OGC Screening and Review Activities
Westcoast Connector Gas Transmission June 11, 2014
Section
Responsible Group
Comments
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4.1 Atmospheric Environment
Air Quality
4.1.2 Appendix 2-A1, Appendix 3A
(EMP)
Acoustic Environment
4.1.3 Appendix 2-A2, Appendix 3A
(EMP)
4.2 Geophysical Environment
Terrain Integrity
4.2.2 Appendix 2-B, Appendix 3A
(EMP)
Soil
4.2.3 Appendix 2-C, Appendix 3A
(EMP)
Environmental Management &
Reclamation/Stewardship
Is the assessment approach used in the application technically unsound?
Is the conclusion on significant impact likely incorrect?
Does the application miss any obvious or likely significant impacts on the matter being assessed?
Is the proposed impact mitigation unsound or unlikely to result in acceptable residual impact?
Does the proposed approach to mitigation conflict with the Commission’s regulatory requirements?
Should be clear that the Commission will issue Air Discharge permits under EMA
Facilities Engineering
Pipeline Engineering
Major Projects
Section 4.2.2 table 4.2-5: Mitigations generally seem adequate, but it is too early / preliminary to assess whether mitigations are appropriate to specific effects, as geotechnical
inspection is still ongoing according to the report, and the mitigations are at a fairly conceptual level.
Section 4.2.2 table 4.2-10: Mitigations generally seem adequate, but at this point there isn’t sufficient information to determine if areas with increased rigour or extra mitigation
might be required.
Appendix 2-B Page 65, section 3.9 point 3: The lowering of the reservoir has had some consideration, but the impacts of this on the pipeline would need to be much better
understood before a crossing design would be approved by the OGC. Appendix 2-B: The report indicates at point 2 of section 1.6 on page 6 that the pipeline route was walked as an
input to the assessment, and on page 7 point 3 that several areas were assessed. The report indicates in the second paragraph of “Toppling Failures” on page 80 that an area could
not be accessed for ground assessment. There are a couple of other spots in the report which indicated an area could not be accessed, but they may refer to the same area. Were
any other areas not able to be assessed on the ground? Or any areas not able to be walked? Specifically which areas? This could potentially pose issues for pipeline construction.
Appendix 2-B Page 94, section 4.4.3.3 paragraph 2 and 3: States that previous experience of similar events impacted values and that the authors are not aware of “debris flows,
avulsion or snow avalanches causing a loss of containment event within British Columbia/Alberta on other large diameter pipelines in environments where avalanches occur.” By
not considering the amount of pipeline (as opposed to just raw numbers), I am not sure that values are being modified in a justifiable manner. I don’t have an issue with the
rationales for vulnerability described in table 2, but if the numbers were modified by raw numbers without per km consideration, they may have been skewed.
Appendix 2-B section 6.2 discussed dredging in some areas to accommodate pipelay ships and/or the pipeline itself. I did not see any discussion on whether the dredging could have
impacts on seabed/offshore geotechnical stability, other than the conclusion that cuts should be evaluated from a geotechnical point of view.
Metal Leaching and Acid Rock
Drainage
4.2.4 Appendix 2-J, Appendix 3A
(EMP)
4.3 Water
Surface Hydrology
4.3.2 Appendix 2-D, Appendix 3A
(EMP)
Stewardship
Appendix 2-B Section 6.4.8.3 noted that fills on glaciomarine material could be unstable. Mitigation for this is not clear.
Reviewed by Allan Chapman. No issues or concerns noted.
Stewardship
A couple of minor errors:
Water Quality and Quantity
Stewardship
On page 4.3-4, the document says Section 8 Water Act approval is required from FLNRO for water use. The approvals are from the OGC, not FLNRO.
On page 4.3-5, the document says that OGC-regulated projects can use either an approval process or a notification process for works in and about a stream, as defined in Part 7 of
the Water Regulation. The OGC does not have access to Part 7 of the Water Regulation, and so all works in and about a stream require an approval under Section 9 of the Water Act.
Sections indicated plus Appendix 2-E Hydrogeology Technical Data Report
4.3.3, Appendix 3A (EMP)
4.4 Marine Ecosystems
Landfall and Nearshore Marine
Habitats and Ecosystems
4.4.4, 4.4.3 Appendix 3B
Offshore Marine Habitats,
Ecosystems and Benthic Areas
4.4.5, 4.4.3, Appendix 2-F,
Appendix 3B
Seabed Sediment and Related
Water Quality
4.4.6, 4.4.3, Appendix 3B
4.5 Fish and Fish Habitat
Fish and Fish Habitat
4.5.2 Appendix 2-K, Appendix 3A
(EMP)
4.6 Terrestrial Vegetation
Entire Chapter, Appendix 2-L,
Appendix 3A (EMP)
4.7 Wetlands
Wetland Function
4.7.2 Appendix 2-M, Appendix 3A
(EMP)
4.8 Wildlife and Wildlife Habitat
Entire Chapter, Appendix 2-N,
Appendix 3A (EMP)
6.1 Human Environment
Current Use of Land and Resources
for Traditional Purposes
6.1.5
7.1 Heritage Resources
Entire Chapter, Appendix 2-R
8.1 Health
Human Health
8.1.2 Appendix 2-P
9.0 Accidents and Malfunctions
All but 9.5, 9.7, 9.8, 9.9
10.0 Effects of the Environment on
the Project
The hydrogeological assessment approach is technically sound and thorough. I have two comments regarding environmental management measures:
 The potential for unregistered water wells within the LSA is not addressed by the mitigation measures.
 The proposed groundwater monitoring program should be clarified. For example, Section 4.3.2 indicates that all groundwater wells within 500 m of the pipeline will be
monitored; Table 2-10, Vol 1, and EMP (Section 3.3) indicate wells within 200 m of the pipeline will be monitored. Sections pertaining to blasting indicate wells within 500 m
of blasting will be monitored. Also more detail is needed regarding the proposed analytical parameters for groundwater quality assessment.
Stewardship
Stewardship
Ancient Murrelet, Cassin’s auklet, long-tailed duck, marbled murrelet, pelagic cormorant, surf scoter – BC Conservation Framework Priority 1 and 2, BC Blue and Red-listed spp.
Check to make sure captured as HPW.
 Temporary burial of salt marshes from sidecastings during pipeline laying and construction.Restoration plans and associated mitigation will be developed for DFO
authorizations?
Potential residual effects of project construction on sensory disturbance and displacement of near shore marine birds are considered to be low magnitude and reversible in the
short-term.
Stewardship
Re-planting of disturbed areas of salt marsh. Fisheries Officer C&E?
Stewardship
Proposed mitigations acceptable. Would like to see DFO’s proposed monitoring requirements and how proponent will adhere.
Stewardship
Stewardship
. Mitigation is acceptable, but clarification required on the following:
 use existing clearings
 disturbance
Proponent must obtain information on any interim reclamation that may have occurred after last disturbance, and not impact this trajectory.
Page 4.7-18: Residual hydrological effects on wetlands (e.g. loss of natural flow) contradicts GEO’s Section 5 of EPMR. Post-construction monitoring proposed is acceptable.
Stewardship
Note: Table 4.8-3 contains recommendations from OGC and FLNRO that I don’t recall being released by the OGC.
Major Projects
In general this section appears to be thorough and complete.
Stakeholder engagement for tenure holders will be conducted as part of the OGC permitting process as per the Consultation and Notification Regulation under OGAA.
It should also be noted that authorizations for ALR lands within NEBC will go through the OGC
Major Projects
Page 4: 1.4 BC Heritage Conservation Act: This is inaccurate “…..except in accordance with a permit issued by the Minister and/or the BC OGC pursuant to Sections 12 and 14.” The
Minister issues all permits under section 14 and the OGC issues all oil and gas permits under section 12 with the exception of NEB. There is no validity to and/or and it is confusing
enough for the client without thinking it is an either or possibility.
Major Projects
Please refer to comments included in the Atmospheric Environment, Aquatic Environment, Vegetation, Wetlands and Accidents or Malfunctions sections for aspects relating to
health regulated by the OGC.
Engineering and Emergency
Response and Safety
No specific comments on this section at this time, but will need to look in more depth at mitigations once detailed design is done.
Section 10.3.2.2 High winds indicate that high winds are not expected to interfere during operations due to burial of the pipeline. Are there any stretches of elevated surface
pipeline and/or aerial crossings? Are there wind patterns in those areas which could impact the line?
Section 10 table 10-7 mitigations generally seem reasonable for pipe uplift, but specific mitigations may need to be reviewed for specific hazards. Statement “very resistant to
seismic motions in the absence of liquefaction or other ground movement”. I am not completely sure that enough work has been done to confirm no ground movement.
The offshore effects seems to consider all of the key issues as potential problems, but there is insufficient information to confirm whether the proposed designs and mitigations are
appropriate to the specific hazards. The report indicates further work will be done in this area.
Section 10.0 Avalanches and snow events appear to consider only buried pipelines. I am not sure it is feasible or correct to assume all stretches of line will be buried. Surface
stretches may be required to mitigate ground instability or for crossings, for example.
Table 10.24 in 10.13.2 mitigations at a general level are appropriate, but we will still need to look at the specific mitigations for particular hazards to confirm.
Table 10.26 in 10.14.2 mitigations at a general level are appropriate, but we will still need to look at the specific mitigations for particular hazards to confirm.
All but 10.11
15.0 Conclusions
Summary of Project Design
Elements
15.1
Pipeline Engineering
Engineering and Major Projects
Section 15.1.1 and table 15.1-1 note above grade onshore pipeline, but some of the analyses in section 10, as discussed previously, assumed minimal to no risk/impact due to line
being buried.
Table 15.1-3, would like further information on the rationale for decisions re. burial vs. surface