1 The Peace River Environmental Society Apri1 4, 2013 Ms. Linda Jones, Panel Manager Review Panels Canadian Environmental Assessment Agency 22 nd. Floor, 160 Elgin Street Ottawa, Ontario K1A 0H3 Mr. Brian Murphy, Executive Project Director BC Environmental Assessment Office PO Box 9426 Stn Prov Govt Victoria, BC V8W 9V1 Dear Ms. Jones and Mr. Murphy: The Peace River Environmental Society has reviewed the subject matter of the EIS and have noted the following concerns: Walter Andreeff, BSc. Applied and Environmental Geology Volume 1: Introduction, Project Planning, and Description Dam Safety Operations, Maintenance and Surveillance Manuals are required to follow the CDA Dam Safety Guidelines (CDA 2007). In the CDA 2007 guide under data requirements for Operations (3.4.2) it is noted that the Dam operator should consider obtaining data for certain aspects of Dam surveillance such as headwater, tail water elevations, flow data, etc. and install the means to gauge flow volumes. It is noted in (Volume 5) that the flows for 1986 were excluded from the Flood frequency analysis of the site C catchment area because of missing records. This suggests that the maintenance and/or surveillance documentation system may not have been fully functional at that time. As noted in of the CDA 2007, the dam owner should establish a procedure to document findings.that require follow-up action.
2 How does the project proponent ensure that Peace River Dam safety systems and required operating, maintenance and surveillance procedures for each dam are audited and inspected? What is the frequency of dam safety audits and are they undertaken by an external third party arms-length organization? What is the historical record of safety evaluations and audits undertaken at all the Dams upstream of the proposed Site C dam project and what does it imply for start-up and normal operations of the proposed dam? References: Canadian Dam Association (CDA), 2007a. Surveillance of Dam Facilities. Volume 2: Assessment Methodology and Environmental Effects Assessment Regional Bedrock Geology and Dam Site Geology CDA 2007 states that the Geotechnical assessment review many types of available information including air photos and other maps along with site reconnaissance. In this instance the EIS need to consider additional work on the underlying geology of the project area. Both sections of the EIS omit a prominent geological feature known as the Peace River Arch that underlies the bedrock units in the technical study area and location of the Site C dam states that tectonic activity has had little effect on the rocks of the proposed Reservoir area but in fact Peace River Arch (PRA) Geological features have been mapped and interpreted as influencing the path of river courses such as the Moberly River and the Peace River near the proposed Site C dam location. In a February 2009 article in the Canadian Society of Petroleum Geologists (CSPG) Reservoir, the writers suggest that several structural elements are easily identified in interpreting High Resolution Aeromagnetic (HRAM) surveys of the PRA area. They further interpret that many structural geological features such as normal, strike-slip faults, pull-apart basins and detached thrust faults can also be observed through HRAM survey. This suggests there is more complex geological story involving tectonic elements that requires further scientific investigation to determine potential tectonic feature impacts to the Site C Dam. I note that in EIS Figures and there is little definition of the number, length or orientation of the PRA faults.
3 Figure 1: Figure 5 from the 2009 CSPG Reservoir. A geological and geophysical data interpretation of the Monias area. This data includes: a seismic line across the Monias field (5A). An HRAM image showing the magnetic expressions of near-surface faults and their relationships to known producing fields (5B). Surface structure map of the Wilder field, which was interpreted from stereo photography (5C) and Landsat imagery showing the surface expression of Wilder Field (5D). Unfortunately, geological structural data such as strike and dip readings nor other typical geological information is available in the EIS for technical review and analysis although it is evident that information has been collected at several site locations. The cross section of Figure does not provide a map to provide the location of the cross section on any map nor the linear orientation of the cross section. Also, The Little Ricky Shear noted on the cross section figure should be described and dip, strike details of the shear be made available. There are also several cross sections denoted as A-A, B-B, D-D and MR-1L that are not in Vol. 2, Appendix B, Geology and Terrain, Part 2 Preliminary Reservoir Impact Lines in the required section of Drawing 13. References: Berger, Zeev, M. Boast, and M. Mushayandebvu, February, 2009, Reservoir Issue 2. The monthly magazine of Canadian Society of Petroleum Geologists, Pp Canadian Dam Association (CDA), 2007b. Geotechnical Considerations for Dam Safety. Landslide inventory The landslide inventory should include an assessment of slides from the Alberta Region. The Eureka River Slide of June 1990 at 50 Million cubic meters of landslide material is one of the seven largest translational landslides to have occurred in the Peace River area within the last 65 years. According to the authors, the texture and Atterberg limits of the sample of preglacial
4 lacustrine sediment collected at the Eureka River landslide are within the range of values found at the Attachie landslide.. This would suggest that these features, although a distance from the proposed Dam location site, should be included in the EIS to better understand the Peace River regional features of the surficial Geology and gain a greater understanding of landslide effects to the Site C project. References: B.G.N. Miller., D.M. Cruden. 2002, The Eureka River landslide and dam, Peace River Lowlands, Alberta, Pp Accessed at the NRC Research Press Web site. Regional Seismicity In this section (line s 39-40) it is noted that no faults in the Peace River Embayment are reported to extend into the Middle or upper Cenozoic. I point out that the Shaftesbury and Dunvegan formations were deposited during the Mesozoic era and faults have been mapped in the late cretaceous rocks of the Dawson Creek Graben. Therefore there may be evidence of faulting due to the tectonic activity within the area of the PRA on formations deposited during the Mesozoic and Paleozoic era that are underneath the base of the proposed Dam location Seismic Hazard Assessment Lines 9-40 lists the experience and proficiency of professionals who were involved in undertaking the Hazard assessment. However, the proceedings of those meeting s and related documented interactions with the project proponent are not available for public review. Nor are there adequate resources and review time supplied by the project proponent to stakeholder professional s or other representatives to properly assess the work of the Hazard Assessment team(s). Without the openness of peer review and public disclosure of the data and information to the private, public sector or academia the public cannot be assured the work was completed in the public interest. Petroleum Industry-Related Activities that may affect Seismicity Information stated in this section on hydraulic fracking suggests that there is little risk to the public from activities yet it was made clear by a 2012 BC Oil and Gas commission report that 38 earthquakes were induced by movements on pre-existing faults due to fluid injection during fracking activities. It is important to note that the area where these earthquakes occurred were remote unpopulated areas of north east BC therefore the public was unlikely at risk. However, within 100 km s of the Site C Dam there are several Oil and Gas development area s that use hydraulic fracking. Given that the research, experience with horizontal well drilling and fracking is relatively young (2005) within the BC Oil and Gas industry and the effects or impacts are not fully understood it may be prudent to limit fracking
5 activities near the dam location during and after the filling of the Site C Dam reservoir for a period of time. Real time Monitoring of potential ground movement s on or near the Moberly River and Tea Creek landslide area s during fracking activities would be prudent when water saturation values in the subsurface are higher than normal due to abnormal precipitation occurrence s. A report and several maps produced in October 2012 on the Montney formation in north east BC by the BC OGC noted several gas pools and new 2012 subsurface land sales near the area of the proposed dam and reservoir. Reservoir development of the Montney depends on fracking and horizontal drilling technology therefore it needs good oversight by the BC Oil and Gas Commission as the Montney play is developed in this area. Figure 2 Montney unconventional play trend 2012 (grey slant lines) Montney horizontal wells are darker grey
6 Figure 3 Montney pools denoted as red circles Figure Montney land sales in red Note subsurface land sales near the Site C dam location References: BC Oil and Gas Commission, August 2012, Investigation of the Observed Seismicity in the Horn river Basin. BC Oil and Gas Commission, October 2012, Montney Formation Play Atlas NEBC.
7 Volume 2: Appendix B Geology, Terrain and Soil, Part 2 Preliminary Reservoir Impact Lines: Bedrock Geology The report section references that past tectonic activity has had little effect on the rocks of the proposed reservoir area. (Pp. 10) However, I believe further field investigation, documentation research and Geological modeling is required. A 2008 report wrote on the reactivation of subsurface faults during the upper cretaceous time period located in the Dawson Creek Graben complex near the Site C location. The study focused mainly on North West Alberta in the subsurface area of the Peace River Arch (PRA). It is well known the PRA is present in North East BC and North West Alberta suggesting that faults in Alberta in the PRA may also be present in the Cretaceous rock of the bedrock underlying the Site C dam location. Figure 4 Note the lineament trending north south above the 7 and the photo 3 displayed below located near the Montagnuese River. Some brief field investigations in the areas of the Montagnuese River and the Peace River valley South West and North West of Fairview Alberta were undertaken in August 2012.
8 The Peace River valley is about 200 meters deep at this location and access to the area is west of secondary road 729. Several photos were taken of the west side of the Peace River of a linear feature at the surface that can be observed on satellite images and on maps. The feature is over 2.5 kilometers long and appears from an observation distance of 4 km s as if a block of material separated from the west valley wall of the Peace River and moved downwards towards the river. The location of the feature is N and W. Also, the direction orientation of the feature appears to strike parallel to the direction of the Montagnuese River. Further site investigation should assist to classify the type of landslide. Photo 1 Observing downstream to the South West Photo 2 Observing to the West
9 Photo 3 Looking to the North West A report published by TUL Petroleum Ltd. stated that the Montagnuese river is underlain by an deep basement fault. A paper from the CSPG (O Connell et al., Vol 38A, Pp. 76) noted the same fault on a structural contour map of the Precambrian surface. If the fault in the river valley is the same fault that may have enabled the landslide mentioned previously it suggests this may be evidence of the surface expression of a deep fault currently impacting the Peace River valley. Combined with studies mentioned earlier on small faulting in Cretaceous rocks it suggests that the Peace River Arch needs to be further defined and researched beneath the Site C Dam location. References: Stapleton, Murray J., 1997, Lamprophyres of the Peace River District, TUL Petroleums Ltd., Peace Diamond Project Assessment Work Report No A. Mei, Shilong. 2007, Updates on Faults and Structural Framework of the Peace River Arch Region, Northwest Alberta, Obtained using a New Approach, 2007 CSPG CSEG Convention, Pp Eaton, D., Hope, J., and Ross, G The rise and fall of a cratonic arch: A regional seismic perspective on the Peace River Arch, Alberta Bulletin of Canadian Petroleum Geology, VOL. 47, NO. 4 (DECEMBER, 1999), P Background on Landslides in the Peace River Valley 4.1 As written, landslides investigations have taken place between Hudson s Hope and the BC/Alberta Border. There is mention of some landslide investigations in Alberta but the locations are not listed. Why are the landslide investigations in Alberta not part of the report and included in the EIS? What is required to disclose this information in the Site C Dam EIS. Seismicity Table 9-3 pseudo-static seismic analyses assumes firm ground conditions at each cross section location. PGA values are based on firm ground conditions when we know ground conditions can vary at each cross section location. Why are firm ground condition s assumed for the application of the 2010 NBCC seismic calculator and why is
10 a conservative approached used when there might be uncertainties in the input of the scenario calculations? Table 9-2 lists shear strength parameters that have different values for a diverse set of surface materials and Table 9-1 lists a summary of 13 scenarios of stability analysis. It s not clear to me how Table 9-1 that are determined by different software packages such as Slide and Seep/W are used as input into Table 9-3. Are there any uncertainty ranges in this methodology and are the uncertainties taken into account in calculating the Table 9-3 results? Also, I note that Table 9-3 uses the Median hazard value when the 2007 Dam Safety Guidelines recommend the use of Mean value. What were the rationale in using the Median value? References: Canadian Dam Association (CDA), 2007c. Seismic Hazard Considerations for Dam Safety. Volume 5: Requirements for the Federal Environmental Assessment: Seismic Data This section refers the EIS reviewer to the Project Proponents (BC Hydro) science and engineering review reports in the EIS rather than conducting a separate science based research and review of the project as the responsible federal crown agency. Given the interprovincial aspect of the water flow from BC to Alberta, the continuation of subsurface geological features, the impacts to the local economies, and indirect and direct effects including cumulative impacts across interprovincial boundaries, the crown has not applied the due diligence required in managing the assessment of this project for the people of Canada nor the people of Alberta downstream from the Site C dam. Seismic Activity No comments are supplied in the EIS. Accordingly, the crown has not conducted a separate science based research and review of the project as the responsible federal crown agency. Given the interprovincial aspect of the water flow from BC to Alberta, the continuation of subsurface geological features, the impacts to the local economies, and indirect and direct effects including cumulative impacts across interprovincial boundaries, the crown has not applied the due diligence required in managing the assessment of this project for the people of Canada nor the people of Alberta downstream from the Site C dam. Earthfill Dams This was a great job. Very impressive interesting reading.
11 Teunis H. op ten Noort, Ir (MSc.) Engineer Dam Breaching Scenarios I have updated my comments, mainly because I fail to understand some result of the dam breach analyses, notably Vol 5 Tables (pp37-56/57/58). How can a Sunny Day situation yield to higher peak flood flows at Site C than the inflowing Probable Maximum Flood (PMF), which is much higher by definition? Unless the breach parameters are completely different. But BC Hydro does not mention them in detail). I only considered Site C, but of course this also holds for the situation further downstream. When W.A.C Bennett Dam (WACBD) and probably Peace Canyon Dam (PCN) as well were designed, similar dam breach investigations may have been modelled. But I would recommend strongly that this exercise for WACBD be repeated since the downstream situation is going to change considerably with the construction of Site C. The effect of WACBD breaching and consequently the other dams in the cascade, PCN and Site C, could have dire consequences for the communities downstream, much more than what has been modelled in Vol 5 Sec I would recommend they use the Sunny Day and PMF situations at WACBD. It is possible that the PMF for WACDB must be updated (Probable Maximum Precipitation, UBC Watershed, etc.), and of course severe inflow from the local catchment between WACDB and Site C must also be included in the analysis. The modelling of this series of events would not be difficult as they have already have the model and the data. EPP (Emergency Preparedness Plan) I had a look at the BC Dam Safety Regulations of 2000, including amendments up to 30 Nov 2011, which are, fortunately, directly available from the internet. There it is specified under EPP that: 3.1 (1) A dam owner of a dam that has a classification of significant, high, very high or extreme must, in the form and manner and within the time period specified by the comptroller or regional water manager, (a) prepare a plan that describes the actions to be taken by the dam owner in the event of an emergency at the dam, and (b) submit the plan to a dam safety officer for acceptance by the dam safety officer. (2) Subsection (1) applies whether or not there is a term or condition in an approval granted or licence issued that requires the preparation of such a plan for the dam. (3) A dam owner of a dam that has a classification of significant, high, very high or extreme must (a) review, and revise if necessary, the emergency preparedness plan for the dam no less frequently than is specified for the classification of the dam in items 5 and 6 in the Schedule 2 table, and (b) submit any revisions to a dam safety officer for acceptance by the dam safety officer. [en. B.C. Reg. 108/2011, App. 1, s. 4.]
12 The specific Emergency Preparedness Process (EPP) for Site C has not yet been presented in the EIS but we expect it will be prescriptive and thorough as described in the 2007 Dam Safety Guidelines sections 1.3, 4.0, and General Throughout the report(s) is mentioned... Maintenance policies and procedures would be implemented to ensure that structures and equipment are maintained in a safe operating condition." (Vol 1 page4-66 line7) I stress the... would be... This is just an example. The question is: who will implement it and when, and who is to check it? What happens if it is not done? Who is to monitor this? Drainage areas mentioned, notably at the key points Bennett Dam, PCN and Site C are not univocal. E.g. In Vol 1 Appendix E Sec 6.1 (page 25) The contributing drainage are at PCN is sq km, in the Water Use Plan (page 4) it is sq km and in Vol2 App I page 6 it is sq km. I did not locate any references made to the future decommissioning when the Site C Dam is at the end of service. As mankind is progressing to find new alternate forms of energy use, decommissioning is a serious option which should be estimated and included in the economic analyses. GHG (Green House Gases) Vol1 Appendix D Pp. 3 upper right corner. Another point is that the EIS states that there are no Green House Gas (GHG) emission s for new projects! Apart from emissions during construction, including fabrication of equipment which would happen with any energy generating project there are numerous GHGs emissions. Only after 30 years or later, are the GHGs more or less equal to the emssion s of a natural lake. In the same context I don't understand why a Canada Boreal Hydroelectric plant would produce more GHGs than the Site C Dam would. Isn't Site C also considered a boreal area (the colder climate the less GHG), see Vol 1 p7-21 Table 7.14 first 2 lines? Also compare Vol 2 p15-16 Table 15.8 last line with the first line in Table The figures in Table 15.8 are much higher than those in What is the reason for this? ENVIRONMENTAL IMPACT STATEMENT (EIS) COMMENT TABLE Name of Party Providing the Comment(s): Teunis H. op ten Noort for the Peace River Environmental Society EIS Volume # and # Page # Line # Comment # Comment Volume 1, Where are the Emergency EIS Guidelines (where relevant)
13 EIS Volume # and # Page # Line # Comment # Comment Preparedness Plans? Volume 1, Figures Fig The cross-sections do not show the following levels: top of radial gates, bottom of radial gates and Volume 2, Appendix I Volume 2, Appendix I and further crest level of auxiliary spillway 54 N/A 3 2) Runoff from onshore construction activities around the dam site These sediment inputs have not been explicitly estimated at this time. These inputs would need to be kept below the effluent criteria to be set out in the Environmental Management Plan. This has to be checked and monitored 55 N/A 4 The estimated total fine sediment input from in stream construction activities during the eight-year construction phase ranges from approximately 18,000 tonnes to 30,000 tonnes. For comparison, the mean annual suspended sediment load in the Peace River is 1.36 million tonnes/yr (at Site C).), It will drop considerably during filling of the reservoir and the period thereafter. This gives rise to degradation the first km d/s of the dam Who will ensure that these plans are made and adhered to? Where is Chapter 9.1.4? , Is there a case where the wave generated by 1000-yr wind is smaller than the one generated by a 100km/h wind? 8 Reference is made to the wrong 9 Reference is made to the wrong , All references made to xxxxx are wrong and should be rectified. (as in comments 7 and 8) The peak PMF inflow is given as 19,300 m 3 /s. However, in Vol1, Appendix E, 6.2, p 25 the EIS Guidelines (where relevant)
14 EIS Volume # and # and further in general Page # Line # Comment # Comment PMF inflow (peak) is given as 20,810 m 3 /s (+7.8%). Which one is correct, and used in the calculations? All references made to xxxxx are wrong and should be rectified Reference is made to the wrong 37-56/47/58 14 Table 37.18: Needs an explanation why the Peak Flood Flow at Site C = m 3 /s compared to m 3 /s and m 3 /s in Table and respectively. Apart from the very high figure in Table which could be the result of an instant breach (please explain), explain why there is little difference in the w/ and w/o project situation. Table 37.21: If all outlet systems including turbines fail and the earth dam gets overtopped, please explain why the peak flood flow is higher than the PMF (even if the retarding effect of Site C reservoir is neglected) Reference is made to the wrong Figure Reference is made to the wrong 17 Consequences of PMF and Dam breaches are calculated but nowhere is indicated what mitigating measures are going to be taken, neither in BC nor in Alberta. Is this (going to be) part of the Emergency Preparedness Plans? In my opinion the population deserves to be informed of what they could expect in some future disastrous situation before the construction of Site C EIS Guidelines (where relevant)