FRASER SURREY DOCKS TEMPORARY COAL … · TEMPORARY COAL OFFLOADING FACILITY PRELIMINARY ENVIRONMENTAL MANAGEMENT PLAN FOR ... Offloading track and barge loading for PRB ... a 1.5

FRASER SURREY DOCKS

TEMPORARY COAL OFFLOADING FACILITY

PRELIMINARY ENVIRONMENTAL MANAGEMENT PLAN FOR CONSTRUCTION

AND OPERATIONS

Prepared for: Prepared by:

Fraser Surrey Docks 11060 Elevator RdSurrey, BC V3V 2R7

8971 Beckwith Road Richmond, BC V6X 1V4

FRASER SURREY DOCKS Environmental Offloading track and barge loading for PRB coal Management Plan

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DOCUMENT BACKGROUND

This DRAFT environmental management plan (EMP) has been prepared by Triton Environmental Consultants LTD. Fraser Surrey Docks (FSD) provided gradation sheets and information on anti-oxidant and dust suppression compounds proposed for use. CWS Engineering provided information on site design, runoff management, wetting systems for dust control etc. Levelton Consultants LTD (Levelton) completed Air Dispersion Modelling to evaluate potential effects on air quality. The RKMS Group prepared a Fire Safety Plan for the operating facility. Separate construction and operational EMP documents will be prepared and issued upon completion of detailed design as required.


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TABLE OF CONTENTS

1.0 Introduction ................................................................................................ 5

1.1 Project Description ................................................................................. 5 1.2 System Components .............................................................................. 6

2.0 Construction Program ................................................................................ 7 3.0 Construction Environmental Management Plans ....................................... 9

3.1 Surface Water Quality and Sediment Control Plan ............................... 10 3.2 Environmental Monitoring Plan ............................................................. 11 3.3 Hazardous Materials Management and Spill Response Plan (HMMSRP) 12 3.3.1 Hazardous Materials Management Strategies .................................. 12 3.3.2 Storage and Use of Hazardous Materials ......................................... 13 3.3.4 Spill Preparedness ............................................................................ 15 3.3.5 Spill Response .................................................................................. 16

3.4 Soils Management Plan (SMP) ................................................................ 17 3.4.1 Managing Known or Suspect Contaminated Soils ............................ 18 3.5 Air Quality Management Plan ............................................................... 18 3.6 Noise Management Plan ...................................................................... 20 3.7 Pile Driving Plan ................................................................................... 22 3.8 Vegetation and Wildlife Protection Plan ................................................ 24

4.0 Operational Environmental Management Plans ....................................... 25 4.1 Air Quality Management Plan ................................................................... 25

4.1.1 Weather Monitoring ....................................................................... 26 4.1.2 Dust Monitoring ............................................................................. 26 4.1.3 Dust Mitigation Measures .............................................................. 27

4.2 Runoff Management Plan......................................................................... 28 4.2.1 Water Treatment............................................................................ 28 4.2.2 Water Quality Monitoring ................................................................ 29

4.3 Emergency Response Plans .................................................................... 29 4.3.1 Combustion ................................................................................... 29 4.3.2 Spill Prevention and Response ..................................................... 30

4.4 Lighting Plans ........................................................................................... 34 4.5 Noise Management Plans ..................................................................... 35

4.5.1 Existing Conditions ........................................................................ 35 4.5.2 Operations ..................................................................................... 36 4.5.3 Public concerns ............................................................................. 38

5.0 References and Information sources ....................................................... 38


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LIST OF TABLES

Table 1. Examples of noise ratings and equipment age. .................................... 20 Table 2. Air quality parameters and associated emission sources...................... 25 Table 3.Comparison of trace element analyses to available provincial and federal

sediment quality guidelines ............................................................................. 33

LIST OF FIGURES

Figure 1. Drainages overview .................................................................................... 41

LIST OF ATTACHMENTS

Direct to Barge Coal Facility Track Layout (September 09, 2012) Drawing No 11076-SK-030A Drawing No 11076-SK-030B Drawing No 11076-SK-030C Drawing No 11076-SK-030D DC6109 MSDS DC6109 FACSHEET DC9148 MSDS DC9148 FACTSHEET SOIL CEMENT® COAL CAR TOPPING MSDS

LIST OF APPENDICES

APPENDIX 1: SUMMARY OF ONSITE / ADJACENT DRAINAGE FEATURES APPENDIX 2: PROVINCIAL, FEDERAL AND REGIONAL AMBIENT AIR QUALITY OBJECTIVES (AAQO)


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1.0 Introduction

This document is a preliminary environmental management plan (EMP) for a proposed, temporary coal offloading facility at Fraser Surrey Docks (FSD), adjacent to the existing Shed 1, on 11060 Elevator Road in Surrey, BC (See attached - Direct to Barge Coal Facility Track Layout, Drawing 11076-SK-030A, B, C and D. This EMP will be finalized upon completion of detailed design and public consultation, and then issued as separate documents for the Construction and Operational phases of the project.

1.1 Project Description

FSD is proposing to build an onsite, temporary coal offloading facility adjacent to Shed 1 for Powder River Basin (PRB)1 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). On arrival, the coal will be loaded into front end dump barges destined for Texada Island, where it will be received by FSD Logistics Partner. Loaded trains will typically arrive at FSD between 12:00 am and 6:00 am and empty trains will leave between 5:00 pm and 10:00 pm on the same day. Barges will be loaded during all tide levels occurring in this timeframe. To control dust during transit down the Fraser River, the loaded barges will be treated with Soil-cement® Coal Car Topping agent (or similar compound identified in consultation with the Port Metro Vancouver) prior to departure from Berth 2. The FSD offloading facility will operate for 6+ years, with approximately 2 million tonnes barged offsite in Year 1, 4 million tonnes barged offsite annually in Years 2 through 5 and potentially 8 million tonnes in Year 6+. Inbound trains will arrive every second day in Year 1, and once daily in Years 2 through 5.

1 Powder River Basin Coal – located in Montana and Wyomng, sub-bituminous A or B coal, low in sulfur, heating values ranging from 8000 to 9400 BTU/lb, friable (Hossfled and Hatt, n.d) 2DC9148 inhibits oxidation and weathering of coal, reduces hot spots, smokers and spontaneous combustion at coal facilities (e.g. generating stations, terminals and mines), reduces dust generating during loading, unloading, stack out and reclamation, reduces in transit losses (GE Power & Water, August 2010). MSDS and factsheet attached. 3 DC6109 is a foam dust control product which controls dust emissions using less moisture, reduces explosion hazards and respirable dust emissions (GE Power & Water, August 2010. MSDS and Factsheet attached.


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Each train will be roughly 7,500 feet (2,286 m) long and each car will carry roughly 12 to 14 metric tonnes of coal. On arrival at FSD the coal will be dumped via bottom dumping rail cars into a pair of ASHROSS RUMig receiving pits adjacent to Shed 1. The coal will be moved out of these pits to the barges via conveyor systems installed on the paved area west of Shed 1. Each receiving barge will have a capacity of 8,000 dead weight tonnes (dwt). Barges will be filled to roughly 70% capacity and will take roughly 3 to 5 hours to load. From the time the loaded trains arrive onsite, the barges will take roughly 5 to 6 hours to fill. Thereafter, the barges will begin transit to Texada. The anticipated transit time of the loaded barges in the Lower Fraser River is approximately 3 hours, travelling at an approximate speed of 11 km/hour (~6 knots). Barges will be towed downstream with 1,200 horsepower tugs. Space is available onsite for emergency stockpiling of up to 15,000 tonnes of coal. The pile would be flat topped. The pile would be located immediately south of Shed 1 and surrounded by a 1.5 m high asphalt and Loc Block berm, which would function in both the dust and fire suppression programs (see Drawing 11076-SK-030A). However, stockpiling would only occur if there was a delay in barge arrival and / an equipment failure. Stockpiling beyond 4 days is not anticipated. On an annual basis, FSD anticipates no more than 120,000 tonnes would require emergency storage.

1.2 System Components

The operating facility will include the following components:

• Roughly 2.614 km of new railway track, extending from the existing Agri-line west of Shed 5 and ultimately connecting with the existing track paralleling River Road

• Two ASHROSS RUMig receiving pits and associated infrastructure

(e.g. rail car unloading shed, electrical control room, sprinkler system for dust control)


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• Covered double out-feed conveyors (each 60” / 152.6 cm wide,

followed by a transfer chute, an additional feed conveyor (60” wide) and a radial Superior Stacker conveyor (60” wide x 100’ (30.5 m) long) for dumping coal into the barges. The conveyors will be fitted \with spill trays to minimize coal spills during onsite transfers

• Drainage management systems to capture and treat site runoff

prior to discharge offsite

• Fire suppression system, which is currently under development and will include eight (8) tower sprinklers at the stockpile area

• Roughly 12 new steel piles, each 24” (600 mm) in diameter at Berth

2 to accommodate the barges. Aside from the piles, no other new in-water structures are expected and no modifications will be required at Berth 2

• Cinching winch, downstream warping winch and warping /mooring

structures with Pivot Fairlead and Sheave to be installed at the existing dock

• Lighting on the conveyors and barge loaders to facilitate safe night

time operations

• Two front end loaders, one additional yard switching locomotive and possibly two more employee pick-up trucks

2.0 Construction Program

Building the facility will include the following tasks:

• Pavement stripping and excavation to 1.2 m below grade to install the new track. This will require excavating up to 9,650 m3 of fill / native soils (2, 614 m length x 3.05 m width x 1.2 m depth)

• Excavation to 10’ (3.05 m) depth for the two receiving pits;

approximate spoil volume of 885 m3 (38.1 m length x 7.62 m width x 3.05 m depth)


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• Excavations for the supporting indexer (152.4 m x 0.914 m x 0.914

m) and electrical trenching (9.14 m x 3.66 m x 0.914 m);approximate spoil volumes of 30.6 m3 and 127.4 m3 respectively

• Excavation dewatering for all of the above, which will emphasize

the collection and subsequent discharge of excavation water direct

to ground in pits specifically created for this task

• A high yield well point dewatering system is not anticipated for use onsite. A series of pumps will be installed in each of the four corners of the receiving pit excavation (the deepest excavation at 3.05 m) and water will be discharged to a series of in-ground dewatering pits

• Crossing upgrade on a green coded drainage4 (non fish-bearing;

insignificant nutrients and flow) immediately east of Elevator Road,

to accommodate Bekaert’s site access5

• Potential shifting of the Shadow Brook channel (red coded,

permanent, fish-bearing) immediately south of Elevator Road to

accommodate the new track (to be verified by survey)

• Potential new crossing on the red coded ditch paralleling the

existing railway track at the Elevator Road entrance into the FSD

property (to be verified by survey)

• Mobilization and onsite assembly of the conveyor systems

• Installation of the unloading shed walls and supporting electrical

and water distribution systems; note the latter will only require tie-ins to existing water mains, no new water main will be required

4 Classification derived from the City of Surrey COSMOS online mapping system 5Onsite and adjacent drainages features are discussed in Appendix 1


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• Installation of the storm water management / dust control / sprinkler

systems which will include

• Two sumps 20 x 4 m to capture site run-off • Two 20, 000 gallon double walled containment tanks for

settling • Potentially two oil/water interceptor(s) • Make up water hook-up • Sprinkling Towers (potentially eight) • Asphalt and Loc Block containment berm around east and

south edges of proposed stockpile site

• Installation of a fire suppression system (which is under

development but will include a combination of personnel training strategies and infrastructure, the latter including but not limited to the 8 sprinkling towers in the stockpiling area and the watering capacity in the unloading shed)

• Pile driving (12 - 24” steel piles roughly 15.24 m apart) at Berth 2

• Installation of cinching winch, downstream warping winch and

Warping/Mooring with Pivot Fairlead and Sheave on the existing dock

3.0 Construction Environmental Management Plans

The following environmental management plans will be implemented during construction:

• Surface Water Quality and Sediment Control Plan • Environmental monitoring plan • Hazardous Materials Management and Spill Response Plan • Soils Management Plan • Air Quality Management Plan • Noise Management Plan • Pile Driving Management Plan


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3.1 Surface Water Quality and Sediment Control Plan

Potential effects on surface water quality are generally not expected during works in and around Shed 1. However, the following mitigation measures will be implemented during construction in this area:

• Catch basin protection will be installed prior to construction in the Shed 1 working areas and adjacent to truck routes supporting construction at the Shed 1 site

• Excavation discharge will be directed to in-ground pits specifically

created to manage turbid excavation waters, and / or concrete contact waters. These pits will be excavated prior to other works beginning onsite

• Excavation waters will not be discharged to storm water mains

or direct to the Fraser River (see Environmental monitoring plan for additional detail)

• Daily site cleaning will be conducted to prevent a build-up of dust that

could become a source of sediment during rain events. Similarly, site cleaning will be conducted as needed during the wet season to prevent mud tracking

• Potentially restricting selected excavation works during inclement

weather

• Inactive soil stockpiles will be located away from catch basins and will be securely covered to prevent wind losses on dry days and rain-splash erosion of wet days

3.1.1 Watercourses Adjacent to Elevator Road

Shadow Brook is located in between Elevator Road and Robson Road in a proposed area of new track running alongside Elevator Road (Figure 1). This drainage has been classified as red coded (permanent, fish-bearing) by the City of Surrey. A review of the survey drawings indicate the new track alignment will not require the relocation of the Shadow Brook channel, although there will be some encroachment (<100 m2) into the riparian zone.



This can be addressed post construction through onsite riparian restoration works. In addition to the works near Shadow Brook, a new access driveway is proposed for the Bekaert’s site. The exact location of the new access has not yet been selected, and may require a crossing of a green coded (non fish- bearing, insignificant nutrients and flow) drainage feature located north of the existing railway track running alongside Elevator Road (Figure 1). The City does not require compensation for green coded drainage features, but they do require consideration in water quality and storm water management contexts. During construction mitigation measures will be implemented to protect water quality (e.g. erosion and sediment controls, hazardous materials management) and to avoid damage to non-target vegetation in the Shadow Brook riparian zone. Equipment storage and maintenance, fuelling and other activities will not be permitted within 15 m of the channel. Machine access will also be restricted in the riparian zone to the extent feasible.

3.2 Environmental Monitoring Plan

As indicated in the Water Management Plan submitted to the Port in June 2012, an environmental monitor will visit the site at least once weekly during construction to evaluate the effectiveness of mitigation measures. A water quality sampling program will be conducted in support of the excavation discharge program. FSD is proposing to collect groundwater from excavation areas and discharge it into separate in-ground infiltration pits. As a precautionary measure, to ensure groundwater from the nearby Bekaert’s site is not being mobilized into FSD’s work area, excavation discharge water quality will be monitored for the following parameters6:

• pH (in situ) • dissolved metals (analytical)

• conductivity (in situ) • total dissolved solids (in situ) Note that if discharge is observed leaving the site then turbidity and / or total suspended solids (TSS) will be measured along with the parameters listed above at the point of discharge.

6 These parameters (the in situ parameters in particular) have been selected because they will indicate changing ground water quality. If changes are observed, excavation collection and discharge strategies may be modified



Environmental monitoring will also be conducted during pile installation at Berth 2 and will include but not necessarily be limited to: coordination with the pile driving contractor to create fish exclusion zones, and conducting water quality and hydrophone monitoring. Environmental monitoring activities and associated data will be summarized in a post construction monitoring report to be submitted to the Port Metro Vancouver (PMV).

3.3 Hazardous Materials Management and Spill Response Plan (HMMSRP)

The Hazardous Materials Management and Spill Response Plan (HMMSRP) provides guidance on managing potentially hazardous materials. This includes chemicals used during construction, and wastes generated as a result of construction. Spills of hazardous materials have the potential to affect soil, water and sediment quality. Hazardous wastes are prohibited from routine landfill disposal. Examples of hazardous materials that are most likely to be associated with the project include: gasoline and diesel fuel, hydraulic fluids, dry concrete products and concrete wastewater, solvents and waste oils.

3.3.1 Hazardous Materials Management Strategies

Effective hazardous materials management strategies include:

• Preparing inventories of chemicals that will be used, or have the potential to be used onsite. Inventories should include anticipated volumes and types of materials and MSDS

• Providing storage and general guidelines for use of hazardous

materials

• Conducting an overview assessment of risks associated with spills of known hazardous materials used in working areas. This requires the contractor to evaluate the potential hazards of working with specific chemicals, in association with a particular task, in a particular area



• Developing and posting spill prevention plans. Such plans would

include guidelines for daily use and overnight fuel storage, as well as designated waste storage areas for oils, solvents, concrete and other potentially hazardous products. These plans also include guidelines for managing suspect or known contaminated materials

• Developing and posting spill preparedness and response plans for chemicals in use onsite. These plans should include, at a minimum, information on appropriate spill response equipment, communications and response plans

3.3.2 Storage and Use of Hazardous Materials

Where feasible and applicable, Contractors should follow these general guidelines for storage and use of hazardous materials in construction areas (Gibb et al., 1999):

• Outdoor storage will be secured when unmanned, and storage of

hazardous or potentially hazardous materials will ideally be arranged so that stored products are away from vegetated areas and there is ≥6 m between stored products, uncontrolled grasses or weeds, and fuel dispensers

• Storage areas and containers will be regularly inspected for leaks, poor

condition, inadequate seals and other problems that may result in the spill or release of a hazardous substance

• Personnel will read and follow the directions for all products, and have

easy access to MSDS for all hazardous material onsite

• Products will be stored in their original containers and their labels maintained in good condition; labels should be protected with transparent tape as necessary

• As needed and where safe to do so, a correctly sized funnel will be

used to transfer hazardous materials from one container to another



• Personnel will avoid mixing chemicals unless specified by the

manufacturer, and will use chemicals as specified on labels, in well-ventilated areas

• Corrosives will be stored away from flammables

• Re-useable or recycled degreasers will be used where possible or

appropriate to machinery and equipment

3.3.3 Spill Prevention

Spill prevention strategies for the project will include the following:

• Daily inspections of machinery for leaks, cracked hoses and other conditions that may result in spills. Contractors will ensure external equipment surfaces are free of oil, diesel and other potential contaminants prior to use

• Routine inspections of storage areas and containers for leaks, poor

condition, improper seals and other problems that may result in the release of a hazardous substance

• Storage of daily use fuels, lubricants and other chemicals over

impermeable areas and / or in lined, leak proof containers. Temporary covers will be used as needed to prevent rainfall from pooling in daily use storage containers

• Daily use chemicals will be stored onsite in a locked container or

will be taken offsite at the end of each day

• Fuelling and equipment maintenance will be undertaken ≥ 30 m away from all permanent drainages

• Written procedures for the proper use and storage of chemicals will

be provided consistent with the potential risks associated with each chemical, anticipated frequency of use and any special handling requirements



3.3.4 Spill Preparedness

Written spill response procedures and communications protocols will be posted at conspicuous locations onsite. Personnel will know the locations of the spill kits in each working area and be trained in their use. Spill kits will be appropriate to the types of hazardous materials and anticipated spills onsite. Contractors will be expected to develop and post a list of contacts and emergency numbers for managing and responding to spills.

Machine operators will have onboard spill kits and one (1) larger spill kit should also be also available at each working area. At a minimum we recommend larger spill kits contain the following:

(50) absorbent pads (4) booms (1) bag granular absorbent (4) disposal bags (1) stop leak plug personal protective equipment (1) roll duct tape flagging and tarps up to 80 empty sand bags instructions and list of contents

Spill kits will be restocked after use. BC rated fire extinguishers, pointed and/or broad shovels, nylon rope (100 m) and recovery / storage drums should also be available for use onsite (Ministry of Water, Land and Air Protection, 2002). Finally, the Province recommends keeping between 250 mL and 1 Liter of commercial, dry or pre-mixed bentonite clay onsite to plugholes in leaking containers during spill response (MWLAP, 2002).



3.3.5 Spill Response

Contractors will develop and post spill response plans prior to construction. These plans will include but not be limited to the following procedures:

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

• Eliminate ignition sources

• Identify spilled product, associated hazards and clean up

requirements (refer to MSDS if uncertain)

• Contact site supervisor • 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 PMV and other agencies as required

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

• Contain spilled materials if safe to do so

• Clean up and dispose of spilled product and used response

materials consistent with the Environmental Management Act, Hazardous Waste Regulation

• 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 like gasoline or fuel

oil ≥ 100 L in volume are reportable.

• Investigate causes of the spill and identify required changes to hazardous materials management strategies and spill response plans



• 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)

3.4 Soils Management Plan (SMP)

A key component of the soils management plan will be to characterize the soils both in the ASHROSS receiving pit excavation and in the proposed dewatering pits, to ensure the absence of surficial contamination these locations. This will minimize the risk of moving potential contamination further into the soil profile by ongoing discharge. Non-native fill will be removed from the discharge pits to expose the underlying sands. These sands will be sampled for metals and hydrocarbons at a minimum, to confirm the absence of contamination prior to discharge. The soil management plan will also focus on appropriate storage of suspect and non-suspect soils and on characterizing excavation spoil destined for offsite disposal.



3.4.1 Managing Known or Suspect Contaminated Soils

In the event contaminated soils are encountered during excavation or in the event of a hazardous material spill to soil, we recommend the following mitigation measures and management strategies:

• Segregate suspect or known contaminated soils. Segregated soils should be placed onto an impermeable surface and protected from the elements to prevent rain splash erosion or wind losses and subsequent contaminant migration

• Contact the Environmental Monitor to arrange for soil sampling to

identify required disposal options. The monitor will collect samples consistent with the methods outlined in the Ministry of Environment’s Technical Guidance on Contaminated Sites 1: Site Characterization and Confirmation Testing (2009). On the basis of these results, soils will be classified and relocated or disposed of consistent with the requirements of their classification

• Ensure confirmed contaminated soils are taken offsite by a licensed hauler and deposited at a licensed facility

3.5 Air Quality Management Plan

The following mitigation measures to prevent air quality impacts are recommended:

• On-road low sulphur diesel fuel should be used in all equipment capable of using such fuel

• Diesel particulate filters should be used on all construction equipment

capable of supporting their use • Covered vehicles are required when transporting bulk fine materials to

the project area • Paved areas need to be cleaned on a routine basis to prevent the

accumulation and mobilization of dust. Speed limits should be also implemented to reduce dust mobilization



• Site-specific worker education programs should be developed to

address: Idling reduction (automatic anti-idling shut-off where feasible) Operation of equipment at optimum rated loads Routine equipment inspection and maintenance Daily inspections to identify dust and equipment exhaust

issues

• Use of 2003 or later model equipment and vehicles

• Compliance with the Canada Wide Standards7 (CWS) for air quality, particularly ‘Annex A’ during construction and operation. Relevant CWS standards emphasize managing PM2.5

8

• Ongoing assessments of the potential for dust generation and

combustion emissions. Steps will be taken to minimize dust and combustion emissions as needed

• Visual assessments of dust and exhaust emissions will be completed

on an ongoing basis during work and / or while machinery is operating

• Use of water trucks to control dust as needed

• Establishing speed limits to control dust mobilization Given the mitigation measures proposed above, the need for air quality monitoring during construction is not anticipated at this time. However, should dust monitoring for example, become a requirement, sampling will be consistent with methods outlined in the following provincial document:

• BC Field Sampling Manual. For Continuous Monitoring and the Collection of Air, Air-Emission, Water, Wastewater, Soil, Sediment, and Biological Samples. Part B – Air and Air Emissions Testing (2003).

7 The Canada Wide Standards are considered objectives under the Canadian Environmental Protection Act (CEPA). 8 PM2.5 - particles ≤2.5 microns in diameter and including dust, dirt, soot, smoke, and liquid droplets. Sources of fine particles include combustion activities (motor vehicles, power plants, wood burning). US EPA http://www.epa.gov/pmdesignations/faq.htm#0



3.6 Noise Management Plan

Examples of noise mitigation measures that may be implemented during construction include but are not necessarily limited to the following:

• Developing a construction noise awareness training program for all personnel addressing site specific and generic construction noise issues, potentially sensitive noise receptors, relevant noise bylaws and performance criteria

• Preparing and submitting a list of equipment, prior to construction,

to evaluate potential noise impacts. Noise ratings for selected machines are provided in Table 1

• Where practical limiting construction to the hours to those identified

in the City of Surrey’s Noise bylaw 7044 (i.e. no construction prior to 07:00 hours or after 22:00 hours)

Table 1. Examples of noise ratings and equipment age (from Gilchrist et al. 2003).

Equipment

Noise levels dBA (measured at 15 m from source)

New equipment Older equipment (>5 yrs old)

compressor 73 76-80

Backhoe 75-80 83-88

concrete mixer 75 85-87

concrete pump 75 82-85

concrete saw 90 n/a

concrete vibrator 75 76-80

Crane 75 85-90

bulldozer 75 83-88

dump truck 84 85-88

excavator 83 85-87

Grader 72-75 85-90

jackhammer 75-80 85-90

Loader 80-85 92-95

paver 80-85 95-101



Table 1. Examples of noise ratings and equipment age (from Gilchrist et al. 2003).

Equipment

Noise levels dBA (measured at 15 m from source)

New equipment Older equipment (>5 yrs old)

rock drill 80-85 95-98

roller 80 88-90

scraper 78-83 96-98

tractor 75 85-90

trencher 83-88 n/a

vibratory rollers 95 n/a

• Selecting less noisy machinery, vehicles and equipment for use onsite wherever possible. Newer equipment, and/or equipment with noise suppression features like exhaust silencers on air tools should be evaluated for use onsite

• Equipment should be kept in good order, emphasizing lubrication, replacement of worn parts and the condition of exhaust systems. Diesel and gas powered equipment should be routinely inspected and equipped with higher quality mufflers where possible

• Locating noisy equipment (e.g. portable generators) away from sensitive noise receptors, such as construction personnel or nearby shoreline areas frequented by birds

• If needed, fit equipment with residential-rated mufflers and/or silencers for night-time work

• Muffling back up beepers where safe and feasible to do so

• Shutting off equipment that is not in use and operating equipment at the minimum speeds permitting effective operation, with hoods and shields closed

• Enforcing speed limits to reduce vehicle noise. This will also help reduce dust mobilization



• Installing temporary noise barriers as needed. If noise barriers are

necessary, they should be located as close as possible to the source of the noise and made from solid materials and ideally lined with absorbing materials

3.7 Pile Driving Plan

A total of 12 – 24” piles steel are proposed at Berth 2. Pile installation will be consistent with the Best Management Practices for Pile Driving and Related Operations – BC Marine and Pile Driving Contractors Association (March, 2003). Standard mitigation measures that will be implemented onsite include:

• Conferring with DFO (and other agencies with jurisdiction) to determine the preferred timing and methods of the pile driving program

o For driving steel pipe piles that are >16“ in diameter, using a

diesel hammer, air hammer, or similar powered hammer equipment, DFO prefers that pile driving occur outside of the March 1 to June 15 sensitive period to protect juvenile salmon and eulachon

o However, this timing restriction may not be imposed on the

program if it is unlikely, given streambed conditions, that large rock may be encountered and if the appropriate mitigation measures to prevent 30 kPa will be implemented

• Maintaining equipment in good condition to prevent leaks or spills of

potentially hazardous materials like hydraulic fluid, diesel, gasoline and other petroleum products

• Recovering waste or any miscellaneous unused materials for disposal

in an appropriately certified facility or placed in storage

• Maintaining emergency spill equipment available whenever working near or on the water



• Positioning water borne equipment in a manner that will minimize

damage to fish habitat. Where possible, alternative methods will be used (e.g. anchors instead of spuds)

• Fish exclusion devices may be installed in the water column around

the pile driving area to prevent fish access. The need for exclusion would be determined on the basis of installation timing, mitigation measures, the success of mitigation measures in the field etc.

• Bubble curtains (with frames acceptable to DFO) over the wetted

length of the pile may be required to mitigate impacts on aquatic life

o Visual and hydrophone monitoring will be conducted during pile driving, at a range of depths in the water column and at varying distances and directions from the pile being driven, to measure sound waves and determine if temporary work stoppages and / or additional mitigation strategies are required to maintain levels below 30 kPa

o Hydrophone monitoring will be carried out throughout the pile

driving from beginning to end and particularly during periods of pile driving resistance or refusal

o Hydrophone monitoring data and associated visual observations

during pile driving will be forwarded to the BC Marine and Pile Driving Contractors Association and the Institute of Ocean Sciences in Sidney, BC

Note: Pile Driving Contractors will be required to prepare a detailed Pile Driving Plan for submission to the Port and other agencies for review and comment. This plan will outline pile driving methodologies, timing and mitigation measures in the context of site specific conditions and constraints



3.8 Vegetation and Wildlife Protection Plan

Given the developed nature of the site, impacts on vegetation and wildlife are not anticipated. However, construction near Shadow Brook and the green coded watercourse will require consideration of the following:

• Pre-clearing and construction nesting bird surveys between March 1

and August 1 to determine if birds are nesting within 30 m of the working areas. Note that surrounding areas will need to be checked for raptor nesting activity, as some raptors like Cooper’s hawk (Accipiter cooperii) can require nest buffers of >100 m depending on site specific conditions. Given the current level of activity at the site, potential conflicts with nesting birds are not expected

• Pre-clearing and construction listed plant surveys, with an emphasis on streambank lupine (Lupinus rivularis) which may be present in the existing track alignment. If specimens are found in clearing / construction areas, FSD and the Contractor will work with the environmental monitor to develop a suitable transplanting plan

• Installing temporary fencing (e.g. snow fence) around the riparian zone of Shadow Brook to prevent personnel and machine access into the area

• Contractors working in areas with noxious weeds will ensure that equipment (bulldozers, skidders, backhoes, crushers and other vehicles) is cleaned, removing dirt and seeds from the tires, tracks and undercarriage to prevent the spread of noxious weeds. To the extent practical, invasives will be disposed of consistent with the recommendations in Targeted Invasive Plants Solutions (T.I.P.S.)9.; prepared by the Invasive Plant Council of BC and providing species specific strategies for invasives.

9 T.I.P.S webpage http://www.invasiveplantcouncilbc.ca/resources/targeted-invasive-plant-solutions-tips



4.0 Operational Environmental Management Plans

The operational management plans will be finalized upon completion of detailed design and consultation. At a minimum however, the following management plans will be implemented during operations:

• Air quality management plan • Runoff collection and treatment plan • Emergency response plan • Lighting plan • Noise management plan

4.1 Air Quality Management Plan

An Air Quality Dispersion Modelling Assessment was completed for the project and addressed potential emissions sources from the facility10. The air quality parameters and emission sources considered are shown in Table 2. These parameters were evaluated in the context of the provincial, federal and regional Ambient Air Quality Objectives (AAQO); which were developed to protect public health and the environment (Appendix 2). The closest residential receptor identified in the assessment was located approximately 520 m southeast of Shed 1 and the associated infrastructure.

Table 2. Air quality parameters and associated emission sources

Parameter Emission sources

Carbon monoxide (CO) tugboats, locomotives, front end loaders

Nitrogen oxides (NOx) tugboats, locomotives, front end loaders

Sulphur oxides (SOx) tugboats, locomotives, front end loaders

Particulate matter (PM10) tugboats, locomotives, temporary stockpiles, materials handling, front end loaders

Particulate matter (PM2.5) tugboats, locomotives, temporary stockpiles, materials handling, front end loaders

10 CALPUFF model series (CALMET, CALPUFF and CALPOST)



Table 2. Air quality parameters and associated emission sources

Parameter Emission sources

Volatile organic compounds (VOC) tugboats, locomotives, front end loaders

Ammonia (NH3) tugboats, locomotives, front end loaders

The modelling results indicated the air quality parameters of interest during operations are expected to be lower than available AAQO at the nearest residential receptor. Particulate emissions for fugitive dust sources are anticipated to be localized at the operating facility, although with the proposed mitigation measures effects on air quality are expected to be limited. Some potential for localized NO2 emissions above the AAQO were identified at Berth 2 and along the rail alignment. However as indicated above; the predicted NO2 levels were below the AAQO at the closest residential receptor. Air quality monitoring programs and mitigation measures will be required at the operating facility. Key components of the plan are outlined in the FRASER SURREY DOCKS DRAFT AIR QUALITY MONITORING PLAN (Levelton, 2013)

4.1.1 Weather Monitoring

Real time and forecasted weather data will be used to plan coal offloading activities. At a minimum, FSD is proposing to install an anemometer for measuring wind speed (including gusts) and direction in the vicinity of the stockpile. Forecasted weather will also be used to plan activities like site cleaning, equipment or track maintenance, temporary coal stockpiling (volumes and pile face configuration).

4.1.2 Dust Monitoring

FSD is also proposing to install dust samplers. The Canada Wide Standard (CWS) for PM2.5 is 30 μg/m3, 24-hour averaging time. The BC provincial air quality objectives for PM2.5 and PM10 are 25 µg/m3 and 50 µg/m3 over 24 hours, respectively11.

11 New Provincial Ambient Air Quality Criteria for PM2.5 http://www.bcairquality.ca/regulatory/pm25-objective.html and Air Quality Objective for PM10 (1995) http://www.bcairquality.ca/reports/aqopm.html



Available Worksafe BC limits for coal dust exposure are as follows (OHS Regulation, Guidelines Part 5, Table of exposure limits):

• Coal dust - Bituminous, Respirable - 0.9 mg/m3 • Coal dust - Anthracite, Respirable, - 0.4 mg/m3

Dust monitoring data will be used to evaluate the need for site cleaning or maintenance, temporary work stoppages, or identify procedural revisions to limit dust generation and / or mobilization.

4.1.3 Dust Mitigation Measures

Dust management will emphasize strategies to limit dust generation, followed by ongoing monitoring and site cleaning / maintenance. These strategies will include but may not be limited to the following:

• Using metrological and dust monitoring data to plan and / or suspend

activities onsite

• Enforcing speed limits of 5 m/h for incoming trains travelling through FSD property and for outbound empty cars during transit at the offloading facility and through FSD property

• Enclosing the ASHROSS receiving pit (i.e. in the railcar unloading

shed) and applying a directed spray to the coal and railcars while they are unloading in the shed

o Empty cars will be sprayed a second time inside the unloading

shed before entering the yard again to prevent dust mobilization associated with the movement of empty cars

• Applying spray at transfer points between conveyor systems and to

loaded barges prior to transport downstream NOTE: If a stockpile is onsite, front end loaders would be used to place coal onto the conveyors. Ongoing sprinkling is proposed during this process

• Routine site cleaning in and around the dumping pit, conveyor systems, transfer points, railway track and surrounding paved areas



• Routine maintenance and cleaning of conveyor belts and other system

components to ensure they are operating as intended

• Ongoing metrological, dust monitoring and observational data compilation to identify potential problem areas or procedures and appropriate corrective action(s)

• Stilling enclosures at all transfer points (minimizes turbulence of the

product flow and the creation of airborne particles)

4.2 Runoff Management Plan

In addition to the storm water management and fire suppression infrastructure described in Sections 1.2 and 2.0 (e.g. sumps, containment tanks, oil/water interceptor, sprinkling towers, stockpile containment berm) the runoff management plan will include the re-use of treated water for dust suppression.

4.2.1 Water Treatment

During dry periods, water used onsite would be treated and re-directed back into the system. During wet periods, excess water would require treatment and periodic offsite discharge (under permit). At a minimum, water treatment programs would emphasize pH adjustment and solids removal (potentially requiring flocculation, detention and settling prior to offsite discharge). A pH adjustment system would likely be required for runoff with a pH of <6.5 (low range of BC Approved Water Quality Guideline for pH for the protection of aquatic life). This can be addressed through injections of buffering agents as part of the treatment process. For solids removal, a flocculant like Chitosan is proposed, which can remove suspended sediment, phosphorus, metals, PAH and other organics. A finishing sand filter may be required as the final step in the treatment system for treating larger volumes of water. The chemicals and infrastructure associated with water treatment onsite will be finalized in consultation with the Port as the management plans for the site evolve.



Sand filters have a backwash phase in a closed loop system to flush particulates from the sands. Treated water can be directed back into the system for re-use, or discharged offsite during high flow. FSD is investigating a permitted discharge to sanitary sewer as part of evaluating offsite discharge strategies.

4.2.2 Water Quality Monitoring

At a minimum, the monitoring program will emphasize in situ measurements of pH, temperature, turbidity / TSS, specific conductivity, TDS, dissolved oxygen (DO) and oxidation reduction potential (ORP). These data will be compiled and maintained by operations personnel to evaluate site and system performance. A detailed breakdown of the water management program for the operation is provided in OMNI Engineering’s DIRECT TRANSFER COAL FACILITY WATER MANAGEMENT PLAN (June 2013).

4.3 Emergency Response Plans

Potential emergencies of environmental concern include fires from the spontaneous combustion of coals and spills or uncontrolled releases to the aquatic environment during barge loading.

4.3.1 Combustion

Combustion mitigation measures will include but not be limited to the following: • Fire suppression system

• Training onsite personnel in required site maintenance procedures and

early detection of spontaneous combustion (e.g. observations of steam, localized white smoke)

• Ongoing weather and dust monitoring, visual inspections of operating systems and surrounding areas and routine site cleaning and equipment maintenance at all parts of the operation to limit the buildup of loose coal



• Restricting the residence time of stockpiled coal onsite and treating with a

sealant, for example, as described above to limit air movement into and inside of the pile

o Routine visual inspections of the stockpile will be conducted and in

some cases, (e.g. depending on weather conditions and the length of time the pile remains onsite), pile moisture and temperature readings may need to be taken. FSD will be equipped to measure moisture and temperature as needed and monitoring data will be compiled and maintained onsite

Spontaneous combustion events are not expected, given the short time frame coals will be stockpiled onsite. However, in the event spontaneous combustion occurs, response measures may include but not be limited to the following (where practical and safe to implement) (NCIG, 2010):

• Isolating the zone of combustion

• Digging out the affected area and moving the coal to a location where

it can be spread out for cooling, saturated with water or compacted and covered with an inert material

4.3.2 Spill Prevention and Response

Spill prevention will be addressed throughout the operation, through routine inspections and maintenance of the track, receiving pits and conveyors. Additionally, the entire offloading operation will be manned from the time trains arrive onsite to the time the loaded barges leave the site. Prior to the trains arriving onsite, personnel will ensure all parts of the system, (including emergency response systems) are functioning as intended. Prior to barge loading, personnel will confirm the barges are empty of debris, in good condition, and are properly closed. As part of the barging contract, FSD will require contractors submit maintenance and training records.



Note: Barge Loading Master Plans will be developed by the operators and submitted to FSD for review and comment. Additionally, barges will be double walled

The coal handled onsite and transported to Texada will be intact - no processing (i.e. burning) will be undertaken onsite. A spill of un-burned coal could impact water quality through elevated turbidity (increasing suspended particles in the water). Coal particles may also settle on the riverbed and become a component of the sediments. The physical effects of coal can be consistent with those of suspended (and settled) sediments including: abrasion, smothering, clogging of respiratory and feeding organs, changes to sediment composition and reduced availability of light (Ahrens and Morrisey, 2005). The potential chemical effects of coal are variable, with some authors considering unburned coal to be largely inert (Chapman et al. 1996). Ahrens and Morrisey, (2005) noted potential toxic effects of selected components of coal are less evident than physical effects and are dependent on coal composition. They further noted the bioavailability of selected components in coal in many cases appears to be low. The bioavailability of the various components is important to characterizing potential effects. The bioavailability of trace elements and PAH is dependent on a variety of factors, including coal composition12, ambient conditions (pH, dissolved organic matter), sediment composition (particle size distribution) and sediment chemistry (pH, cations, oxides, sulfides, % carbon). Under the more neutral pH conditions in the Fraser River13 leaching of selected metals like cadmium, copper, lead and zinc would be less of a concern.

12Analyses of the Cloudy Peak coal indicate 53.02% carbon and 25.81% moisture (as received); with dry levels consisting of 71.46% carbon 13 (MWLAP, 2004) pH in the Fraser River between 1971 and 2003 (Pattullo ~ 7.2 to 7.8) (Annacis Island ~ 7.4 -7.7) EMS stations 0300005 and 0301311 respectively. Fraser River Water Quality Buoy, 12 km u/s of the mouth (EMS station E271643) ~ average pH of 7.64 (n=76)



Under more acidic conditions these metals could be leached to a more bioavailable form14. PAH are expected to remain bound to the coal particles thus limiting their bioavailability15. Trace element data were provided for Cloudy Peak coal and are shown in Table 3. These data suggest the available sediment quality guidelines for the parameters shown would not be exceeded in the event of a spill and subsequent coal particle settling.

14 Metals like cadmium, lead, copper, and zinc can remain can be bound in sediments through sulfide formation (Jim

McGeer,

Gerry Henningsen,

Roman Lanno,

Nicholas Fisher,

Keith Sappington5

, and John Drexler, Eastern Research Group, Inc 2004) 15 PAH are characterized by low solubility and high affinity for organic carbon. As a result, PAHs in aquatic environments are primarily sorbed to suspended or settled particulates. The Koc values for PAH, which describe the potential for a compound to bind to organic carbon in soils and sediment, range from 103 to 104 for low molecular weight PAH to 105 to 106 to high molecular weight PAH (ATSDR, Toxicological Profile, PAH, 1995)


September 2012 V4 Page 33

Table 3.Comparison of trace element analyses to available provincial and federal sediment quality guidelines

Arsenic Cadmium Chromium Copper Lead Manganese Mercury Nickel Selenium Silver Zinc

1.9 0.09 3 9 0.7 16 0.034 2 0.6 0.03 5

1 0.05 3 9 1.2 15 0.049 2 0.6 0.02 6

1.5 0.06 2 9 1.2 21 0.053 2 0.6 0.04 6

1.6 0.05 2 9 1.2 21 0.068 2 0.5 0.03 5

2.1 0.05 2 9 1.1 27 0.095 2 0.6 0.05 3

1.1 0.07 2 9 1.3 15 0.058 2 0.5 0.03 5

1.3 0.04 2 7 0.7 16 0.059 1 0.4 0.02 3

1.3 0.04 3 10 1.1 16 0.038 2 0.5 0.02 4

1.6 0.07 3 9 1.3 68 0.0413 2 0.4 0.02 5

Average of source coal samples 1.5 0.06 2 9 1.1 24 0.055 2 0.5 0.029 5

BC Working sediment quality guidelines - freshwater 5.9 (ISQG) 0.6 (ISQG) 37.3 (ISQG) 35.7 (ISQG) 35 ISQG 460 (LEL) 0.170 ISQG 16 (LEL) 2 0.5 123 ISQG

BC Working sediment quality guidelines - marine 7.24 (ISQG) 0.7 (ISQG) 52.3 (ISQG) 18.7 ISQG 30 ISQG - 0.130 ISQG 30 (ERL) - 1.0 (ERL) 124 ISQG

CCME Sediment quality guidelines - freshwater 5.9 (ISQG) 0.6 (ISQG) 37.3 (ISQG) 35.7 (ISQG) 35 - 0.170 ISQG - - - 123 ISQG

CCME Sediment quality guidelines - marine 7.24 (ISQG) 0.7 (ISQG) 52.3 (ISQG) 18.7 ISQG 30.2 - 0.130 ISQG - - - 124 ISQG

ISQG - Interim sediment quality guideline

LEL – lowest effect level ; concentration that 95% of the benthic biota can tolerate (Ontario Ministry of Environment and Energy - freshwater biota)16

ERL - effects range low ; concentration below which effects are rarely observed or predicted among sensitive life stages and (or) species

16 http://pubs.usgs.gov/circ/circ1156/circ1156.10.html



In the event of a spill to the Fraser River during barge loading, the following mitigation measures will be implemented:

• Operations will stop and the Director of Engineering and

Maintenance (DEM), Site Superintendent, Unloading shed operator, Train conductor and the Port will be informed of the spill

• Personnel will make an estimate of the volume released and, in

consultation with DEM determine if the material can be effectively recovered. This will depend on a variety of factors including but not limited to tide level and volume released

• In the event of a larger spill at the Berth, occurring for example if a

barge door fails during filling, onsite personnel in consultation with the DEM and the Port will determine if a suction dredge or similar needs to be mobilized to the spill site for recovery. Mitigation measures consistent with the Fraser River Estuary Management Plan (FREMP) guidelines for dredging would be applied to coal recovery in this context

• Post spill (and clean up) water and sediment sampling would be

conducted onsite and in adjacent areas to determine the potential effects of the spill and ensure clean-up is completed consistent with the applicable provincial and federal guidelines and regulatory framework

4.4 Lighting Plans

No new mast lighting is anticipated. Direct lighting along the conveyors, barge loader and inside of the unloading shed will be required for safe operations. Any additional lighting required to operate the offloading facility will be consistent with The Occupational Health and Safety Regulation, Part 4, Illumination, and selected, installed and operated with consideration of the following mitigation measures

• Minimizing nighttime activity (to the extent practical)

• Using light on an ‘as and when needed’ basis



• Directing light toward the ground on working areas

o Reducing the height of lighting to the extent possible o Minimizing the number of lights required through strategic

spacing

• Eliminating upward directed lighting

• Using fittings on lamps to direct and confine the spread of light

• Ensuring lights are in good condition at all times

• To the extent possible given security and safety requirements, using lights with appropriate wavelengths to avoid attraction and disorientation by birds. These will be selected in consultation with the PMV

• Shutting off lights when they are not needed

4.5 Noise Management Plans

4.5.1 Existing Conditions

FSD is an industrial facility operating 24 hours a day 7 days a week. The closest residential properties to the proposed infrastructure at Shed 1 are approximately 520 m to the southeast, and are adjacent to the existing River Road corridor and the South Fraser Perimeter Road (SFPR) (under construction). FSD handles inbound and outgoing cargo including containers, dimensional lumber, logs, steel (steel plate, coil, pipe and wire rod) and dry bulk agricultural products. FSD has an existing rail infrastructure with CN,CP, BNSF and Southern Rail trains moving in and out of the property at all times on a daily basis. Haul trucks move in and out of the site daily.



Vessels accessing the site and equipment in regular use as part of the operation include:

• BB and Containerized Vessels • Tug boats to assist vessel berthing • Container stackers • Front end loaders • Skid steers • Conveyor systems • Lift Trucks • Off road tractors and trailer assemblies • Container gantry cranes • Hydraulic barge ramp • Pick-ups • Yard locomotives

4.5.2 Operations

4.5.2.1 Train and Vessel Traffic

The proposed terminal operation during the initial phase will include a maximum of one additional train trip every second day, with the second phase a unit train per day in and out of the site. Coal trains will arrive between 00:00 hours and 06:00 hours and depart between 17:00 hours and 22:00 hours. Coal and Agri-bulk rail traffic is expected to cross at Robson Road. The Tannery and Elevator Road crossings will be eliminated beginning in 2013 / 2014. The Tannery Road crossing will be replaced with an overpass (eliminating the need for sounding whistles) and the Elevator crossing is going to be eliminated outright. Crossings at Robson Road will occur during unloading and typically between 07:00 and 17:00 hours. Once the Tannery and Elevator Road crossings are eliminated, train whistles associated with the coal and Agri facility will sound at only one crossing. Trains will move at a maximum speed of 3 mph (5 km/h) onsite to minimize noise levels associated with the operation.



Tug boat traffic supporting the coal terminal will generally be coming in and out of the site at 06:00 to 09:00 hours and 15:00 hours to 17:00 hours. This will also be consistent with existing tug traffic levels at the site. Tugs will travel at a minimal speed in the vicinity of Berth 2 to avoid wash.

4.5.2.2 Unloading facility

The rail car unloading shed and coal conveyor systems will be electric, with anticipated conveyor noise levels of roughly 60 to 65 decibels (dB). This level of noise is in the range of normal conversation at a distance of 3 feet / 0.914 m. The unloading shed will be covered on two of four sides, limiting the travel of noise associated with bottom dumping into the ASHROSS RUMig receiving pits. Front end loaders will primarily be needed to establish and / or maintain stockpiles, which will be onsite only if there is an interruption in the barge loading systems. Stockpiling more than four days at a given time is not anticipated. Front end loaders currently operate on FSD property as needed on a 24 hour and 7 day a week basis, so the addition of one or more front end loaders for periodic stockpile creation and maintenance would not be expected to substantially increase noise levels or result in changes to the timing of noise associated with this type of equipment. The berm surrounding the stockpile will also help mitigate noise / sound travel resulting from activity in this area. Barge loading will be via conveyor with a radial and lifting arm. Given the material is loose, light weight particulate matter with a low drop height, noise associated with barge loading would be limited. System maintenance will be performed on an ongoing basis and will help limit noise levels associated with the operation. System components will be maintained to operate below maximum operating noise levels wherever feasible. Maintenance records will be maintained for review by FSD’s management staff. Noisy mobile equipment supporting the operation will be removed from service wherever practical and replaced with a less noisy alternative.



For the life of the operation, FSD will evaluate noise levels and onsite activities to identify opportunities for using less noisy equipment and / or making changes to day to day operations that may reduce overall noise levels. Weather monitoring conducted at the site (e.g. wind speed and direction) may be helpful in determining when it may be necessary to suspend potentially noisy activities associated with the operation

4.5.3 Public concerns

FSD will promptly respond to community issues of concern. All input from the public will be documented, and the coal facility and operations will be evaluated in the context of specific comments and concerns to identify potential solutions. Resolutions will be communicated to the individual(s) raising concerns about noise levels from the operation. Documentation associated with managing public input will include the following at a minimum:

• Date, time and method by which concern was raised • Details of the concern (e.g. timing, nature and duration of the noise) • Steps taken by FSD to address the concern

5.0 References and Information sources

AHRENS, J. and DJ MORRISEY (2005) BIOLOGICAL EFFECTS OF UNBURNT COAL IN THE MARINE ENVIRONMENT. Oceanography and Marine Biology: An Annual Review, 2005, 43 , 69-122, R. N. Gibson, R. J. A. Atkinson, and J. D. M. Gordon, Editors, Taylor & Francis BC Marine and Pile Driving Contractors Association (2003) Best Management Practices for Pile Driving and Related Operations. Brian Naito (pers comm, 2012). Information on pile driving windows in the Lower Fraser River Calvin, EM and JE Williams (n.d.) A Rail Emission Study: Fugitive Coal Dust Assessment and Mitigation City of Surrey (COSMOS) (accessed 2012). Municipal online GIS system



Colinet, JF, JP Rider, JM Listak, JA Organiscak, AL Wolfe (2010) Best Practices for Dust Control in Coal Mining Fure, A (2006) Bats and lighting. The London Naturalist, No. 85, 2006 G.D. Stricker and M.S. Ellis (1999) Chapter PQ COAL QUALITY AND GEOCHEMISTRY, POWDER RIVER BASIN, WYOMING AND MONTANA, in U.S. Geological Survey Professional Paper 1625-A GE Power & Water (August 2010) DusTreat*DC9148 Anti-oxidant and Dust Control Agent – CoalPlus* Treatment Program. Fact Sheet GE Power & Water (August 2010) DusTreat*DC6109 Foam Dust Control Agent. Fact Sheet

Gibb, A.; Kelly, H; Schueler T.; Horner, R.; Simmler, J.; Knutson, J. (1999). Best Management Practices Guide for Stormwater. Burnaby, B.C.: Greater Vancouver Sewerage and Drainage District. Gilchrist A, E N Allouche, D Cowan (2003). Prediction and mitigation of construction noise in an urban environment

Guaranaschelli, C (1977) In-transit Control of Coal Dust From Unit Trains. Environmental Protection Service, Fisheries and Environment Canada. Report EPS-4-PR-77-1 Hossfield RJ and R Hatt (n.d.) PRB Coal Degradation – Causes and Cures Jason Jones and Charles M. Francis (2003) The effects of light characteristics on avian mortality at lighthouses. JOURNAL OF AVIAN BIOLOGY 34: 328–333 http://www.bsc-eoc.org/download/Francis-Jones-light-mortality.pdf Johnson, R. and R.M. Bustin (2006) Coal dust dispersal around a marine coal terminal (1977–1999), British Columbia: The fate of coal dust in the marine environment. International Journal of Coal Geology 68 (2006) 57–69 Levelton Consultants LTD (2013). FRASER SURREY DOCKS DIRECT COAL TRANSFER FACILITY: DRAFT AIR QUALITY MANAGEMENT PLAN



Longcore T., C. Rich and S.A. Gauthreaux, Jr. (2008) Height, Guy Wires, and Steady-burning Lights Increase Hazard of Communication Towers to Nocturnal Migrants: A Review and Meta-analysis. The Auk 125(2):485–492 MWLAP (2002). A Field Guide to Fuel Handling, Transportation and Storage.

New Castle Coal Infrastructure Group (2010) Coal Export Terminal. Operation Environmental Management Plan.

OHS Regulation, Guidelines Part 5 (accessed online 2012)

OMNI Engineering INC (2013) DIRECT TRANSFER COAL FACILITY WATER MANAGEMENT PLAN

Poot, H., B. J. Ens, H. de Vries, M. A. H. Donners, M. R. Wernand, and J. M. Marquenie. 2008. Green light for nocturnally migrating birds. Ecology and Society 13(2): 47. http://www.ecologyandsociety.org/vol13/iss2/art47/

Port Metro Vancouver (2010) Harbour Operations Manual-Vancouver Fraser Port Authority – updated June 2012 Standard Laboratories Inc. Table V Primary Surrogate Seive Analysis. Spring Creek Mine, 2-Stage Ramsey Mechanical Sampler. April 20, 2012. 1880 North Loop Drive, Casper Wyoming 82601.



MWLAP (2002). A Field Guide to Fuel Handling, Transportation and Storage.

New Castle Coal Infrastructure Group (2010) Coal Export Terminal. Operation

Environmental Management Plan.

OHS Regulation, Guidelines Part 5 (accessed online 2012)

Poot, H., B. J. Ens, H. de Vries, M. A. H. Donners, M. R. Wernand, and J. M.

Marquenie. 2008. Green light for nocturnally migrating birds. Ecology and

Society 13(2): 47. http://www.ecologyandsociety.org/vol13/iss2/art47/

Port Metro Vancouver (2010) Harbour Operations Manual-Vancouver Fraser

Port Authority – updated June 2012

Standard Laboratories Inc. Table V Primary Surrogate Seive Analysis. Spring

Creek Mine, 2-Stage Ramsey Mechanical Sampler. April 20, 2012. 1880

North Loop Drive, Casper Wyoming 82601.

Figure 1. Drainages overview

The data provided is compiled from various sources and is NOT warranted as to its accuracy or sufficiency by the City of Surrey. This information is provided for information and convenience purposes only. Lot sizes, legal descriptions and encumberances must be confirmed at the Land Title Office. Use and distribution of this map is subject to all copyright and disclaimer notices at cosmos.surrey.ca.

Scale: 1: 2,000

Map created on: September-25-12

Legend

0 0.060 0.120

Kilometers

Enter Map Description

Lots (Outline)

Road Names1000_4000

Drainage Flow Arrows

Drainage Mains

Proposed

In Service/For Construction

Abandoned

Drainage Mains (labels)

Fish Class (Open Channels)

A

AO

B

C

Unknown

Fish Class (Water Bodies)

A

AO

B

C

Unknown

Drainage Ditches

Water Courses

Creek

River

Aerial Photo April 2012

Red: Band_1

Green: Band_2

Blue: Band_3

Hooks

Lots

BC Gas

BC Hydro

BC Rail Standard Lot

BN Rail Standard Lot

CN Rail

City Land Standard Lot

City Land Strata

FRPA Foreshore Tenure

Federal Standard Lot

GVRD Standard Lot

Harbour Board Standard Lot

Park - City Dedicated

Park - City Purchased

Park - Provincial

Park - Regional

Private Standard

Private Strata

Provincial Standard

Road

School Standard Lot

Transit Standard Lot



APPENDIX 1: SUMMARY OF ONSITE DRAINAGE FEATURES

8971 Beckwith Road Phone 604 279 2093 Richmond, BC V6X 1V4 Fax 604 279 2047

Offices in Richmond, Terrace, Prince George, Kamloops & Calgary Page 1 www.triton-env.com

September 27, 2012 V2

Fraser Surrey Docks

11060 Elevator Road

Surrey, BC, Canada

V3V 2R7

Attn: Jurgen Franke, Director Engineering and Maintenance

Re: Summary of watercourse assessments conducted in support of the FSD Coal

Barge Loading facility in Surrey, BC

1.0 Introduction

This letter provides a summary of watercourse assessments conducted on FSD

property in the vicinity of Elevator and Robson Road in August 2012 (Figure 1). These

assessments were completed in support of the proposed coal offloading facility at FSD,

which includes a new section of track that extends south from Shed 1 along the access

driveway into the property. This new track may require some encroachment into the

riparian habitat of Shadow Brook west of Robson Road and at an upgraded crossing

over the green-coded1 watercourse at the Bekaert’s site. Shadow Brook has been

classified as red-coded (permanent, fish bearing) by the City of Surrey.

2.0 Methods

The two drainages were assessed using Resource Inventory Standards Committee

(RISC) fish habitat Site Cards. Field crews identified culvert crossings and the direction

of flow in each of the surveyed drainages and generally described the associated

riparian zones. The top of bank was also staked in each of these drainages so that it

could be surveyed and included in site development plans.

1 Green coded watercourses are non-fish bearing and provide insignificant nutrients and flow downstream

FSD drainage summary for coal offloading facility September 2012


3.0 Results and Discussion

Shadow Brook had an average channel width of 1.81 m (n=12) and an average wetted

width of 1.65 m (n=12). The substrate was largely fines with occasional gravels.

Functional large woody debris (LWD), boulder, and cut bank cover were absent from

surveyed areas. Riparian cover included Himalayan blackberry (Rubus armeniacus),

red alder (Alnus rubra), reed canary grass (Phalaris arundinacea), and horsetail

(Equisetum sp.).

The green-coded ditch had an average channel width of 2.37 m (n=6) and an average

wetted width of 1.7 m (n=6). Like Shadow Brook, the substrate was dominated by fines,

and lacked LWD, boulder, and cut bank cover. Instream vegetation included duckweed

(Lemna minor), cattail (Typha latifolia), and plantain (Alisma sp.). Riparian species

included Himalayan blackberry, evergreen blackberry (Rubus laciantus), reed canary

grass, hardhack (Spiraea douglasii), fireweed (Epilobium angustifolium), nightshade

(Atropa belladonna), and black cottonwood (Populus trichocarpa).

Table 1. Summary of stream characteristics

Parameter Green-coded

watercourse Shadow Brook

Avg channel width (m) 2.37 1.8

Avg wetted width (m) 1.7 1.65

Avg Bankfull depth (m) 0.59 0.43

Avg res pool depth (m) 0.10 0.22

Avg slope % 1 1

pH 8.11 7.9

temperature 13.1 12.65

bed material Fines (g) Fines (g)

dominant cover Overstream

vegetation

Overstream

vegetation

Spawning habitat was absent in all surveyed areas, and rearing cover was limited with

pools meeting at least one of the minimum size criteria using the provincial Fish Habitat

Assessment Procedure2 (residual depth of ≥0.20 m ) occurring in Shadow Brook only.

Functioning LWD (e.g., to create scour pools or hiding cover) was absent, as was

2 Fish Habitat Assessment Procedure (FHAP). NT Johnson and PA Slaney (1996) Watershed Restoration Technical Circular Number 8.



boulder/cobble cover. Riparian habitats were fragmented in both drainages and

dominated by invasive plant species.

None of the surveyed drainages provided critical fish habitat. Additionally, the generally

poor condition of the riparian areas associated with abundant invasives and

fragmentation (surrounded by roads and or railway track) would limit their suitability for

use by listed wildlife species like Pacific water shrew (Sorex bendirii) and red-legged

frog (Rana aurora). Listed plant species were not observed in riparian areas, nor were

they observed along the railway tracks in the vicinity. Any losses to the riparian habitats

in these drainages associated with the new track could be offset onsite as needed with

habitat enhancements in the Shadow drainage on FSD property.

Sincerely,

Karla Graf

Project Manager

Bach Env. Eng., Dip T RRM

Cert Tech, Comm



Photo 1. Shadow Brook west of Robson Road

Photo 2. Shadow Brook, west of Robson Road



Photo 4. Green-coded watercourse, north of access into FSD property

Photo 3. Shadow Brook east of Robson Road adjacent to the railway tracks



APPENDIX 2: PROVINCIAL, FEDERAL AND REGIONAL

AIR QUALITY OBJECTIVES

Parameter

BC objective Federal objective Metro

Vancouver Objective (μg/m3)

Level A (μg/m3)

Level B (μg/m3)

Level C (μg/m3)

Maximum Desirable(μg/m3)

Maximum Acceptable

(μg/m3)

Maximum Tolerable (μg/m3)

CO - 1 hr max 14,300 28,000 35,000 15,000 35,000 - 30,000

CO - 8 hr max 5,500 11,000 14,300 6,000 15,000 20,000 10,000

SO2 - 1 hr max 450 900 900-1300

450 900 - 450

SO2 - 24 hr max 160 260 360 150 300 800 125

SO2 annual mean 25 50 80 30 60 - 30

NO2 - 1 hr max - - - - 400 1,000 200

NO2 - 24 hr max - - - - 200 300 200

NO2 annual mean - - - 60 100 - 40

PM 24 hr max 150 200 260 - 120 400 -

PM annual mean 60 70 75 60 70 - -

PM10 24 hr max - 50 - - - - 50

PM10 annual mean - - - - - - 20

PM2.5 24 hr max 25 30 25

PM2.5 annual mean 8 8 8

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Material Safety Data Sheet Issue Date: 24-AUG-2006 Supercedes: 24-AUG-2006

DUSTREAT DC6109

1 Identification of Product and CompanyIdentification of substance or preparationDUSTREAT DC6109

Product Application AreaDust control agent.

Company/Undertaking IdentificationGE Betz, Inc.4636 Somerton RoadTrevose, PA 19053T 215 355-3300, F 215 953 5524

Emergency Telephone(800) 877-1940

Prepared by Product Stewardship Group: 215 355-3300

2 Composition / Information On Ingredients

Information for specific product ingredients as required by the U.S. OSHA HAZARD COMMUNICATION STANDARD is listed. Refer to additional sections of this MSDS for our assessment of the potential hazards of this formulation. HAZARDOUS INGREDIENTS: Cas# Chemical Name Range(w/w%) * (E021)LINEAR ALKYL SULFONATE;TSRN 125438 - 5011P * Irritant (skin and respiratory)

3 Hazards Identification

******************************************************************************** EMERGENCY OVERVIEW WARNING May cause moderate irritation to the skin. Severe irritant to the eyes. Mists/aerosols may cause irritation to upper respiratory tract. DOT hazard is not applicable Odor: Sweet; Appearance: Light Yellow To Amber, Liquid Fire fighters should wear positive pressure self-contained breathing apparatus(full face-piece type). Proper fire-extinguishing media:

Page 1Substance or Preparation: DUSTREAT DC6109

dry chemical, carbon dioxide, foam or water ******************************************************************************** POTENTIAL HEALTH EFFECTS ACUTE SKIN EFFECTS: Primary route of exposure; May cause moderate irritation to the skin. ACUTE EYE EFFECTS: Severe irritant to the eyes. ACUTE RESPIRATORY EFFECTS: Mists/aerosols may cause irritation to upper respiratory tract. INGESTION EFFECTS: May cause gastrointestinal irritation. TARGET ORGANS: No evidence of potential chronic effects. MEDICAL CONDITIONS AGGRAVATED: Not known. SYMPTOMS OF EXPOSURE: May cause redness or itching of skin, irritation, and/or tearing of eyes (direct contact).

4 First Aid Measures

SKIN CONTACT: Wash thoroughly with soap and water. Remove contaminated clothing. Thoroughly wash clothing before reuse. Get medical attention if irritation develops or persists. EYE CONTACT: Remove contact lenses. Hold eyelids apart. Immediately flush eyes with plenty of low-pressure water for at least 15 minutes. Get immediate medical attention. INHALATION: If nasal, throat or lung irritation develops - remove to fresh air and get medical attention. INGESTION: Do not feed anything by mouth to an unconscious or convulsive victim. Do not induce vomiting. Immediately contact physician. Dilute contents of stomach using 2-8 fluid ounces (60-240 mL) of milk or water. NOTES TO PHYSICIANS: No special instructions

5 Fire Fighting Measures

FIRE FIGHTING INSTRUCTIONS: Fire fighters should wear positive pressure self-contained breathing apparatus (full face-piece type). EXTINGUISHING MEDIA: dry chemical, carbon dioxide, foam or water HAZARDOUS DECOMPOSITION PRODUCTS: oxides of carbon and sulfur FLASH POINT: > 200F > 93C P-M(CC)


6 Accidental Release Measures

PROTECTION AND SPILL CONTAINMENT: Ventilate area. Use specified protective equipment. Contain and absorb on absorbent material. Place in waste disposal container. Flush area with water. Wet area may be slippery. Spread sand/grit. DISPOSAL INSTRUCTIONS: Water contaminated with this product may be sent to a sanitary sewer treatment facility,in accordance with any local agreement,a permitted waste treatment facility or discharged under a permit. Product as is - Incinerate or land dispose in an approved landfill.

7 Handling & Storage

HANDLING: Normal chemical handling. STORAGE: Keep containers closed when not in use. Store in cool ventilated location. Store away from oxidizers.

8 Exposure Controls / Personal Protection

EXPOSURE LIMITS CHEMICAL NAME (E021)LINEAR ALKYL SULFONATE;TSRN 125438 - 5011P PEL (OSHA): NOT DETERMINED TLV (ACGIH): NOT DETERMINED ENGINEERING CONTROLS: adequate ventilation PERSONAL PROTECTIVE EQUIPMENT: Use protective equipment in accordance with 29CFR 1910 Subpart I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA’S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR’S USE. USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. If air-purifying respirator use is appropriate, use a respirator with dust/mist filters. SKIN PROTECTION: rubber gloves-- Wash off after each use. Replace as necessary. EYE PROTECTION: splash proof chemical goggles

9 Physical & Chemical Properties

Specific Grav.(70F,21C) 1.055 Vapor Pressure (mmHG) ~ 18.0 Freeze Point (F) ~ 30 Vapor Density (air=1) < 1.00 Freeze Point (C) ~ -1 Viscosity(cps 70F,21C) 72 % Solubility (water) 100.0 Odor Sweet Appearance Light Yellow To Amber Physical State Liquid Flash Point P-M(CC) > 200F > 93C pH 5% Sol. (approx.) 8.1 Evaporation Rate (Ether=1) < 1.00


Percent VOC: 0.0 NA = not applicable ND = not determined

10 Stability & Reactivity

STABILITY: Stable under normal storage conditions. HAZARDOUS POLYMERIZATION: Will not occur. INCOMPATIBILITIES: May react with strong oxidizers. DECOMPOSITION PRODUCTS: oxides of carbon and sulfur INTERNAL PUMPOUT/CLEANOUT CATEGORIES: "B"

11 Toxicological Information

Oral LD50 RAT: 2,500 mg/kg Dermal LD50 RABBIT: 2,150 mg/kg

12 Ecological Information

AQUATIC TOXICOLOGY Daphnia magna 48 Hour Static Renewal Bioassay LC50= 16; No Effect Level= 6.3 mg/L Fathead Minnow 96 Hour Static Renewal Bioassay LC50= 4; 10% Mortality= .78 mg/L Rainbow Trout 96 Hour Static Renewal Bioassay LC50= 7.1; No Effect Level= 5 mg/L BIODEGRADATION BOD-28 (mg/g): 303 BOD-5 (mg/g): 7 COD (mg/g): 860 TOC (mg/g): 200

13 Disposal Considerations

If this undiluted product is discarded as a waste, the US RCRA hazardous waste identification number is : Not applicable. Please be advised; however, that state and local requirements for waste disposal may be more restrictive or otherwise different from federal regulations. Consult state and local regulations regarding the proper disposal of this material.

14 Transport Information

DOT HAZARD: Not Applicable PROPER SHIPPING NAME: DOT EMERGENCY RESPONSE GUIDE #: Not applicable Note: Some containers may be DOT exempt, please check BOL for exact container classification


15 Regulatory Information

TSCA: All components of this product are listed in the TSCA inventory. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): No regulated constituent present at OSHA thresholds SARA SECTION 312 HAZARD CLASS: Immediate(acute) SARA SECTION 302 CHEMICALS: No regulated constituent present at OSHA thresholds SARA SECTION 313 CHEMICALS: No regulated constituent present at OSHA thresholds CALIFORNIA REGULATORY INFORMATION CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION 65): This product contains one or more ingredients known to the state of California to cause cancer. MICHIGAN REGULATORY INFORMATION No regulated constituent present at OSHA thresholds

16 Other Information

NFPA/HMIS CODE TRANSLATION Health 2 Moderate Hazard Fire 1 Slight Hazard Reactivity 0 Minimal Hazard Special NONE No special Hazard (1) Protective Equipment B Goggles,Gloves (1) refer to section 8 of MSDS for additional protective equipment recommendations. CHANGE LOG EFFECTIVE DATE REVISIONS TO SECTION: SUPERCEDES --------- --------------------- ---------- MSDS status: 30-JAN-1997 ** NEW ** 11-FEB-2000 ;EDIT:9 30-JAN-1997 05-JUL-2001 12 11-FEB-2000 26-APR-2006 3,4,9,11,15 05-JUL-2001 18-JUL-2006 2 26-APR-2006 24-AUG-2006 2 18-JUL-2006


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Material Safety Data Sheet Issue Date: 19-AUG-2008 Supercedes: 19-APR-2004

DUSTREAT DC9148

1 IdentificationIdentification of substance or preparationDUSTREAT DC9148

Product Application AreaMaterial handling treatment

Company/Undertaking IdentificationGE Betz, Inc.4636 Somerton RoadTrevose, PA 19053T 215 355-3300, F 215 953 5524

Emergency Telephone(800) 877-1940

Prepared by Product Stewardship Group: T 215-355-3300 Prepared on: 19-AUG-2008

2 Hazard(s) identification

******************************************************************************** EMERGENCY OVERVIEW CAUTION May cause slight irritation to the skin. Potential skin sensitizer. May cause moderate irritation to the eyes. Mists/aerosols may cause irritation to upper respiratory tract. DOT hazard is not applicable Odor: Strong; Appearance: Amber, Liquid Fire fighters should wear positive pressure self-contained breathing apparatus(full face-piece type). Proper fire-extinguishing media: dry chemical/CO2/foam or water--slippery condition; use sand/grit. ******************************************************************************** POTENTIAL HEALTH EFFECTS ACUTE SKIN EFFECTS: Primary route of exposure; May cause slight irritation to the skin. Potential skin sensitizer. ACUTE EYE EFFECTS: May cause moderate irritation to the eyes. ACUTE RESPIRATORY EFFECTS: Mists/aerosols may cause irritation to upper respiratory tract.


INGESTION EFFECTS: May cause slight gastrointestinal irritation. TARGET ORGANS: No evidence of potential chronic effects. MEDICAL CONDITIONS AGGRAVATED: Not known. SYMPTOMS OF EXPOSURE: May cause redness or itching of skin.

3 Composition / information on ingredients

Information for specific product ingredients as required by the U.S. OSHA HAZARD COMMUNICATION STANDARD is listed. Refer to additional sections of this MSDS for our assessment of the potential hazards of this formulation. HAZARDOUS INGREDIENTS: Cas# Chemical Name Range(w/w%) 25212-19-5 ADIPIC ACID, DIETHYLENETRIAMINE, EPICHLOROHYDRIN 30-60 POLYMER Irritant (eyes)

4 First-aid measures

SKIN CONTACT: Wash thoroughly with soap and water. Remove contaminated clothing. Get medical attention if irritation develops or persists. EYE CONTACT: Remove contact lenses. Hold eyelids apart. Immediately flush eyes with plenty of low-pressure water for at least 15 minutes. Get immediate medical attention. INHALATION: Remove to fresh air. If breathing is difficult, give oxygen. If breathing has stopped, give artificial respiration. Get immediate medical attention. INGESTION: Do not feed anything by mouth to an unconscious or convulsive victim. Do not induce vomiting. Immediately contact physician. Dilute contents of stomach using 2-8 fluid ounces (60-240 mL) of milk or water. NOTES TO PHYSICIANS: No special instructions

5 Fire-fighting measures


FIRE FIGHTING INSTRUCTIONS: Fire fighters should wear positive pressure self-contained breathing apparatus (full face-piece type). EXTINGUISHING MEDIA: dry chemical/CO2/foam or water--slippery condition; use sand/grit. HAZARDOUS DECOMPOSITION PRODUCTS: oxides of carbon and nitrogen, hydrogen chloride FLASH POINT: > 200F > 93C SETA(CC)

6 Accidental release measures

PROTECTION AND SPILL CONTAINMENT: Ventilate area. Use specified protective equipment. Contain and absorb on absorbent material. Place in waste disposal container. Flush area with water. Wet area may be slippery. Spread sand/grit. DISPOSAL INSTRUCTIONS: Water contaminated with this product may be sent to a sanitary sewer treatment facility,in accordance with any local agreement,a permitted waste treatment facility or discharged under a permit. Product as is - Incinerate or land dispose in an approved landfill.

7 Handling and storage

HANDLING: Normal chemical handling. STORAGE: Keep containers closed when not in use. Protect from freezing. Do not store at elevated temperatures. Shelf life 270 days.

8 Exposure controls / personal protection

EXPOSURE LIMITS CHEMICAL NAME ADIPIC ACID, DIETHYLENETRIAMINE, EPICHLOROHYDRIN POLYMER PEL (OSHA): NOT DETERMINED TLV (ACGIH): NOT DETERMINED ENGINEERING CONTROLS: adequate ventilation PERSONAL PROTECTIVE EQUIPMENT: Use protective equipment in accordance with 29CFR 1910 Subpart I RESPIRATORY PROTECTION: A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA’S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR’S USE. USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS. If air-purifying respirator use is appropriate, use any of the following particulate respirators: N95, N99, N100, R95, R99, R100, P95, P99 or P100. SKIN PROTECTION: rubber, butyl, viton or neoprene gloves -- Wash off after


each use. Replace as necessary. EYE PROTECTION: splash proof chemical goggles

9 Physical and chemical properties

Specific Grav.(70F,21C) 1.068 Vapor Pressure (mmHG) ~ 18.0 Freeze Point (F) 29 Vapor Density (air=1) < 1.00 Freeze Point (C) -2 Viscosity(cps 70F,21C) 1300 % Solubility (water) 100.0 Odor Strong Appearance Amber Physical State Liquid Flash Point SETA(CC) > 200F > 93C pH As Is (approx.) 9.4 Evaporation Rate (Ether=1) < 1.00 Percent VOC: 0.0 NA = not applicable ND = not determined

10 Stability and reactivity

STABILITY: Stable under normal storage conditions. HAZARDOUS POLYMERIZATION: Will not occur. INCOMPATIBILITIES: May react with strong oxidizers. DECOMPOSITION PRODUCTS: oxides of carbon and nitrogen, hydrogen chloride

11 Toxicological information

Oral LD50 RAT: >5,000 mg/kg Dermal LD50 RABBIT: >2,000 mg/kg Skin Irritation Score RABBIT: 0.0 Eye Irritation Score RABBIT: 5.33 NOTE - Maximum score at 1hr; completely reversible by day 2 Skin Sensitization HUMAN: POSITIVE NOTE - Small number of positives recorded probably due to breakdown products Skin Sensitization G.PIG: NEGATIVE NOTE - Results are for material tested at slightly less concentration

12 Ecological information

AQUATIC TOXICOLOGY Bluegill Sunfish 96 Hour Static Acute Bioassay LC50= 4.5 mg/L Daphnia magna 48 Hour Static Renewal Bioassay LC50= 6.6; No Effect Level= .62 mg/L


Fathead Minnow 96 Hour Static Renewal Bioassay LC50= .9; 20% Mortality= .62 mg/L Rainbow Trout 96 Hour Static Acute Bioassay LC50= 2.1; No Effect Level= 1 mg/L BIODEGRADATION BOD-28 (mg/g): 0 BOD-5 (mg/g): 0 COD (mg/g): 610 TOC (mg/g): 187

13 Disposal considerations

If this undiluted product is discarded as a waste, the US RCRA hazardous waste identification number is : Not applicable. Please be advised; however, that state and local requirements for waste disposal may be more restrictive or otherwise different from federal regulations. Consult state and local regulations regarding the proper disposal of this material.

14 Transport information

DOT HAZARD: Not Applicable PROPER SHIPPING NAME: DOT EMERGENCY RESPONSE GUIDE #: Not applicable Note: Some containers may be DOT exempt, please check BOL for exact container classification

15 Regulatory information

TSCA: All components of this product are included on or are in compliance with the U.S. TSCA regulations. CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ): No regulated constituent present at OSHA thresholds NSF Registered and/or meets USDA (according to 1998 Guidelines): Registration number: Not Registered SARA SECTION 312 HAZARD CLASS: Immediate(acute) SARA SECTION 302 CHEMICALS: No regulated constituent present at OSHA thresholds SARA SECTION 313 CHEMICALS: No regulated constituent present at OSHA thresholds CALIFORNIA REGULATORY INFORMATION CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION 65): No regulated constituents present MICHIGAN REGULATORY INFORMATION No regulated constituent present at OSHA thresholds

16 Other information


HMIS vII CODE TRANSLATION Health 1 Slight Hazard Fire 1 Slight Hazard Reactivity 0 Minimal Hazard Special NONE No special Hazard (1) Protective Equipment B Goggles,Gloves (1) refer to section 8 of MSDS for additional protective equipment recommendations. CHANGE LOG EFFECTIVE DATE REVISIONS TO SECTION: SUPERCEDES --------- --------------------- ---------- MSDS status: 19-APR-2004 ** NEW ** 19-AUG-2008 4,7,8,10 19-APR-2004


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