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Ref#.

Ecosystem Application Volume, Section, Summary Comment/Rationale Information Request


Topic or ESA or Pages
Supplemental
Report#
Acoustic AETDR Sectior 2.5.1 Section 2.5.1 stales that for noise modelling at the nearby human The recording of results in Table 4-5 for IC6 should be checked to make sure
Environment Table 4-5 receptor locations, it was assumed that downwind conditions would that they are accurate. Depending on the results of this check, it may be of
Appendix A Table exist 100% of the time with_ a moderate temperature inversion. .
value for all reporting of noise calculations and results, or even the
A-3 Given that similar assumptions are likely to have been used when calculations themselves, to be checked to ensure they are accurate. If these
modelling individual facility locations, and that noise attenuates with calculations are accurate, additional expla·
expl nation is necessary to show why
distance, some of the results presented In the AE TDR are noise levels are higher at . receptor locations farther away from the noise
questionable. source(s) than those receptors that are closer to the source(s) and the
reason that a number greater than a criterion value is stated pS being in
For example, in Table 4-5, receptor location IC6 has a predicted compliance with It.
Ldn of 51.7 dB, which exceeds the MNL criteria of 47 dB. Table A-3
indicates that IC6 is 1062 m from the facility fence line.

In contrast, in Table 4-5, receptor location IC5 has a predicted Ldn


of 39.6 dB, and it is located approximately 308 m from the facility

I
fence line.

It is unclear how a receptor located at 1062 m from the facility


would have much higher predicted noise levels than a receptor
location located 308 m given that similar assumptions would have
been used In the modelling for the specific facility and nearby
receptor locations (e.g. downwind with moderate temperature
inversion).

Not only do the numbers appear abnormally high per the


comparison to IC5, but the last column of Table 4-5 indicates that
the result is in compliance with the MNL criterion of 47 dBA, when it
is clearly 4.7 dB higher. Furthermore, the information here is
neither self-consistent nor consistent with that in Table 4-13.
Acoustic ESA Volume 4, Part B, According to the Table, during operations, noise associated with Health Canada advises that the proponent verify that the sound power levels
Environment New Brunswick tanks,'foreshore facilities and associated infrastructure (exclusive for the tankers and tug boats presented in Table 3-2 of the Acoustic
Marine Terminal of interconnect pipeline) and the loading of berthed tankers was Environment Technical Data Report were used in the noise modelling to fully
Complexes, Table evaluated.' In addition lo these noise sources, ship traffic to and account for the noise contributions from ship traffic.
3-4 from the marine terminal may also be a contributor to increased
noise levels from project operations.

Noise from ships iii transit may be disruptive to Indigenous peoples


undertaking traditional activities on or near the water, and as such,
these additional noise sources should be evaluated for the marine
terminal facility.

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Ref#. Ecosystem Application Volume, Section, Summary Comment/Rationale Information �equest
Topic or ESA or Pages
Suppl_emental
Report#

ESA Volume 2, Section Blasting was not included in the noise assessment, with the Given that blasting noise was not evaluated, ii is unclear whether or nof the
3.3.2 (Northern justification that since blasting details (e.g. location and frequency) proposed mitigation will be elfective.
ON, ON East, NB) were not defined, they were not carried forward in the effects
Volume 2, Section assessment. Nevertheless, general mitigation was considered for Since blasting noise is high-energy and impulsive, there should be a
3.4 and. 3.5 (all blasting (i.e. "work with blasting contractors to review design and discussion about when blasting will likely occur (i.e. during the day and/or
segments) associated mitigation measures to control noise and to monitor night!), the amount of time blasting is·expected to occur (hours/day,
implementation of the blasting program"). days/weeks, and weeks/year), whether the community will be Informed in
Volume 4, Part B, advance of any blasting activity, and whether there will be a formalized
New Brunswick, complaint response process established which could include monitorl_ng
Section 3.3.2, page during blast events. Meaningful consultation has been shown in specific
3-9 situations to reduce the number of noise-related complaints. Health Canada
_notes that given that, for sonic booms, little or no public annoyance is
AETDR Sectior. 5, page 5-1 expected to result from any number of daytime sonic booms per day provided
their measured·or predicted peak value Is below 125-10 log N dB (US EPA,
2
1974} 1 . Based on Schomer e'. al. (1997) , It is reasonable to assume that this
would also be the case for blastinn noises lastinQ less than 1 vear.
Acoustic ESA Volume 4, Part B, With respect to proposed mitigation measures at the marine Health Canada requests that more detailed, specific mitigation measures are
Environment New Brunswick terminal during project operations, the report states that further provided in order to understand how the Proponent plans to implement any
Marine Terminal mitigation may be required following detailed design and that this noise monitoring/management program, including any trigger conditions (e.g.
Complexes, information will be included as part of additional reporting to be exceedance values) that woud be employed, and what types of proposed
Section 3.4.2 submitted to the NEB in 04 of 2014. Health Canada was unable to responses would be considered in order to mitigate potential noise effects.
locate the additional reporting that was to be submitted in 04 of
2014,
Acoustic Acoustic Section 2.1_.3.1 For construction noise, the AE TDR uses mitigation noise levels Health Canada has no official position with respect to the use of MNLs, the
Environment Environment pages 2-2 and 2-3; (MN Ls) for construction activities lasting less than one year to lack of a need to collect base ine noise levels for short-term construction, nor
Technical evaluate significance. The ESA states that construction activities the lack of a need to evaluate the incremental contribution of short-term
Data Report Appendix D,-Tables lasting less than one year do not require the determination of construction-related noise to overall noise levels (i.e. cumulative effects).
(AE TOR) 0-1 to D-7; baseline sound levels and that for transient and short-term Therefore, Health Canad;:i (2010} should not be cited-as the source for these
construction based activities, the potential incremental contribution statements/assumptions.
ESA Volume 2, Section of the Project to cumulative effects are not assessed or required. )
3.2.1 (all The reference cited for all of these assumptions is Health Canada }\�dlt!onal refe,rence� anci aiug;
iug;it�n_tia�ion
tia�ion
ia�ion,�ryou!� t,i� irovi�e d
. id, . .. , "
segments); (2010) (entitled "Useful Information for Environmental �emonstrate that the Health Cana(!a,slatements
Cana(!a,slatements· lrUhe referenced _ documen\
Volume 4, Part B, Assessments"). b�(i Nolsefevel'.crljerion of the ESA and t6.
be.re;c�'sl into the .Mitjg�iti>n Nolsefevel'. .
Section 3.2, page Where. pre(!lction 9f baseline noise
�oq�rm wti'etll�r,r,r there are ponditions Whe'
3-3 (New Health Canada (2010) does not discuss MNLs, nor the need/lack levels,may not be n�e�ectl
Brunswick Marine thereof for baseline noise levels and/or an evaluation of cumulative

1 United States Environmental Protection Agency (US EPA). 1974. Information on Levels of Environmental Noise Requisite to Protect Public Health an<! Welfare with an Adequate Margin of Safety (Report No. 550/9-74-004).
2 Schomer, P.O., Sias, J.W. and Maglieri, D. 1997. A Comparative Study of Human Response, Indoors, to Blast Noise and Sonic Booms. Noise Control Eng. J. 45(4), 169-182.

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Ref#. Ecosystem Application Volume, Section, Summary Comment/Rationale Information Request
Topic or ESA or Pages
Supplemental
Reoort #
Terminal) effects for short-.term/transient construction noise. Adoi.tlon?ll references st\oulil b� provide<! t.o. S!Jbstantlate the assumptions
Adoitlon?ll
HSed iri 'eyall.1�
�t(ng
t(ng shq(t-term: �o)"lstrttctlc>r) n9ise .l�'v.els ahd tti� stgnificlilnce of
Volume 2, Section For short-term construction noise, Health. Canada {2010) states ,
tties� .noise. Iev:eIsi
3.6 {all segments) only the following:
• If construction noise lasts for less than two months at receptors, it
may be considered temporary, and community consultation is
advised.
For construction noise at receptors with durations of less than one
year (i.e. short-term), Heallh Canada advises that mitigation bl(]
proposed if the resulting levels are predicted to result in widespread
complaints or a stronger community reaction, based on the U.S.
3
EPA method (U.S. EPA 1974; Michaud et al., 2008)." • 4
Acoustic AETDR Section 2.3, page The AETOR states that baseline sound pressure level Given that the baseline noise measurement was for a period of approximately
Environment 2-8 and measurements were collected from the spring to fall periods in 24 hours at any individual location, a rationale should be provided in order to
Section 4.1, page 2013 and 2014 {specific dates not identified in the report) and that justify that this duration is reasonable for determining a representative
4-1 they were unattended and conducted over a period of baseline noise level.
approximately 24 hours. It is unclear whether one-24 hour sample
during sometime from the spring ·10 the fall is sufficient in order to
determine a representative baseline noise level.
Acoustic ESA Volume 2, Section According to the ESA, "noise mitigation measures were applied to Health Canada advises that noise levels be modelled with and without
Environment 3.5 {all segments) the noise sources used in the acoustic models and the mitigation measures implemented. A no-mitigation scenario would be useful
corresponding propagation c_alculations". As such, the worst-case for planning purposes in the event of noise concerns in order to determine
scenario {i.e. without mitigation) was not modelled in the noise whether the actual noise sources were noisier than expected and/or the
assessment. This may result in an .underestimation of future noise mitigation implemented was less effective than expected (in which case
levels depending on the effectiveness of the proposed mitigation additional mitigation would be warranted and could be directed at the noisiest
measures. sourcesl.
Acoustic AETDR Section 2.5.1, page Section 2.5.1 indicates that the noise modelling was conducting In addition to the proposed mitigation for the locations where noise levels are
Environment 2-11 using ISO�613, which has an accuracy of+/- 3 dB al a distance of predicted lo exceed the applicable MNL, additional consideration is needed
and up.to 1.5 km from the source. for those locations which are nearing the MNL as public complaints may
Tables 4-4 to 4-10 occur.This could include monitoring in the event of public complaints or
Tables 4-4 to 4-10 present noise prediction results for project additional mitigation in those areas where exceedances may occur.
· facility construction and-compare the predicted values to a MNL of
47 dB or 52 dB (depending on location of the facility). Several
locations have predicted Ldn values that are near or above the
indicated MNL (+/- 3 dB), and aiven the accuracv of ISO 9613

3
Michaud, D.S., Bly, S.H.P. and Keith, S.E. 2008. Using� change in percent highly annoyed with noise as a potential health effect measure for projec ts under the Canadian Environmental Assessment Act. Journal of Low Frequency
Noise, Vibration and Active Control, 27(4): 2S3-265.
4
U.S. EPA. 1974. Office of Noise Abatement and Control. Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety.
www.nonois·e.org/library/levels74/levels74.htm
evels74/levels74.htm

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Ref#. Ecosystem Application Volume, Section, Summary Comment/Rationale Information Request
Topic or ESA or Pages
Supplemental
Reoort#
these locations may actually exceed the applicable MNL (e.g. HR1,
WE1, WE2, WE4, WES, PP1, IC1, IC4, IC?, IC8, DD4, RA1, RA2,
Kl1 IR1, LA2, DO5 DO6, DO10, LE12, SJ2, SJ9, SJ13, SJ14).
Acoustic AETDR Table D-1, Table D-1 indicates that for mainline over land construction, the Explain how the final MNL was calculated for both construction activities, with
Environment Appendix D basic mitigation noise level (MNL) is 47 dBA with a +10 dBA elaboration of how the adjustments to the MNL were arrived at.
adjustment for construction duration, with a final NML of 52 dBA.

For open cut watercourse crossings, the basic MNL is 47 dBA with
a +10 dBA adjustment for construction duration, with a final MNL of
57 dBA.

It is unclear how the same basic MNL for both activities with the

I
addition of a 10 dBA adjustment factor could result in a final MNL of
52 dBA for mainland over land construction and a final MNL of 57
dBA for ooen cut watercourse crossinas.
Acoustic ESA Volume 2, Section The deinitions
definitions of "dwelling" and "residence" have a certain level of Clarify what receptor locations were evaluated in the assessment. If specific
Environment 3.2.2 (all complexity to them. Therefore, it is not clear if certain types of human receptor locations were excluded from evaluation, locations of these
segments) trailer parks, campgrounds or mobile homes may have been receptors should be identified and justification should be provided as to why
Volume 4, Part B, considered as receptors while others may not. The ESA states: they were not evaluated (i.e. campsites, mobile trailers, etc. which may be
Section 3.2.2, page 1) "a receptor is defined as any dwelling unit in accordance occupied by Indigenous Peoples).
3-7 (New with Directive 038. A dwelling unit is any permanently or
Brunswick Marine seasonally occupied residence".
Terminal) 2) "trailer parks and campgrounds may qualify as dwelling unit
if it can be demonstrated that they are in regular and
consistent use during the applicable season".
3) "seasonally occupied dwelling is defined as a fixed
residence, that, while not being occupied on a full-time
basis, is occupied on a regular basis" and
4) "the residence must not be mobile and should have some
sort of foundation or features of permanence (e.g. electrical
power, domestic water supply, septic system) associated
with it. Summer cottages or mobile homes are examples of
seasonally occupied dwellings"

Acoustic AETDR Section 5.1, pages Section 5.1 presents proposed mitigation measures for the Review the New South Wales Guidance document and discuss which, if any,
Environment 5-1 to 5-2 construction phase of the project Health Canada also advises that additional mitigation measures will be implemented to reduce noise levels to
further mitigation, such as those measures presented in the New the extent possible.
South Wales Construction Noise Guideline (attached) be
considered in order to reduce construction noise where the

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Ref#. Ecosystem Application Volume, Section, Summary Comment/Rationale Information Request
Topic or ESA or Pages
Supplemental
Reoort #
predicted noise environment plus the estimated uncertainty is
above the EPA (1974) criterion for wid�spread complaints (i.e.,
above the MNL per the proponent's re-formulation of the
normalized Ldn criterion in terms of the MNL.
AETDR AE TDR document It would be useful to have noise contours presented on the maps of Consider including noise comours on the maps of the individual facilities with
the individual facilities which would also identify the locations of the receptor locations also identified.
nearest human receotor locations ldwellinasl that were evaluated.
Acoustic AETDR Table 4-7, page4- Table 4.7 presents data for LE12 (Levis Pump Station), however, in Add LE12 to Table A�4.
Environment 14 Table A-4 the receptor location is missing from the table.
and
Appendix ATable
A-4
Acoustic ESA Volume 4 Part B, The nighttime Ln is defined as N/A, whereas in the paragraph Correct the typo.
Environment Table 3-6 (New preceding this table, it indicates that the value is zero. This is a
Brunswick Marine typo.
Terminal)
Acoustic AETDR Table 2-8 In terms of modelling parameters, the receptor height was assumed As presented in the 2013 Ontario NPC-300 environmental noise guideline for
Environment to be 1.5 m above grade. stationary sources5 , it is advised that the proponent consider re-evaluating
the Ld and Ln, using a more representative typical building height.
A receptor height of 1.5 m is appropriate for single storey
residences, but may underestimate levels on ap·artment balconies
facing the source, or open windows on the second storey of
buildinos.

5 Ontario Ministry of the Environment. 2013. Environmental Noise Guideline: Stationary and Transportation Sources -Appro�al and Planning. Publication NPC-300. Prepared by Environmental Approvals Access and Service
Integration Branch and Environmental Approvals Branch. August. http://www.acoustical-consultants.com/wp-content/uploads/2013/11/NPC-300 Final-Approved 011-0597.pdf

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EIS APPUCATrON for Energy East Pipeline Project - HC Initial Screening notes (spring 2015) - Acronyms lisf below

Potential Issues Noted by Coordinator


What is the potential importance to HC's
- point form notes, sucb as:
Application o,• review, considering the project in its entirety
Env'tal and Socio-ec Would this issue potentially (nnd NEB's review)?
No. Area of Expertise Volume, Section, Pages !. /11forma1io11 Missing - where a11d whar
Assessment (ESA) or need HC expert support'/
2. U11clcar - clariftcalio11 needed, /11couslste11cies
Supplemental Report# ie. Major issue, unce,tain, technical detail, minor
3. Teclmicol error
conunent
4. lm1e will, judgeme/11, interpretatio11, ratio11ale
..
I Air Quality ESA Volume 2: Part A: 2.1, PJ) 2-1 Construction vehicles and equipment releases - only considered No (but will run TR by them) Major
Alberta NOx, 502, l'Ml0. PM2.5 and CO. Other potential COPCs not
included (eg: voes, total petroleum hydrocarhons and PAHs
whi�h·muy be associated with diesel exhaust)

2 Air Quality ESA Volume 2: Pait A: 2.l,pp2-1 Storage tank releases - lots of CO PCs that are not included with No (but will nm IR by them) Major
Alberta regards to those that could volatiliz,e off the_ tanks (eg: Petroleum
.
Hydrocarbon fractions, PAl Is, sulphtlr-containing compounds
and VOCs (only benzene presented))
3 Air Quality ESA Volume 2: Part A: 2.1.1 (AB, SK/MB, It is recommended that the U.S. _EP� NAAQs for NO2 and SO2 No Minor
Alberta Northern ON), pp 2-2 . be used for comparison until the .<;:1',AQs,
<;:1',AQs arc finalised
4 Air Quality ESA Volume 2: Part A: J'ablc 2.1, pp 2-3 The 24-hour and a1mual vah1cs for hydrogen sulphide don't No Minor
Alberta match those in the HHRA ·(paii;e 9-i8, Table 9-8)
5 Air Quality ESA Volume 2: Part A: Table 2.1, pp 2-3 No regulatory guidelines arc presented for constrnction-related No Minor
Alberta COPCs (NOx·, SO2, PM 1o, PM2.s or CO)
, _
6 Air Quality ESA Volume 2: Part ,\: 2.1.3.4, pp 2-5 (Vol 2 Part Little information on how sensitive receptors were determined No (but will run JR by them) uncct1ain
Alberta A -AB); 9.3.l pp 9-12 (Vol and whether they are schools,hospitals, immunocompromised?
3 Part A: AB); 2.1.3.4 pp 2- FiThi Nations? For the NB .assessment, lhey refer lo Volume 3,
6 (Vol 2 Part B - SK/MB); Part E, Section 9 but that doesn't exist. It looks like it was just
3.5.3.1 pp 9-26 (Vol 3 Part ciled incorrectly and it's volume 4 of the same document. There
C - Noithern ON); 2.2.5.1 aren't any FN groups listed or any indication as to where FN
(Vol 4 Part 8: NB); groups are located in this LSA.

7 Air Quality ESA Volumi: 2: Part A: 2.2.2.2. pp 2-13 Alllbien! background concentrations were only presented for Yes Mnjor
Alberta substances predicted to be released during operations. but not
considered for conslruction phase COPCs.
8 Air Quality ESA Volume 2: Part A: 2.' 5.3.3 They note the new values for PM2.s· in 2020, but they don't use it No Minor
AJberta in their assessment. The project is expected to be built beyond
2020, so they should use this value.

Pagel of9

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DRAFT

9 Air Quality ES/\ · Tahlc 2-l l, Pl) 2-25 (Vol 2 Rdeas�s ofCAC, provi<le<l in kt/y but not in concentration Yes Major
Part A - Albc1ta); 25.2, pp (µglm3) and were not comp3r�d to regulato,y standards.
2-22 (Vol 2Partfl-
SK/MB); 2,5.2 pp 2-14 (Vol
2 Part C2 - Ont F.ast); 2.3,
pp 2-20 and Table 2-15, pp
2-25 (Vol 2 Pal'I D - QC);
2.55 (Vol 4Patt B - NB)

10 Air Quality ESA Vol11n1e 2: Pa11 A: 2.5.3.3 Issue with increase in ben7.ene ("highest increases in Application Yes Major
Alberta Case air emissions compared with the Baseline Case arc
a�sociated with benzene. which are about 5% greater") and
que.1tioning their rationale for nut considering it of minimal
concern.
II Air Quality ESA Volume 2: Part .I\: 2.6, pp 2-23 States there are certain and reasonably foreseeable physical No Likely a typo; technical error
Alberta activities but then state that a cumulative eITcets assessment was
not undertaken
12 Air Quality ESA Volume 3: Part!\: 9.3.1. pp 9-6 For the asscssmc -nt ofhuman health ri�ks \l1ajnhalation. health Yes Major
Alberta risks were expressed as conceotratio1 ! rat,i?s (Clls) but there is no
consideration for I LCRs
13 Air Quality ESA Volume 3: Pa11 A: 9.3.1. pp 9-12 Construction is not considered in the HHRA ·because the Yes Major
Alberta Proponent state.s it occurs at 'ati ·intermittent hnsis and is tran.1icnt
and spread ov�r various eqi1ipmenis and activities and therefore
is only considered quali'tat, vely. These releases should be
quali'ta iively.
considered in tl\e T-flfRA ·.;,
14 Air Quality ESA Volume 2: Part A: Table values for H 2S don't match those on page 2-3 (Table 2-1 of No Minor
Alberta the BEAssessment) ··- ·" "
15 Air Quality ESA Volume 3: !'art A: 9.5.3.4, pp 9-20 One-hour exposure coi1ccntralion of Hi S and benzene exceed the Yes Major-
Alberta human health criteria for lhe baseline and application cases.. The
rationale for these to not be a concern is potentially a concern.

16 Air Quality Volume 2: Biophysical 2.1.2, pp 2-3 Table 2-1 values don't maich the Table 9-8 values in the HHRA No Minor
..
Effects Assessment - Part B
SK and MB

Page 2 of 9

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& 58
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17 Air Quality Volume 2: Aioph)('lical 2.3. pp 2-lS Operation-relaced emissions are from headspaccs of Che tanks Yes Major
Eftccts Assessment , Part 8 und during tank-lilling. H2S, l>enzcnc and mcrcaptans. There nre
SK and MB a 101 of potential COPCs that were not included with regards 10
those that could volatilize off the tanks. In TMX, the proponent
provided a list of chemical constirnents in Cold T.ake Winter
Blend (diluted bitumen) aod th�n screened Ute chemicals on the
basis or volatility, followed by consideration of a TMX study
f
looking at the e111issio1i flux rates of a freshwater holding tank
containing CLWB. The l1nal list ofCOPcs included Petroleum
Hydrocarbon Fractions. PAHs, Sulphur-containing compounds
and VOCs (nol just benzene)
18 Air Quality Volume 2 SK/Mil 2.5. l, pp 2-20 For tlte other locations (AB, QC and NB). there is no discussion Yes Major
about how the residual effects characterizmion criteria are based
on the scenario where geneml mitigation has been implemented.
Shouldn't tile evaluation be for a worst-case scenario'/ Whnt
about in the event of an accidcnt/malf\mction'>

19 Air Quality Volume 2 SK/MB Table 2-15 (Section How did they calculate the 11g/m3 base� 'on 'AfRlv100 wbicb Yes/No Minor
2.5.3.3), pp 2-27 · '
calculates emissions in t/y.
20 Air Quality ESA: Volume 3: Part B: 9.1.3.2, pp. 9-2 Answers question posed earlier about.wheth�r receptors include Yes/No Minor
Saskatchewan and Manitoba FN. Answer is not right now b�ausc they haven't completed the
TEK/ILU studies but instead for the HHRA use the max ground
level concenlrations-wh.ich \.-ould "overstate" the risk to sensitive
receptor locations'. Ts this �dequate?
·,. I

21 Air Quality ESA: Volume 3: Part B:


Saskatchewan and Manitoba
9.2.2, pp 9-5 What was the source or baseline ambient air quality data (SK
and MB) and for wh'at year? What did they use for baseline
values for benzene'/
No. (will run TR by them) Minor
I
22 Air Quality ESA: Volume 3: Part B: 9.3.l, pp 9-6 Releases to ground water and.country foods could occur for No ?
Saskatchewan and Manitoha spills?

23 Air Quality ESA: Volume 3: Pait B: 9.5.:U. pp 9-12 Receptors of concern - includes sensitive life stages and No. (will nm JR by them) Major
Saskatchewan and Manitoba immunocompromiscd. 38 locations. Question - need to find out
if this includes fN groups
24 Air Quality ESA: Volume 3: Part R: 9.S.3.1, pp 9-12 Rationale for only doing a qualitative assessment on constmction Yes Major
Saskatchewan and M, .nitoba air releases - This is nor adequate. Should be considered in the
HHRA
25 Air Quality Volume 2: Biophysic,.! 2.1, pp 2-1 Constrnction emissions and greenhouse gas emissions from lbe Yes Major
Effects Assessment - Part c;::: gas turbine generators al the 8 pump stations. There is no
Northern Ontario discussion ahont other potential COPCs such as VOCs, total
petroleum hydrocarbons (TPH) and PAHs which may be
associated with diesel exhaust. What aboul ozone?

Page 3 of9

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26 Air Quality Volume 2: Biophysical 2.2.2.2, pp 2-23 Ambient air quality provided/ NO2, CO and PM2 _5 are measured No Minor
Effects Assessment - Pait C on a continuous basis at a variety of monitoring stations in the
Northern Ontario NAPS network. There is 110 discussion about background
concentrations of SO2. What baseline was used in deriving the
predicted future concentrations in the baseline+ project
scenario?
27 Air Quality Volume 2: Biophysical Tahle 2-3, pp 2-4 Why was the NAAQO "Maximum acceptable" criteria used No Minor
Effects Assessment - Part C instead of the "Maximum desirable" level when determining the
N011hem Oniario apolicablc criteria lo use in the assessment?
2R Air Quality Volume 2: Biophysical Table 2-3, pp 2-4 HC advises that predicted filturc PM 2.s concentrations be No Minor
Effects Assessment - Part C compared lo the new and more stringent CAAQS which are
Northern Ontario effective as of 2020 given lhal this project is expected lo be
operational past 2020 and the new CAAQS will be applicable
during project operation.
29 Air Quality Vol\lme 2: Biophysical 2.5.3.4, pp 2-34 3
How did they calculate the µg/m based on A ERMOD which No Minor
Effects Assessment - Part C calculates emissions in 1/y.
Northern Ontario -.
30 Air Qu.1lity Volume 2: Biophysical 2.5.3.4 l'rojccl Case ResL1l1s Dispersion modelling results for predicted ground-level Yes Major
Effects Assessment - Part C (Table 2-16), pp 2-34 conccnrmtions of NO2, CO. PM2.5 and P/vl 10 from the pump
N01them Ontario station sources alone as well as ::umulatively,y with background.
y,
For lhe maximum predicted ground fov°el concentrnlions (project
case- wbicb includes gas turbine gener'at�rs at 8 pump stations),.
NO2, CO, PM2.5 and .PM IO were evaluated. It is unclear why
SO2, VOCs, PAI-ls were'npt ev�lualed given that these
generators are liu
liurning
rn
_ ing diesel fuel.
31 Air Quality Volume 3: BSA - Part C - 9.5.3. J, pp 9-26 Choice of COPCs\ ls ll)erc an issue with NOT evaluating SO2 Yes Minor
Northern Ontario liiuantitatively? Should show values
32 Air Quality Volume 3: ESA - Part C - 5.3, pp. 5-4 They note there will be a need for new access roads and updating Uncertain
N011hern Ontario of existing roads. What about construction releases for this?

33 Air Quality Volume 3: ESA - Part C - 5.3, pp. 5-4 Because most oflhis is a rural inhabited area, there is likely Uncertain
Northem Ontario going to be clearcutting. What about releases lo air during
clearcutting? Is this considered in the construction releases
estimate?
34 Air Quality ESA: Volume 2: Part C2 - 2.2, pp 2-8 No baseline values are provided. The Proponent indicates that No Minor
Ontario East there were 11110 exceednnces etc. 11 al these monitoring stations
again;1 air quality objectives.

Page 4 of 9

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35 Air Quality ESA: Volume 2: Pat1 C2 - 2.2, pp 2-8 No ambienl background concentrations were presented for the No Minor
Ontario Easl CACs identified as being assessed for this po,1ion of the pipeline
project (CO, N02 and PM2.S). In addition, there is no discussion
about background S02 concentrations that were used in lhe air
dispersion modelling
36 Air Quality ESA: Volume 2: Part C - 2.5.1, pp 2-11 For the other local ions (AB, QC ,md NB I, lhcl'C is no discussion Yes Major
Northern Ontario aboul how the residual effects charncterizalion criteria are based
on the scenario wberc general mitigation has been implemented.
Shouldn't the evalualion be for a worsl-cnse scenario? Whal
about in the event ofan accidcnl/malfuncliun'?

37 Air Quality ESA: Volume 2: Part D: 2.1, pp 2-1 No menlibn of what the project components are. Is it a No (will run LR by them) Major
Quebec conversion? New pipeline'! Tank lerm.inal? Pump stations?
Based on Section 2.3 (Pote,1tial Effecls). only consideling
pipeline and pump station (including permam,nt access roads}
construction and their changes to air ql\alily. There is 110
discussion of what COPCs will be cvalunlcd during lho
construction phase of the project. Ag�in, no suhstances other

I-
tban S02, NO�, PM2.5, PM 10 and Cd were quanlitativcly
evaluated. ,. ,\�
38 Air Quality ESA: Volume 4: Part D: 2.1. pp 2-1 Very limited list. Same as other provinces, why are there PAHs. No (will nm JR by them) Major
New Brunswick Petroleum hydrocarbon fraciio�s;VOC:s not inclncled'?
39 AirQualily ESA: Volume 4: P�rt B: 2.l,pp2-I COPC.,s were I isled fo1,co11s'tniction:·opcration of lank lenninal Yes Major
New Brnnswick and loading of be1thing vessek There is no evaluation of other
VOCs, petrolci,m hydr()carpons (TPH) aodior PAHs which may
be associaled with marine �hipping. There are a lot of potential
COPCs that were nm included with regards to those that could
volatilize off the tanks. In olher assessments (like TM.XJ, the
Proponent provided a list of chemical constiti1cnts i.i1 Cold Lake
Winter Blend (diluted bitumen) and then screened the chemicals
on the basis of volatility. followed by consideration ofa TMX
sl\ldy looking al the emission nux rates off a freshwater holding
tank containing Cl.WB. The final list of COPCs included
Petroleum Hydrocarbon Praclions. PAI-ls, Sulphur-containing
compounds and VOCs (not just benzene)

Page Sof9

- . VVUU&58
DRAFT

40 Air Quality ESA: Volume 4: Part B: Table 2-2, pp 2-4 Several regulatory criteria differ between the two tables (for QC No Minor
New Brunswick and NB), in particular for SO2, the Quebec I-hour standard is
900 ug/m3 is used in Quebec, but 450 ug/m3 is used for New
Brunswick. The Quebec 24-hour standard is 288 ug/m3 whereas
it appears the 24 hour standard for New Brunswick is 150 ug/m3
(in Table 2-2 (NB) - there arc 2 !-hour criteria presented for
SO2, ii is assumed that the second value actually represents the
24-hour guideline value).
Given that this is one project, it would he reasonable to assume
that the most conservative air quality standards for the entire
project area would be applicable.

41 Air Quality ESA: Volume 4: Pa11 B: 2.3, pp 2-14 I see this as a big issue ...the fact that potential effects are based Yes Major
New Brunswick on professional judgement and not modelled results ....but then
they provide construction emissions (kt/y) for S02, NO2, PMI0,
PM2.5 and CO for the marine lerminal as residual effects .
.,
42 Air Quality ESA: Volume 4: Part B: 2.3, pp 2-16 Construction releases of CACs mainly from diesel combustion
New Brunswick from heavy equipment. Operation and ln�infeilance releases of
CACs are from marine vessels and vapour combustion units, as
well as emissions from oil prod1ict t�;lks. Behzene emissions are
considered high? Or do they just state this? They don't provide
numbers of benzene emissions in comparison to standards 10
show if there are exceedences. In the HHRA it looks like the
concentration ·r�tios for bchzcne (MPOI and 23 receptors) are
less lhan I and ther � are n9 exceedences (short or long term).

43 Air Quality ESA: Volume 4: Part B: 2 . .5.5, Pl> 2-20 They didn't include oft�horc emissions because they're at a Yes Major
New Bnmswick greater distance to tbe receptors and aud are less than onshore
emissions therefore a negligible effect is expected. ls this
adequate? What about people using the waters?
44 Air Quality ESA: Volume 4: Part B: 2.5.6, pp 2-21 What about i11gitive releases from tanker holds'/ TI1ey only Yes Major
New Brunswick considered combusion releases from the marine vessels. Or is
this fairly minor'/
45 Air Quality ESA: Volume 4: Part R: 2.5 .6, pp 2-23 Emis.sions of CACs from marine ves.sels estimated in tonnes/year Yes Major
New Bnmswick (SO2, Nox, PM, PMIO, PM2.5, CO, ben�cm,) and for tanker
vessels and tug boats (Table 2-12). There appears to be a lot of
CO PCs missing. Furthermore, a1-c emissions while at berth really
considaed worst case for emission levels'/ What about
combusiion d1Jrir1g marine vcssd transit'/

Page6of9

- . VVUU&58
DRAFT

46 1\irQuality ESA: Volume 4: Parl B: 2.5.6, pp 2-23 Annual emission rates for VCUs arc provided in Table 2-13 Yes Major
New Brunswick (tonnes/year) !'or SO2, Nox, PM. PM I 0, PM2.5, CO, hcnzcne
and consider 3 stacks. Lots of COl'Cs not considered here. Need
rationale to explain why lhey were not included.

47 AirQuality ESA: Volume 4: Part B: 2.5.7.1, pp 2-26 Project Case - need to look at NOx values
New Brnnswick
48 AirQuality ESA: Volume'4: Part B: 2.5.7.2, pp 2-28 Application Case - need to look at updated regulatory values/ No Minor
New Brunswick for Nitrogen oxides, they don� note that there isn� a threshold.
Same with PM
49 Air Quality ESA: Volume 4: PartB: 15.5.2.1, pp 15-18 The Proponent is cu,,-ently analyzing the projected consequences No Minor
New Bnmswick of spill scenarios at the marine lcrminals and will review this
modelling with l'N groups who have expressed concerns
regarding accidents and malfunctions. When will Ihis be
available'/
50 Air Quality ESA: Volume 4: Part B: 19.5.:1.1, pp 19-15 Unlike the HHRA for Trans Moumain Pipeline where they Yes Major
New Brunswick conducted an HHRA and mnlli-mcdia HHRA, Energy East ,toes
not look at I'AHs. sulfur-containing C911)POLIQ!ls and VOCs
(although b�nzene was considered). Furlper. there is no
cousidcrati_on for assumed chcrnJcal t:tti.xtures for the terminal
(i.e. acute and chronic inhalation of¢yc irritants, nasal irritants,
respiratory irl'ilanls, reprc4uctivc .arid developmental toxicanls,
i1mnunotoxicants and neLirotoxicarits)
51 Air Qunli. ty ESA: Volume 4: l'a,1 13: 19.5 ..U, pp 19-15 There is no determiiiation _of lLCRs for caminogcns because of a Yes Major
New Brw1�wick limited COPC list.
52 Air Quality ESA: Volume 4: Part B: 19.5.3.1. pp t9-l5 There is no uncertainly and co111idc11ce section. There is no No Minor
New !lrun�wick summary of the maJor assumptions applied u, tile HHRA aod the
associated uncertainties.
53 Air Oualitv All air documents All air documents There is no consideration for ozone releases. Yes Maior
54 AirQualily All air documents All air documents There is no mention that PMIO and PM2.5 are considered non- No Minor (will mention in IR)
threshold substances, meaning that beallh cllects may occur at
any level of exposure. From the guidance document: "It is '
widely accepted that.PM/1 and PM2.5 are considered 11011-
thri!$hol<I s11bs11111ces, meaning that health effects may occ11r at
any level ofexposure. Health Canada holds the view that there
is more risk associmed with exposure to ve1yji11e pmtic/es,
partic11larly PM2.5. The !ARC recently classified particulute
111e11ter as carci11oge11ic to !111ma11s (20/ 3). Health Canada
suggests that when assessing the pote11tial health �Oec/s ofPM,
there is ack11owledge111e111 that there is 110 threshold below
which there is 110 adve1:ie health effect. "

Page 7 of9

- . VVUU&58
DRAFT

55 Air Quality All air documents for each Section 2.5.1 (Table 2-10) With respect to defining "duration" for the residual effects Yes Minor
province characterization criteria in Table 2-10, sbo1Hcrm is define<.! as
"effect is measurable for.less than I month" and medium-term is
· "effect is measurahlc for greater than 1 month but less than 2
years" - this should be substance-speci fie, as some substances
are acute respiratory i1Tita111s and any exceedancc may result in
adverse health e!focts
56 Air Quality Volume2 Section 2.3 (SK and MB; The EfS lists measurable parameters for changes in air quality ? Minor
Northern ON; ON East; and a rationale for their selection.
QC;NB) For the SK and MB s�gment, the EIS states "there are no key
Volume 4, Section 2.3 - indicators identified for this assessment".
Marine terminals (QC and For the Northern ON and QC segments, it states "there are no
NB) key indicators identified for these VCs"
For Ontario East and NB segments it states "there are no key
indicators identified for the atmospheric environment"
For the QC and NB marine terminal components, it states "there
are no key indicators identified for th� �tmospheric
environment". '
What do these statements mean?
57 Air Quality Volume2 Section 2.5.4 (AB, SK and Determination of significance "a significant _adverse residual Yes Major
MB, Nor1he111 ON); Section effect for air quality is one whpre project-rclittcd releases of air
2.5.2 (QC) contaminants degrade the 91.iality ofthe•ainbient air such that the
predicted concentrations (CO\nbined wi'th background) are likely
to e,�cecd rclcya11t reg1ilatory criteria for ambient air quality, ancl
are. of concennelative tci tbe geographical extent of predicted
cxcceJenccs. their frcquen�y of occ1m-eoce ond the presence of
polentially
. suscep'tible r�cptors" - hut then the 1Jrediclcd
construction emissions ·revels are in tonnes/year which ,ire not
directly comparable to regulatory criteria which is in ug/1113

58 Air Quality all documents Potential gap? They did not look at various lifestyles for Yes Major
inhalation (e.g. Aboriginals, urban dwellers, non-mban dwellers
and area users). Therefore assuming highest exposure for all
receptors. Also no consideration of physical characteristics of the
people pptcntially at risk a,id their differing inhalation rates
(mJ/day) (i.�. infants, toddlers, child, teen, adult). Or is this
because there is no multi-media HHRA'!
59
60
61
62

Page 8of9

- . VVUU&58
DRAFT

List of Acronyms
CO carbon monoxide
CO2 carbon dioxide
COPC(s) contaminant(s) of potential concern
EA environmental assessment
HC Health Canada
HHRA human health risk assessment
NH3 ammonia
N20 nitrous oxide
NO2 nitrogen dioxide
NOx nitrogen oxides
PAHs polycyclic aromatic hydrocarbon, (e.g. benzolalpyrene)
PM2.S particulate matter less than 2.5 mm In diameler
PMl0 particulate matter less than 10 mm In diameter
PCBs polychlorlnated biphenyls
SO2 sulphur dioxide
SOx sulphur oxides
TSP total suspended particles
voe, volatile organic compounds (e.g. benzene, toluene, xylene)

Page9of9

- . V VUU
&58
Health Canada's Preliminary Review of the Energy East Project

Summary of concerns: what is sufficient/appropriate, gaps, errors


Rationale: why is this relevant to HC review?

Air Quality . : · ·J ·.....


....... ' ' • · - - ·"
'

Summary of concerns Top two concerns Rationale


- Not all COPCs were assessed and no rationale 1. Limited airborne COPC are assessed and - Modelling should be performed and air pollutants
3
was provided for their omission. When COPCs predicted exposures are not compared to concentrations in mg/m should be provided for all
were assessed, results were not in proper regulatory standards relevant proposed Project-related COPC emissions
concentration units and were not compared to (i.e. emissions from storage tanks, filling operations,
regulatory standards. 2. Limited information is provided on impacts to and gas turbine generators at the eight pump
aboriginal receptors stations), or provide a detailed rationale.of their
- Construction emissions were not quantitatively exclusions. Predicted exposures should then be
assessed and no rationale was provided. 3. Residual Effects Characterization Criteria compared to guideline/regulatory levels. Lacking of
section is inconsistent for different provinces the above assessment may result in
- For the other locations (AB, QC and NB), there is underestimation of potential risk to human health.
no discussion about how the residual effects
characterization criteria are based on the scenario - A detailed discussion is only provided for ON, but
where general mitigation has been implemented. not for AB, QC and NB. Health Canada suggests
providing a discussion regarding the residual effects
- location of aboriginal receptors and potential characterization criteria based on the scenario
impacts were not clearly identified where general mitigation has been implemented be
included for all provinces.
- Discussion on residual effects is missing for AB,.
QC, and NB.

- There is no uncertainty and confidence section.


There is no summary of the major assumptions
applied in the HHRA and the associated
uncertainties. There is no determination of ILCRs
for carcinogens because of a limited COPC list.

- NO2 levels as a result of the proposed Project are


predicted to increase substantially above baseline
for all three timescales at the New Brunswick marine
terminal, while 1- and 24-hour NO2 concentrations
are predicted to increase dramatically as a result of
marine shipping activities at this terminal (over 20X
in the case of 1-hour NO2). NO 2 levels are also
predicted to increase significantly above background
at all locations in Northern Ontario. Mitigation
measure should be provided for these non-threshold
COPCs.

- . VVUU&58
Last updated: 23 November 2016
Health Canada's Preliminary Review of the Energy East Project

Summary of concerns: what is sufficient/appropriate, gaps, errors


Rationale: why is this relevant to HC review?

- Country Foods/HHRA •":'' - ., ,_ ,


,.'
- - -, �;.""""' ' '"
-
··'f� -
-
Summary of concerns Top two concerns Rationale
1.

Noise ' --
,,
,-_
--- _,
: ..·: \·\:
,, ._._-.,: _,-:.- ,,,
\:_•!
- - -
-
._
''·
'-
\
-
,,.
·
·.'
._
-- -- ,1 . ,_
-

' ;

Summary of concerns Top two concerns Rationale


• Noise modelling results are questionable 1. Noise model results are inconsistent - for Noise model results cannot be confirmed or
• Certain noise sources have not been example some locations farther from considered reliable
included in the assessment project-related noise sources site were Future noise levels may be underestimated because
• Blasting noise was not evaluated (highly predicted to be higher than locations closer some noise sources do not appear to have been
impulsive noise) to project-related noise sources included in the assessment
• Some additional noise technical documents 2. At the port of Saint John, ship traffic and
were not found during HC's review noise from the marine terminal were not
• Baseline noise levels were for a period of 24 included in the noise evaluation which
hours and may not be representative of could underestimate future noise levels at
longer-term baseline noise levels nearby residences
• Noise levels were predicted only with
mitigation assumed; which may
underestimate noise levels if mitigation is
not as effective as predicted
• Predicted noise levels at several receptor
locations are approaching criteria levels
and with model uncertainties, may exceed
these acceptable levels
• ...
'Water· ·Quality " "' ,,
"' . ,,,:,_
-
; ;,, ++,,
,_
-

'·\•.·,, --_
,-
,,
Summary of concerns Top two concerns Rationale
- . VVUU&58
Last updated: 23 November 2016
Health Canada's Preliminary Review of the Energy East Project

Summary of concerns: what is sufficient/appropriate, gaps, errors


Rationale: why is this relevant to HC review?

1.

Accidents and ;MalfunctlQris/Emergency·Respoose


tlQris/Emergency·Respoose Plan••··
' ' ,, ' :1 .', , ·,

...,. :, ' '{ ..::· .


Summary of concerns Top two concerns Rationale.
1.

- . VVUU&58
Last updated: 23 November 2016
FOR INFORMATION

MEMORANDUM TO THE DIRECTOR GENERAL OF SAFE E1'rvIRONMENTS


DIRECORATE Ai� TO THE DIRECTOR GENERAL OF ENVIRONMENTAL
HEALTH AND CONTROLLED SUBSTAJ.'\'CES

Energy East and Eastern Mainline Projects


Health Canada's Participation in the Environmental Assessment Process

SUMMARY

• Energy East and Eastern Mainline Projects (Energy East) is a 4500 km pipeline proposed
to carry 1.1 million barrels of crude oil per day from Alberta and Saskatchewan to Quebec
and New Brunswick, as well as to a marine terminal in New Brunswick. Given the
breadth of the project, there are over 200 Indigenous groups that have the potential to be
impacted. (See Appendix A- Map of Route)
• The National Energy Board (NEB) is the responsible authority for the project and has
granted Health Canada (HC) "Intervenor" status for participating in the environmental
assessment process. This allows HC to make a formal written submission on its review of
the Proponent's assessment of potential impacts on human health
• Regulatory Operations and Regions Branch (RORE), is the lead Branch for Panel
Hearings, and will be coordinating the review of information and the Environmental
Assessment (EA) program participation in the Panel process. HECSB will be providing the
policy lead and coordination ofHC's technical experts in the Panel process.
• �Iea!tk;· Ew,ironrnentaAd CoHsl:lmer Products BuFea1:1 (IIECSB) is cooFdinatiRg HC's
participatioa iatheP�I process .and the R�p1lat9f)' Operations aad Regioll:S Brangh
(R-ORB) will ae leading di:e review ofinformation aad pa11icipafoi:g it1 tke hearing proeess.l__t ... •·· Comment [NCl]: Roseanne ... given
• HC's written and oral evidence will focus on increased noise along the pipeline route and
discussion today bow would you like to
adjust this
at the terminals, air quality issues at pump stations and the marine terminal, possible
drinking water and country food contamination in the event of a spill/accident along the
pipeline route, �nd possible rights concerns related to First Nation lands and access to
traditional foods/hunting and gath ering areas.i ................. .............................................. .L.··· · Comment (RU]: I think that this point
needs to be clarified - it is not mentioned in
the body ofthe BN. What does this mean
for HECSBIRORB staff/ Would we be
relying completely on external expertise
(e.gfNIHB, INAC)? Will staff require
BACKGROUND training to be able to speak to tbese issues?
The Energy East and Eastern Mainline Pro jects are subject to the requirements of the Canadian
Environmental Ass ssment Act and the National Energy Board Act in a quasi-judicial Panel
Assssment
e

process. The Panel will make a recommendation to the Governor in Council as to whether or not
the Project should proceed and, ifso, under what conditions.

On 30 October 2014, Energy East Pipeline Ltd. (Energy East) submitted an application to the
NEB to construct and operate the Energy East pipeline as well as construct and operate the
Eastern Mainline. Energy East is a subsidiary ofTransCanada Oil Pipelines (Canada) Ltd .
... 1

Page: 18 of/de 40
A2016000958
The project would include:
• Converting an existing natural gas pipeline to an oil transportation pipeline;
• Constructing new pipeline in Alberta, Saskatchewan, Manitoba, Ontario, Quebec and New
Brunswick to link up with the converted pipe; and
• Constructing the associated facilities, pump stations and tank terminals required to move
crude oil from Alberta to Quebec and New Brunswick, including marine facilities that
enable access to other markets by ship.
• The environmental effects of increased marine shipping to and from any proposed marine
terminal will also be included.

Energy East would consist of approximately 279 km of new gas pipeline and related
components and would be constructed in four sections beginning near Markham, Ontario and
finishing near the community of Brouseville, Ontario. About 203 km of the proposed 279 km
pipeline would be installed adjacent to existing pipeline, railway and public highway rights-of­
fied compression facilities at existing
modiied
way. The Project would also include new and modi
compressor stations along the proposed route

Eastern Mainline project was a separate project from Energy East project initially. On 16 June
2016, the National Energy Board announced that, on account of the interconnections between the
· applications, the Energy East and Eastern Mainline projects are more effectively assessed within
a single hearing process, with one record, reviewed by one Panel of Board Members. The Panel
also deemed the applications are complete to proceed to assessment and a public hearing, starting
the 21-month review process.

Health Canada has been granted "Intervenor'' status to participate in the process.. This is the first
time that Health Canada will participate fully in an NEB review. Past pipeline reviews where HC
participated as a "Commenter'' include Northern Gateway Pipeline and Trans Mountain
Expansion project. (See Appendix C - Definitions)

The Panel must submit a report to the Minister of Natural Resources recommending whether or
not the projects should proceed. This report is due no later than 16 March 2018. (See Appendix
C.:... Project Timelines)

The Major Projects Management Office is providing a whole of government coordination


function for this project. HC (HECSB and RORB) participates in these bi-weekly calls and has
established an internal working group (HECSB and RORB).

CONSIDERATIONS
Comment [RL3]: This section needs
Indigenou� Cone����-... further clarification

... 2

Page: 19 of/de 40
A2016000958
•Given the breadth of the project, there are over 200 Indigenous groups that have the
potential to be impacted
•access to traditional foods/hunting and gathering areas.

�edi�ublic interest Comment [RL4]: Comment from QC:


We could also mention that there's a strong
opposition from the general public, from
The project has, and continues to receive! high media and public attention on a national scale. many mayors of the Montreal region (whore
lives more than 4 million peoples) and from
Aboriginals First Nations of Quebec
(L'Assemblee des Premieres Nations
Quebec - Labrador • 43 communities).
ROLES and RESPONSIBILITIES

Regulatocy Operations and Regions Branch (RORB), is the lead Branch for PanelHearings, and
will be coordinating the review of information and �e Environmental Assessment (EA) program
participation in the hearing process.HECSB will be providin� the policy lead and coordination
ofHC's technical experts in the hearing process.

Experts fromHealth Products and Foods Branch, First Nations and InuitHealth Branch and
other parts ofHECSB have been engaged in the review of specific technical areas and will
continue to support in the preparation of !Rs, final submission and potentially present at the
hearings

CURRENT STATUS

From August 2016 to December 2016 the Panel is holding Public Sessions in some communities
along the pipeline route to allow Intervenors (primarily public and smaller Intervenors) to make a
short statement and ask high-level questions of the Applicant. At this point, federal intervenors
have indicated they will not present in these sessions, but may attend some of the sessions as an
observer. HC is taking a similar approach and is monitoring the sessions via webcast.

HC is in the early stages of reviewing the Application; considerations inHC' s review will
include increased noise along the pipeline route and at the terminals, air quality issues at pwnp
stations and the marine terminal, possible drinking water and traditionaVcountcy food
contamination in the event of a spill/accident along the pipeline route
health impacts during construction and operations for the following environmental parameters:
air quality, countcy foods, drinking and recreational waters, and noise.

Thus far the main health concerns identified are the lack of a thoroughHumanHealth Risk
Assessment as the report is dismissive of the likelihood of human health impacts. Additionally,
accidents and malfunctions and emergency response plans have not been described in any detail
and thus difficult to assess potential human health risks.

...3

Page: 20 of/de 40
A2016000958
In order to provide a more robust review of the accidents, malfunctions and emergency response
plans for the project, HECSB has engaged the Chemical Emergency Preparedness & Response
Unit (CEPRU) to assist in providing expertise for this component.

Upcoming milestones and deadlines:


• lnfonnation Requests (IR) round 1 due to NEB January 10. 2017
• IR round 2 due March 16, 2017
• Submission of fmal written evidence due April 25, 2017

ROLES and RESPONSIBILITIES

�king tb:e coordina�on lii!ad for HC's pa-Ftiei-pation inth:e Panel process, w�
will be leadirw the reYiev; ofinformation afld participafrae -in the hearin0 process,l ·········· •••• · ··· ·· ··· ..
__________
_comment (NCS]: Rosanne see comment
above.
,.__ __,
Experts from Health PFeducts and Feeds Branch, First Nations and Inuit Ifoalth · "Bra1:1ch aod
ether parts efIIECSB have beefl engaged in the review of specific teclmieal areas afld will
coriti1u1e to support i1-1 the preparation of!Rs, fo�al s1:1bnlission and potentially presCHt a-t the
heariH<>s

1'.'EXT STEPS

HC will prepare IRs and a draft submission over the fall to enable efficient participation in the
review process in 2017.

Contact: Wendy Wilson, A/Environmental Assessment Coordinator


Telephone: 613-954-6792

. 4

Page: 21 of/de 40
A2016000958
Appendix A

Energy East Pipeline Route Map

v
���
NL _,. .. ,.
AB ;:�."'� r::{ ,, ,.,
SK
MB �,:-/
�-:•·\.......\•"
� .
QC

f::J �l�TV I ·-�� . .. '


{i s..i.�tooe. j t ON ... .. . , . §'t' !
:/
� I' i ����' l *·,,_/;-�' (}�
_,:--�
,_,_:(}� • " -' �"•• •�•�I
-�-.NB
�-..NB
�- NB ·,
"'� .
I
,$' .,.
.,, ,l ./ i' ✓ .,_ ·:, ,iv'\....__.......,, �-
_,_ -
i''----;J'_..,_,_#
--1 ��
� �---
-- :fl --...___,btUHO:!AllA't
--- ' ••
'�,✓ �.:«!.
.:«!. ;';��---
.:«!.
••
;';��
;';��-
I .•
---- I
.$' ,;f' -l_
♦ ---,......,.,.� ·.., .;.•;,• �, _J��
t:,'l,_r,..,.."� _ir�.,--: •,.._
1
f------'--------'-------'--
f---
f- -- ---'---
----
-- -'-----
-'------
-----'----
---'-----
--'---- --
---'-
--'--
-'----
---�
- ..,
��...;,,.
' ...;,,.• ,t), -� -- .....::._'11-'r
•,t)
,t), ���t
��
j · .
�,!"'�=I�:,,..,.,
�,!�=I�:,,..,.,
TransCanadaEnergyEastPipellneProject __ --�- -;:��"-"'\
-;:��"-"'\..

L..#,1,
.
\ -,�:�-<:?;
01tocr;.atur&<

--�ln9Pip11i1'111Segmenb 'N.)forbody
-�_J;,

· '::_
�/ td'
":. ·;'\- .. -�.- u:.,,w.-,
F.-<:muo.s
El TankTear.In.al
·: .j.).'tf.�_-<
· ... __ .. · ·,;--j.·
.. :-.,_, �..�
-� / "\
■ Marine Termf� O 100 200 400 km ......... • . •
-;t
,j,
.::
_.,-:.:

Fig. I TransCanada Energy East Pipeline Project Route from Hardist, AB to Saint John, NB.

...5

Page: 22 of/de 40
A2016000958
AppendixB

Definitions

Intervenors - may file written evidence, are expected to participate in the public hearings,
directly receive all documents filed by the company and other intervenors, seek the NEB's leave
to file information requests, comment on evidence and ask questions of all parties involved, and
make a final argument. Intervenors are also subject to cross-examination during public hearings.
HC as an intervenor will be submitting information requests, preparing a final submission,
responding to information requests from other intervenors and providing oral presentation(s).

Commenters only have the right to submit their views (which are not considered evidence since
they are not tested by cross-examination) in writing to the NEB. Commenters are not considered
a Party to the hearing, cannot ask information requests or cross-examine other Parties. and
cannot provide final argument.

... 6

Page: 23 of/de 40
A2016000958
Appendix C

Timelines

Exnected Process Steo Exnected Timing- HCR9le Comoleted


Consolidated Application by
Enernv East Pipeline Ltd. filed
May 16, 2016
n/a ✓
List of Participants issued June 22, 2016 n/a ✓
Completeness determination (of
annlication)
June 16, 2016
n/a ✓
Hearing Order• issued July 20, 2016 n/a ✓
Panel Sessions in communities August- HC may participate as an
along oioeline route December 2016 observer
Written Process for Participants January - May HC will submit written
2017 evidence by Apr l 25,
i

2017
Draft Conditions for Comment Mid 2017 HC will comment on draft
conditions
Final Argument November- HC will present final
December 2017 argument
NEB Report to Governor in March 2018 HC will provide input
Council upon request but does not
expect to have a role

' The hearing order giv� a brief description of the proposed project or application, the list of issues that will be
considered, as well as details on the steps in the hearing process and the schedule for the various steps. Ifthere is an
oral portion, the date, location and time of the oral hearing may be shared if these details are known. It includes
information on how people might participate in the hearing and may contai.n detailed information such as the
deadlines for the various steps in the process, including submitting evidence or letters of comment and asking
questions.

...7

Page: 24 of/de 40
A2016000958
Comments Received from HC Experts - AIR QUALITY

P�oject Title: En:e,f!.Y l=astPry/ecr

Area of Ex ertise: Air


Date Comments Submitted to EAD:
Number of expert hours spent on review:

Initial Review of EA Documents (ESA, Technical Data Report)

All documents saved here:


ESA
Type of Review: L:\EAD\ACTIVE EAs\PIPELINES\AB SK MB ON QC NB NS PR Energy East Pipeline\Application (Proponent's
(ie. Initial review of EA documents; review of proponent's replies to SIR, etc.) EIS)\English\ESA _

Technical Data Reports·


Reports
L:\EAD\ACTIVE EAs\PIPELINES\AB SK MB ON QC NB NS PR Energy East Pipeline\Application (Proponent's
EIS)\English\Supplemental Report No. 1\Appendix Volume 5-Technical Data Report\5A - AB, SK, MB

Comments
Referenc,
[i.e. Project ToR, published paper
Application citation,
or ESA or standard or guideline (URL link
Supplements Volume, Section, acceptable),
I Reoort # Paces Issues noted bv Co ordinator Health Canada Air Qualitv Expert Input oersonal exoeriencel
l

I
!

- 'VVUU&58
Reference
[i.e. Project ToR, published paper
Application citation,
or ESA or standard or guideline (URL link
Supplementa Volume, Section, acceptable),
# I Reoort # Pacies Issues noted by Coordinator Health Canada Air Quality Expert
' Input
Expert oersonal experience1
1 ESA Table 2-11, pp 2- Background: For every province (except Northern Ontario), a full Qualitative descriptions of construction-
25 (Vol 2 Parl A - construction HHRA was not completed and was only considered related emissions are not informative with
Alberta); 2.5.2, pp quantitatively as emissions during construction (kilotonnes per respect to air quality-related impacts.
2-22 (Vol 2 Part year). These air emissions are not presented as µglm3 (except for Modelling should be performed and air
3
B - SK/MB); 2.5.2 l\orthern Ontario) and are not compared to any regulatory. pollutants concentrations in fLg/m should be
pp 2-14 (Vol 2 guidelines. Ambient b13ckground concentrations are also not provided for all relevant proposed Project-
Part C2 - Ont provided because the Proponent states emissions associaied with related COPC emissions. We agree that in
East); 2.3, pp 2- o:instruction are temporary and move along the RoW. general, it is difficult to determine the
20 and Table 2- potential for adverse health effects without
15, pp 2-25 (Vol 2 Questions: comparing exposure concentrations to
Part D - QC); 2.55 1. Do our air quality experts agree that we should ask the regulatory standards. The methodology for
(Vol 4 Part B - proponent to calculate the µg/m3 construction emissions for calculating ground-level concentrations .
NB) each province and compare them to regulatory standards? How based on emissions is the same as is done
can Trans Canada state that there are no adverse effects when for other project phases, and it should be
emissions are not directly comparable to regulatory slandards? provided somewhere.
As well, some substances have no thresholds and may have
acute effects on receptors, therefore if concentrations are
present at sensitive receptors for even a short period of time,
adverse health effecls may occur.
2. Should we ask the proponent to show how they calculated the
µg/m3 concentrations based on AERMOD which outputs
emissions In tonnes/year? (Specific to Northern Ontario) Or is
this not necessary? ..

- . VVUU&58
Reference
[i.e. Project ToR, published paper
Application citation;
or ESA or standard or guideline (URL link
Supplementa Volume, Section, acceptable),
# I Reoort # Pages Issues noted bv Coordinator Health Canada Air Qualitv Expert Input oersonal exoerience]
2 ESA Volume 2: Part A: Background: NOx, SO2, PM10, PM2.5 and CO were considered Air quality Impacts assessments should
Alberta - Section as potential COPCs from construction vehicle and equipment consider aU COPCs that are expected to be
2.1 (pp 2-1) releases. Other potential COPCs such as VOCs, total petroleum emitted as a result of Project-related
hydrocarbons and PAHs associated with diesel exhaust were not emissions or provide a strong rationale as to
included. why a COPC can be excluded from
consideration. Other COPCs emitted from
Question: Should we request that these COPCs be considered? diesel construction equipment (e.g. PAHs)
should therefore be included or a clear,
Proposed comment/information request (IR): strong rationale for their exclusion should be
Potential chemicals of potential concern (COPes) from construction provided; agree with proposed comment.
vehicle and equipment releases include NOx, SO2, PM10, PM2.5
and CO. However, other potential eoPes such as voes, total
petroleuni hydrocarbons and PAHs associated with diesel.exhaust
\Nere not included.
a) Include voes, total petroleum hydrocarbons and PAHs in the
analysis ofconstruction releases or provide a rationale as to
why they were not included.

3 ESA Volume 2: Part A: Proposed Comment/JR: If there are certain and reasonably
Alberta foreseeable physical activities, then a
2.6 (PP 2-23) TransCanada states that there are certain and reasonably cumulative effects assessment should be
foreseeable physical activities but does not provide a cumulative provided for this section of the propo,sed
effects assessment. Provide a cumulative effects assessment for Project.
the Alberta portion of the project.

•. VVUU&58
Reference
[i.e. Project ToR. published paper
Application citation.
or ESA or standard or guideline (URL link
Sup'plementa Volume, :Section, acceptable),
# I Recor!# Paaes Issues noted bv Coordinator Health Canada Air Qualitv Expert Input oersonal exoerience]
4 ESA Volume 3: Part A: Background: The one-hour exposure concentration of H2S and Extreme, rare and transient meteorological
Alberta (Section benzene exceed the human health criteria for baseline and conditions are known lo affect modelled
9.5.3.4 and Table application cases; however, the maximum predicted ground�level concentrations. Elimination of the highest 8
9-10, Page 9-20) concentrations for both the baseline and application case are based modelled concentrations from consideration
on the first highest predicted concentration. The proponent notes in.the assessment is acceptable for this
that typically the highest eight one-hour predicted concentrations in reason.
each single year are disregarded to account for extreme. rare and
transient meteorological conditions according to Alberta guidance
(AESRD 2013). When the ninth-highest predicted ground-level
concentration is considered for both H2S and benzene, the CRs are
< 1.

Question: Do you agree with this methodology as per the Alberta


g1Jidance (AESRD 2013)?

AESRD (Alberta Environment and Sustainable Resource


Development), 2013. Alberta Ambient Air Quality Objectives
(AAAQO). Available online:
calinfollibrar't/5726:ll.df
h/tfl.://environment. gov.ab. clinfollibrar't/5726:

- . VVUU&58
Reference
[i.e. Project ToR, published paper
Application citation,
or ESA or standard or guideline (URL link
Supplementa Volume, Section, acceptable),
# I Reoort # Paaes Issues noted bv Coordinator Health Canada Air Qualitv Exoert lnout oersonal exoeriencel
5 ESA Volume 2: Background: In terms of operation-related emissions from the It is mentioned in at least one location (table
Biophysical headspaces of storage tanks and during tank-filling, the Proponent 2-9) that benzene represents all VOCs;
Effects includes H2S, benzene and mercaptans as potential COPCs. It however, analyses such as the ones
Assessment - appears a lot of other potential COPCs were not included (eg: mentioned ( i.e. provide a list of chemical
Part B: petroleum hydrocarbon fractions, PAHs, sulphur-containing constituents in a typical diluted bitumen and
Saskatchewan compounds and VOCs (not just benzene)). In the case of another then screen the chemicals based on volatility,
and Manitoba - crude oil pipeline (Trans Mountain Pipeline - TMX), the Proponent followed by consideration of a TMX study
Section 2.3 (pp. provided a list of chemical constituents in a typical diluted bitumen looking at the emission flux rates off a
2-18) and then screened the chemicals based on volatility, followed by freshwater holding tank containing the
consideration of a TMX study looking at the emission flux rates off a bitumen; speciation profiles for tank vapours)
freshwater holding tank containing the bitum_en. As well, In the would be more informative and realistic than
Technical Appendix A Alberta Technical Data Report (TDR), they provide speciation the choice of three COPCs to represent
Data Report (found here: profiles for tank vapours for Light Sweet Synthetic (LSS), Heavy VOCs and sulfur-containing compounds
(Alberta) O:\EADIACTIVE Low TAN (HL T), Heavy High TAN (HHT) and Froth Treated (FT) in (mercaptans are sulfur-containing organics).
EAs\PIPELINES\ Appendix A. Given the number of substances Identified in the The Proponent should include all possible
AB SK MB ON tables, it is unclear why only H2S, mercaptans and benzene were airborne COPC emissions from storage tanks
QC NB NS PR qJantitatively evaluated in the dispersion mpdelling. and filling operations in the assessment or
Energy East provide a detailed, strong rationale for their
Pipeline\Applicati Question: Should we request that these COPCs be considered or exclusion.
on (Proponent's ask the proponent to justify why they were not included?
EIS)\English\Supp
le.mental Report Proposed Comment/lR:
No. 1\Appendix In terms of operation-related emissions from headspaces of storage
Volume 5- tanks and during tank-filling, Trans Canada includes H2S, benzene,
Technical Data mercaptans as potential COPCs.
Report\SA -_AB, a) Include petroleum hydrocarbon fractions, PAHs, sulphur-
SK, MB\ containing compounds and other VOCs or explain why they
EEP TOR AB Al· were not assessed.
R Dec2014.odfl

- . VVUU&58
Reference
[i.e. Project ToR, published paper
Application citation,
or ESA or standard or guideline (URL link
Supplemenfa Volume, Section, acceptable),
# I Reoort # Paaes Issues noted bv Coordinator Health Canada Air Qualltv Exoert lnout oersona,I exoeriencel
6 ESA Volume 4: Part B: Background: With regards to marine shipping, COPCs were listed Some discussion of the relative contributions
New Brunswick - for construction and operation of the tank terminal and loading of of 'at berth' and "in transit" marine emissions
Section 2.1 (pp. berthing vessels. Emissions of CACs from marine vessels were of all COPCs that cause degradation to· air
2-1). Section estimated in tonnes/year (S0 2, NOx, PM, PM10 , PM2.5 , CO, quality as a result of the proposed Project
2.5.5 (pp, 2-20) benzene) and for tanker vessels and tug boats (Table 2-12). The should be undertaken or a clear, strong
and Section 2.5.6 proponent did not include offshore emissions because they are at a rationale to Justify the exclusion of types of
(pp. 2-23) greater distance from receptors and will be ultimately less than • emissions( e.g. "in transit" emissions) or
onshore emissions and therefore a negligible effect is expected. certain COPCs (other marine diesel
emissions) should be provided.
Question:
a) Should there also be an evaluation of other voes, All receptors which may be affected by
petroleum hydrocarbons (TPH) and/or PAHs which may be marine shippi_ng emissions, including use of
associated with marine shipping? the water by Aboriginals and others, should
b) Should combustion releases during marine vessel transit be be considered or a strong, clear rationale for
considered? Or do our experts accept the proponent's their exclusion should be provided.
rationale that emissions while at berth are considered the
worst case for emission levels and are therefore the only
scenario considered?
c) What about Aboriginal people using the waters?·

7 ESA Volume 4: Part B: Background: The proponent currently considers combustion A discussion of the relative contributions of
New Brunswick - releases from marine ves�els. combustion versus fugitive marine emissions
Section 2.5.6 (pp should be undertaken as part of a rationale
2-21) Question: Should there be consideration for fugitive releases from for their exclusion from further consideration.
tanker holds or Is this_ fairly minor in comparison to combustion
releases and therefore not needed?

- . VVUU&58
Reference
[i.e. Project ToR, published paper
Application citation,
or ESA or standard or guideline (URL link
Supplementa Volume, Section, . acceptable),
# I Report# Paaes Issues noted by Coordinator Health Canada Air Quality Expert Input Personal exoerience]
8 ESA Volume 4, Part A Background; Several regulatory criteria differ between the two The out-dated Canadian NMQOs are being
- Quebec, tables (for QC and NB), in particular for SO2, the Quebec 1:hour replaced for SO2 and NO2 and will likely
3
.3,
Section 2.1.3, slandard is 900 ug/m is used in Quebec, but 450 ug/m3 is used for resemble the US NMQS. Until the CMOS
Table 2-4 (pp. 2- New Brunswick. The Quebec 24-hour standard is 288 ug/m3 for NO2 and SO2 are established it Is
5) whereas it appears the 24 hour standard for New Brunswick is 150 recommended that the US EPA NAAQS for
ug/m3. In Table 2-2 (NB), there are also two 1-hour criteria NO2 and SO2 be used for comparison with
Volume 4, Part B: presented for SO2, although ii is assumed that the second value Project-related airborne concentrations of
New Brunswick, actually represents the 24-hour guideline value and is incorrectly these two COPCs. The proposed comment
Section 2.1.5, listed. But even with these discrepancies, the SO2 values are not in has been edited in red.
Table 2-2 (pp. 2- agreement with what HC supports throughout the documents (1-
3
4) hour NAAQS of 196 ug/m ).

Proposed Comment/lR:
The Government of Canada is in the process of esiablisliing
Canadian Ambient Air Quality Standards (CAAQS), which will
replace the outdated National Air Quality Objectives (NMQO). It is
expected that the CAAQS will be substantially more
conservativesmalleF than the NMQO based on new scientific
knowledge about health effects. In the interim, Health Canada
supports the use of the US EPA 1-hour NMQS for NO2 (188
3
-�Im') and SO2 (196 ug/m ) because it is based on a more current
µµ�Im')
database similar to that being used in the CMOS process. Revise
the ESA to use the US EPA 1-hour NMQS for NO2 (188 µg/m')
and S02 (196 ug/m3).

i
I
f
- . VVUU&58
Reference
[i.e. Project ToR, publisl1ed paper
Application citation,
or ESA or standard or guideline (URL link
Supplementa Volume, Section, acceptable),
# I Renert# Pages Issues noted bv Coordinator Health Canada Air Qualitv Exoert Input oersonal exoeriencel
ESA Volume 2: Part A Proposed Comment/lR: Not sure about this comment. Duration
- AB, Section With respect to defining duration for the residual effects seems to be classified appropriately as short-
2.5.1, Table 2-10 characterization criteria, short-term is defined as "effect is term for construction emissions ( < 2 yrs) and
(pp, 2-24) measureab/e for less than 1 month" and medium-term is defined as long-term for operation emissions (entire
"effect is measureable for greater than 1 month but less than 2 operations phase). The duration of the air
Volume 2: Part B years''. Health Canada suggests that these characterization criteria quality impacts has nothing to do with the
- SK/MB, Section ·should .be substance specific, as some substances are acute acute or chronic nature of the health effects
2.5.1, Table 2-11 respiratory irritants and any exceedance may result in adverse of COPCs, only with how Jong the air quality
(pp. 2-21) health effects. effects as a result of the Project will be ·
measurable. We also note that some
Volume 2: Part substances can have both acute and chronic
C2: Ontario East, effects.
Section 2.5.1,
Table 2-7 (pp. 2-
12)

Volume 2: Part
C1: Northern
Ontario, Section
2.5.1, Table 2-13
(pp 2-28)

Volume 4: Part B
- NB, Section
2.5.4, Table 2-8,
Inn. 2-19}

- . V VUU
& 58
Reference
[i.e. Project ToR, published paper
Application citation,
or ESA or standard or guideline· (URL link
Supplementa Volume, Section, acceptable),
# I Report# Paoes Issues noted bv Coordinator Health Canada Air Qualltv Excert In cut nersonal experience]
10 ESA Volume 2 Part A - Proposed Comment/lR: Agree with proposed comment.
Alberta: Section Little information is provided on the characteristics and locations of
2.1.3.4 (pp 2 -5) sensitive receptors and Aboriginal groups within the LSA.

Volume 3 Part A: a} Health Canada suggests that descriptions/characterization


Alberta: Section of potential human receptors (i.e. Aboriginal reserves, local
9.3.1 (pp9-12} residents, schools, hospitals, recreational users, country
foods collecting areas, etc.} and distance of receptors to the
Volume 2 Part B - Project site as well as a map showing the location of human
Saskatchewan receptors versus the estimated COPC concentrations is
and Manitoba: provided.

I
Section 2 .1.3.4
(pp 2-6)
b) Provide clarification for the NB assessment where Volume
3, Part E, Section9 was referenced but does not exist in
l
the ESA.
Volume 3 Part C

j-
- Northern
Ontario: Section
3.5.3.1 (pp9-26)

Volume 4 Part B:
New Brunswick:
Section 2.2.5.1
/oo 2-6)
11 ESA Volume 3: Part B Proposed Comment/lR: Agree with proposed comment.
- Saskatchewan 38 locations have been identified as receptors of concern, including
and Manitoba, people living/working/visiting in the area and people of all ages.
Section9.5.3.1 Clarify If these receptors include Aboriginal groups.
(pp9-12)

- . V VUU
&58
Reference
(i.e. Project ToR, published paper
Application citation,
or ESA or standard or guideline (URL link
Supplementa Volume, Section, acceptable},
# I Reoort # · Paoes Issues noted bv Coordinator Health Canada Air Quality Expert Input oersonal exoerienceJ
12 All General Air- Proposed Comment/lR: Consideration of the effects of increased
documents Quality Question In the absence of quantitative analysis, the EIS should include a precursor emissions from the proposed
discussion of the NOxNOC balance in the area and what the Project on secondary air pollutants (e.g.
expected direction of ozone formation would be as a result of ozone, secondary PM2.5) should be
changes in NOx levels and other precursors, in order to justify its undertaken. Agree with the proposed
exclusion from assessment. comment, although the two paragraphs are
redundant.·
Health Canada is of the opinion that the Air Quality Study section
should include a discussion of NOxNOC balance in the area and
what the expected direction of 03 formation would be as a result of
I
I
changes of NOx and other precursors.

13 All General Air Background: The proponent did not look at various lifestyle Comparison of the highest expected

II
documents Quality Question impacts for inhalation exposure (e.g. Aboriginals,' u'rban dwellers, exposure concentrations to guideline levels is
non -urban dwellers and area users}. There is also no consideration part of the standard approach in
or physical characteristics of the people potentially at _risk and Environmental Assessments. Lifestyle and
differing inhalation rates (m3/day} (i.e. infants, toddlers, child, teen, physical characteristics do not play Into this.
adult) were not given. The proponent has not completed the Some guidelines are specifically designed for
TEK/TLU (traditional knowledge) studies and therefore uses the sensitive subpopulations (e.g. S0 2 and
maximum ground level concentrations for the HHRA which they feel asthmatics}, while others are set for effects
would "overstate" the risk to sensitive receptor locations. without a threshold at the population level,
though recognizing the existence of sensitive
Question: Is this a potential gap? Or is assuming the highest subpopulations (e.g. PM 2. 5, N0 2, ozone}. For
exposure for all receptors an appropriate approach? such pollutants, where a continuum of health

l
effects exists throughout a population, a I
health burd·en analysis would be required to
more adequately address the health impacts
of exposure; however this is generally not

I
part of the current Environmental
Assessment paradigm.

f
I
- . VVUU&58
Reference
[i.e. Project ToR, published paper
Application citation,
or ESA or standard or guideline (URL link
Supplementa Volume, Section, acceptable),
# I Report# Pages Issues noted bv Coordinator Health Canada Air Qualitv Exoert lnout personal experience]
14 ESA Volume 2: Proposed Comment/lR: All Project-related emissions should be
Biophysical Regarding construction emissions and greenhouse gas emissions considered or a clear, strong rationale for
Effects from the gas turbine generators al the eight pump stations, Health their exclusion should be provided.
Assessment - Canada advises that a discussion about other potential COPCs
Part C - Northern such as voes, total petroleum hydrocarbons (TPH) and PAHs
Ontario, Section which may be associated with diesel exhaust be provided.
2.1 (pp 2-1)

15 ESA Volume 2: Part C Proposed Comment/lR: Agree with proposed comment.


- Northern Ambient concentrations of N0 2, CO and PM25 are measured on a
· Ontario, Section continuous basis at a variety of monitoring stations in the NAPS
2.2.2.2 (pp 2-23) network. However, no discussion about background concentrations .
of S0 2 was provided. Specify what baseline concentrations were
used in deriving the predicted future concentration in the "baseline +
project" scenario.

16 ESA Volume 2: Part C Background: For the maximum predicted ground level All emissions which occur as a result of
- Northern concentrations (project case- which includes gas turbine generators proposed Project-related activities should be
Ontario, Section at 8 pump stations), N02, CO, PM2.5 and PM1 o were evaluated. considered or a clear, strong rationale for
2.5.3.4 Project their exclusion should be provided; agree
Case Results, Question: Should S0 2, VOCs, PAHs be evaluated as well given with proposed comment.
(Table 2-16) (pp that these generato(s are burning diesel fuel?
2-34) (Is this a repeat of comment 14 on a different

II
!
Proposed Comment/lR: section of the document?)
N02, co· , PM2. 5 and PM,o were evaluated for the maximum
predicted ground level conceritrations for the project case.
However, it is unclear why S02 , VOCs and PAHs were not
evaluated given that the project case includes gas turbine
generators at eight pump stations which burn diesel fuel. Evaluate
S02 , VOCs and PAHs in the project case or provide a justification
for their exclusion.

17 ESA Volume 3: ESA - Question: S02 is an important criteria air contaminant,

I
Part C - Northern ·Do our air quality experts feel there is an issue with not evaluating and all emissions which occur as a result of
Ontario, Section S02 quantitatively? It is commonly included in other EAs. proposed Project-related activities should be
9.5.3.1 (pp 9-26) considered or a clear, strong rationale for
their exclusion should be provided.

- . VVUU&58
Reference
[i.e. Project ToR, published paper
Application citation,
or ESA or standard or guideline (URL link
Supplementa Volume, Section, acceptable),
# I Reoort # Paaes Issues noted bv Coordinator Health Canada Air Qualitv Exoert In out oersonal exoeriencel
18 ESA Volume 2: Part C Proposed Comment/lR: Agree with pr.oposed comment.
- Northern Discussion provided under the Residual Effects Characterization
Ontario: Section Criteria section is inconsistent for different provinces. A detailed
2.5.1 (pp 2-27) discussion is only provided for ON, but not for AB, QC and NB.
Health Canada suggests providing a discussion regarding the
residual effects characterization criteria based on the scenario
where general mitigation has been implemented be included for all
provinces.

19 ESA All sections Proposed Comment/lR: Agree with proposed comment.


The ESA does not acknowledge that PM10 , PM2 .5 and NOx �re
considered non-threshold substances and population health effects
can occur at any level of exposure. (Environment Canada and
Health Canada 2012). There is an increased health risk to very fine
particles, particularly PM2.5• Revise the ESA to acknowledge that
there is no threshold below where there is no adverse health effect
for PM10, PM2.5 and NOx.

20 ESA Volume 2: Part A Proposed Comment/lR: Agree with proposed comment.


- Alberta and Part The regulatory criteria values for H2S are not consistent in the ESA.
B - SK/MB - Table In Table 2-1 (pp 2-3), the 24-hour and annual averaging periods are
2-1, (pp 2-3) different than in the Human Health section shown in Table 9-8.
Explain the discrepancy In values used between the Atmospheric
Compared to Environment an.d Human Health sections of the ESA.
Volume 3: Part A
- Alberta and
Volume 3: Part B
- SK/MB, Table
9-8 (pp 9-18)

- . VVUU&58
Reference
[i.e. Project ToR, published paper
Application citation,
or ESA or standard or guideline (URL link
Supplementa Volume, Section, . acceptable),
# I Reoort # Paaes Issues noted bv Coordinator Health Canada Air Qualitv Exoert lnout oersonal exoeriencel
21 ESA Volume 2 (AB, Proposed Comment/lR: Agree with proposed comment.
SK/MB, N ON, E The ESA lists measurable parameters for changes in air quality. It is
ON, QC, NB) unclear what is meant by the phrase "There are no key indicators
Section 2.3 identified for these VCs (valued componen/)"Clarify the meaning of
these statements.
Volume 4: Marine
Terminals (QC,
NB) Section 2.3

22 ESA Volume 4: Part B Question: Annual emission rates for VCUs are provided In Table 2- Vapor combustion units are apparently an
-NB, Section 13 (tonnes/year) for SO2, NOx, PM, PM10, PM2.5, CO, benzene improvement in technology over open flaring.
2.5.6 (pp. 2-23) a�d consider 3 stacks. Do our experts feel there are any COPCs However, we cannot offer insight as to
a·e mi�slng from emissions from VCUs (3 stacks)? whether these COPCs adequately capture
the important emissions from VCUs.

23 ESA Volume 6 Section Background: "Due to the expected small scale of spills associated A 1-in-200 risk of a large spill is not low, and
6.4.1.1 with construction, any vapour plume that results from a spill would it is recommended that a worst-case scenario
likely dissipate in hours and no adverse long-term effects would be of a large spill be included as part of the
expected to human health or the environment." assessment.

Question: Small nature of spill, is this a correct assessment?·


Should not they take into account large spills (of 10,000 bbl or more
trat occur 0.5% of time?).

24 ESA Volume 3: Part A Proposed Comment/lR: Agree with proposed comment.


- AB, Section 9 Tnere is no uncertainty and confidence section. Provide a summary
of the major assumptions applied in the human health risk
Volume 3:Part B - assessment and the associated uncertainties,
SK/MB, Section 9

Volume 3: Part
C1 - Northern
ON, Section 2

- . VVUU&58
Reference
[i.e. Project ToR, published.paper
Application citation,
or ESA or standard or guideline (URL link
Supplementa Volume, Section, acceptable),
# I Reoort # Paaes. Issues noted bv Coordinator Health Canada Air Qualitv Exoert lnout nersonal experience]
25 ES.A Volume 2 Part Proposed Commenl/lR: The construction schedule Indicates that the
C1: Table 2-3, pp The ESA notes the new CAAQS that will replace the outdated proposed Project will be finished by the end
2-4 NAAQS in 2020 for PM 2.5 as a footnote but includes the outdated of 04 of 2018 (i.e. by Q1 2019). Only 12
NAAQS as applicable regulatory criteria. Since the Energy East months of the operation of the proposed
pipeline will be operation past the year 2020 ii is suggested that the Project, then, will occur under the present air
new CAAQS 2020 value for PM 2 .5 la-�e applied as applicable quality standard (if there are no construction
regulatory criteria. delays). It might be more realistic, then, to
consider the CMOS as applicable criteria for
the entire operational phase of the proposed
Project.

- . V VUU
&58
Reference
[i.e. Project ToR, published paper
Application citation,
or ESA or standard or guideline (URL link
Supplementa Volume, Section, acceptable),
# I Reoort # Paaes Issues noted by Coordinator Health Canada Air Qualitv Exoert lnout oersonal exoeriencel
26 ESA Volume 4A: Table Additional comment N O2 levels as a result of the proposed
2-21, p. 2-31; Project are predicted to increase substantially
above baseline for all three timescales at the
Volume 4A: Table New Brunswick marine terminal, while
2-21, p. 2-31; 1- and 24-hour NO2 concentrations are
predicted to increase dramatically as a result
Volume 4B: Table of marine shipping activities at this terminal
2-16, p.2-29; . (over 20X in the case of 1-hour NO2). !,·
,� ·, f ;

Volume 2C1: ·-t / ' . .I. �; :


Table 2-16. pp.2- . II: ,,, . ·; ti:,, ,,. ,.·:,.

34 - 2-37; -�·;•;I .. �d: :;! f • : � ,••,J.�i•,e!.-,j .v- . :!' ;1- 1••'.,.·:1


.v-.:!'
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1

Volume 4C; Table ·� ! ' ,, f• ! Ji , · 11 ; • �- l N 02


2.1-9, P.2.1-16; levels are ijlso predicted to increase
significantly above background at all .!
Volume 4C: Table locations in Northern Ontario. , , ,: ,, ,,, ,
3.1-6 : 1' : d1• •t;·. !,.1; - , "·. '.c!-.:;:•. r: :,-'!,':
1!" ' ., ]',' ;,,, . .. , • /:; "; Ji ·;. ·, i'. \,.,' ·i:;: l ', : -� ''�,
l ;, ,. , .. l! .,
,,, , , There is no evidence of a threshold
at the population level for the health effects o'
PM 2.s and NO2 , and the characterization of
potential health impacts should acknowledge
that health risks exist below ambient
standards and objectives. Mitigative efforts
are recommended for these pollutants. The
. principles of keeping clean areas clean and
continuous improvement are operative, and
thus risk analysis and proposed risk
management measures should not be
confined to meeting the standards, but
should also be targeted towards reducing
population exposure at whatever
concentrations are found,

- . VVUU&58
Withheld
Pages 40-67
s.69(l)(e)

Page: 40 of/de 40
A2016000958