October 23, 2015 Ottawa, Ontario K1A 0H3 · 5. Invasive Plants A comment directed at the southern...

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October 23, 2015 Canadian Environmental Assessment Agency Compliance Promotion and Enforcement Unit 160 Elgin Street Ottawa, Ontario K1A 0H3 Attention: Mr. Patrick Lemay Dear Mr. Lemay: Re: Written Warning Canadian Environmental Assessment Act, 2012, Agency File No.: 004387 – Site C Clean Energy Project Thank you for your letter, dated October 9, 2015, regarding the CEA Agency’s inspection of the Site C Clean Energy Project (the Project) on September 22-23, 2015. BC Hydro appreciates the opportunity to review and respond to the compliance issues that you have described, and offers the following summary of actions that have been implemented since the September 22-23 inspection. BC Hydro recognizes that the environmental issues raised require effective management programs to be in place to ensure that construction activities are conducted in compliance with the conditions of the Project’s Decision Statement and Environmental Assessment Certificate, as well as the conditions of permits and authorizations. BC Hydro is currently reviewing all management programs, including, for example, erosion and sediment control management and waste and wildlife management, as well as the roles of QEPs. BC Hydro would be happy to share these programs in draft with the CEA Agency for comment. Condition 2: Accidents and Malfunctions Agency Requirement: Condition 2 of the Decision Statement requires that BC Hydro develop, submit and implement a plan to prevent accidents and malfunctions and to outline procedures in the case of occurrence of an accident or malfunction. On June 5, 2015, BC Hydro submitted an Accidents and Malfunctions Plan to the Agency in accordance with this condition. Included in the plan are the requirements that all vehicles be equipped with an appropriately sized spill kit, and that personnel operating the vehicles have applicable training. Agency Observation: Four Duz Cho trucks, working on the south bank of the Project, did not have a spill kit in or with their vehicles. BC Hydro Response: A Field Advice Memo has been sent to contractors regarding spill kits. Vehicle inspections are taking place regularly. Contractors’ Environmental Monitors will be required to complete spill kit inspection forms to monitor presence and adequacy of the spill kits on-site. A draft inspection form is provided in Appendix D. These forms will be finalized and implemented by October 31, 2015. Attachments: Appendix B: Field Advice Memos regarding spill kit requirements. Appendix D: Inspection Form for Spill Kits

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Condition 8: Fish and Fish Habitat Agency Requirement: Condition 8 of the Decision Statement requires that BC Hydro develop, submit and implement a fish and fish habitat management plan. On June 1, 2015, BC Hydro submitted a Fisheries and Aquatic Habitat Management Plan to the Agency in accordance with this condition. The Plan refers to the Construction Environmental Management Plan (CEMP), which requires the implementation of erosion and sediment control measures to mitigate potential effects on fish and fish habitat during construction. The erosion and sediment control measures include, among other mitigation measures, maintaining ground cover or using materials such as geotextiles/erosion control cloth to stabilize slopes. Agency Observation: A silt fence was improperly installed across the water course that was dry at the time of the inspection near the North Bank Access road (L3 ravine location). Also observed was a lack of sediment and erosion control measures to stabilize slopes and control site runoff at the L3 Ravine. The Agency determined that the improperly installed silt fence and lack of sediment and erosion control measures may result in effects on fish and fish habitat in the watercourse near River Road. BC Hydro Response: Since the inspection on September 22-23, BC Hydro has taken the following actions:

The improperly installed silt fence in L3 ravine has been removed

In L3 ravine o Check dams have been installed o A settling pond at the outlet of the proprietary pipe has been installed. The

installation will be supplemented with other settlement ponds. BC Hydro has issued a Field Advice Memo to the contractor to adopt a strategy for installing erosion and sediment control measures prior to the commencement of the “bad weather season”

o An erosion and sediment control plan has been prepared by the contractor’s QEP. The contractor is implementing the plan.

Attachments:

Appendix A - photograph of the ravine where the silt fence was removed and a check dam installed

Appendix B - Field Advice Memo to Morgan Construction, dated October 1, 2015

(note: a response from Morgan will be provided by October 31, 2015)

Appendix C - Erosion and Sediment Control Plan prepared by contractor’s QEP Please don’t hesitate to contact me if you have any additional comments or questions on these plans. Sincerely,

Bettina Sander Regulatory Manager Site C Clean Energy Project

<Original signed by>

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Cc: Chris Parks, Senior Compliance and Enforcement Officer, EAO Autumn Cousins, Manager of Compliance, EAO Monica Perry, Executive Project Director, EAO Magali Francoeur, Compliance Program Manager, CEAA Brian Naito, Senior Habitat Biologist, DFO Jennifer Tennant, Senior Environmental Assessment Officer, Environment Canada Tanya Martin, Aboriginal Relations Advisor, Transport Canada James Smith, Natural Resource Officer, MFLNRO Jason Yarmish, IEM, Environmental Dynamics Diane McSherry, Vice President and Project Director, BC Hydro Darren Kahl, Project Manager and Director of Operations, BC Hydro Al Strang, Environmental Manager, BC Hydro Danielle Melchoir, Environment and Regulatory, BC Hydro Karen von Muehldorfer, Senior Environmental Coordinator, BC Hydro

Appendix A – Photographs

Photograph of L3 ravine

o Improperly installed silt fence in ravine has been removed

o Check dam has been installed

Closed bin on the south bank at Duz Cho’s construction office

o In accordance with Human-Wildlife Conflict Management Requirements

o October 20, 2015

Appendix B – Field Advice Memos

Field Advice Memo from BC Hydro to Morgan Construction, dated October 1, 2015

o Erosion and Sediment Control in L3 Ravine

o Vehicle Spill Kits

o Wildlife Attractants

o Outhouses

Field Advice Memo from BC Hydro to ATCO-Two Rivers Lodging Group, dated October

1, 2015

o Erosion and Sediment Control

o Vehicle Spill Kits


o Outhouses

o Invasive Plants

Field Advice Memo from ATCO-Two Rivers Lodging Group to BC Hydro, dated October

7, 2015


o Outhouses

o Invasive Plants

Field Advice Memo

No. 1016.MCE01.FAM.O.00087 Contract North Bank Site Preparation

Date 01/10/2015

To Alan Willick Company Morgan Construction

From Wayne Loo Company BC Hydro

Subject Site C Compliance Inspection Sept. 22-23, 2015

Reference

A Site C Compliance Inspection was carried out on Sept. 22-23, 2015, by Compliance and Enforcement staff from the Canadian Environmental Assessment Agency, Min. of Forests, Lands, and Natural Resource Operations and the BC Environmental Assessment Office. As a result of the site visit, several non-conformance issues were identified as summarized below. In the week since the audit, measures have been established to address the audit findings. Wherever possible these measures are acknowledged as notes.

1. Erosion and Sediment Control in L3 Ravine At west access point, above the private property – large areas of exposed soils. At east side where North bank Road approaches L3 – high risk due to potential for sediment

erosion to impact fish habitat at the lower end of L3 Ravine prior to the creek entering the Peace River.

Some silt fences have been improperly installed. Adopt strategy of planning for and installing erosion and sediment control measures prior to bad

weather season starting as opposed to a reactive approach. Note: MCE has provided a site specific erosion and sediment control plan dated Sept 24, 2015, RSEM L3 Gully and Proprietary Culvert: Field Based Erosion and Sediment Control Plan. BCH will provide review comments on the submitted plan.

2. Vehicle Spill Kits Approximately 50% of the vehicles inspected on the north bank did not have appropriate spill

kits. Note: This issue has been addressed through daily operations, equipment inspections and environmental content at tool box meetings.

3. Wildlife Attractants Wildlife attractants left on-site – jerry cans stored outside of larger storage bins, and some

garbage cans without lids on them. Bear proof containers are preferred.

4. Outhouses (port-o-potties) Outhouses on-site have not been secured as required to prevent them from falling over in

accordance with S.4.16 Waste Management (BCH CEMP), and S. 8.9.4 Sanitary Facilities (MCE EPP).

Please provide verification that the above noted compliance issues have been addressed (notably Point 3 & 4) or that there is a plan to implement corrective measures. A response is requested to be provided by Oct. 7, 2015.

2015-10-01

XBC Hydro's Representative or DelegateSigned by: Wayne Loo

Distribution


Field Advice Memo

No. 1016.TRL01.FAM.O.00027 Contract Worker Accommodations

Date 01/10/2015

To Patrick Cain Company Two Rivers Lodging Group

From Wayne Loo Company BC Hydro

Reference

Subject Site C Compliance Inspection Sept. 22-23, 2015

A Site C Compliance Inspection was carried out on Sept. 22-23, 2015, by Compliance and Enforcement staff from the Canadian Environmental Assessment Agency, Min. of Forests, Lands, and Natural Resource Operations and the BC Environmental Assessment Office. As a result of the site visit, several non-conformance issues were identified as summarized below. In the week since the audit, measures have been established to address the audit findings. Wherever possible these measures are acknowledged as notes.

1. Erosion and Sediment Control (ESC) The compliance audit team observed temporary storm water drainage installations adjacent to large

areas of exposed soils in the south-central side of the work area that had recently conveyed flowing water. Verbal comments at the time acknowledged the temporary nature of drainage ditches and anticipated the permanent perimeter ditch and settling ponds, with the proviso that temporary measures are adequate to settle and control site run-off.

Further comments for the Project and not specifically ATRLG are to: Adopt strategy of planning for and installing erosion and sediment control measures prior to bad weather season starting as opposed to be reactive.

Request: Continue to follow the ATRLG Environmental protection Plan Appendix A.1 Erosion and Sediment Control and Surface Water Quality Management Plan, and Appendix B. Storm Event Contingency Plan.

2. Vehicle Spill Kits Approximately 50% of the vehicles inspected on the north bank ndid not have appropriate spill kits Note: This issue has been addressed through daily operations, equipment inspections and environmental content at tool box meetings.

3. Wildlife Attractants Wildlife attractants left on-site – jerry cans stored outside of larger storage bins, BBQ’s left outside and

some garbage cans without lids on them. Bear proof containers are preferable.

4. Outhouses (port-o-potties) Outhouses on-site have not been secured as required to prevent them from falling over in accordance

with S.4.16 Waste Management (BCH CEMP). 5. Invasive Plants

A comment directed at the southern topsoil storage area and disturbed zones along the eastern boundary was that there are “many large areas of open soil that could become infested by invasive plants. This comment was interpreted as highlighting the need to control potential invasive species seed sources from cleared areas and relocated topsoil stockpiles as well as establishment of pioneering species on the exposed slopes; and,

Known areas of invasive plants that were identified by a stake in the field should be verified as having had the invasive species removed. e.g., wetland 3. BC hydro was responsible for sanitizing this polygon and will provide verification of completion.

Please provide verification that the above noted compliance issues have been addressed (notably Point 3, 4, & 5) or that there is a plan to implement corrective measures. A response is requested to be provided by Oct. 7, 2015.

2015-10-01

XBC Hydro's Representative or DelegateSigned by: Wayne Loo

Distribution


Field Advice Memo

No. 1016.TRL01.FAM.I.0037 Date 07/10/2015

To Wayne Loo Company BC Hydro From Pat Cain Company ATCO Two Rivers Lodging Subject Response to BCH FAM #1016.TRLO1.FAM.O.00027 Site C Compliance Inspection

Distribution

Please see the below ATR action and responses for items 3,4 & 5 from the Site C Compliance Inspection Audit Finding -Wildlife Attractants ・ Wildlife attractants left on-site – jerry cans stored outside of larger storage bins, BBQ’s left outside and some garbage cans without lids on them. ・ Bear proof containers are preferable. ATR Response: Issues noted were communicated to contractors and relevant personnel. Fuel storage using jerry is minimal and will remain stored in spill trays with lids closed outside for safety reasons. Exterior garbage cans are primarily for construction waste. All refuse bins are to be emptied daily at end of shift. (Sept 24/15) Outhouses (port-o-potties) ・ Outhouses on-site have not been secured as required to prevent them from falling over in accordance with S.4.16 Waste Management (BCH CEMP). ATR Response: This deficiency was communicated to contractors and relevant personnel and outhouses on site were secured. (October 7/15) Invasive Plants ・ A comment directed at the southern topsoil storage area and disturbed zones along the eastern boundary was that there are “many large areas of open soil that could become infested by invasive plants. This comment was interpreted as highlighting the need to control potential invasive species seed sources from cleared areas and relocated topsoil stockpiles as well as establishment of pioneering species on the exposed slopes; and, ・ Known areas of invasive plants that were identified by a stake in the field should be verified as having had the invasive species removed. e.g., wetland 3. BC hydro was responsible for sanitizing this polygon and will provide verification of completion. ATR Response: this item was discussed with BCH representative, Cam Forrester and he agreed to follow up. BCH retained a subconsultant to investigate/assess the status of knapweed infestation before the site preparation. The results of this report should have been communicated directly with BCH.

Appendix C – Contractor Materials

Erosion and Sediment Control Plan for RSEM L3 Gully and Culvert, dated September

24, 2015

3990 22nd Avenue P 250.562.9155

Prince George, BC V2N 3A1 F 250.562.9135

Local offices in Vancouver, Terrace, Prince George, Kamloops, Fort St. John and Calgary

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MEMORANDUM

TO: Alan Willick, Marc Secord; Morgan Earthworks Ltd.

FROM: Triton Environmental Consultants Ltd.

DATE: 24/09/2015

FILE NAME: 5350/WP:P3509

RE: RSEM L3 Gully and Proprietary Culvert: Field Based Erosion and Sediment Control Plan

This erosion and sediment control plan (ESCP) is intended as a supplement to Appendix 3 of the EPP

(Erosion and Sediment Control Plan) and to summarize currently implemented, and planned

mitigation measures, to reduce the potential for negative environmental effects as a result of

construction activity within RSEM L3 Gully and the Proprietary Culvert locations. Giving consideration

to the scope of work and planned construction activities (i.e. infilling the RSEM area; culvert

installation and substantial road fill at the Proprietary Culvert), the main objectives of the ESCP are

to:

Minimize erosion potential through appropriate planning, procedures, and management;

Reduce the work footprint to the extent practicable (delineated project boundaries);

Prevent loss of soil by storm water runoff and/or wind erosion during construction;

Maintain downstream water flow (where necessary); and,

Maintain downstream water quality.

Site Conditions

The climate in this area is generally dry and relatively warm compared to other surrounding

biogeoclimatic zones. Winters are cold (average temperature of –12°C) and summers are cool with

mean temperatures around 15°C. The annual precipitation in the Fort St. John area is 292 mm and

the annual snowfall is 190 cm (Environment Canada, 2015).


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Precipitation in the form of rainfall (of most concern for erosion control) typically increases through

spring with the majority of rainfall accumulating between May and September (Table 1). Major rain

events (e.g., > 10 mm in one day) are uncommon, but one or two events per month should be

anticipated between June and August. Summer rainfall in the region tends to occur in short bursts

associated with convective cells and thunderstorms, rather than large low-pressure weather systems

although these also occur.

Climate normal data for the Fort St. John A weather station (1981-2010) indicate an average of 44.7

mm of precipitation for September (40 mm of rain and 4.8 cm of snow) and 30.8 mm for October

(13.3 mm of rain and 19.6 cm of snow). Rainfall extremes for September and October are 37.3 mm

and 15.2 mm respectively. The average daily temperature for October is 3.6°C and November is -

6.5°C, and snowfall accumulation outweighs rainfall in November.

Table 1. Average precipitation for Fort St. John calculated from data collected between 1981 and

2010 (Environment Canada, 2015).

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Precipitation

Rainfall (mm) 0.4 0.4 0.7 9.7 31.9 65.6 75.2 51.1 40.0 13.3 3.4 0.7

Snowfall (cm) 32.7 25.3 28.7 12.7 6.4 0.0 0.0 0.1 4.8 19.6 32.5 26.8

Extreme Daily

Rainfall (mm) 8.1 4.0 6.6 28.9 49.8 80.3 60.2 58.4 37.3 15.2 12.7 5.8

Days with Precipitation

>= 0.2 mm 10.6 8.4 9 6.9 8.8 11.1 12.9 10.4 10.4 9.6 11.1 9.5

>= 5 mm 1.5 0.97 1.6 1.3 2.5 3.9 4.4 3.4 2.7 1.9 1.7 1.2

>= 10 mm 0.27 0.13 0.10 0.31 1.1 2 2.3 1.5 1.2 0.57 0.33 0.17

>= 25 mm 0 0 0.03 0.03 0.14 0.43 0.40 0.30 0.27 0.04 0 0


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Figure 1. Temperature and precipitation chart for Fort St. John (1981-2010 Normals).

To date, the most significant rainfall event recorded at the work site was 26 mm of rainfall within a

28 hour period (between September 2 and September 3, 2015). This event did not produce any sign

of surface flow within the RSEM L3 Gully bottom or increase to the seepage present within the lower

(approximately) 15 m of the Proprietary Culvert location. Based on this event and consistent

monitoring of additional, lesser precipitation events and local weather patterns; it is anticipated

that even a period of significant or extreme rainfall on par with the highest amount recorded (as

per Climate Normal data), would not produce immediate surface flows through the location that

could not be addressed using the current mitigation measures and planned procedures.

Table 2: Northbank Rain Gauge at Morgan Site Office

Date Time

Precipitation

(mm)

Gauge

Emptied Comments

02-Sep-15 7:00 1 N Began early morning.

02-Sep-15 11:00 6 N Steady rain.

02-Sep-15 15:00 15 N Heavy, steady rain.

02-Sep-15 16:30 19 N On-going heavy rain; saturated ground.

03-Sep-15 10:55 26 Y Overcast; light rain; tapering off. EMPTIED

04-Sep-15 11:45 0 N


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Erosion and Sediment Control Features

Pre-construction erosion and sediment control (ESC) planning for the areas was high-level, and

intended to address all possible scenarios (e.g. up to 2.0 m3/s flows within the L3 system). Based on

consistent daily field inspections and office based activities (regarding weather forecasting), field-fit

mitigation measures have been implemented to reduce the chance of sediment mobilization

downstream and prepare to deal with anticipated quantities of surface flows within the L3 system.

To help achieve these outcomes, the following practices and construction activities have, and/or

will be implemented:

Ensure all parties are aware of the limits of construction such that no additional or

unnecessary vegetation removal occurs. To the extent practicable, tree stumps, root

networks, topsoils and woody-debris/mulch (remaining following clearing activity from a

previous contractor) have been retained within the RSEM L3 Gully and Proprietary Culvert

locations. Retention of vegetated ground cover is intended to reduce the likelihood of

exposing erodible soils and act as buffers between construction activities and potentially

sensitive downstream areas.

Maintain consistent and thorough site inspections to identify and rapidly address any

potentially significant erosion and sediment control issues that may result in negative

downstream impacts.

Maintain the Site Office Rain Gauge and closely monitor local weather and weather

forecast.

Slopes that do not have root networks present and will not be filled (e.g the west cut slope

towards the diversion ditch along RSEM L3) will be treated by scarification, vertical tracking

or have readily available woody-debris rolled-back to minimize the chance of erosion and

downslope sediment mobilization.

Additional sediment fencing or spring-berms may be installed on the contours at low-point

swales to reduce overall slope length on slopes above the watercourse. Natural woody-

debris remaining on-site or shallow earthen berms may also be installed to achieve the same

outcome.

Construction is occurring during months of low precipitation (drier) and diversion features will

be in place prior to spring freshet to handle run off volumes in the stream. Construction

activities will be completed in such a manner as to minimize the risk of negative

environmental impact and timed to avoid forecasted heavy rain events. The Site Supervisor,

shall cease operations, modify construction methods, or relocate to an alternative site within

the project area during periods of inclement weather to avoid siltation that cannot be

properly treated.

Works are suspended during heavy rainfall events that present unsafe work conditions or

significant potential for environmental degradation of downstream habitats.


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At the RSEM L3 infill location; an earthen berm is in place upstream of current works, with an

adjacent pad for installation of a 6-inch pump. Should it be necessary to begin pumping

flows around the active work site, the 6-inch pump is currently located at Howe Pit being

used for water withdrawal activity, and can be relocated anywhere on-site within

approximately 30 minutes. Approximately 500 m of hose is available on-site, and a standing

order for additional hose and pumps (as needed) exists with United Rentals in Fort St. John.

The 6-inch diesel pump is capable of moving approximately 6.4 m3/min. An additional

earthen plug (approximately 2.5 m high across the channel) is in place downstream of the

work site, and is adjusted to suit the expanse of works (currently installed ~10 m upstream of

private property boundary). Downstream berms are to reduce the chance of slope runoff

entering the work site, picking up sediment, and transporting it towards downstream

habitats. To reduce runoff towards the channel itself, as much as possible root networks,

stumps, topsoil and coarse woody-debris have been retained to stabilize soils. In the event

of turbid water accumulation within the work site that requires removal, a 2-inch trash pump

is available on-site and will be used to remove turbid water and discharge to a vegetated

area away from the watercourse, with suitable scour protection.

At the Proprietary Culvert location;

o Current activity (clearing-timber removal) has been conducted in such a manner as

to minimize disturbance to vegetated areas, the channel banks and the channel

substrate.

o Sediment fence is in place across the channel immediately downstream of the

worksite, as a temporary measure to reduce the chance of sedimentation

downstream. To date, there has been no significant surface flow through the location

and no sedimentation issues.

o A 2-inch trash pump, with drip tray, spill kit and hose, is stationed near the downstream

end of the Culvert site; to be used for turbid water removal as necessary (discharge to

southeast flat area with existing vegetation, to suitable scour protection).

o Access trails and cut slopes have earthen berms established across them at the end

of each work day, to reduce the downslope movement of runoff and sediment.

o During installation of the Culvert, an upstream and downstream earthen berm or dam

will be installed to isolate the site, and a 6-inch pump will be ready to pump flows

around if necessary.

o Sumps located in field identified areas (such that they do not impede work) will

capture and contain any turbid water, which can then be pumped away from the

channel for infiltration to vegetation (or filter feature and snow, depending upon

conditions).

o Due to the constant seepage downstream of the work site, it is not anticipated that

sump excavation or potential turbid water removal from the work site will de-water


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the downstream channel, as with decreasing elevation downstream, there is

additional seepage that enters from each side of the Gully. As well, it is likely that the

channel naturally de-waters overwinter. On-going monitoring and assessment of the

area will aide in verification of these assumptions and enable field-fit modifications to

the ESCP as necessary.

In the highly unlikely scenario that a 100-year event was imminent, such as in late June 2011

when 117 mm of rain fell in Fort St. John within a 48 hr period (Environment Canada weather

and meteorology website); it is anticipated that regular monitoring of weather forecasts

would allow for a rapid deployment of ESC measures and procedures to further isolate and

stabilize the work site. These could include:

o Immediately pumping clean water around the work area to keep site dewatered

(using the 6-inch pump). An energy dissipater would be installed at the downstream

end of the work areas so that flows can be reintroduced into the stream channel

without scouring the stream bed.

o In order to reduce dependency on pumps, a diversion ditch will be shaped along the

west slope (construction of the feature is currently underway). The diversion ditch

would receive poly-sheeting, geo-textile, rock, or similar product or method, to reduce

erosion of soils within the ditchline. The ditch-diversion designed flow capacity will

meet 2.0 m3/sec, as recommended in the BC Hydro pre-construction document

“Activity Description for Dam Site Area-RSEM L3 Ravine”. An earthen berm/channel

plug will be installed upstream of the L3 fill, to convey potential flows into the diversion

ditch.

o Existing sumps and earthen berms/plugs would be reinforced with gravels to ensure

soil berms are not further eroded. If water becomes turbid and requires removal (ie. it

is threatening to overtop or de-stabilize the berms), pump water to sump downstream

and let settle out, or pump to existing vegetated area for natural infiltration away from

the work site. During a significant event, constant monitoring will be conducted (EM

during the day; labour during the night whenever possible). Open lines of

communication will be maintained between day shift EMs and night shift supervisors

and labourers to ensure rapid response times can be met if needed.

The following measures, or similar techniques to achieve the same outcome, will be

implemented to control runoff during filling of the gully:

o Compacting the downstream face after the placement of each lift of fill using a

sheep foot-style drum compactor or similar roller to give a compacted, indented

face;

o Installing catchment drains along the contacts between the compacted fill and the

natural ground (gully edges);

o Sloping the top surface of the fill to the upstream so that surface runoff will be

conveyed to the drains along the contacts and not down the downstream face; and,


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o Stilling basin (runoff catchment) at the downstream end of the RSEM will be installed

to coincide with RSEM infilling, and be completed prior to spring freshet.

ESC Supplies

Current ESC supplies on site include: 6 rolls of sediment fence in use at low-point swales along North

Bank Rd, 4 rolls along the Left Bank Excavation Area, 2 rolls at Wuthrich Quarry and 2 rolls in Howe Pit

(once they are no longer needed in an area, these measures are removed for re-use if they are still

in suitable condition). One 6-inch pump is located at Howe Pit, and a 2-inch trash pump is staged

near the Proprietary Culvert location.

At the Left Bank Site office Sea-can, there are 10 additional rolls of sediment fence; 6 rolls of

polyethylene sheeting (@ 2000 ft2 = 12000 ft2), 100+ empty sandbags , 12 sections of 1 m long

Synthetic Permeable Ditch Barrier for ditch applications, 7 large tarps and 6 large rolls of geotextile

fabric (~100-ft x 10-ft). As well, locally sourced riprap (rock material) and gravel is readily available

for use as needed (currently used at Wuthrich Quarry for ditch lining and check dams); gravel

stockpiled at Gravel Laydown area of the Left Bank work site.

Given the project location to Fort St John and larger center of Prince George, the following

materials can be quickly obtained: 6-mm polyethylene sheeting, sediment fence, rolled-erosion

control products (e.g. coco-mat), straw wattles, synthetic permeable ditch barrier, geotextile fabric

etc.

Due to the costs associated with several ESC materials (rolled erosion control matting, etc), natural

features such as earth berms have been used instead with the understanding that material will be

purchased, as necessary.

Environmental Monitoring

Current environmental monitoring includes daily visits and inspections to both the RSEM L3 and

Proprietary Culvert locations. Checklist items include inspecting ESC measures for functionality (e.g.

sediment fence downstream of Proprietary Culvert and earthen berms along access trails) and a

thorough assessment of areas for evidence of surficial runoff patterns or potential problem areas

(particularly during and after precipitation events).

Should stream flows occur following rainfall events, downstream water quality monitoring will be

conducted as needed to ensure water quality reaching downstream fish habitats are within

permitted values (as per Section 4.14 of CEMP). Water quality would be measured using a LaMotte

2020we turbidity meter, measuring nephelometric turbidity units (NTU).


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Closure

Triton has prepared this document to provide a summary of current measures being implemented

and field fit recommendations for ESC associated with the RSEM L3 Gully and Proprietary Culvert

works. Should you require any further information, or have any questions or comments, please do

not hesitate to contact the undersigned.

Yours truly,

Triton Environmental Consultants Ltd.

Scott Ramey, B.A. BC-CESCL

Environmental Technician

CC: Trisha Merriman, R.P. Bio, CPESC, PMP


Appendix D – Spill Kit Inspection Form

To be completed by Contractors’ Environmental Monitors

Site C Clean Energy Project - Spill Kit Inspection Form

Name of Contractor Vehicle Licence Number

Date (YY-MM-DD)

Spill Kit Present

(Y/N)

Spill Kit Adequate

(Y/N)

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