

After an initial spill response, analytical samples would be collected from multiple depths in the

settling pond for comparison with the Restricted Waste Criteria. Treatment would be

implemented as necessary to ensure compliance with the Bylaw. Examples of generic spill

response procedures that will be implemented onsite are as follows:

o Confirm the safety of all personnel and secure the area (as needed)

o Eliminate ignition sources

o Identify spilled product, associated hazards and clean up requirements

o Determine if the spill can be contained and cleaned up by onsite staff. Spills that

cannot be managed by onsite personnel should be directed to the District and

other agencies as required.

o Stop the flow of spilled materials if safe to do so

o Contain spilled materials if safe to do so

o Clean up and dispose of spilled product and used response materials consistent

with the Environmental Management Act

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o Notify the Environmental Protection Division of Environment Canada and the

Provincial Emergency Program (PEP) in the event of a reportable spill, as

defined by the Spill Reporting Regulation of the Environmental Management Act

Spills of flammable Class 3 Liquids (e.g.) gasoline, fuel oil) ≥ 100 L

are reportable

o Investigate causes of the spill and identify required changes to hazardous

materials management strategies and spill response plans

o Complete spill reporting forms ensuring the following information is provided:

Name of the person(s) reporting the spill

Witnesses of the spill

Date, time and location of the spill

Source of spill

Type and estimated volume of product

Nature of the receiving environment (soil, water)

Spill response measures

Estimated volume recovered

Impact of the spill on terrestrial and / or aquatic resources

Required remediation (if any)

Measures take to prevent similar spills in future

Agencies made aware of the spill (as needed)

SECTION H: WASTEWATER CLASSIFICATION AND QUALITY

Laboratory analyses were conducted on 600 mg/L solutions of Power River Basin (PRB) coal

and water to evaluate potential pH, BOD5, total metals, PAH, VOC, sulphate and phenols

concentrations in wastewater generated onsite. These analyses were completed to assess

water quality based on potential residence times in the treatment system, and included samples

from 600 mg/L solutions that sat or one and two weeks respectively prior to extraction for

metals, sulphate and organics analyses4. These results are summarized in Table 2 and show a

limited number of metals and organics were detected (Table 1, Appendix 1). None of the

detected parameters were above available Schedule B-Restricted Waste Criteria.

Table 2. Detected parameters – 600 mg/L PRB coal and water solutions

Parameter Units Detection

limit

< 2 mm Coal @

600 mg/L - 1 WEEK

< 2 mm Coal @

600 mg/L - 1 WEEK

(agitated)

< 2 mm Coal @

600 mg/L - 2 WEEK

< 2 mm Coal @

600 mg/L - 2 WEEK

(agitated)

< 2 mm Coal @ 600

mg/L – analysed

upon preparation

GVSD&D Restricted

waste criteria

4 BOD5 analyses were conducted as per the required laboratory methodology and were below detection (<10 mg/L)

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17-Sep-13

17-Sep- 13

24-Sep-13

24-Sep- 13

10-Sep- 13

pH pH units 0.01 7.15 7.12 7.36 7.06 7.34 5.5 to 10.5

Aluminum, total mg/L 0.05 <0.05 0.21 <0.05 0.42 0.06 50

Barium, total mg/L 0.05 <0.05 0.28 <0.05 0.37 0.09 -

Copper, total mg/L 0.002 <0.002 <0.002 <0.002 0.003 - 2

Iron, total mg/L 0.1 <0.1 0.2 <0.1 0.5 - 10

Magnesium, total mg/L 0.1 <0.1 0.1 <0.1 0.2 - -

Manganese, total mg/L 0.002 <0.002 0.003 <0.002 0.007 - 5

Sodium, total mg/L 0.2 0.9 1 1.1 1.3 0.2 -

Strontium, total mg/L 0.01 <0.01 0.04 <0.01 0.07 -

Benzo (a) pyrene ug/L 0.01 <0.01 0.01 <0.01 <0.01 -

Phenanthrene ug/L 0.1 <0.10 0.17 <0.10 <0.10 0.11 -

Total PAH ug/L - n/d 0.18 n/d n/d 0.11 50

Chloroform ug/L 1 6.2 5.6 6.2 6.5 - -

Methylene chloride ug/L 3 <3.0 6.8 <3.0 <3.0 - -

n/d – not detected

SECTION I: FLOW INFORMATION

FSD is proposing a direct connection with the GVS&DD Trunk Sewer as per attached drawings.

The proposed flow rates are outlined in Table 3.

Table 3. Flow rates – FSD – DTB – temporary coal transfer facility

Parameter Quantities / flow rates

Total annual wastewater discharge ≤15,834 m3

Maximum instantaneous flow rate 5 liters / second

Maximum daily flow ≤432 m3 / day

Average daily discharge ≤43.3 m3 / day

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Flow Rates Discharge to the sanitary sewer will primarily be determined by rainfall. Average discharge rates

will be low, but the peak run off flow rate caused by heavy rainfall will require accommodation. It

is conventional practice to use a 10 year return period IDF (Intensity Duration Frequency) curve

for the design of relatively small storm drainage areas such as the FSD process areas. The

closest and most relevant rainfall gauge data is at Vancouver International Airport. The Rational

Method is an appropriate and conservative methodology for this application whereby:

Q = CIA Q = Volume of runoff m3 C = Concentration factor; in this case 0.9 was used I = rainfall intensity mm/hr for the time period under consideration (from the IDF curve)

A = Area; total area of the Dumper Process Area, Loading Process Area = 11, 164 m2.

As runoff accumulates it either has to be temporarily stored (“detained”) or discharged from the

site. The amount of detention storage required will depend upon the rate at which it can be

discharged from the site. Table 2 illustrates a typical scenario for this site where the maximum

discharge rate has been set at a rate of 5 L/sec. The following table illustrates a typical scenario

for this site where the maximum discharge rate is set at a 5 L/sec (80 US gpm). The resulting

storage required is approximately 338.3 m3

Table 4. Storm water Accumulation for 10 year rain event

Time

Minutes

mm/hr

IDF curvemm c

area

m2

volume

runoff

m3

pump

L/sec

volume

discharge

m3

volume

stored

m3

5 55 4.6 0.9 11164 46.1 5 1.5 44.6

10 40 6.7 0.9 11164 67.0 5 3 64.0

15 31 7.8 0.9 11164 77.9 5 4.5 73.4

20 28 9.3 0.9 11164 93.8 5 6 87.8

30 22 11.0 0.9 11164 110.5 5 9 101.5

40 19 12.7 0.9 11164 127.3 5 12 115.3

60 15 15.0 0.9 11164 150.7 5 18 132.7

120 11 22.0 0.9 11164 221.0 5 36 185.0

480 6 48.0 0.9 11164 482.3 5 144 338.3

600 4.8 48.0 0.9 11164 482.3 5 180 302.3

720 4.1 49.2 0.9 11164 494.3 5 216 278.3

1440 2.9 69.6 0.9 11164 699.3 5 432 267.3

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Note the table above illustrates the discharge rate required for the extreme rainfall event. The

average discharge rate will be much lower than this. Flow Frequency Available data for rainfall over 0.2 mm indicates: January 20 days 178 mm February 17 days 125 mm March 19 days 116 mm April 15 days 85 mm May 13 days 73 mm June 12 days 63 mm July 6 days 50 mm August 8 days 31 mm September 8 days 56 mm October 9 days 152 mm November 12 days 192 mm December 19 days 222 mm 158 1,343 mm These records include days of low precipitation (<1.5 mm) which will not produce any significant

runoff. There will also be however some days with equipment wash-downs. In general these

days will roughly cancel out and the assumed days of discharge to the sanitary sewer is

approximately 158.

Flow monitoring would be completed with a conventional 3” diameter water meter and data

logger which would record readings of instantaneous flow rate and accumulated flow volume

every 15 seconds approximately. Equipment details will be specified during final design.

SECTION J: REQUESTED PERMIT TERM

FSD is requesting a 5 year permit term, consistent with the proposed operating period of the

facility.

SECTION K: REQUIRED ATTACHMENTS (APPENDIX 3)

Drawing 13024-SK-030A P8 - CWA Engineering

Drawing 13024-SK-030G P4 - CWA Engineering

Drawing 2113-SK002 Rev 5 – Omni Engineering

Drawing 2113-100 P1 – Omni Engineering

Drawing 2113-101 P1 – Omni Engineering

Connection to North Surrey Interceptor

NS Interceptor

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SECTION L: SIGNED DECLARATION

A signed declaration is attached to this letter. Jurgen Franke, P. Eng. Director of Engineering

and Maintenance for FSD has provided sign off for this application.

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FSD Sanitary sewer discharge permit application Rev 1 Nov 2013

ATTACHMENT 1: SIGNED DECLARATION

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ATTACHMENT 2: RE: ADDENDUM (2) TO JULY 2013 SANITARY SEWER APPLICATION FOR THE

FRASER SURREY DOCKS (FSD) TEMPORARY COAL OFFLOADING FACILITY – SUPPORTING

INFORMATION (OCTOBER 2013) W/PMV CORRESPONDENCE

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1


October 15, 2013 Metro Vancouver 4330 Kingsway Burnaby BC V5H 4G8 Attention Natasha Silva

Re: Addendum (2) to July 2013 sanitary sewer application for the Fraser Surrey Docks

(FSD) temporary coal offloading facility – supporting information

In response to MV letter dated September 23rd, this letter summarizes the following:

Supporting rationale for a five (5) year discharge to sanitary sewer as opposed to a

discharge to the Fraser River (Option B) or to ground (Option C) (please reference

attached Water Management Plan for further details surrounding each of the alternate

options and the issues surrounding each option)

Changes to the proposed discharge to sanitary sewer program for the Fraser Surrey

Docks (FSD) direct to barge coal transfer facility, based on initial feedback from Metro

Vancouver (received September 23rd, 2013)

o These changes emphasize a reduction in the proposed discharge rates .

Results of additional laboratory analyses conducted on 600 mg/L solutions of Powder

River Basin (PRB) coal and water to evaluate potential metals, polycyclic aromatic

hydrocarbons (PAH), volatile organic compounds (VOC) , sulphate and phenols

concentrations in wastewater generated onsite

o These analyses were completed to evaluate water quality based on potential

residence times in the treatment system and included samples collected from

600 mg/L solutions which sat for one and two weeks respectively, prior to

extraction for metals, sulphate and organics analyses

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RATIONALE FOR DISCHARGE TO SANITARY SEWER

FSD has developed a comprehensive dust control management plan including but not limited to:

a covered dumping shed, covered conveyors, a wastewater collection and treatment system, and

spray on the loaded barges to limit the potential for coal dust enter the environment1. These

measures are being implemented to meet the requirements of local permit granting agencies (e.g.

Port Metro Vancouver & Metro Vancouver) and, importantly, to directly address stakeholder

concerns about coal entering the Fraser River from the proposed facility. First Nations and other

stakeholders have expressed concern about coal spills and other mechanisms for coal to enter

the Fraser from the facility. As a result, FSD made a commitment early in the planning process to

avoid an effluent discharge to the Fraser. Similarly, the Port has raised concerns about the viability

of a discharge of treated wastewater to ground onsite (from a subsurface contamination

standpoint) and FSD anticipates clear stakeholder resistance to this strategy as well. In the

contexts of environmental risk management and commitments made to stakeholders on keeping

coal out of the Fraser River, a periodic discharge to sanitary sewer is considered a more

favourable option than discharge to the Fraser or to ground.

1 A twice yearly sediment quality monitoring program will be implemented for the lifetime of the project to measure potential coal accumulations at the Berth (% coal, particle class and % total organic carbon). FSD will be conducting this program to evaluate the effectiveness of their on-dock strategies to prevent coal from entering the Fraser River.

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3


DISCHARGE TO SANITARY SEWER VS. DISCHARGE TO THE ENVIRONMENT

The table below details a summary of the treatment options and the associated costs and

challenges with each option.

Category

Option A – Discharge

to MV Sanitary

Option B – Discharge to

the Fraser River

Option C – Discharge to

ground water

1 Permitting Agencies Metro Vancouver MOE and PMV MOE and PMV

2 Estimated length of permitting process

60 to 90 days 24 months + 24 months +

3 Stakeholder preferred option (through public consultations)

Preferred Not preferred Not preferred

4 Discharge to the Environment

No Yes Yes

5 TSS requirements <600 ppm <50 ppm <50 ppm

6 Required use of Coagulants and Flocculants

None Yes Yes

7 Pre-project assessments

Currently none defined Yes, as per conversation with PMV and MOE

Yes as per conversation with PMV

8 Estimated Incremental Capital cost (assuming cost for settlement ponds already required).

Trenching and tie into MV line; $75k

Construction of a two dual stage settling ponds with stringent monitoring system a per MV permit requirements (Reference Omni Drawing “GA – Option A Discharge to Sanitary Sewer”, rev p5).

Trenching and tie into Fraser River with new outfall

Chemical treatment system Stringent monitoring systems Total cost estimate of $250k

Trenching and tie into infiltration field.

Chemical treatment system Stringent monitoring

systems Total cost estimate of $200k

9 Estimated operating cost/L

General annual fees calculated at:

Permit Admin fee: $7,752.00 Liquid Waste Disposal fee: Usage Charge: $5,580.00 Capacity Charge:

$1,838.00 Total fee: $15,170.00

Pumping and disposal fees, tank rental and misc. for 24 months to overcome permit delay

Stringent monitoring systems upkeep and consultant costs

Coagulant and flocculent costs

Total annual cost estimate of $150k for first 24 months. Approximately $30k thereafter.

Pumping and disposal fees, tank rental and misc. for 24 months to overcome permit delay

Stringent monitoring systems upkeep and consultant costs

Coagulant and flocculent costs

Total annual cost estimate of $150k for first 24 months. Approximately $30k thereafter.

Although the general fees for discharge to MV is based on volume, as opposed to no general fees

for discharge to the environment, capital costs and operating costs are still substantially lower for

over the course of five to ten years (the estimated length of operation) for the discharge to MV

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sanitary. It should also be noted that although a two year window was estimated for operating

costs prior to receiving permit approval from MOE, this time frame could be substantially longer.

Conversations were had with both approval agencies PMV and MOE regarding discharge to the

Fraser River (reference attached email from PMV requirements) and to ground. We anticipate a

provincial effluent permit application process would be lengthy (potentially threatening the viability

of the project). The process would include but not limited to pre-application meetings with the

Ministry and completion of a Technical Assessment2; the latter requiring information on detailed

site design and operations, non-product outputs (air contaminants, effluents and refuse), human

health and ecological risk assessments, Total Costs Assessment (TCA), receiving environment

characterization, discharge characterization (relative to guidelines and legal standards),

modeling, cumulative impact assessment and proposed monitoring programs. The effluent

discharge permitting process would also require its own stakeholder consultation process. Also

of note is that the terminal is not tied to any municipal storm sewers and that all storm

water is currently directed into the Fraser River. For this reason no contact was made

with the City of Surrey to direct into their storm sewer system.

CHANGES TO THE DISCHARGE PROGRAM

Proposed revised flow rates are provided in Table 1. The maximum instantaneous flow rate has

been dropped from 12 l/s to 5 l/s and FSD will further investigate options for reducing water

volumes prior to and during operations.

Table 1. Revised flow rates – FSD – DTB – temporary coal transfer facility

Parameter Current proposal (October 2013)

Previous proposal (August 2013)

Difference between the two

proposals

Total annual wastewater discharge ≤15,834 m3 ≤20,980 m3 (-) 5,146 m3

Maximum instantaneous flow rate 5 litres / second 12 litres / second (-) 7 litres / second

2Potential application requirements discussed with Mr. Chor, Surrey MOE, Senior Environmental Protection Officer. Based on a

review of the Environmental Management Act with Mr. Chor, the project would not be exempt from the permitting process. Technical

assessment requirements outlined in GUIDANCE ON APPLICATIONS FOR PERMITS UNDER THE ENVIRONMENTAL

MANAGEMENT ACT – TECHNICAL ASSESSMENT

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Maximum daily flow ≤432 m3 / day ≤1,000 m3 / day (-) 568 m3 / day

Average daily discharge ≤43.3 m3 / day ≤57.4 m3 / day (-) 14.1 m3/d

Note: for flow rate calculations Q=CIA, with a concentration factor of 0.9, an area of 11, 164 m2

and an (I) of a 10 year rainfall event

The revised volumes shown in Table 1 are a result of a size reduction in the coal Processing

Area from an original 15,397 m2 (to accommodate the emergency stockpile) down to 11,164 m2.

The stockpile was eliminated from the proposal on the basis of agency and stakeholder input

into multiple project design iterations.

ADDITIONAL LABORATORY ANALYSES

With the elimination of the emergency stockpile and the potential for water to sit in the treatment

ponds during dry periods prior to discharge, FSD retained CARO Analytical to conduct

analyses on 600 mg/L coal and water solutions sitting for one and two weeks. These included

conducting analyses on “decanted” water from the one and two week samples, and on solutions

prepared from the one and two week samples after they were agitated to redistribute the coal

particles. Consistent with the Synthetic Precipitation Leachate Procedure (SPLP) results

reported in September 2013 a limited number of metals and organics were detected (Table 2,

Appendix 1) and none of the detected parameters were above available Schedule B-Restricted

Waste Criteria.

Table 2. Detected parameters – 600 mg/L PRB coal and water solutions


limit

< 2 mm Coal @ 600

mg/L ‐ 1 WEEK

< 2 mm Coal @ 600 mg/L ‐ 1 WEEK (agitated)

< 2 mm Coal @ 600

mg/L ‐ 2 WEEK

< 2 mm Coal @ 600 mg/L ‐ 2 WEEK (agitated)

GVSD&D Restricted waste criteria 17‐Sep‐

13 17‐Sep‐

13 24‐Sep‐

13 24‐Sep‐

13

Water Water Water Water

pH pH units

0.01 7.15 7.12 7.36 7.06 5.5 to 10.5

Aluminum, total mg/L 0.05 <0.05 0.21 <0.05 0.42 50

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Barium, total mg/L 0.05 <0.05 0.28 <0.05 0.37 ‐

Copper, total mg/L 0.002 <0.002 <0.002 <0.002 0.003 2

Iron, total mg/L 0.1 <0.1 0.2 <0.1 0.5 10

Magnesium, total mg/L 0.1 <0.1 0.1 <0.1 0.2 ‐

Manganese, total mg/L 0.002 <0.002 0.003 <0.002 0.007 5

Sodium, total mg/L 0.2 0.9 1 1.1 1.3 ‐

Strontium, total mg/L 0.01 <0.01 0.04 <0.01 0.07 ‐

Benzo (a) pyrene ug/L 0.01 <0.01 0.01 <0.01 <0.01 ‐

Phenanthrene ug/L 0.1 <0.10 0.17 <0.10 <0.10 ‐

Total PAH ug/L ‐ n/d 0.18 n/d n/d 50

Chloroform ug/L 1 6.2 5.6 6.2 6.5 ‐

Methylene chloride ug/L 3 <3.0 6.8 <3.0 <3.0 ‐

A comparison of trace element data for the Westshore PRB coal used here and Spring Creek

Mine PRB coal proposed for handling at FSD is provided in Table 3. These data indicate the

Westshore coal is a reasonable surrogate for evaluating potential water quality conditions in the

treatment system for PRB coal that will be handled at FSD; with most parameters in the

Westshore sample falling into the range of concentrations from samples provided by the Spring

Creek mine. Table 3. Comparison of Westshore PRB coal used for preliminary analyses and the Spring Creek

Mine Coal that will be handled at FSD

Analyte Units

< 2mm Coal

Sample - Westshore PRB coal

Spring Creek PRB

source

Spring Creek PRB

source

Spring Creek PRB

source

of 56 11/19/13

7


coal (mean)

coal (min)

coal (max)

Antimony mg/kg dry 0.2 0.15 0.11 0.21

Arsenic mg/kg dry 1.8 1.5 1 2.1

Barium mg/kg dry 530 663 567 747

Beryllium mg/kg dry 0.2 0.2 0.1 0.3

Boron mg/kg dry 18 30 22 35

Cadmium mg/kg dry 0.07 0.06 0.04 0.09

Chromium mg/kg dry 4 2 2 3

Cobalt mg/kg dry 1 1.1 0.8 1.3

Copper mg/kg dry 8.9 9 7 10

Lead mg/kg dry 2.5 1.1 0.7 1.3

Lithium mg/kg dry 1.5 4.3 3.3 5.2

Manganese mg/kg dry 17 24 15 68

Mercury mg/kg dry 0.1 0.055 0.034 0.095

Molybdenum mg/kg dry 0.8 0.7 0.5 1

Nickel mg/kg dry 2 2 1 2

Selenium mg/kg dry 0.9 0.5 0.4 0.6

Silver mg/kg dry <0.2 0.03 0.02 0.05

Strontium mg/kg dry 290 328 275 413

Thallium mg/kg dry <0.1 0.06 0.04 0.09

Table 3. Comparison of Westshore PRB coal used for preliminary analyses and the Spring Creek Mine Coal that will be handled at FSD

Analyte Units

< 2mm Coal

Sample - Westshore PRB coal

Spring Creek PRB

source

Spring Creek PRB

source

Spring Creek PRB

source

of 56 11/19/13

8


coal (mean)

coal (min)

coal (max)

Thorium mg/kg dry 0.7 0.6 0.5 0.7

Tin mg/kg dry 0.3 0.2 0.2 0.2

Uranium mg/kg dry 0.6 0.4 0.3 0.5

Vanadium mg/kg dry 9.8 11 9 12

Zinc mg/kg dry 7 5 3 6

Zirconium mg/kg dry 8 10.5 7.9 12.9

If you have any questions, please contact Jurgen Franke by phone at 778.838.7581 or by email

at [email protected].

Sincerely,

Jurgen Franke, P.Eng. Director of Engineering and Maintenance Fraser Surrey Docks cc. Triton Environmental

SNC-Lavalin Inc

Omni Engineering

Encl: Appendix 1 – Revised Lab results

Appendix 2 - WMP October 15th 2013

Appendix 3 – email from PMV

of 56 11/19/13

of 56 11/19/13


Page 13

APPENDIX 1: SUMMARY OF SEPTEMBER 2013 METALS, PAH, VOC, SULPHATE AND PHENOLS RESULTS


limit

< 2 mm Coal @

600 mg/L ‐ 1 WEEK

< 2 mm Coal @

600 mg/L ‐ 1 WEEK

< 2 mm Coal @

600 mg/L ‐ 2 WEEK

< 2 mm Coal @

600 mg/L ‐ 2 WEEK

GVSD&D Restricted waste criteria

17‐Sep‐13 17‐Sep‐13 24‐Sep‐13 24‐Sep‐13

Sulfate mg/L 1 <1.0 <1.0 <1.0 <1.0 1500

pH pH units 0.01 7.15 7.12 7.36 7.06 5.5 to 10.5

Hardness, Total (Total as CaCO3)

mg/L ‐ <5.0 <5.0 <5.0 <5.0 ‐

Aluminum, total mg/L 0.05 <0.05 0.21 <0.05 0.42 50

Antimony, total mg/L 0.0010 <0.001 <0.001 <0.001 <0.001 ‐

Arsenic, total mg/L 0.005 <0.005 <0.005 <0.005 <0.005 1

Barium, total mg/L 0.05 <0.05 0.28 <0.05 0.37 ‐

Beryllium, total mg/L 1.00E‐03 <0.001 <0.001 <0.001 <0.001 ‐

Bismuth, total mg/L 1.00E‐03 <0.001 <0.001 <0.001 <0.001 ‐

Boron, total mg/L 0.04 <0.04 <0.04 <0.04 <0.04 50

Cadmium, total mg/L 0.0001 <0.0001 <0.0001 <0.0001 <0.0001 0.2

Calcium, total mg/L 2 <2 <2 <2 <2 ‐

Chromium, total mg/L 0.005 <0.005 <0.005 <0.005 <0.005 4

Cobalt, total mg/L 0.0005 <0.0005 <0.0005 <0.0005 <0.0005 5

Copper, total mg/L 0.002 <0.002 <0.002 <0.002 0.003 2

Iron, total mg/L 0.1 <0.1 0.2 <0.1 0.5 10

Lead, total mg/L 1.00E‐03 <0.001 <0.001 <0.001 <0.001 1

Lithium, total mg/L 0.0010 <0.001 <0.001 <0.001 <0.001 ‐

Magnesium, total mg/L 0.1 <0.1 0.1 <0.1 0.2 ‐

Manganese, total mg/L 0.002 <0.002 0.003 <0.002 0.007 5

Mercury, total mg/L 0.0002 <0.0002 <0.0002 <0.0002 <0.0002 0.05

Molybdenum, total mg/L 0.0010 <0.001 <0.001 <0.001 <0.001 1

Nickel, total mg/L 0.002 <0.002 <0.002 <0.002 <0.002 2

Phosphorus, total mg/L 0.2 <0.2 <0.2 <0.2 <0.2 ‐

Potassium, total mg/L 0.2 <0.2 <0.2 <0.2 <0.2 ‐

Selenium, total mg/L 0.005 <0.005 <0.005 <0.005 <0.005 1

Silicon, total mg/L 5 <5 <5 <5 <5 ‐

Silver, total mg/L 0.0005 <0.0005 <0.0005 <0.0005 <0.0005 1

Sodium, total mg/L 0.2 0.9 1 1.1 1.3 ‐

Strontium, total mg/L 0.01 <0.01 0.04 <0.01 0.07 ‐

Sulfur, total mg/L 10 <10 <10 <10 <10 ‐

Tellurium, total mg/L 0.002 <0.002 <0.002 <0.002 <0.002 ‐

Thallium, total mg/L 0.0002 <0.0002 <0.0002 <0.0002 <0.0002 ‐

Thorium, total mg/L 1.00E‐03 <0.001 <0.001 <0.001 <0.001 ‐

Tin, total mg/L 0.002 <0.002 <0.002 <0.002 <0.002 ‐

Titanium, total mg/L 0.05 <0.05 <0.05 <0.05 <0.05 ‐

Uranium, total mg/L 0.0002 <0.0002 <0.0002 <0.0002 <0.0002 ‐

Vanadium, total mg/L 0.01 <0.01 <0.01 <0.01 <0.01 ‐

Zinc, total mg/L 0.04 <0.04 <0.04 <0.04 <0.04 3

Zirconium, total mg/L 1.00E‐03 <0.001 <0.001 <0.001 <0.001 ‐

2‐Chlorophenol ug/L 0.2 <0.2 <0.2 <0.2 <0.2 ‐

3 & 4‐Chlorophenol ug/L 0.3 <0.3 <0.3 <0.3 <0.3 ‐

of 56 11/19/13




limit

< 2 mm Coal @

600 mg/L ‐ 1 WEEK

< 2 mm Coal @

600 mg/L ‐ 1 WEEK

< 2 mm Coal @

600 mg/L ‐ 2 WEEK

< 2 mm Coal @

600 mg/L ‐ 2 WEEK


17‐Sep‐13 17‐Sep‐13 24‐Sep‐13 24‐Sep‐13

2,3‐Dichlorophenol ug/L 0.2 <0.2 <0.2 <0.2 <0.2 ‐

2,4 & 2,5‐Dichlorophenol ug/L 0.2 <0.2 <0.2 <0.2 <0.2 ‐




2,3,4‐Trichlorophenol ug/L 0.5 <0.5 <0.5 <0.5 <0.5 ‐






2,3,4,5 & 2,3,5,6‐Tetrachlorophenol

ug/L 0.5 <0.5 <0.5 <0.5 <0.5 ‐

2,3,4,6‐Tetrachlorophenol ug/L 0.5 <0.5 <0.5 <0.5 <0.5 ‐

Pentachlorophenol ug/L 0.5 <0.5 <0.5 <0.5 <0.5 ‐

Phenols (chlorinated) ug/L ‐ n/d n/d n/d n/d 50

Phenol ug/L 0.5 <0.5 <0.5 <0.5 <0.5 ‐

2‐Methylphenol ug/L 0.5 <0.5 <0.5 <0.5 <0.5 ‐

3 & 4‐Methylphenol ug/L 0.5 <0.5 <0.5 <0.5 <0.5 ‐

2,4‐Dimethylphenol ug/L 0.5 <0.5 <0.5 <0.5 <0.5 ‐

2‐Nitrophenol ug/L 0.5 <0.5 <0.5 <0.5 <0.5 ‐

4‐Nitrophenol ug/L 0.5 <0.5 <0.5 <0.5 <0.5 ‐

2,4‐Dinitrophenol ug/L 0.5 <0.5 <0.5 <0.5 <0.5 ‐

2‐Methyl‐4,6‐dinitrophenol

ug/L 0.5 <0.5 <0.5 <0.5 <0.5 ‐

Phenols (non chlorinated) ug/L ‐ n/d n/d n/d n/d 1000

Acenaphthene ug/L 0.05 <0.05 <0.05 <0.05 <0.05 ‐

Acenaphthylene ug/L 0.05 <0.05 <0.05 <0.05 <0.05 ‐

Acridine ug/L 0.1 <0.10 <0.10 <0.10 <0.10 ‐

Anthracene ug/L 0.05 <0.05 <0.05 <0.05 <0.05 ‐

Benzo (a) anthracene ug/L 0.05 <0.05 <0.05 <0.05 <0.05 ‐

Benzo (a) pyrene ug/L 0.01 <0.01 0.01 <0.01 <0.01 ‐

Benzo (b) fluoranthene ug/L 0.05 <0.05 <0.05 <0.05 <0.05 ‐

Benzo (g,h,i) perylene ug/L 0.05 <0.05 <0.05 <0.05 <0.05 ‐

Benzo (k) fluoranthene ug/L 0.05 <0.05 <0.05 <0.05 <0.05 ‐

Chrysene ug/L 0.05 <0.05 <0.05 <0.05 <0.05 ‐

Dibenz (a,h) anthracene ug/L 0.05 <0.05 <0.05 <0.05 <0.05 ‐

Fluoranthene ug/L 0.05 <0.05 <0.05 <0.05 <0.05 ‐

Fluorene ug/L 0.05 <0.05 <0.05 <0.05 <0.05 ‐

Indeno (1,2,3‐cd) pyrene ug/L 0.05 <0.05 <0.05 <0.05 <0.05 ‐

Naphthalene ug/L 0.3 <0.30 <0.30 <0.30 <0.30 ‐

Phenanthrene ug/L 0.1 <0.10 0.17 <0.10 <0.10 ‐

Pyrene ug/L 0.1 <0.10 <0.10 <0.10 <0.10 ‐

Quinoline ug/L 0.1 <0.10 <0.10 <0.10 <0.10 ‐

Total PAH ug/L ‐ n/d 0.18 n/d n/d 50

of 56 11/19/13


Benzene ug/L 0.5 <0.5 <0.5 <0.5 <0.5 100



limit

< 2 mm Coal @

600 mg/L ‐ 1 WEEK

< 2 mm Coal @

600 mg/L ‐ 1 WEEK

< 2 mm Coal @

600 mg/L ‐ 2 WEEK

< 2 mm Coal @

600 mg/L ‐ 2 WEEK


17‐Sep‐13 17‐Sep‐13 24‐Sep‐13 24‐Sep‐13

Bromodichloromethane ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

Bromoform ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

Carbon tetrachloride ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

Chlorobenzene ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

Chloroethane ug/L 2 <2.0 <2.0 <2.0 <2.0 ‐

Chloroform ug/L 1 6.2 5.6 6.2 6.5 ‐

Dibromochloromethane ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

1,2‐Dibromoethane ug/L 0.3 <0.3 <0.3 <0.3 <0.3 ‐

Dibromomethane ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

1,2‐Dichlorobenzene ug/L 0.5 <0.5 <0.5 <0.5 <0.5 ‐

1,3‐Dichlorobenzene ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

1,4‐Dichlorobenzene ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

1,1‐Dichloroethane ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

1,2‐Dichloroethane ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

1,1‐Dichloroethene ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

cis‐1,2‐Dichloroethene ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

trans‐1,2‐Dichloroethene ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

1,2‐Dichloropropane ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

cis‐1,3‐Dichloropropene ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

trans‐1,3‐Dichloropropene ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

Ethylbenzene ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

Methyl tert‐butyl ether ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

Methylene chloride ug/L 3 <3.0 6.8 <3.0 <3.0 ‐

Styrene ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

1,1,2,2‐Tetrachloroethane ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

Tetrachloroethene ug/L 1 <1.0 <1.0 <1.0 <1.0 50

Toluene ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

1,1,1‐Trichloroethane ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

1,1,2‐Trichloroethane ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

Trichloroethene ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

Trichlorofluoromethane ug/L 1 <1.0 <1.0 <1.0 <1.0 ‐

Vinyl chloride ug/L 2 <2.0 <2.0 <2.0 <2.0 ‐

Xylenes (total) ug/L 2 <2.0 <2.0 <2.0 <2.0 ‐

of 56 11/19/13



Parameter Units Detection limits

< 2 mm Coal @ 600

mg/L

GVSD&D Restricted waste criteria 10‐Sep‐13

Sulfate mg/L 1 <1.0 1,500

BOD, 5‐day mg/L 10 <10 500

pH pH units 0.01 7.34 5.5 to 10.5

Hardness, Total (Total as CaCO3) mg/L ‐ <5.0 ‐

Aluminum, total mg/L 0.05 0.06 50

Antimony, total mg/L 1.00E‐03 <0.001 ‐

Arsenic, total mg/L 0.005 <0.005 1

Barium, total mg/L 0.05 0.09 ‐

Beryllium, total mg/L 1.00E‐03 <0.001 ‐

Bismuth, total mg/L 1.00E‐03 <0.001 ‐

Boron, total mg/L 0.04 <0.04 50

Cadmium, total mg/L 0.0001 <0.0001 0.2

Calcium, total mg/L 2 <2 ‐

Chromium, total mg/L 0.005 <0.005 4

Cobalt, total mg/L 0.0005 <0.0005 5

Copper, total mg/L 0.002 <0.002 2

Iron, total mg/L 0.1 <0.1 10

Lead, total mg/L 1.00E‐03 <0.001 1

Lithium, total mg/L 1.00E‐03 <0.001 ‐

Magnesium, total mg/L 0.1 <0.1 ‐

Manganese, total mg/L 0.002 <0.002 5

Mercury, total mg/L 0.0002 <0.0002 0.05

Molybdenum, total mg/L 1.00E‐03 <0.001 1

Nickel, total mg/L 0.002 <0.002 2

Phosphorus, total mg/L 0.2 <0.2 ‐

Potassium, total mg/L 0.2 <0.2 ‐

Selenium, total mg/L 0.005 <0.005 1

Silicon, total mg/L 5 <5 ‐

Silver, total mg/L 0.0005 <0.0005 1

Sodium, total mg/L 0.2 0.2 ‐

Strontium, total mg/L 0.01 <0.01 ‐

Sulfur, total mg/L 10 <10 ‐

Tellurium, total mg/L 0.002 <0.002 ‐

Thallium, total mg/L 0.0002 <0.0002 ‐

Thorium, total mg/L 1.00E‐03 <0.001 ‐

Tin, total mg/L 0.002 <0.002 ‐

Titanium, total mg/L 0.05 <0.05 ‐

Uranium, total mg/L 0.0002 <0.0002 ‐

Vanadium, total mg/L 0.01 <0.01 ‐

Zinc, total mg/L 0.04 <0.04 3

Zirconium, total mg/L 1.00E‐03 <0.001 ‐

2‐Chlorophenol ug/L 0.2 <0.2 ‐

3 & 4‐Chlorophenol ug/L 0.3 <0.3 ‐

2,3‐Dichlorophenol ug/L 0.2 <0.2 ‐

2,4 & 2,5‐Dichlorophenol ug/L 0.2 <0.2 ‐



of 56 11/19/13




< 2 mm Coal @ 600

mg/L



2,3,4‐Trichlorophenol ug/L 0.5 <0.5 ‐






2,3,4,5 & 2,3,5,6‐Tetrachlorophenol ug/L 0.5 <0.5 ‐

2,3,4,6‐Tetrachlorophenol ug/L 0.5 <0.5 ‐

Pentachlorophenol ug/L 0.5 <0.5 ‐

Phenol ug/L 0.5 <0.5 ‐

2‐Methylphenol ug/L 0.5 <0.5 ‐

3 & 4‐Methylphenol ug/L 0.5 <0.5 ‐

2,4‐Dimethylphenol ug/L 0.5 <0.5 ‐

2‐Nitrophenol ug/L 0.5 <0.5 ‐

4‐Nitrophenol ug/L 0.5 <0.5 ‐

2,4‐Dinitrophenol ug/L 0.5 <0.5 ‐

2‐Methyl‐4,6‐dinitrophenol ug/L 0.5 <0.5 ‐

Acenaphthene ug/L 0.05 <0.05 ‐

Acenaphthylene ug/L 0.05 <0.05 ‐

Acridine ug/L 0.1 <0.10 ‐

Anthracene ug/L 0.05 <0.05 ‐

Benzo (a) anthracene ug/L 0.05 <0.05 ‐

Benzo (a) pyrene ug/L 0.01 <0.01 ‐

Benzo (b) fluoranthene ug/L 0.05 <0.05 ‐

Benzo (g,h,i) perylene ug/L 0.05 <0.05 ‐

Benzo (k) fluoranthene ug/L 0.05 <0.05 ‐

Chrysene ug/L 0.05 <0.05 ‐

Dibenz (a,h) anthracene ug/L 0.05 <0.05 ‐

Fluoranthene ug/L 0.05 <0.05 ‐

Fluorene ug/L 0.05 <0.05 ‐

Indeno (1,2,3‐cd) pyrene ug/L 0.05 <0.05 ‐

Naphthalene ug/L 0.3 <0.30 ‐

Phenanthrene ug/L 0.1 0.11 ‐

Pyrene ug/L 0.1 <0.10 ‐

Quinoline ug/L 0.1 <0.10 ‐

Total PAH ug/L ‐ ‐ 50

Benzene ug/L 0.5 <5.0 100

Bromodichloromethane ug/L 1 <10.0 ‐

Bromoform ug/L 1 <10.0 ‐

Carbon tetrachloride ug/L 1 <10.0 ‐

Chlorobenzene ug/L 1 <10.0 ‐

Chloroethane ug/L 2 <20.0 ‐

Chloroform ug/L 1 <10.5 ‐

Dibromochloromethane ug/L 1 <10.0 ‐

1,2‐Dibromoethane ug/L 0.3 <3.0 ‐

Dibromomethane ug/L 1 <10.0 ‐

1,2‐Dichlorobenzene ug/L 0.5 <5.0 ‐

of 56 11/19/13




< 2 mm Coal @ 600

mg/L


1,3‐Dichlorobenzene ug/L 1 <10.0 ‐

1,4‐Dichlorobenzene ug/L 1 <10.0 ‐

1,1‐Dichloroethane ug/L 1 <10.0 ‐

1,2‐Dichloroethane ug/L 1 <10.0 ‐

1,1‐Dichloroethene ug/L 1 <10.0 ‐

cis‐1,2‐Dichloroethene ug/L 1 <10.0 ‐

trans‐1,2‐Dichloroethene ug/L 1 <10.0 ‐

1,2‐Dichloropropane ug/L 1 <10.0 ‐

cis‐1,3‐Dichloropropene ug/L 1 <10.0 ‐

trans‐1,3‐Dichloropropene ug/L 1 <10.0 ‐

Ethylbenzene ug/L 1 <10.0 ‐

Methyl tert‐butyl ether ug/L 1 <10.0 ‐

Methylene chloride ug/L 3 <30.0 ‐

Styrene ug/L 1 <10.0 ‐

1,1,2,2‐Tetrachloroethane ug/L 1 <10.0 ‐

Tetrachloroethene ug/L 1 <10.0 50

Toluene ug/L 1 <10.0 ‐

1,1,1‐Trichloroethane ug/L 1 <10.0 ‐

1,1,2‐Trichloroethane ug/L 1 <10.0 ‐

Trichloroethene ug/L 1 <10.0 ‐

Trichlorofluoromethane ug/L 1 <10.0 ‐

Vinyl chloride ug/L 2 <20.0 ‐

Xylenes (total) ug/L 2 <20.0 ‐

of 56 11/19/13


APPENDIX 2: FRASER SURREY DOCKS EMERGENCY RESPONSE PLAN

of 56 11/19/13

Fraser Surrey Docks Emergency Response Plan

Latest Update Nov 2013

1

7.0 Chemical and Dangerous Goods Spill First Response 7.1 MINOR CHEMICAL SPILLS

Inform Security (235)

Security: Call on duty Superintendent (224)

Security: Call BNSF directly at 604-522-7539 to clear the track IF 911 CALLED.

1 Wardens are responsible for moving everyone upwind, out of the isolation zone. Do not allow unauthorized personnel to enter the contaminated area.

SEE MARSHALLING AREAS MAP FOR MARSHALLING LOCATIONS.

Wind direction

Upwind

Isolation

Zone

Spill

Upwind

Diagram 1

2 Determine health and safety risks by observing WHMIS or TDG labeling. Use binoculars in the ERV if necessary.

3 GET MATERIAL SAFETY DATA SHEET AND DETERMINE APPROPRIATE CLEANUP PROCEDURES FOR THE MATERIAL.

of 56 11/19/13



2

4 Decide if you can safely handle the spill. IF UNSURE, CALL 911, SURREY FIRE DEPARTMENT, or HAZMAT FOR ASSISTANCE.

5 Immediately advise Dock First aid of any emergency situation.

6 Eliminate all ignition sources if flammable material is involved.

7 If safe, remove injured personnel from the emergency area.

8 Attend to any person who may have been contaminated.

9 Collect information on the chemical using the form on the previous page.

10 Fill out Warden Procedures' form 4

11 See SPILL REPORTING section for reporting chemical spills.

12 Fill out the Chemical/Dangerous Goods Emergency Response Statement Form 8

13 Notify Port Metro Vancouver Ops Center (604-665-9086)

14 Fill out Emergency Information – Form 1

15 Fill out Emergency Plan Activation – Form 2

of 56 11/19/13



3

Figure 1 - Chemical / Dangerous Goods Emergency Response Statement – Form 8 Date:___________________ Time:___________ Exact Location:____________________

Person Discovering Problem or Receiving Information:__________________________________

Chemical or Dangerous Goods Container Number (if any):______________________________

UN #

CLASS SHIPPING NAME

PACKING GROUP

TOTAL WEIGHT

Emergency Response guidebook GUIDE # _________ Page # __________ Detailed Description (Fire, Explosion, Spill, etc.): ______________________________________

_____________________________________________________________________________________

_______________________________________________________________________

Potential Hazards: _______________________________________________________________

______________________________________________________________________________

Response Actions Taken to Stop, Contain, or Minimize Effects of Spill:

_____________________________________________________________________________________

_____________________________________________________________________________________

________________________________________________________________

Safety Barrier Erected: __________ metres per Emergency Response Guidebook

Material Safety Data Sheet Copied and Distributed: YES NO Evacuation Initiated: YES NO Time: _________ Distance: _________ metres Call Out Procedures: On Call Superintendent (604-582-2224) Name: _______ Time: _______ Canutec (1-613-996-6666) Name: _______ Time: _______ Surrey Fire Department (604-543-6700) Name: _______ Time: _______ CEDA (604-540-4100) Name: _______ Time: _______ I.L.W.U 502 Business Agent (604-580-8882) Name: ______ Time: _______ I.L.W.U 514 Union Representative (604-298-9684) Name: _______ Time: _______ Shipper/Owner of Cargo ( ) Name: _______ Time: _______ Is the spill a reportable quantity? (See Reportable Quantities in this section): YES NO If YES, report incident to the Provincial Emergency Program (1-800-663-3456) Time: ______ If the Spill is to Water or a Vessel is Alongside Call Out Procedure: Chief Mate or Captain of the Vessel ( ) Name: ______ Time: _______ Port Metro Vancouver (604-665-9086) Name: ______ Time: _______ Coast Guard Ship Safety (604-666-6011) Name: ______ Time: _______ Note: Foremen are to inform workers of the hazard, restricted area, and emergency response actions being initiated. A copy of this document will be provided for the vessel's security log.

of 56 11/19/13



4

7.2 SPILL CLEANUP

Take remedial action only if your safety is not in danger

Begin first response, using equipment contained in the Emergency Response Vehicle (ERV) as follows:

1 Wear impermeable protective clothing as necessary and remove injured personnel from the danger area.

2 Stop the source of the release; if possible, by closing valves, standing drums upright, etc. 3 Stop the spread of the spill with absorbents, sandbags, rubber drain covers, etc. Choose

absorbents designed for hydrocarbons or water-based chemicals as appropriate. 4 Prevent the spill from entering sewer drains or contacting exposed soil. Obtain a map from

security providing the location of all sewers. 5 If further storage tank capacity is required, A&A Anderson (604-277-1628), or Phillips

Environmental Service can provide a pump truck.

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7.3 IF SPILL IS TO WATER

CALL 911, Surrey Fire Department

CALL SECURITY (235)

SECURITY: Call BNSF directly at 604-522-7539 to clear the track

SECURITY: Call on duty Superintendent (224)

1 Contact the Port Metro Vancouver and advise them of the situation (604-665-9086).

2 Stop the spread of the spill to the water, if safe to do so, with absorbents, booms, etc.

(Surrey Fire Dept have bladders that can inflate to fill storm drains) 3 Request assistance from Port Metro Vancouver as necessary. 5 If a vessel is alongside, inform the ship of the spill and request assistance from ship

personnel. 6 Fill out the Chemical/Dangerous Goods Emergency Response Statement Form 8

7 Fill Out Emergency Information – Form 1 and


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7.4 LARGER SPILLS BEYOND FSD CONTAINMENT CAPABILITIES

CALL 911, Surrey Fire Department

CALL SECURITY (235)

SECURITY: Call BNSF directly at 604-522-7539 to clear the track

SECURITY: Call on duty Superintendent (224)

In the event of a spill, the On‐Call Superintendent will act as the Lead ERC (Emergency Response Contact) and will be responsible to make all calls in accordance to the Spill Response Plan.

1. Stop the spread of the spill to the water, if safe to do so.

2. Contact the Port Metro Vancouver and advise them of the situation (604-665-9086).

Request assistance from Port Metro Vancouver as necessary. 3. Contact Western Canada Marine Response Corporation at 604-294-9116 as necessary.

4. Contact Canadian Coast Guard – Marine Communications and Traffic Services (604-666-

6012)

5. Do not wear contaminated clothing beyond the clean-up area. Wash thoroughly with soap and water as soon as possible upon leaving the spill area. Place soiled clothing and equipment in the proper receptacles for disposal according to environmental regulations (the plastic garbage pails stored in the ERV can be used for this purpose)

6. All contaminated material, such as chips, sand, sludge, etc., shall be stored in marked drums pending disposal in accordance with environmental legislation. DO NOT HANDLE CONTAMINATED MATERIAL. Disposal is the responsibility of FSD or the spiller. Environment Canada (604) 666-6100 and/or BC Environment, Lands & Parks 1-800-663-3456 may be consulted for advice.

9 Fill out the Chemical/Dangerous Goods Emergency Response Statement Form 8

10 Fill Out Emergency Information – Form 1 and


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7.5 SPILL REPORTING

See Figure 5 - Reportable Quantities on Adjacent Page

The Spill Reporting Regulation of the BC Waste Management Act requires that spill in excess of the reportable quantity, as shown on the schedule on the adjacent page, be reported to the Provincial Emergency Program (PEP) (1-800-663-3456, 24 hrs). The Lead ERC, or delegate, is responsible for making this assessment and contacting PEP.

The reporting person will be asked to provide the following information:

1 Your name and telephone number 2 Name and telephone number of the person who caused the spill 3 Time of the spill 4 Proper name of chemical spilled and its PIN # (UN#) 5 Quantity of substance spilled 6 Cause and effect of the spill 7 Details of action taken or proposed to stop, contain and minimize the effects of the spill 8 Description of the spill location and of the area surrounding the spill 9 Details of further action contemplated or required 10 Names of agencies on the scene 11 Names of other persons or agencies advised concerning the spill

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Figure 2 - Schedule of Reportable Spill Quantities Substance Spilled Specified Amount

Explosives (TDG Class 1) Any

Flammable gases (TDG Class 2, Division 1) 10 kg - where spill results from equipment failure, error or deliberate action or inaction

Non-flammable gases (TDG Class 2, Division 2) 10 kg - where spill results from equipment failure, error or deliberate action or inaction

Poisonous gases (TDG Class 2, Division 3) All - where spill results from equipment failure, error or deliberate action or inaction

Corrosive gases (TDG Class 2, Division 4) All - where spill results from equipment failure, error or deliberate action or inaction

Flammable liquids (TDG Class 3) 100 litres

Flammable solids (TDG Class 4) 25 kg

Oxidizing substances (TDG Class 5, Division 1) 50 kg

Organic peroxides (TDG Class 5, Division 2) 1 kg

Poisonous substances (TDG Class 6, Division 1) 5 kg

Infectious substances (TDG Class 6, Division 2) Any

Radioactive materials (TDG Class 7) All discharges

Corrosives (TDG Class 8) 5 kg

Miscellaneous substances (TDG Class 9, Division 1) 50 kg



Waste Asbestos (Section 1, Special Waste Regulation)

50 kg

Waste Oil (Section 1, Special Waste Regulation) 100 litres

Waste containing a pest control product (Section 1, Special Waste Regulation 9)

5 kg (or 5 litres)

A substance not covered above that can cause pollution

200 kg

* NOTE: 1 kg = 1 litre for conversion purposes

A spill is considered any release of material outside an approved containment device. If you are in doubt as to whether a spill is reportable, err on the side of caution and report it anyway to the Provincial Emergency Program (PEP) (1-800-663-3456, 24 hrs).

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APPENDIX 3: DRAWINGS

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Dave Stewart

Callout

Proposed Connection to North Surrey Interceptor

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Dave Stewart

Callout

Proposed Connection Location


APPENDIX 4: DESIGN MEMORANDUM

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TECHNICAL MEMORANDUM 2113-3 Rev 3

Project Title: FRASER SURREY DOCKS PROPOSED COAL LOADOUT FACILITY

Subject: Sizing of Loading Area Secondary Cell

Omni File: 2096 Date of Revision: November 1, 2013

Page 1 of 9

To: Fraser Surrey Docks – Jurgen Franke P.Eng. Purpose of Memorandum: To explain the rationale in determining the size of secondary settling cell (loading area settling pond) required to consistently meet the Metro Vancouver Restricted Waste Criteria of < 600 mg/L ( ppm) Proposed Settling Pond Parameters:

1. Maximum Overflow Rate Q= 5 liters /sec. (approximately 80 USgpm)

2. Secondary Settling Cell Plan Area = 165 m2

3. Secondary Settling Cell Working Volume = 432 m3 .

Theoretical Approach to Determining Cell Size: The theoretical approach to determining settling basin dimensions is based on equating the overflow rate of the settling pond to the settling rate of the smallest particle to be removed :

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The design upflow velocity of the secondary settling cell is

5 Liters per second = 3.03 x 10-5 m/sec 165 m2 To determine the smallest size of particle which will be completely removed, Stokes Law is employed:

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Note how water viscosity increases with falling temperature resulting in dramatically decreased settling velocity

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When Stokes Law is applied to coal particles with a SG=1.4 the following calculation results:

The highlighted 155 m2 is roughly equivalent to the secondary settling area of 165 m2. Thus theoretically all particles greater than 15 microns in diameter will be removed by the proposed secondary settling cell when it is operating at its maximum overflow rate of 5L/sec. Of course, when the secondary settling cell is not operating continuously at this rate ie when the overflow rate is less, smaller particles will be removed (in theory if the secondary settling cell was completely quiescent for several days, virtually all the coal particles would settle).

However without data on the incoming influent suspended solids content and particle size distribution, we cannot say conclusively that removal of all particles larger than 15 microns will result in an effluent with suspended solids content less than 600 ppm. However, the calculation does, to this author at least, provide some sort of comfort level.

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Practical Approach to Determining Cell Size:

The “retention time” approach is sometimes used as a practical approach to estimate suspended solids removal in a settling basin based upon lab testing of the influent to be settled.

Settlement Time = Volume of Basin = 432 m2 = 1440 minutes (1 day) Overflow Rate 5 L/sec However, with a pump out basin, it is overly optimistic to assume that the whole volume of the settling basin will be occupied by an influent because at various times the basin will not be full.

A reasonable approximation might be ½ the volume so the average retention time becomes 720 minutes.

Settling tests were performed on lab specimens prepared at 10.000 ppm Lab tests were performed as described following. Care was taken to keep the water temperature low. The 100 mm depth approximates the depth of the pump intake.

Results were:

TIME (minutes) CONCENTRATION (ppm)

0 10,000

10 1480

20 1320

120 491

1440 92

A simplistic analysis of these results would infer that we could expect a suspended solids content somewhere in the vicinity of 300 ppm when the secondary settling cell is operated at maximum overflow rate of 5L/sec. However this analysis suffers from the same deficiency as the theoretical analysis in that the lab samples do not necessarily represent the suspended solids content or particle size distribution of the actual influent that will come from the primary settling cell.

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SECTION A: INTRODUCTION, BUSINESS NAME AND ADDRESS

Documents

Transcript of SECTION A: INTRODUCTION, BUSINESS NAME AND ADDRESS