LNG Marine Terminal and Multi-Purpose Pier EIA Review

Ground water

Existing conditions

The surface runoff in the vicinity of the proposed Project area drains into the Saint John Harbour. The area of the proposed LNG facilities and pipelines is generally well drained, with some confined areas that are poorly drained. The majority of water supply comes from surface water. Also, the city operates and maintains two production wells and there are also privately owned wells in the area.

Impact analysis

Ground water extracted from project area may be contaminated by petroleum hydrocarbons. Water quality may be reduced as a consequence of high enrichment with silt particles or as a consequence of increased water temperature. The project may also contribute to the disruption of extraction and transmission of potable water. All of the above may occur during the construction and the decommissioning phases. Potential sills of contaminants during operation of the Project are possible.

The main activities that will be undertaken as a part of the project that will affect water quality and quantity are site preparation activities and the production of concrete. Vegetation clearing is also necessary for site preparation. This activity will increase surface runoff thus decreasing infiltration and water recharge. Concrete production will contribute to an increased amount of silt particles in the water. Spills of contaminants and tranches along pipelines are other potential problems. In the areas of shallow ground water flow, pipeline trenches may become preferential passage for water. This will alter groundwater flow pattern and due to this downgradient wells will receive less water.

Determination of significance

As is mentioned in the EIA report, no significant residual effects, including cumulative environmental effects, are expected to result from Project activities. This includes taking into account many proposed mitigations.

Mitigation and follow-up

Monitoring measures of water quality and quantity during Project activities, well driller’s reports, and water chemistry results for wells in the area will be necessary.

Mitigation measures for site preparation activities will be necessary. These will include: erosion and sediment control to reduce surface runoff, preblast well surveys, and remedial action to restore damaged wells. Additionally, wash water from concrete production will be directed to settling basins for appropriate disposal. Low permeability plugs within trenches along pipelines should prevent shallow groundwater from using trenches as preferred pathways. In the case of hazardous material spills, the mitigation measure will be the implementation of an emergency response plan and remedial actions to restore damaged wells and/or provide temporary potable water will be necessary.

Fresh water fish and fish habitats

Existing conditions

There are five streams that were crossed by the proposed pipelines between the LNG storage facility and the Irving Refinery. Also, relocation of the outlet creek from Canaport pond is necessary. The steams that were crossed are the Bean Brook stream, the Beyea Brook stream, Hazen Creek and two unnamed creeks.

Freshwater fish and fish habitats are protected through federal and provincial legislations. Fish habitats are protected throughPolicy of the management of fish habitat; the main goal of which is to achieve no net loss of the productive capacity of the fish habitat from project activity. Another protective act is Watercourse and wetland alteration regulations 90-80 of theClean Water Act.By this act there a permit is needed for any vegetation clearing, soil excavation, construction or any landscaping activity within 30m of a watercourse. Water quality of watercourses is protected under Section 36 of Fisheries act and under New Brunswick’s Clean Water Act.

The fish species that are found in streams within the area of the project are Brook trout, mummichog, nine-spine stickleback and American eel. None of these species is considered rare or endangered.

Impact analysis

As it is stated in the EIA, many construction activities that would be undertaken in the immediate vicinity of the watercourses have the potential to alter fish habitat. This would be due toreduced shading and cover, changes to channels following pipeline installation, and sedimentation of important habitat features such as gravel deposits suitable for spawning.

There are five species of special concern in New Brunswick: inner Bay of Fundy Atlantic salmon, Lake Utopia dwartsmelt, redbreast sunfish, shortnose sturgeon and squat duskysnail. None of these species’ habitats were identified at or within 100 m of proposed pipeline stream crossings.

The main activities of the project that will result in loss of riparian vegetation, reduction of habitat quality and increased fish mortality are site preparation activities, watercourse crossing activities, maintenance and repair activities and removal of pipelines activities. Removal of vegetation during site preparation activities will result in increased bank erosion and reduction of shading which will also cause change in the habitat. Watercourse crossing, maintenance, repair and removal of pipeline activities, will require blockage of the stream during the work period. This will put a lot of stress on the species living in the stream. Hazardous material spills are another problem associated with the project.

Determination of significance

The adverse residual environmental effects on the fresh water fish and fish habitats were predicted not to be significant if all the mitigation measures are performed.

Mitigation and follow-up

Mitigation measures for site preparation activities will include minimizing the removal of shrubs, the development and implementation of a sediment control plan, re-vegetatation of banks with native plants after work is done and relocation of the Canaport stream before starting site preparation. To mitigate the activities involved in water crossing and removal of facilities, it will be necessary to implement a sediment control plan. This will involve conducting activities in the dry period between June and September (Period of least risk to fish) and the restoration of the streambed to pre-construction condition. In order to conduct water crossing activities in the dry season, it is necessary to isolate the work area and salvage all the fish before commencing crossing work. Also, for mitigation of the removal of facilities it was proposed not to remove pipeline within 30 m of the watercourse. During maintenance and repair it will be necessary to minimize vegetation removal within 30 m of fish habitat. As for hazardous material spills, dedicated refuelling areas more than 100 m from fish habitat should be established and spill response procedures should be developed and incorporated.

According to the EIA, all of the necessary permits were to be acquired and all the work was to be performed as established by legislation rules.

Atmospheric Impacts

The major physical and biological section comprises a brief description of the existing environmental condition, both marine and terrestrial, as well as the potential impacts and interactions between the LNG project and the environment that has been identified in the EIA report.

For each section we will explain the significance and the evaluation of each environmental impacts followed by the mitigation and monitoring proposed by the company in order to diminish or eliminate any possible impacts

Air quality

Existing Conditions

The province of New Brunswick is monitoring the air quality in the region of Saint John since 1961. Saint John is considered as an urban area with an important industrial base and consequently significant sources of air pollutants; e.g.: two pulp and paper mill, three thermal generation stations, two oil refinery, plastics processing facilities, printing operation and many other commerce and industries. Due to its downwind location, Saint-John is broadly subjected to long-range transport of air pollutants (LRTAP) from remote sources by the Southwest prevailing winds. The usual vehicle emissions combined with all theses different air contaminants sources result in short and long term challenges for the authorities and the population to cope with the air quality management.

According to the EIA report the Air Quality in Saint John is relatively good despite the high emission levels of air pollutants from a diversified range of sources. The report insists on the fact that for an industrial area, the air quality in Saint John is considered adequate, disregarding the relatively dense residential area in the Census Metropolitan Area.

Environmental Impact Analysis

An extensive study was done to estimate the project-related emission and evaluate the concentration level of the following air contaminants:

• particulate matter (PM), total suspended particulate (TPS) and dust
• particulate matter less than 10 microns (PM10)
• particulate matter less than 2.5 microns (PM2.5)
• sulphur dioxide (SO2)
• nitrogen oxides (NOx)
• carbon monoxide (CO)
• natural gas or methane (CH4)
• carbon dioxide (CO2)

One of the major contributors of air pollutants in the Saint John area is the long-range transport of vehicle exhaust and industrial emissions from the heavily populated in Central Canada and Eastern United States areas blown by the prevailing Southwest winds.

The compounds containing carbon element are called Volatile Organic Compounds (VOCs); they evaporate easily at ambient conditions and they will be largely generated from heavy machinery and equipment operation on the project site.

There is no doubt about the possibility of interactions between the construction activities and Air Quality; where, during the construction phase, heavy equipments (earth movers, excavation, grading, vessels, truck and motor vehicle, etc.) will operate continually which will certainly result in emissions from fuel burning, dust, particulate matter and so on. Nevertheless, significant adverse effects on air quality are not anticipated from increased vehicle traffic emissions during construction, given the volume of traffic and its short duration.

During Construction and commissioning phase of the proposed facility, the potential exist for emission of air contaminants and greenhouse emission. However comparing those emissions with the major source of contaminant for the year 2001 in Saint John Airshed, the emissions generated during operation are quite low.

Concerning the cumulative effect the EIA report took in consideration the background concentration of the air contaminant of interest which includes:

• Emissions from natural sources
• Emissions from nearby source (vehicle traffic, other industry, etc.)
• Emissions of air contaminants from distant sources that are carried into the region via long range transport.

Relatively to the cumulative environmental effects, the EIA report recognized that others projects in operation and/or future activities may provoke negative interactions with the environment. Nevertheless, according to the EIA report, a number of industries are constantly trying to improve their energy dependence and efficiency; therefore it is difficult to quantify and rate their cumulative impact on environment. Given that, they are classify as activities resulting in neutral environmental effects.

Actually there are no federal or provincial restrictions and regulation regarding greenhouse gases emissions; however Irving Oil Limited is trying to comply with the standard of the Kyoto Protocol for his actual infrastructures as well as its developing project.

Beside, according to the EIA report the likelihood of leak or spill of LNG is especially low, due to the strict requirement of operation and to the design of the facility. In addition, accidents, malfunctions , spills and unplanned event could have undeniable impact on the ecosystem (including marine vessel accidents, hazardous materials spills, accumulation of gas in confined area, forest fire , terrorist attacks; however the report indicates that the chances of such events are so small that it should not be considered significant. The report indicates that most can be mitigated through preventative maintenance.

Determination of Significance

The project would significantly affect the Air quality by a greater than 5% increase of the emission rate of the air contaminants of interest.

According to the EIA report the project related emission of air pollutant are quite small comparing to other source in Saint John and that the project will result in an increase in total conventional air contaminant emission of less than 5 % in the region. Moreover the project will take place over a short duration (3year) and it is not expected to exceed the air quality standards for that area. Overall, based on the magnitude, frequency and duration of air emission associated with the project, the potential adverse residual environmental effects, including cumulative effects, and spills scenarios on the atmospheric environment are not rated significant.

Mitigation and Monitoring

Mitigation would include a number of initiatives; below are just few of the numerous established during construction, commissioning and operation phases:

• Use natural gas fired engines
• Use of low sulphur fuel for vehicles
• Use of a baghouse on the concrete silos
• Preserve natural vegetation and buffers zone where it is possible
• Paving of the active portions of the site as soon as practicable
• Minimize activities that generate large quantities of escaping dust during high winds
• Cover truck loads if raw materials which could generate dust
• Application of dust suppressants
• Health & Safety management system
• Emergency Response Plan for Operations
• Follow equipment maintenance schedule
• Erosion control structures (silt fences & coffer dams)

Escaping emission of particulate matter and air contaminant will be controlled and limited during the construction and commissioning phase in order to diminish the impact on the air quality. Volatile emission will be mitigated by the application of dust suppressants (water) during periods of heavy activity and dry periods to ensure that the particulate matter concentration in the air will remain under the standard established.

Since the emissions ensuing from the project are considered as relatively small comparing to other sources of pollution in Saint John, the measurable air pollutants source will be mitigated directly on the project site during operation.

There are actually several ambient air quality monitors operating in Saint John that was lay down by both the Environmental Protection Service of Environment Canada (EPS) and the New Brunswick Department of Environment and Local Government (NBDELG). They are responsible for the creation of a network referred to as the National Air Pollution Surveillance (NAPS). So those infrastructures are in place to ensure the monitoring of the air quality. In addition there will be some natural gas monitors implemented on the project site to detect any leak of LNG, paired to a preventative maintenance and repair program.

Climate quality

Existing Conditions

Saint John region is a modified continental climate, where the mixing of the continental and maritime masses of air (Bay of Fundy and Lurcher marine areas) alleviates the air temperature during both summer and winter. The flow of massive air block from the continent, blending with a large body of cold water such as the Bay of Fundy greatly influence and control the temperature gradient, the air density and the stability of the flow. Consequently these air movements can significantly influence the dispersion of funnel exhaust and air contaminant.

Data describing the climate in the area of proposed project are recorded by one Environment Canada weather station, located at the Saint John Airport. The weather data are considered relatively uniform along the studied area (Bay of Fundy and Mispec Point to shipping lanes). During a year period, the temperature usually varies between 34.4°C and -36.7°C. In the vicinity of the project, the average annual precipitation is approximately 1390.3mm. Moreover the relative humidity of the air in the area is somewhat high, producing frequent fog episode in the area. The average annual wind speeds are not alarmingly elevated comparing to other coastal city; however wind squall become more important for the period of winter.

Environmental Impact Analysis

The project could possibly interact with climate, and of the several physical changes that could arise, the followings are more likely to occur: accentuate variation in temperature; change in precipitation duration, frequency and quantity; wind inconstancy; variation of sea level.

Canadian Environmental Assessment Agency (CEAA 2003) provided guideline to orientate the research and suggest an evaluation of the subsequent aspect associated to the potential effects of the project on climate:

• establish the quantities of greenhouse gas emissions generated by each phase of the proposed project.
• establish the marginal contribution of the proposed project to the provincial and national emissions
• establish relevant jurisdictional policies
• establish the industry profile for greenhouse gas emissions and best practices for projects that are similar
• identify whether the project is a low, medium or high intensity emitter of greenhouse gases

Surprisingly, there is no LNG industry profile existing in Canada since there are just few LNG facilities in our country and even less information on the nature of the greenhouse gases emissions of those facilities.

Furthermore, the greenhouse emissions of the proposed project were compared with an analogous one in Louisiana (Hackberry LNG terminal); the results of the two facilities were quite similar with even lower emission for the Irving proposed project.

The project will be qualified as a Large Final Emitter (emit 8 kilotons CO2 equivalent per year); subsequently mandatory monitoring and reporting to governmental organism will be instigate. The most continuous source of emission is occurring during the submerged combustion vapourizers (SCVs) regassification phase. But comparing to alternative technologies, the well known advantages of the regassification are a more important then the encountered drawbacks (high fuel and thermal efficiency; reduce emission of certain air contaminants; reliable operation during winter, etc.). That makes regassification the best available technology for that purpose, economically and environmentally speaking.

Project related emissions of greenhouse gases are very small (8 kilotons CO2 equivalent per year) comparing to the guidance provided by the Canadian Environmental Assessment Agency (CEAA 2003); and it is one of the major reasons why the report concluded that the project would not contribute considerably neither measurably to climate change. Besides the report recommended mitigation measures and strategies in order to further diminish the project related greenhouse gas emission.

Determination of Significance

Agreeably to the report, even though the emissions of greenhouse gases are a significant and considerable contributor to climate change; the scientific world is not all in agreement about the explicit cause-and-effect relationship between the local emission (provincial and national) to the global climate change. The project will produce relatively low amount of greenhouse gases (35 239 tons/year during construction and commissioning, 386 411 tons/year during operation); which would possibly not result in significant effect on climate.

To resume, the environmental effects on the climate are rated as not significant for all Project activities, except Accidents, Malfunctions, natural catastrophes and Unplanned Events which are rated significant but not likely to happen.

Mitigation and Monitoring

A follow-up program will be put in place to manage greenhouse gas emission and to do the emissions inventory through the National Air Pollution Surveillance Network (NAPS) and NBDELG. As well Irving will continue to participate in the Large Final Emitters Program, and will maintain his research and development to improve his energy efficiency and periodically reevaluate the best available technology on the market.

Sound quality

Existing Conditions

In the Saint John surrounding area the outdoor sound quality is affected by the numerous industries located, for the majority, in the Census Metropolitan Area. Degradation of sound quality is influence by, among others natural and anthropogenic factors, the vehicle traffic (trucks, cars), heavy equipment operation (bulldozers, diesel generators), weather conditions (temperature, humidity, wind) and topographical features such as hills or wooded areas.

Environmental Impact Analysis

Any unnecessary sound that will occur at different frequencies (usually between 20-20000 Hertz which is the audible human range) can fit in the outdoor noise category. In order to assess the estimated disturbance of the project on the sound quality, a baseline noise evaluation took place. The purpose of this experience was to examine the existing and envisaged sound pressure level via a weighted scale also called an equivalent sound level (Leq) and it is measured over a period of time of 1 hour.

Currently in New Brunswick there is no detailed and obligatory noise guideline existing, but in some case the New Brunswick Department of Environment and Local Government (NBDELG) have specified a limit of 10dBA for project related sound emission. Depending of the provinces and the countries, sound baseline varies significantly (Nova Scotia: day-65dBA/night-55dBA) (Ontario: rural-15dBA) (United States: limit -55dBA). With regards to the rural nature if the project area and the USA sound guideline, the EIA report set at 55dBA as the limit that will not consequence in environmental effects on health and safety.

Surprisingly and to illustrate the inconsistency between the EIA report and the reality; during the meeting #25 of the Canaport Community Environmental Liaison Committee (CCELC), mister John Logan, a representative of Irving Oil Limited and Canaport LNG, answered to a inhabitant question’s about the allowable noise level, saying that the permissible level of noise is 65dBA from 7:00 am — 10:00 pm, and 60 dBA from 10:00 pm — 7:00 am for a 1-hour equivalent sound level.

With regards to the land use patterns and the human levels of activity, the EIA report stated that some disturbance of the sound quality is expected. However, consistent with the report, vegetation buffers and structures can greatly diminish the sound propagation in that region. The presence of a natural mature buffer of 30 meters can apparently attenuate beneath 10dBA (Federal Highway Administration 2000).

Determination of Significance

According to the report, the project would significantly create a disturbance and consequently an adverse residual environmental impact at the closest residential area, if the sound pressure level periodically goes beyond 55dBA. And this would be true during any phase of the project and/or when the ambient levels already surpass 55dBA and that the project noise result in an increase of more than 5dBA.

Even though the impact on the noise quality was showed by the report, they consider that the residual environmental effects on the sound quality can be rated as not significant for all Project activities assessed since extensive mitigation and monitoring programs will be instigate. As well, the cumulative environmental effects of this project combined to others in the region are rated not significant.

Mitigation and Monitoring

Alleviation would include a number of actions, program and sound baseline; below are just few set up during construction, commissioning and operation phases:

• Noise control (e.g. mufflers)
• Scheduling/planning of noisy activities (e.g. blasting) during workday/daylight hours where possible
• Use of strobe lights instead of backup beepers on heavy equipment for nighttime operation
• Minimize vehicle traffic (e.g. number and frequency of deliveries)
• Minimize spills/releases at source
• Emergency Response Plan for Operation

In order to address any resident complaints during the construction activities and the pile driving, a noise monitoring program was suggested. And in the case of exceeding sound level, Irving would directly consult NBDELG and implement a mitigation plan. Irving would also work preventively with land owners in the area to discuss of a possible action plan if a noise nuisance is identified. Moreover, before starting the construction phase, a 24-hour baseline noise monitoring was performed at Mispec Beach.

Terrestrial and Wetlands Environments

Existing Conditions

The only wetland, in the proximity of the project, considered by the report important is the Red Head Marsh. This wetland was designated Environmentally Significant Area (ESA) by the New Brunswick Department of Environment and Local Government (NBDELG) since it is an highly productive freshwater marsh creating a flourishing biodiversity for several variety of breeding birds and reptiles. This fragile zone was avoided and not include in the planning of the site to avoid any adverse environmental effects. Irving report stated that only wetland smaller than one hectare could be affected by the project. In these wetland areas, no endangered plant species were identified by the rare plant surveys carried out in 2002 and 2003. The second Environmentally Significant Area (ESA) protected in the area is Courtenay Bay where a high concentration of shorebirds (gulls and ducks) is foraging during winter in the area.

The six following streams will have to be crossed and disturbed by the LNG pipeline: Bean Brook, Beyea Brook, Hazen Creek and three unnamed tributaries to Hazen Creek. Of the fish species found in those river, the Brook trout, American eel, mummichog and nine-spine stickleback were of the most abundant. But none of them were found rare or endangered.

Due to the intensive industrialization in the region (including Irving’s industries), major portion of matured forest were clear cut. Irving decided to initiate a massive forest management in order to replant different species of trees and, with the help of extensive pesticide treatment, to improve the biodiversity of the forest.

In accordance with the report, the large proportion of young forest supply a good habitat for the fauna using scrub or edge and wetlands for reproducing (especially seabirds). Over the area, 13 rare birds’ species, 1 species of wood turtle and one herpetile species were found and recorded by the Atlantic Canadian Conservation Data Center (ACCDC). Of the bird species identified none were recognized as endangered, however wood turtle and herpetile species were considered of special conservation concern in Saint John region.

Environmental Impact Analysis

The EIA report stated that the lands cleared for the project site are assumed to be a permanent habitat loss; however the land on which the pipeline between the LNG tank and the Irving refinery are considered as a change in habitat type (from forest to open field).

Some of the construction steps like clearing and grubbing may have impacts on the terrestrial component and could cause habitat fragmentation. Pipeline installation, operation and maintenance could possibly diminish land and habitat quality and even cause avoidance of the area by wildlife.

Consistent with the report, by minimizing clear cut of vegetation cover, the decommissioning impacts on the land could be constrained and most of the area affected would be shrub and edge habitat.

Two wetlands could not be avoided by the pipeline route; the 2.4 ha Canaport pond wetland and 0.5 ha fen along the pipeline (1.2 km north of Red Head Road). Inconsistently, Irving report affirmed that no wetland greater than 1 ha would be affected. Red Head Marsh, the only wetland of importance in term of size in the vicinity of the project, was protected by a restriction of any activities within 30 meter of the marsh. Without mitigation measure and protective construction techniques, adverse environmental effect on wetland could occur during trenched crossing and excavation. In addition, by limiting the stress on the habitat (ground, wetland and vegetation) and establishing a 30 meter buffer zone, the potential negative effects on wood turtle would be attenuate.

During the whole process of the project it is likely to observe an increase in the traffic vehicle on Red Head Road, a highway which goes through really fragile habitat. It could result in avoidance by wildlife of the region and/or an augmentation of death among animals crossing road. Increased vehicle traffic on Red Head Road in all phases could result in the avoidance of the usual habitat or restrict wildlife from crossing the road. But the report claimed that the habitat along the Red Head Road is not critical and that the wildlife is already acclimate to traffic noise.

Mispec Point is one of the sections mostly affected, in terms of territory loss, by the existing and proposed activities (20 % loss of land base). The LNG storage tanks would remove around15 hectares (150 000 m2) of shrub and forested habitats. Routing the pipeline and locating the facilities beside existing areas of disturbance could help the task of mitigation and minimized the potential cumulative effects of habitat change.

Determination of Significance

Along with the report, a significant adverse residual environmental effect on the Terrestrial and Wetland Environments is characterized as one that would alters terrestrial and/or wetland habitat in such way to cause:

• A change or decline in the ecological function of that habitat; or
• A change or decline in the distribution or abundance of a rare plant or animal population that is dependent on that habitat, such that natural recruitment would not restore the community to its original level within one generation.

Given that no plant species of special conservation concern was found, the effect on rare plants is concluded not significant. The consequence on habitats and wildlife are not judged significant since there will be appropriate mitigation measure to ensure an acceptable remediation of the residual and cumulative impact generated by the project.

Industrial and commercial activities in Saint John indubitably have an effect on terrestrial and wetland habitats within the vicinity of the Project. Although according to the EIA report, the Irving project will not do a big difference and the impacts associated with it are not considerable. With planned prevention and mitigation, the cumulative environmental effects of the Project on Terrestrial and Wetland are expected to be not significant.

Mitigation and Monitoring

An Environmental Protection Plan (EPP) was developed before the beginning of construction and then submitted for review to suitable controlling agencies (NBDELG, CCELC, Environment Canada, and CEAA). The EPP summarized all environmental protection measures to be employed during construction and operation of the Project in order to prevent and/or minimize concerns and affects.

All construction activities would require inspection and monitoring to ensure that erosion control structures were properly installed, maintained and removed. During the construction period, an environmental inspector should be present to attest that the EPP planned mitigation measures are carried out and that the conditions of the Watercourse and Wetlands Alterations Permits are met. Other inspections will take place to verify that no wildlife is buried or trapped by the operations and equipments.

A follow-up plan of the two wetlands will be implemented, monitoring until 3 years after the Orimulsion pipeline construction, and the 5 years following the natural gas pipeline construction. Additionally, for the Canaport pond, another follow-up program will be instigate; also three and five years following construction of the new outlet.

The follow-up program will guaranty that any loss of wetland function will be reported to NBDELG and Environment Canada for discussion, evaluation of the suitable solutions, and possible remedial action.