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Technical Volume 8
Contaminated Sites

Technical Volume 8 is an Assessment of the potential impacts related to the investigation and mitigation of potentially contaminated sites along the proposed SFPR corridor.
The proponent fails to adequately test and evaluate the risk locations identified in the document or detail any mitigation pertaining to this section.

The following are questions and comments regarding a review of the document with a conclusion statement and recommendation;

Pre-construction mitigation - an oxymoron. As there are no actions in place before work starts, the only thing that qualifies as mitigation is site reclamation. Semantic, but the whole thing is in a legal document form; Semantics mean everything.

Referring to the various figures of Volume 8, the proponent has shown acceptable efforts were given to identify the location of "Possible" and "Likely" contaminations. The application document is, however, careful to not state any of these in any absolute terms. And there has been only first stage evaluation, namely studies of the public records for the properties in question. Actual contamination levels and types are not specified.

In fact, the true extent of the contamination is as yet unknown, and the so-called pre-construction mitigation is in fact the "Preliminary Site investigation" (PSI) which consists of third party subsurface sampling and lab testing of the samples taken from acquired properties classified as Tier 1 only. How might a permit for treatment, or a certificate from Environmental Assessment Office be issued when there is no scientific data regarding contaminated site risk levels?

Referring again to the figures, a very large area of land in the proposed alignment is classified as Tier 2, for which the pre-construction mitigation is cited as asking the owner of the site a number of potentially incriminating questions about their land use. As a casual observer, my concern is that owners hoping to avoid litigation or environmental clean up costs, might down-play the type and extent of the polluting their business does. Sites may in fact be significantly more dangerous than anticipated by this application.

Also not clarified by the report is any reasonable estimate of the actual land area in some standardized unit -Therefore evaluating of the over land route with any accuracy is only possible with the available information if an individual measured each area on the maps with a ruler and calculated the approximate land area. The time required would be undesirably long to provide any feedback, again pressing the matter of extending the Public review deadline. Such an evaluation would give the public and the assessment office a better sense of how much hazardous or toxic material might be released, and determine from that how much damage to the environment might result if satisfactory steps for mitigation are not achieved by the proponent. It seems that, from a common sense point of view, one would be most interested in how much damage might result from a mismanaged project. Why is actual affected land area and estimated depths of contamination not included in this application? Even assuming some reduced mean contamination level could allow for a crude modeling of an outflow of toxins from a preload region of the project.

Questions like, will we have to close the fisheries for a season because 600 tonnes of preload has squeezed out 5 tonnes of lead/zinc from a contaminated site previously stable? These are the type questions the proponent must answer, better now than when it's too late!

According to appendix 10, heavy metals often contaminate roadways and railbeds - These should be considered to be tier 1 sites and should be identified on the maps as such in all regions where the SFPR is in proximity to the existing road alignments. According to the Memorandum of Understanding shown in Appendix 10, this material can in some instances be cast-off the side of a road provided it does not elevate the concentration above the acceptable commercial limits for that area. However, detailed profiling is required to determine if that is possible. Given that Tier1 classification is given to sites that are likely to be heavily contaminated, why is there no tier 1 classification along river road where traffic moves slowly and where concentrations are very likely to exceed commercial limits and in some cases even industrial limits?

Railbeds outside of the scope of this project are granted a minimal Tier 2 classification, which will require some form of sampling in proximity to the SFPR alignment. I argue that this assessment application has ignored the roadway tier 1 classifications because the cost impact for mitigating contaminants which will spread swiftly and easily in the soft ground predominantly covering the North Delta section of the alignment. With some further study a reasonable cost estimate should be made and added to the SFPR costs summary. However, annotation of the drawings to include contamination in proximity to roadways should be done so that a more complete picture of the contamination is available to the public and Environmental Office.

Some of the challenges not discussed: given any tier 1 site with hydrocarbons & heavy metals treatment costs about 10 years ago (from my experience) were $2500 to $3500 per ton. Treatments at that time were typically thermal or biological. As that industry had been peddling the same mediocre ideas for fifty years prior to my work in the field, I'll make the bold assumption, that there are not any outstanding alternatives even now.

The biological often had the shortcomings of long treatment time and only 90% reduction of hazardous materials given perfect environmental conditions (So this rarely happened), biological treatments often only attack a very narrow range of chemical species, thus making multi-contaminant sites unfeasible for bioremediation.

The thermal processes required, at that time, the removal of soils to a treatment facility, to a process which rendered the soils entirely inert. The resulting material is devoid of any capability to support vegetation or invertebrate life. Given the predominant bio-matter composition of the soils surrounding Burns Bog, thermal processes are likely to be undesirable. The remaining soil mass would be largely carbon and silts, but of considerably less volume than what was removed. To refill a treated site, common fills of porous aggregates would be required to permit water exchange from Fraser River to the Bog. Due to the generally limited knowledge of how the raised mound bog operates, it cannot be reasonably determined how such a change of ground type will impact the Bog. This presents a considerable risk to the viability of the Bog, one which can absolutely not be mitigated by payments in like-kind protection programs or by experimenting with a new untested technology.

Conclusion,

The content of Technical volume 8 minimally shows that the proponent has made the initial foray into determining the risk locations in proximity to the alignment. Risk level is crudely identified, but with a substantial margin of error given that little if any actual site testing was carried out in preparation for this assessment application.

Given the early stages of engineering evaluation and review, this is in the correct stage of evaluation, what is difficult for me as a member of the public, and a practicing engineer, to understand is how this data could be considered adequate to render a decision on issuance of a certificate for continuance of this project.

My limited understanding of the environmental assessment tells me that the process is employed to determine what risks exist and what strategies can be employed to eliminate or mitigate such risks. However, the sheer lack of data in this one document makes such a determination very nearly impossible as far as I can ascertain.

If a crude profile with quantified toxic and hazardous materials data is not available, no one can estimate or even approximate the amount of damage that might be done should the material not be contained as expected. Should there be materials that are unreported or unknown, they would not be discovered until long after all other options for the alignment have been abandoned. Without any sense of the potential damage that a contamination source might cause, how is it possible to assign requirements for mitigation of the affects of such a release? And in the absence of comparative alternative routes, there is no opportunity to capitalize on possible benefits such an alternative might offer to eliminate the risks.

I find this process bureaucratically circumvents proper Engineering thinking in the interest of minimizing immediate costs, at the expense of our future health and environmental well being.

Were I given this report by my subordinates, I would not grant a certificate under any circumstances due to the lack adequate evaluative data and lack of alternative solutions evaluations.

Simply put: The survival and protection of the local environment cannot be adequately determined on the basis of the data presented in Technical Volume 8. As a tax payer I earnestly demand that this application not be granted a certificate.