Hearing Order OH File No. OF- Fac- Oil- N

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1 1 To: Enbridge Northern Gateway Pipelines Re: Northern Gateway Project Application From: Cheryl Brown Hearing Order OH File No. OF- Fac- Oil- N Information No tool by Det Norske Veritas (DNV). The per voyage methodology was selected in completing the marine quantitative risk analysis (QRA) and the methodology use to complete the QRA was based on the International Maritime organization of a Formal Safety Assessment. Many tools are available by DNV and it has not been identified in the references.. Please supply the name of the DNV tool used for the QRA and a copy of the DNV tool. 2.2 The QRA report references interviews with Stakeholders that were held in Prince Rupert and Kitimat in 4.3 pg 46 a. Were the interviews done in a group session or individually? b. How many people from each sector and place were interviewed?

2 2 2.3 In , the report refers to causes of a powered grounding usually due to navigator s inability to follow the correct course or correct a steering malfunction. The reasons may include misjudgment, lack of attention or the navigators condition (illness, intoxication etc). Could you please indicate how these factors were actually tabulated in the risk assessment for powered groundings? 2.4 In it states that the K traffic density equals the world average of 1.0 when at least 5 vessels may be encountered during the transit of a segment and where it is relatively easy to pass vessels at a safe distance. Please describe what a passage of 2 vessels at a safe distance is. 2.5 : The Marine QRA report does not assign a risk factor to the cargo oil nor is the risk of spilling oil rated with comparison to other types of hazardous cargo spills.

3 3 Can you compare within the risk analysis the risk of oil spill with other hazardous cargos that are being transported within the assessed water way?. 2.6 In the reports sensitivity analysis 7.4.2, projected increased traffic density with current and future projects increased the incidence of collisions. As the cargoes on these vessels would have risk factor that should be factored into the risk analysis of a collision, would you please indicate the current and projected traffic of vessel type, the volume of vessel along with type of cargo. 2.7 : In the methodology section of the QRA it was determined through the TERMPOL the statistically valid local tanker incident frequencies could not be established for BC due the few incidents that occurred involving vessels of relevant size and therefore alternative international incident frequencies would be used. Within a risk assessment, being aware of what were the issues for the incidents on the BC coast would be relevant for the analysis. Would you please provide a list of the incidents of vessels of relevant size, results from the findings of the incidents and who investigated them?

4 4 2.8 Due to limited historical traffic through the route, the use of international information has been used in part to establish risk assessment and recommendations for this report. I request that several examples of passage from other areas with similar conditions be provided for comparison, that indicate risks identified and recommendations. 2.9 Kitimat is currently a private harbor/port. No current TERMPOL is in operation that provides direction for management of vessels in the harbor. Please state the current situation for the Kitimat harbor that include the current restrictions and directions to vessels Technical data report Hydrogeology - figure B 11 The Northern Gateway pipeline as proposed, will cross several significant aquifers from the Onion Lake flats to the Douglas Channel. The Dubois aquifer at the Onion Lake Flats is a significant source of water for the region and has a rapid recharge rate due to the high porosity of the soils and high precipitation levels.

5 5 Contamination of this aquifer by hydrocarbons would impact Lakelse Lake and Skeena watershed systems as well as the Kitimat valley watershed. a. What additional measures are taken when building a pipeline over an aquifer to prevent contamination in the event of a spill. b. What changes to the route could be proposed to avoid this aquifer? c. What additional measures will be taken regarding the Clearwater pumping station that is currently planned to be situated over the aquifer? d. Will the proponent locate the pumping station in a less sensitive area? 2.11 Technical data report- Freshwater fish and Fish Habitat Pg 3-97 The report indicates on the Kitimat river section of the proposed pipeline, that there are severe construction- timing constraints on the Kitimat river and its tributaries. Most of the tributaries such as Hunter Creek, Chist Creek, Deception, Wedeene, Little Wedeen, Goose and Duck Creek have no periods of least risk. The rest of the river system has a period from Aug 1-31 for least risk. Table 3-39 on pg 3-98 indicate few periods of least risk on any part of the Kitimat water shed. a. How does one intend to schedule the construction of the proposed pipeline within these recognized constraints? b Please indicate the impact of construction on this sensitive river system in terms of habitat loss, fish loss during the construction, future loss of stocks, and loss to fishers.

6 Technical data report Geology and Terrain Coastal Mountain section Pg 3-44 The report speaks to the glaciomarine sediments that are prevalent in the Kitimat valley and report large flow slides in the area. The proposed pipeline will have to avoid these areas from the Onion Lake Flats to the marine terminal. Please supply the sites of glaciomarine sediments of the Kitimat valley from the upper to lower Kitimat including the Onion Lake Flats within the proposed pipeline right of way route : Vol. 6C Environmental and Socio- economic assessment. Parameters for the setting of the Socio- economic assessment found in are based on criteria that include a number of factors such as. A population greater than 1000 within 40 km of the ROW or the Kitimat Terminal A population less that 1000 within 10 km of the ROW or the Kitimat terminal Presence of traditional land and resource use area that could be directly affected by the project Figure of coastal British Columbia Region demonstrates these criteria. As a result communities that are affected on the coastal region such as Hartley Bay are not been considered within this assessment piece. The project for consideration for the JRP includes the marine component and this has not been included here. Please extend the setting for the Socio- economic assessment and complete it so that the effected marine communities are included.

7 : Vol. 6C Environmental and Socio- economic assessment. In reference to cumulative effects implication on pg it is pointed out that the greatest cumulative effect of the project will be Kitimat where project effects related to changes in well being, delivery of protection and social services are rated as moderately adverse and therefore could act in a cumulative fashion with other projects. Although several larger construction projects have been identified for this area, most are short term and are planned for completion therefore the project, so there will be no overlapping effects if construction of these projects occurs as planned. Projects approved and proposed along with timelines have change since the socio economic assessment was prepared. Please update the assessment to reflect the current status of the socio economic environment : Vol. 6C Environmental and Socio- economic assessment. In it is stated that the management of potential social problems in the Kitimat area will require Northern Gateway and all other companies proposing major developments to work with the regional government and service agencies so that opportunities for effects management are identified and implemented early, and are modified as required. Please give a proposed detailed plan as to how this will be approached along with proposed timelines of engagement with the government and agencies.

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