Section 6

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SECTION 6

ENVIRONMENTAL EFFECTS
ASSESSMENT
Table of Contents
6 ENVIRONMENTAL EFFECTS ASSESSMENT ..................................................................6-1
6.1 PHYSICAL ENVIRONMENT .................................................................................................. 6-1
6.1.1 Groundwater............................................................................................................ 6-1
6.1.1.1 Boundaries and Threshold .................................................................................. 6-1
6.1.1.2 Interactions and Potential Effects ........................................................................ 6-4
6.1.1.3 Mitigation .......................................................................................................... 6-5
6.1.1.4 Potential Residual Effects ................................................................................... 6-6
6.1.1.5 Monitoring and Follow-up ................................................................................... 6-6
6.1.2 Surface Water .......................................................................................................... 6-6
6.1.2.1 Boundaries and Threshold .................................................................................. 6-6
6.1.2.2 Interactions and Potential Effects ...................................................................... 6-10
6.1.2.3 Mitigation ........................................................................................................ 6-11
6.1.2.4 Potential Residual Effects ................................................................................. 6-12
6.1.2.5 Monitoring and Follow-up ................................................................................. 6-13
6.1.3 Climate.................................................................................................................. 6-13
6.1.3.1 Boundaries and Threshold ................................................................................ 6-15
6.1.3.2 Interactions and Potential Effects ...................................................................... 6-16
6.1.3.3 Potential Residual Effects ................................................................................. 6-22
6.1.3.4 Monitoring and Follow-Up ................................................................................. 6-22
6.1.4 Air Quality ............................................................................................................. 6-22
6.1.4.1 Boundaries and Threshold ................................................................................ 6-22
6.1.4.2 Interactions and Potential Effects ...................................................................... 6-26
6.1.4.3 Mitigation ........................................................................................................ 6-32
6.1.4.4 Potential Residual Effects ................................................................................. 6-33
6.1.4.5 Monitoring and Follow-up ................................................................................. 6-35
6.1.5 Acoustic Environment ............................................................................................. 6-36
6.1.5.1 Boundaries and Threshold ................................................................................ 6-36
6.1.5.2 Interactions and Potential Effects ...................................................................... 6-39
6.1.5.3 Mitigation ........................................................................................................ 6-43
6.1.5.4 Potential Residual Effects ................................................................................. 6-43
6.1.5.5 Monitoring and Follow-Up ................................................................................. 6-43
6.2 ECOLOGICAL ENVIRONMENT ............................................................................................ 6-45
6.2.1 Terrestrial Habitat .................................................................................................. 6-45
6.2.1.1 Boundaries and Threshold ................................................................................ 6-45
6.2.1.2 Interactions and Potential Effects ...................................................................... 6-47
6.2.1.3 Mitigation ........................................................................................................ 6-48
6.2.1.4 Potential Residual Effects ................................................................................. 6-49
6.2.1.5 Monitoring and Follow-up ................................................................................. 6-49
6.2.2 Terrestrial Fauna .................................................................................................... 6-49
6.2.2.1 Boundaries and Threshold ................................................................................ 6-51
6.2.2.2 Interactions and Potential Effects ...................................................................... 6-53
6.2.2.3 Mitigation ........................................................................................................ 6-55
6.2.2.4 Potential Residual Effects ................................................................................. 6-56

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6.2.2.5 Monitoring and Follow-up ................................................................................. 6-56
6.2.3 Freshwater Fish and Fish Habitat ............................................................................. 6-57
6.2.3.1 Boundaries and Threshold ................................................................................ 6-57
6.2.3.2 Interactions and Potential Effects ...................................................................... 6-60
6.2.3.3 Mitigation ........................................................................................................ 6-62
6.2.3.4 Potential Residual Effects ................................................................................. 6-62
6.2.3.5 Monitoring and Follow-up ................................................................................. 6-62
6.2.4 Species at Risk ....................................................................................................... 6-64
6.2.4.1 Boundaries and Thresholds............................................................................... 6-64
6.2.4.2 Interactions and Potential Effects ...................................................................... 6-66
6.2.4.3 Mitigation ........................................................................................................ 6-68
6.2.4.4 Potential Residual Effects ................................................................................. 6-69
6.2.4.5 Monitoring and Follow Up ................................................................................. 6-69
6.3 ECOLOGICAL ENVIRONMENT: MARINE ................................................................................ 6-71
6.4 SOCIO-ECONOMIC ENVIRONMENT ..................................................................................... 6-71
6.4.1 Key Settlements, Land Use, Community Services and Infrastructure ........................... 6-74
6.4.1.1 Boundaries and Threshold ................................................................................ 6-74
6.4.1.2 Interactions and Potential Effects ...................................................................... 6-75
6.4.1.3 Mitigation ........................................................................................................ 6-77
6.4.1.4 Potential Residual Effects ................................................................................. 6-77
6.4.1.5 Monitoring and Follow-Up ................................................................................. 6-78
6.4.2 Economic Development........................................................................................... 6-78
6.4.2.1 Boundaries and Threshold ................................................................................ 6-78
6.4.2.2 Interactions and Potential Effects ...................................................................... 6-79
6.4.2.3 Mitigation ........................................................................................................ 6-80
6.4.2.4 Potential Residual Effects ................................................................................. 6-80
6.4.2.5 Monitoring and Follow-Up ................................................................................. 6-80
6.4.3 Marine Navigation .................................................................................................. 6-80
6.4.3.1 Boundaries and Threshold ................................................................................ 6-80
6.4.3.2 Interactions and Potential Effects ...................................................................... 6-83
6.4.3.3 Mitigation ........................................................................................................ 6-83
6.4.3.4 Potential Residual Effects ................................................................................. 6-84
6.4.3.5 Monitoring and Follow-Up ................................................................................. 6-84
6.4.4 Fisheries, Aquaculture and Marine Harvesting ........................................................... 6-84
6.4.4.1 Boundaries and Threshold ................................................................................ 6-84
6.4.4.2 Interactions and Potential Effects ...................................................................... 6-85
6.4.4.3 Mitigation ........................................................................................................ 6-86
6.4.4.4 Potential Residual Effects ................................................................................. 6-87
6.4.4.5 Monitoring and Follow-Up ................................................................................. 6-87
6.4.5 First Nations Land and Resource Use ....................................................................... 6-87
6.4.5.1 Boundaries and Threshold ................................................................................ 6-87
6.4.5.2 Interactions and Potential Effects ...................................................................... 6-88
6.4.5.3 Mitigation ........................................................................................................ 6-88
6.4.5.4 Potential Residual Effects ................................................................................. 6-88
6.4.5.5 Monitoring and Follow-Up ................................................................................. 6-89

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6.4.6 Archaeology ........................................................................................................... 6-89
6.4.6.1 Boundaries and Threshold ................................................................................ 6-89
6.4.6.2 Interactions and Potential Effects ...................................................................... 6-89
6.4.6.3 Mitigation ........................................................................................................ 6-89
6.4.6.4 Potential Residual Effects ................................................................................. 6-89
6.4.6.5 Monitoring and Follow-up ................................................................................. 6-90
6.5 CUMULATIVE EFFECTS .................................................................................................... 6-90
6.5.1 Cumulative Interactions and Potential Effects on VECs............................................... 6-90
6.6 EFFECTS OF THE ENVIRONMENT ON THE PROJECT ................................................................. 6-98
6.6.1 Extreme Weather ................................................................................................... 6-98
6.6.2 Sea Ice.................................................................................................................. 6-99
6.6.3 Climate Change and Sea Level Rise.......................................................................... 6-99
6.6.4 Seismic Activity .................................................................................................... 6-100
6.6.5 Security ............................................................................................................... 6-100

List of Tables
Table 6-1: Potential Environmental Effects Assessment Matrix for Groundwater ................................... 6-7
Table 6-2: CCME Guidelines for the Protection of Aquatic Life ............................................................ 6-9
Table 6-3: Surface Water Environmental Effects Assessment Matrix ................................................. 6-14
Table 6-4: Baseline greenhouse gas emissions for the 3-year construction phase of proposed Project. 6-17
Table 6-5: Baseline annual greenhouse gas emissions for operations phase of Proposed Project. ........ 6-18
Table 6-6: Regional and national GHG emission inventories for 2012, compared to proposed Project
annual operation GHG emissions.................................................................................................... 6-19
Table 6-7: Potential Environmental Effects Assessment Matrix for Climate......................................... 6-23
Table 6-8: Nova Scotia Air Quality Standards .................................................................................. 6-24
Table 6-9: Canadian Ambient Air Quality Standards ......................................................................... 6-24
Table 6-10: Comparison of Project’s Emissions with NOX Air Emissions Limits ..................................... 6-25
Table 6-11: Estimated Annual Emissions – Proposed Natural Gas Liquefaction Plant (Tonnes/Year) ...... 6-27
Table 6-12: Summary of Industrial Atmospheric Emissions in the Study Area (2013) ........................... 6-28
Table 6-13: Maximum Predicted Concentrations in Ambient Air for the LNG Plant, including LNG Vessel
Hotelling and Background Concentrations at Normal Operation. ........................................................ 6-30
Table 6-14: Maximum Predicted Concentrations in Ambient Air for the LNG Plant with Flaring, including
LNG Vessel Hotelling and Background Concentrations at Normal Operation. ....................................... 6-31
Table 6-15: Potential Environmental Effects Assessment Matrix for Air Quality .................................. 6-34
Table 6-16: Health Canada Approach to Noise Assessment ............................................................... 6-38
Table 6-17: LNG Facility Construction Sound Levels at Off-Site Receptors ......................................... 6-40
Table 6-18: LNG Facility Operation Sound Levels at Site Boundary and Off-Site Receptors .................. 6-42
Table 6-19: Potential Environmental Effects Assessment Matrix for the Acoustic Environment ............. 6-44
Table 6-20: Potential Environmental Effects Assessment Matrix for Terrestrial Habitat ........................ 6-50
Table 6-21: Potential Environmental Effects Assessment Matrix for Terrestrial Fauna .......................... 6-58
Table 6-22: Potential Environmental Effects Assessment Matrix for Freshwater Fish and Fish Habitat .... 6-63
Table 6-23: Potential Environmental Effects Assessment Matrix for Species at Risk ............................ 6-70
Table 6-24: Potential Environmental Effects Assessment Matrix for Marine Habitat............................. 6-72
Table 6-25: Potential Environmental Effects Assessment Matrix for Marine Life ................................. 6-73
Table 6-26: Roles of Marine Authorities within the Strait of Canso .................................................... 6-82

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Table 6-27: Overview of Socio-economic Consequences of Bear Head LNG Project ............................ 6-91

Appendices
G: Air Quality Assessment
H: Noise Assessment Study

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6 ENVIRONMENTAL EFFECTS ASSESSMENT

6.1 Physical Environment

6.1.1 Groundwater

Groundwater is important because of its vital role in the hydrologic cycle, its ecological function (i.e.,
surface water discharge) and as a water supply. Precipitation and surface water infiltrate the ground,
where it fills voids in unconsolidated materials and fractures in consolidated materials. Interaction
between surface water and groundwater can occur where the water table (upper surface of the
saturated zone) meets the surface at springs, lakes, and streams. Based upon the potential effects of
further Project activity, groundwater is considered a VEC for the following reasons:
 Changes to the groundwater table and groundwater usage have the potential to affect other
environmental components including terrestrial habitat (particularly wetlands), freshwater fish
and fish habitat, and surface water quantity and quality;

 Contamination of groundwater sources can cause long-term adverse effects on the environment;
 Potential risk to human health in the event of groundwater contamination; and
 Because groundwater can be a pathway for contaminant migration to other environmental
components, i.e., aquatic and terrestrial receptors.

6.1.1.1 Boundaries and Threshold

Spatial

The spatial boundaries are based upon:

 Hydraulic properties of the aquifer;


 Flow direction;
 Distance between wells, Project activities (construction, operation, or decommissioning) and
ecological receptors;
 Aquifer capture area; and
 Geological characteristics, as related to seismic properties and response to damage from
vibration (wells in soft bedrock, such as sandstones and shales, are less susceptible to damage
from vibration and seismic activity).
As described in the 2004 Bear Head LNG environmental assessment, a typical domestic (low-yield)
water well capture zone is less than 100 m. Minimal damage from blasting and vibration is expected to

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occur to these wells at any distance greater than 200 m. To provide commentary on risk to damaging
water wells and in accordance with the Nova Scotia Environment Procedure for Conducting a Pre-Blast
Survey, a value of 800 m was chosen as a spatial boundary (NSE, 2009). A pre-blast survey is required
for any well within this zone.

Temporal

Most construction-related physical effects on groundwater resources will be temporary in nature, while
the potential for chemical effects from spills exists through all phases of the Project. Spill impacts may
be short or long-term, depending on factors such as the type of substance and quantity of the
substance spilled. It could take many years to remediate a severely contaminated site. The major
components contributing to risk of a groundwater contamination are petroleum, oil and lubricants
(POL), and chemicals used in the construction, operation or decommissioning phases of the Project.

Administrative

The following guidelines, standards and regulatory requirements pertaining to water and water quality
apply to all operations at the Bear Head LNG site that may generate spills of potential contaminants,
including hydrocarbons:
 CEPA
 Atlantic RBCA (Risk-Based Corrective Action) for Petroleum Impacted Sites in Atlantic Canada,
Version 3 (January 2015)
 For potential health and environmental issues involving petroleum hydrocarbon spills
 Nova Scotia standard for evaluating petroleum hydrocarbons in groundwater is the Risk-
Based Screening Level (RBSL)
 CCME Canadian Environmental Quality Guidelines (2007)
 Water supplies, recreational water, Canadian water quality guidelines, water quality
guidelines for the protection of aquatic life and agricultural uses

 Health Canada Guidelines for Canadian Drinking Water Quality (2014)


 Drinking water quality parameters
 Applicable only for water being withdrawn and used as potable water
 Nova Scotia Water Resources Protection Act
Although consideration has been given to drilling wells to provide potable water at the facility, it is
more likely that drinking water will be trucked from adjacent municipal water supplies. Process water,
however, may be provided by wells and treated as necessary to ensure compliance with provincial

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regulations. This will include obtaining a Water Withdrawal Approval from NSE. If production wells are
drilled, all necessary steps will be taken to protect the nature and quality of the aquifer and
watershed.

Technical

As described in the Baseline Environmental Site Assessment (ESA) (JW, 2007), there are a number of
boreholes and monitoring wells on the Project site as shown on Figure 4-2. On October 22nd, 2014, a
site visit was conducted in search for these wells. The only one that was found was MW-5. It is
believed that many were buried during the construction and subsequent maintenance of the existing
infrastructure (roads, ditches and site clearing). Monitoring wells located along the property boundaries
could not be located although there are still clearly marked cut-lines. The cut-lines along the property
boundaries were used to locate the previous surface water sampling locations. It is pertinent that the
aquifer below the Project site does not provide water to either a municipal supply or to a residential
well.

Thresholds

The following evaluation criteria are used to determine whether a residual environmental effect on
groundwater is significant, not significant, or positive:
A significant adverse effect would occur should groundwater on site be impacted by petroleum
hydrocarbons above criteria stipulated by Partners in RBCA Implementation (PIRI); and/or physical or
chemical changes to the aquifer is such that interaction with surface water alters stream flow or
chemistry, in turn adversely affecting aquatic life. The results of water quality analysis will be checked
against the CCME Water Quality Guidelines to ensure the protection of relevant water uses, but
specifically for aquatic life and the supply of drinking water. The results shall be used as the basis for
evaluating the significance of any measured change.
An adverse affect that does not exceed the stipulated criteria is considered not significant.
A positive effect is one that enhances the quality of the aquifer or groundwater-fed surface water.
The relative magnitude ratings defined below are used to establish the magnitude of a residual effect
on groundwater:
High: A change in groundwater relative to baseline, which causes exceedances of standards and
guidelines, or extends beyond the Project site.
Medium: A change in groundwater relative to baseline, which is within the Project site and within
standards and guidelines.
Low: A change in groundwater that is within the normal variability of baseline conditions.

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6.1.1.2 Interactions and Potential Effects

Construction

Construction and site work may involve clearing, grubbing and stripping of topsoil. A large portion of
this preparatory site work has already been performed, but the tasks remaining will likely require some
additional grading work and the placement of excess material to temporary piles. As shown in Figure 4-
2, all residential wells are located more than 800 m away from the Project site, substantially minimizing
any risk of damage from blasting, should the latter prove necessary, or vibration during construction.
Figure 4.2 also shows that there are no residential or community wells within the depicted watershed.
In the unlikely event that contaminants did enter the aquifer below the Project site, there would be no
impact on private wells or community water supply.
The main source of contamination during construction is associated with the accidental spill of POL or
chemicals from equipment and their operation. There is also a risk of contamination occurring from the
wastewater used to clean the concrete truck troughs, or wastewater generated by an onsite concrete
batch plant, if this option is selected for the Project.

Operations and Maintenance

LNG vapourizes at -160oC which means that there is very little risk of LNG entering the aquifer and
groundwater table in the event of an accident. The main source of potential contamination during the
normal operation and maintenance of the facility would be related to the accidental spill of POL or
chemicals from equipment and their operation. Contaminants, for example, could be transported over
the site to aquifer points of entry by storm water. Should on-site production wells be used to supply
process or potable water, the quantity of water in the aquifer(s) may also be affected.

Accidents and Malfunctions

Accidents and malfunctions may affect groundwater by exposing aquifers to chemical and POL
contamination from spills. The risk of these contaminants impacting groundwater is present during all
phases of the Project, i.e., construction, operation and decommissioning.

Decommissioning

Activities during the decommissioning phase of the Project are expected to present the same risks to
groundwater as during the construction phase. Potential effects to groundwater during this phase will
be considered and addressed in a decommissioning plan which would be developed prior to
decommissioning and incorporate future relevant standards and regulations.

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6.1.1.3 Mitigation

Best management practices will be detailed in the Environmental Management Plan (EMP) and
associated EPPs to prevent spillages and accidents that would impact the aquifer and groundwater.
Detailed mitigation measures to be executed in response to an accidental spillage of hydrocarbon or
other hazardous agent will be explicit in the EPP; they will include the following:

 Handling of chemical and hazardous substances and hazardous wastes storage in accordance
with manufacturers’ recommendations and applicable federal and provincial regulations;
 Secondary containment for tanks in which diesel fuel is stored;
 Training in chemical storage and handling for all on-site staff;
 Installation of safety measures including leak alarms, emergency shutdown systems, spill
containment and provisions to protect piping from the effects of transient pressure variations;
 Maintenance of equipment in good working order and execution of efficient monitoring
protocols for leaks;

 Storage, stockpiling and use of fuel, lubricant and other hazardous substances in designated
areas outside of buffer zones designed to protect sensitive habitats including surface water
and wetlands;
 Development and implementation of a Spill Management Plan to include the immediate clean-
up, containment and removal of impacted groundwater and the removal and proper disposal
of impacted soil; and
 The restoration of any damage to residential wells in the surrounding area that can be shown
to have resulted from activities at the Project site and the provision, if needed, of a temporary
source of potable water.
In the event that groundwater wells are established on site, the necessary authorizations will be sought
from NSE and the wells will be operated in accordance with accepted best management practices.
Entry to groundwater wells will be controlled and limited in order to prevent potential contamination of
groundwater resources.
Any effects occurring during the decommissioning phase of the Project will be mitigated as prescribed
in the Decommissioning Plan, which would be developed prior to decommissioning and incorporate the
current standards and regulations.

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6.1.1.4 Potential Residual Effects

With the implementation of the identified mitigation measures, significant adverse residual effects to
groundwater are not likely to occur. A matrix depicting the potential effects to groundwater, associated
mitigation measures and determination of residual effects is presented in Table 6-1.

6.1.1.5 Monitoring and Follow-up

Baseline monitoring will be performed prior to any additional site work, and a groundwater monitoring
program will be maintained over the life of the Project in accordance with requirements stipulated by
NSE. Monitoring locations will be established down-gradient of hazardous materials storage areas and
at the property boundaries. Two monitoring wells will be established upstream of the Project site to
monitor background concentrations in groundwater.

6.1.2 Surface Water

Surface water is a VEC because of its contribution to the health of fish and fish habitat and wetlands,
and its linkage to terrestrial and marine ecosystem components, recreational activities and
groundwater. Any changes to surface water flows, quantity or quality, could potentially affect
groundwater recharge, aquatic life, terrestrial and marine ecosystems, and human health.

6.1.2.1 Boundaries and Threshold

Spatial

The development on the Project site affects three watershed areas and two small surface water
streams, namely Stream A (west) and Stream B (east). Stormwater has been rerouted around the
north side of the Project site using open channel hydraulics. This reconnects to a small wetland,
Stream B, and the estuary. Rerouting storm water away from Project activities minimizes the risk of any
contamination to surface water bodies. Stormwater that is not diverted and runs over the Project site
will be channelled to the jetty sedimentation pond. Although the property borders the coast, Streams A
and B extend beyond the property boundary downstream an additional 350 and 450 m respectively.
Surface water analysis included surface waters from within the property boundary, downstream
portions of Streams A and B and their estuaries. Increased runoff from the site would be expected to
increase the flow in the streams to the east and west of the site. Based on the comparative catchment
area of theses streams, the predicted increase in runoff as a result of the proposed development is
expected to be on the order of 2% of the annual mean flow at the western stream, and 5% of the
annual mean flow at the eastern stream. Best management practices for quality control can be
implemented to balance site runoff to pre-development levels.

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Table 6-1: Potential Environmental Effects Assessment Matrix for Groundwater
Significance Criteria
Activity Effect Mitigation Magnitude Geographic Duration/ Reversibility Eco/Socio Context Significance
Extent Frequency
Construction and Commissioning
Clearing, grubbing, and grading  Spill of POL or chemicals from construction  Avoid blasting within 800 m of residential Low 1 km around 1-36 months/ Reversible Developed area with Not significant
(majority of which is complete) equipment or wastewater may enter the aquifer wells Project area < 11 events/year no residential wells
 Grading may expose additional points of entry to  Perform a pre-blast well survey within 1 km around
the aquifer  Restore damaged wells and provide Project site
 Building/construction of roads (i.e. blasting) could temporary water to residents affected
cause fracture of nearby underground  Follow emergency spill and POL cleanup
infrastructure, geology and impact ground water procedures
quality
Operation and Maintenance
Operation of LNG liquefaction  Spill of POL or chemicals from equipment and  Attain necessary approvals Low 1 km around >72 months Reversible Developed area with Not significant
trains, supporting infrastructure operations (leaks, malfunctions or system  Follow Operations Manual Project area Continuous no residential wells
and LNG storage. backups) may enter the aquifer  Create stormwater bypass for water to within 1 km around
Wastewater treatment system  Should on-site production wells be employed to minimize potential for contamination Project site
Stormwater management system supply process or potable water requirements, the  Ensure stormwater passing over site is
quantity of water in the aquifer(s) may also be diverted to sedimentation ponds
affected  The wastewater (sewage) treatment system
 Domestic wastewater effluent may enter aquifer if will be designed (operation and disposal)
not disposed of properly based upon provincial and national standards
 Stormwater running over Project site could be
contaminated and follow a point of entry to the
aquifer
Accidents and Malfunctions
Sedimentation or erosion,  Majority of earthwork has been performed  Restore damaged wells and provide Low 1 km around >72 months Reversible Developed area with Not significant
particularly during construction  Additional work being perform could release temporary water to residents affected Project area Continuous no residential wells
Spills or accidents sediments to surface water and contaminate  Follow emergency spill and POL cleanup within 1 km around
Accidental explosions (vibrations) aquifers and surface water with spills (POL and procedures as prescribed in the EPP Project site
chemical)
 Accidental explosions could cause damage to
wells and underground infrastructure
Decommissioning
Facility decommissioning  Effects expected to be similar to those during  Restore damaged wells and provide Low 1 km around 1-12 months Reversible Developed area with Not significant
construction temporary water to residents affected Project area < 11 events/year no residential wells
 POL from construction equipment may enter the  Follow emergency spill and POL cleanup within 1 km around
aquifer (contamination of aquifer) procedures as prescribed in the EPP Project site
 Follow a decommissioning plan

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Temporal

Vehicular movements and exposed soils are the most likely sources of contamination during
construction to surface waters. Such construction-related physical effects on surface waters will be
temporary in nature and can be addressed through good management practices. The potential for
chemical effects from spills exists through all phases of the Project. Depending on various factors, spill
impacts may be short or long-term, e.g., the substance spilled, the quantity spilled and the time to
detection; the nature of the spill will be determine the remediation timeline necessary to return the
impacted surface waters to a pre-impacted state.

Administrative

Increased runoff presents a potential for increased sediment loading and higher temperatures. To
reduce environmental risk and protect existing habitat from contaminants entrained in stormwater
runoff, it is important to establish quality objectives for the proposed development. In large measure
these have been established by federal and provincial authorities. The Fisheries Act, for example,
prohibits the release of deleterious substances into waters frequented by fish or that may eventually
enter waters frequented by fish.
The following guidelines, standards, and regulatory requirements related to surface water will apply to
the Project:

 CCME Canadian Environmental Quality Guidelines (2007)


 Water supplies, recreational water, Canadian water quality guidelines, water quality
guidelines for the protection of aquatic life and agricultural uses
 Fisheries Act - Deleterious Substance Provisions
 CEPA
 Nova Scotia Environment Act
 Nova Scotia Water Resources Protection Act
 Nova Scotia Environment Erosion and Sedimentation Control Handbook for Construction Sites,
1988 and updates

 Nova Scotia Department of Transportation and Infrastructure Renewal Standard


Specifications, 2011
According to the Canadian Water Quality Guidelines for the Protection of Aquatic Life (CCME, 1999), the
most important parameters to consider to protect aquatic life in surface waters are TSS and turbidity.
Table 6-2 describes the guideline values of each of these parameters.

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Table 6-2: CCME Guidelines for the Protection of Aquatic Life1

Guideline Value
Parameter
Clear Flow High Flow
Maximum increase of 25 mg/L from
Maximum increase of 25 mg/L from background levels at any time when
background levels for a 24 hour period; and background levels are between 25 and 250
Total Suspended mg/L.
Solids (TSS) Maximum average increase of 5 mg/L from
background levels for exposure between 24 Should not increase more than 10% of
hours and 30 days background levels when background is
greater than 250 mg/L.
Maximum increase of 8 NTU from
Maximum increase of 8 Nephelometric
background levels at any one time when
Turbidity Units ( NTUs) from background
background levels are between 8 and 80
levels for a 24 hour period; and
NTUs.
Turbidity
Maximum average increase of 2 NTUs from
Should not increase more than 10% of
background levels for levels of exposure
background levels when background levels
between 24 hours and 30 days.
are above 80 NTU.

Stormwater quality objectives for the proposed development will be established that adhere to the most
stringent municipal, provincial and federal recommendations. In the absence of applicable site-specific
guidelines, methods developed for other Canadian jurisdictions may be considered. For example, the
Stormwater Management Planning and Design Manual developed by the Ontario Ministry of the
Environment quantifies TSS removal based on existing conditions and habitat sensitivity. Existing site
conditions may require enhanced protection for the post-development stormwater management
scenario. This level of protection requires removal of 80% of TSS in stormwater runoff. A number of
methods can be used to help reduce water quality concerns and meet the minimum water quality
targets.
Stormwater Best Management Practices (BMP) to meet water quality and quantity targets can take
many forms including the creation of wet or dry detention ponds, the construction of wetlands,
underground storage, roof leaders to surface storage or ponding areas, vegetated swales, the
installation of filter strips, infiltration chambers or oil/grit separators. The existing site development
includes two (2) sedimentation detention ponds and extensive surface water controls.

1
Reference: http://ceqg-rcqe.ccme.ca/en/index.html#void

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Technical

There is sufficient data and knowledge regarding the surface water at the Project site to adequately
conduct the effects assessment.

Thresholds

The following evaluation criteria are used to determine whether a residual environmental effect on
surface water is significant, not significant or positive:
A significant adverse effect would occur if surface water was impacted by petroleum hydrocarbons
above the CCME Guidelines for the Protection of Aquatic Life; or alteration of stream flow or chemistry
resulted in adverse effects to aquatic life. Increased levels of turbidity or TSS are also of concern and
may have an adverse effect if levels described in Table 6-2 are exceeded.
An adverse effect that does not exceed the above criteria is considered not significant.
A positive effect is one that enhances the quality of the surface water.
The relative ratings defined below are used to establish the magnitude of a residual effect on surface
water:
High: A change in surface water relative to baseline, which causes exceedances of standards and
guidelines, or extends beyond the Project site.
Medium: A change in surface water relative to baseline within the Project site that is within standards
and guidelines.
Low: A change in surface water, that is within the normal variability of baseline conditions.

6.1.2.2 Interactions and Potential Effects

The key interactions between the Project and surface water with the potential to result in adverse
effects include:
 Construction-related land disturbance resulting in erosion and leading to increased levels of
TSS and turbidity in surface water;

 Contaminated stormwater discharges resulting from rerouted water or water flowing over the
Project site;

 Wastewater discharge from construction activities, operations and maintenance, and


decommissioning; and
 Sanitary wastewater discharge.

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Construction

Initial site work, i.e., clearing, grubbing and stripping of topsoil, has been largely completed. The tasks
remaining may require the placement of excess material on temporary piles and, perhaps, limited
blasting. These activities have the potential to cause erosion and sediment transport into surface
waters.
Any impacts to on-site surface waters, including wetlands and streams, will most likely be a result of
erosion, sediment transport or chemical contamination from stormwater runoff. There is also a risk of
contamination from alkaline wastewater used to rinse concrete troughs.
Off-site surface water contamination, if any, is not expected to be significant as the site-grading
provides that runoff from the site is directed to one of two sedimentation ponds currently existing on
site (the Jetty and Eastern Sedimentation Ponds). This water will be discharged to the marine
environment once it has been shown to meet provincial and federal regulatory requirements.

Operation and Maintenance

Once constructed and in operation, the Project may impact surface waters through stormwater runoff
(POL from spills, chemicals and sediments from erosion), increased stormwater flows resulting from a
change in surface porosity, the discharge of sanitary wastewater and the discharge of water from
demineralization units.

Accidents and Malfunctions

Accidents and malfunctions may affect surface waters by causing them to be exposed to chemicals,
POL spills and stormwater runoff. The risk of accidental events or malfunctions impacting surface
waters is present during the construction, operation and decommissioning phases of the Project.

Decommissioning

The effects of the decommissioning process on surface waters are expected to be similar to those
incurred during the construction process. These will be addressed in a decommissioning plan which
would be developed prior to decommissioning and incorporate future relevant standards and
regulations.

6.1.2.3 Mitigation

The potential contributors to adverse effects on surface waters are stormwater runoff and construction
and sanitary wastewaters. Each of these has the potential to carry contaminants, such as POL,
chemicals and sediments from erosion. Stormwater diversion has been created such that water
upstream from site will be diverted to Stream B and water flowing over the site will be diverted to

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sedimentation ponds. Additional mitigation measures, such as silt fences, sedimentation and erosion
controls, soil and stockpile covers, sedimentation ponds and appropriate wastewater treatment
methods will be employed as warranted to minimize the likelihood of such effects. The alkaline waters
used to wash concrete truck troughs will be collected in a basin and neutralized to a pH range
acceptable for discharge to the Strait. Construction may need to be suspended during extreme weather
events, such as high precipitation.
Mitigation measures and BMP to prevent and respond to a petroleum or hydrocarbon spill will be
detailed in the EPP and will include the following:

 Chemical storage and handling in accordance with manufacturers’ recommendations and


applicable federal and provincial regulations;
 Secondary containment for diesel storage tanks;
 Training in chemical storage and handling for all on-site staff;
 Installation of safety measures including leak alarms, emergency shutdown systems, spill
containment and provisions to protect piping from the effects of transient pressure variations;
 Provision of accessible spill kits;
 Maintenance of equipment in good working order and execution of efficient monitoring
protocols for leaks;
 Storage, stockpiling and use of fuel, lubricant and other hazardous substances in designated
areas outside of buffer zones designed to protect sensitive habitats including surface water
and wetlands;

 Development and implementation of a Spill Management Plan to include the immediate clean-
up, containment and removal of impacted surface water and the removal and proper disposal
of impacted soil; and

 Installation of concrete wash containment.


Any effects during the decommissioning phase of the Project will be mitigated as prescribed in the
Decommissioning Plan, which would be developed prior to decommissioning and address the prevailing
standards and regulations.

6.1.2.4 Potential Residual Effects

With the implementation of the identified mitigation measures, significant adverse residual effects to
surface water are not likely to occur.
A matrix depicting the potential effects to surface water, associated mitigation measures and the
determination of residual effects is presented in Table 6-3.

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6.1.2.5 Monitoring and Follow-up

Baseline monitoring will be performed prior to any additional site work, and a surface water monitoring
program will be maintained over the life of the Project in accordance with requirements stipulated by
NSE. Monitoring locations will be established, for example, at streams A and B and in the vicinity of
POL storage. Any additional monitoring required to achieve environmental compliance will be outlined
in the EPP. A baseline surface water monitoring program was undertaken in 2014, providing analytical
results for general chemistry. Once onsite activities resume, a water monitoring program will be
coordinated in NSE.

6.1.3 Climate

Climate change refers to the observed rise in the average temperature of the Earth’s climate systems
over the past 100 years, driven by increasing concentrations of GHGs produced by human activities
(IPCC, 2013). Climate change is a public concern in Nova Scotia due to the expected impacts on sea
levels, weather patterns (including extreme events), fish stock distributions, and snow and ice extents
(Climate Change Nova Scotia, 2009).
This section outlines a GHG assessment related to the proposed Project. It includes a discussion of the
proposed Project boundary with respect to anticipated emissions, Project emission inventory and
facility emission intensity, and expected mitigations through the application of best available control
technologies (BACTs). This GHG assessment follows provincial guidance on considering climate
change:
 Guide to Considering Climate Change in Environmental Assessments in Nova Scotia (Nova
Scotia Environment, February 2011); and
 Guide to Considering Climate Change in Project Development in Nova Scotia (Nova Scotia
Environment, February 2011).

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Table 6-3: Surface Water Environmental Effects Assessment Matrix
Significance Criteria
Activity Effect Mitigation Magnitude Geographic Duration/ Reversibility Eco/Socio Context Significance
Extent Frequency
Construction and Commissioning
Clearing, grubbing, and grading  The construction process may lead to increased levels  Diversion of stormwater runoff (upstream from site) to Stream B Low On-site 1-36 months/ Reversible Developed area Not
(majority of which is complete) of TSS, turbidity or high pH values in surface  Diversion of stormwater runoff (on-site) to sedimentation ponds 1-10 km < 11 Municipal supply not close to significant
watercourses or bodies  Implementation of EPP, which shall include erosion and sediment events/year Project site
Wastewater resulting from construction  Clearing and grubbing could contribute to land control, buffer zones, stormwater management plan, and spill Sedimentation ponds have
process (i.e. concrete wash waters) erosion, thus, affecting the quality of surface waters prevention and emergency response plan been construction
 Grading could change surface water courses  Designated fueling site for equipment located away from surface
 Spills of POL and chemicals from construction areas Note: Majority of this work
equipment in runoff to surface water  Installation of silt fences and berms has already been performed
 Restrict the removal of riparian plants to appropriate setbacks from
surface waters
 Concrete wash waters will be collected and treated prior to discharge
Operation and Maintenance
Operation of LNG liquefaction trains,  Contamination of surface water from runoff and spills  Diversion of stormwater runoff (upstream from site) to Stream B Low On-site >72 months Reversible Developed area Not
supporting infrastructure and LNG (POL, chemicals, and TSS)  Diversion of stormwater runoff (on-site) to sedimentation ponds 1-10 km Continuous Municipal supply not close to significant
storage.  Contamination of surface water from wastewater  Implementation of EPP, which shall include erosion and sediment Project site
Wastewater treatment system effluent/discharge control, buffer zones, stormwater management plan, and spill Sedimentation ponds have
Stormwater management system prevention and emergency response plan been construction
 Re-vegetation of disturbed soils, if required
 Designated fueling site for equipment located away from surface
waters
 Installation of silt fences and berms
 Treatment of wastewater compliant with provincial and federal
requirements
Accidents and Malfunctions
Spills or accidents  Contamination of surface water from runoff and spills  Diversion of stormwater runoff (on-site) to sedimentation ponds Low 1 km around >72 months Reversible Developed area Not
(POL, chemicals)  Spill kits accessible at all times Project area Continuous Municipal supply will not significant
  Implementation of EPP, which includes spill prevention and close to the Project site
 emergency response plans Sedimentation ponds

Decommissioning
Facility decommissioning  Effects expected to be similar to those during  Implementation EPP, including spill prevention and emergency Low 1 km around 1-12 months Reversible Developed area Not
construction. response plans Project area < 11 Municipal supply not close to significant
 The decommissioning process may lead to increased  Diversion of stormwater to appropriate areas events/year Project site
levels of TSS or turbidity in surface watercourses or  Re-vegetation of disturbed areas, if required Sedimentation ponds have
bodies  Follow a decommissioning plan been construction
 Spills of POL and chemicals from construction
equipment in runoff to surface water

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6.1.3.1 Boundaries and Threshold

Spatial Boundaries

The spatial boundary of the GHG assessment includes all activities on the proposed Project footprint,
from feedstock gas entering the facility (at the gas metering station) to the berthing operations of the
LNG marine tankers. The following activities are not included in the GHG assessment because they are
outside the control of the proponent of the proposed Project:
 Marine LNG tankers while underway and all tug associated activities;
 Upstream natural gas extraction and transportation to the facility;
 GHG emissions associated with electricity generation for electricity consumed on site; and
 Downstream LNG transportation and usage.
Although impacts to climate change caused by GHG emissions can have far reaching effects that span
the globe, these are hard to quantify and impossible to link to a single project. It is assumed that if
impacts to climate change are negligible at the national scale, then they will not have a significant
impact globally. Therefore, GHG emissions associated with the proposed Project will be evaluated on a
regional (Nova Scotia) and national scale (Canada).

Temporal Boundaries

The temporal boundaries for the GHG assessment include the construction, operation and
decommissioning phases of the Project. Construction is expected to last approximately 3 years.
Operational emissions will be constant over the life of the Project.

Administrative Boundaries

The Province of Nova Scotia passed the Environmental Goals and Sustainable Prosperity Act in 2007,
which requires GHG emissions to be reduced to 10% below 1990 levels by 2020. To reach this goal,
the Greenhouse Gas Emissions Regulations, passed in 2009 under the Environment Act, established
absolute GHG targets for the electricity sector, which produces half of the province’s GHG emissions.
No provincial GHG regulations currently exist for the LNG industry; the proposed Project has taken a
“Beyond No Regrets” approach in technology selection.
The “Beyond No Regrets” approach involves the implementation of BACTs to ensure that the facility
meets any future regulatory requirements to the degree possible. NSE is currently in the preliminary
stages of investigating best management practices for GHG emissions from LNG facilities within the
framework of the 2007 Environmental Goals and Sustainable Prosperity Act. Mitigation measures may
be defined and the proponent of the proposed Project commits to continue to collaborate with NSE on
relevant GHG policies as the latter are finalized.

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Threshold for Significance

A relative magnitude rating was also established for climate impacts. The following criteria are
considered when determining the significance of an effect:
High: An environmental effect that can significantly impact regional GHG emissions by greater than
5%.
Medium: An environmental effect that can impact regional GHG emissions by between 1-5%.
Low: An environmental effect that does not impact regional GHG emissions (less than 1%)

6.1.3.2 Interactions and Potential Effects

The Project related interactions with the climate due to the combustion of fossil fuels and the removal
of CO2 entrained in the feedstock gas. Diesel will be the primary fuel used during construction and
decommissioning and natural gas will be the primary fuel used during operation. This section outlines
the GHG emissions associated with construction, operation and decommissioning.
The GHG species considered in the assessment include CO2, CH4 and N2O. Other GHG species such as
HFCs, CFCs and SF6 were not included because no emissions of these species are expected given the
technology proposed for the facility. All GHG emissions are reported in tonnes (or kilotonnes) of CO2
equivalent (CO2e), which accounts for the different global warming potential (GWP) values of the GHG
species.

Construction

Construction of the proposed Project is expected to last approximately 3 years. The GHG source
included in the proposed Project’s construction GHG emissions inventory was diesel combustion
associated with construction equipment. Activity levels, emission factors and emissions are
summarized in Table 6-4. Emission factors are sourced from the Environment Canada 2012 National
Inventory Report and activity levels were provided by the proponent. GHG emissions associated with
land clearing were not included because the site has already been largely cleared and the expanded
footprint requires less than 5% of additional clearing of existing carbon sink vegetation. Therefore, any
climate change impact would be insignificant.

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Table 6-4: Baseline greenhouse gas emissions for the 3-year construction phase of
proposed Project.

Emission source Activity level Emission factor GHG emissions (t CO2e)

Construction diesel
24,000,000 L 2.994 kg CO2/L 71,900
consumption
TOTAL 71,900

Operation

The following GHG sources were included in the proposed Project’s operations GHG emissions
inventory:
 Stationary combustion of natural gas for compressors, auxiliary heaters and thermal oxidizers;
 Stationary combustion of diesel for emergency equipment, e.g., generators, water pumps,
etc.;
 Flaring of natural gas in three flares (cold, warm, and marine flares);
 Fugitive emissions of CO2 and CH4 from onsite infrastructure, piping and equipment;
 Removal of CO2 entrained in the natural gas feedstock; and
 LNG tankers maneuvering in and out of dock, and auxiliary engine activities at berth.
Data was provided by the proponent based on the expected activities at the facility based on 4 LNG
trains operating at a production level of 8 mtpa. Table 6-5 summarizes the baseline facility GHG
emissions.
The GHG calculation methodology used to develop the inventory was the Western Climate Initiative
(WCI) reporting requirements (World Climate Initiative, 2011). The WCI methodology is the GHG
calculation methodology used for mandatory GHG reporting by facilities in California, British Columbia,
Ontario and Quebec. The GWP values used in the WCI methodology are from the Fourth Assessment
Report of the United Nations Intergovernmental Panel on Climate Change (IPCC, 2007).
For comparison, Table 6-6 lists the GHG emissions for Nova Scotia and Canada for 2012 (the last
available year), grouped by emission category (Environment Canada, 2012). As can be seen, the
proposed Project will increase provincial GHG emissions by approximately 10.3% and Canadian
emissions by only 0.3%.

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Table 6-5: Baseline annual greenhouse gas emissions for operations phase of Proposed
Project.

GHG emissions
Emission source Notes
(t CO2e)

Natural gas liquefaction


1,230,600 High pressure (HP) fuel gas at 13.05 t/h per train
compressors

Natural gas boilers and oxidizers 199,200 Low pressure (LP) fuel gas at 2.14 t/h per train

Diesel emergency equipment 200 5 pieces of equipment, ~500 hrs per year total

Removal of entrained CO2 488,300 Assumes 1.8% concentration in feedstock gas

Flaring 31,800 Includes warm, cold and marine flares

Fugitives 400

LNG tanker manoeuvring and


3,900
hotelling

TOTAL 1,954,500

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Table 6-6: Regional and national GHG emission inventories for 2012, compared to
proposed Project annual operation GHG emissions.

Emission category Nova Scotia (kt CO2e) Canada (kt CO2e)

Energy 17,700 566,000

Industrial processes 505 56,500

Solvent & other product use 8 310

Agriculture 360 56,000

Waste 450 21,000

TOTAL 19,000 699,000

Proposed Project annual operations GHG


1,954 1,954
emissions

Proposed Project as percentage of TOTAL 10.3% 0.3%

The design of the Proposed Project follows the patented OSMR® LNG liquefaction process. Developed
by LNG Limited LLC in the mid 2000s, OSMR® combines several proven technologies into an integrated
system with the following control technologies:
 Gas turbine waste heat steam generation: waste heat is recovered and transformed into
mechanical energy through steam production (combined heat and power);
 Closed loop anhydrous ammonia pre-cooling of inlet and mixed refrigerant (MR) streams:
direct cooling of inlet air in gas turbine improves both the output of the turbine and also the
operational stability. The inlet MR stream is cooled with ammonia such that the MR returns to
the main compressor at a lower temperature which improves compressor performance (and
LNG production). The power to drive the ammonia pre-cooling system is primarily derived
from the gas turbine waste heat exhaust;
 Use of General Electric LM2500+G4 aero-derivative gas turbines: The first generation of LNG
export plants built used single cycle gas turbine (SCGT) technology for compression drives.
While SCGT is a mature technology, more fuel efficient technologies such as combined cycle
gas turbines (CCGT) and aero-derivatives (adapted from aerospace gas turbines) are now
considered the best in class compression drive technologies for recently built and in
development LNG export plants;

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 BOG will be re-liquefied instead of flared: this is an OSMR® patented process where BOG is
lightly compressed and re-liquefied in the liquid methane separator, which separates flash gas
out before LNG is delivered to the storage tanks (flash gas is used as a lean LP fuel gas in the
auxiliary boiler);
 Optimized modular design: Each LNG train is divided into five main process modules, which
can be fabricated off site at a fabrication facility and transported to the proposed Project site
by ocean barge or similar method. The fabrication facility approach ensures a more reliable
product and is inherently safer; and
 Improved flare, venting and fugitives management (described in more detail in the following
sections).
The use of OSMR® is considered implementation of “Best Available Control Technology”. Given
OSMR®’s efficiencies, the proposed Project is expected to have a world class LNG GHG emission
intensity; a benchmark of LNG export plant GHG performance that measures GHG emissions per unit
of production. No consistent reporting standard yet exists so reported GHG emission intensities can
vary widely depending upon what emission sources LNG export plant projects include in their GHG
emission inventories. Using the baseline GHG emissions listed in Table 6-5 and a production value of 8
mtpa of LNG, the proposed Project’s emission intensity is 0.24 t CO2e/t LNG.

Accidents and Malfunctions

The proposed Project will be designed with two primary flares, warm and cold, as well as a secondary
marine flare. It is expected that flaring will only be required during start-up, shutdown, plant upset and
emergency conditions. Emergency overpressure conditions include power and instrument failures,
fires, entrapment of cold liquids and exchanger tube ruptures. A pilot runs on each flare so emergency
flows are combusted rather than vented. The warm flare handles wet or warm relief fluids while the
cold flare is designed for fluids lower than ambient temperature. Both flares include knockout drums
where liquids are collected into a sump. Sump components will be periodically vacuumed out and
trucked to an approved offsite disposal facility. The design capacity of the flares will be determined
during final design, but a hydrocarbon destruction efficiency of at least 99.5% is expected. This
destruction efficiency exceeds Environmental Protection Agency (EPA) guidance on current BACT for
flares and as such the proposed Project flare system satisfies BACT (EPA 40, CFR 60.18). Flaring
during upset conditions is preferable to venting since flaring converts most of the CH4 (GWP of 25) into
CO2 (GWP of 1).

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Decommissioning

A decommissioning plan will be completed at the end of the proposed Project prior to decommissioning
that incorporates regulations and best practices at the time. Effects are expected to be similar to those
of the construction phase of the Project.

Mitigation

The design of the proposed Project will lead to significant reduction in GHG emissions compared to
most other LNG facilities considered or in operation today. Technical documentation suggests that the
OSMR® technological improvements such as waste heat recovery, the use of ammonia and BOG
recovery in aggregate, resulting in a significant reduction in GHG emissions.
Another mitigation measure is the use of natural gas compressor turbines instead of electrically driven
turbines where electricity is supplied from the provincial grid. The gas turbines generate approximately
2,250 GWh of energy per year of operation. Given the baseline GHG emissions associated with the
turbines is 1,230,600 t CO2e, this corresponds to a GHG intensity of approximately 540 t CO2e/GWh.
The 2012 grid intensity in Nova Scotia is approximately 790 t CO2e /GWh (Environment Canada, 2012).
As such, the use of aero-derivative compressor drives is an improvement of approximately 32% over
conventional grid electricity.
During the FEED for the proposed Project, a detailed GHG management plan will be developed that
includes the following elements:
 Detailed inventory of the proposed Project’s baseline GHG sources;
 Definition of annual GHG reporting requirements, including boundary definition, source
identification and auditing requirements;
 Detailed flaring and venting management program (described under “Accidents and
Malfunctions” above);
 Fugitive management program following best practices: A Directed Inspection and
Maintenance (DIM) program that includes leak definition, detection and repair methods,
component targeting and tagging (accounting for inaccessible components), monitoring
frequencies, personnel training, equipment calibrations, record keeping, and performance
objectives; and
 Identification of a facility energy efficiency program.

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The GHG management plan will be updated annually and will be designed to meet any future NSE
regulatory requirements.

6.1.3.3 Potential Residual Effects

A matrix depicting the potential effects on GHG emissions is provided in Table 6.7 GHG emissions
from operations are considered a significant residual effect at a provincial level as they are estimated
to contribute approximately 10.3% of Nova Scotia’s GHG emissions. The proposed Project is following
a “Beyond No Regrets” approach by implementing the BACTs to mitigate GHG emissions and further
mitigation may be considered both in response to the provincial policies once they have been adopted
and to Project specific monitoring results. The provincial government is currently developing GHG
policies for the LNG industry within the framework of the 2007 Environmental Goals and Sustainable
Prosperity Act. The proponent commits to collaborate and work with NSE on the development and
application of these GHG policies.

6.1.3.4 Monitoring and Follow-Up

As part of the detailed GHG management plan, annual GHG reporting will be performed, including
boundary definition, source identification and auditing requirements.

6.1.4 Air Quality

The link between air pollution and human health has been understood for quite some time, with air
pollution affecting the health of humans and animals and causing soiling and deterioration of buildings
(Lave, 1970). Health effects of air pollution vary depending on the contaminants in question (PM2.5,
NOx, SOx, O3, CO, est.), but short term effects can include reductions in lung function, respiratory
inflammation, chest pains, coughing, nausea, and pulmonary congestion. Long term effects can include
effects on breathing and respiratory systems, damage to lung tissue, cancer, and premature death
(EPA, 2014).

6.1.4.1 Boundaries and Threshold

Spatial Boundaries

Atmospheric transport of Project emissions may have far reaching effects on air quality that can span
the globe. These effects, however, are hard to quantify and model. As a result, impacts will be
considered on a more regional scale (Nova Scotia). If impacts to air quality are avoided or negligible at
the regional scale, then they are not expected to have a significant impact on global air quality.
Dispersion modelling considered effects over a distance of approximately 10 km.

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Table 6-7: Potential Environmental Effects Assessment Matrix for Climate

Significance Criteria

Activity Effect Mitigation Significance


Magnitude Geographic Duration/Frequency Reversibility Eco/Socio
Extent Context

Construction and Commissioning

 Emissions of  - Limit vehicle idling


Construction activities, use of Low >10km 3 years, during construction hours Non Developed Not significant
GHGs  - Where available, use fuel efficient equipment
equipment  - Vehicle and equipment maintenance according to manufacturer’s (07:00 – 19:00) reversible area
recommendations.
 - Use of appropriate vehicles/equipment for each task

Operation and Maintenance

 Emissions of  - GHG management plan


Operation and general High >10km Continuous emissions over the life of Non Developed Significant (provincially)
GHGs  - Implementation of best available control technologies
maintenance  - Limit vehicle idling the Project reversible area
 - Where available, use fuel efficient equipment
 - Conduct vehicle and equipment maintenance according to Not-significant (nationally,
manufacturer’s recommendations globally)
 - Use of appropriate vehicles/equipment for each task

Accidents and Malfunctions

 Emissions of  - Venting and flaring management program


Flaring and venting Low >10km Intermittent over the life of the Project Non Developed Not significant
GHGs  -Conduct equipment maintenance according to manufacturer’s
recommendations. reversible area

Decommissioning

 Emissions of  - Limit vehicle idling


Facility decommissioning Low >10km To be determined Non Developed Not significant
GHGs  - Where available, use fuel efficient equipment
 - Conduct vehicle and equipment maintenance according to reversible area
manufacturer’s recommendations.
 - Use of appropriate vehicles/equipment for each task

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Temporal Boundaries

Temporal boundaries will include the construction and operation phases of the Project. Construction is
expected to last approximately 3 years, while operation emissions will span the life of the Project.

Administrative Boundaries

The Nova Scotia AQS under the Environment Act outlines maximum permissible concentrations for SO2,
NO2 and O3 and the Canadian Ambient Air Quality Standards (CAAQS) from the CCME outlines
maximum permissible concentrations for O3 and PM2.5. The Nova Scotia AQS and CAAQS are outlined in
Tables 6-8 and 6-9 respectively.

Table 6-8: Nova Scotia Air Quality Standards

Contaminant Averaging Period Maximum Permissible


Ground Level Concentration

µg/m3 pphm

Carbon Monoxide (CO) 1 hour 34,600 3,000


8 hours 12,700 1,100
Hydrogen Sulphide (H2S) 1 hour 42 3
24 hours 8 0.6
Nitrogen Dioxide (NO2) 1 hour 400 21
Annual 100 5
Ozone (O3) 1 hour 160 8.2
Sulphur Dioxide (SO2) 1 hour 900 31
24 hours 300 11
Annual 60 2
Total Suspended Particulates (TSP) 24 hours 120 -
Annual 70* -
* Geometric mean µg/m3 – micrograms per cubic meter phm – parts per hundred million

Table 6-9: Canadian Ambient Air Quality Standards


Pollutants Old Standards New Standards
2015 2020
3
PM2.5 annual - 10 µg/m 8.8 µg/m3
PM2.5 for 8-hour 30 µg/m3 28 µg/m3 27 µg/m3
Ozone for 8-hour 69 ppb 63 ppb 62 ppb
* ppb – parts per billion
Other emissions standards applicable to the Project are federal emissions standards from the Multi-
Sector Air Pollutants Regulations and the Canadian Base Level Industrial Emissions Requirements

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-24


(BLIER). These regulations impose mandatory performance standards on industrial equipment.
Specifically, the Multi-Sector Air Pollutants Regulations imposes limits on the amount of NOx that can be
emitted from boilers. A working group formed under the Canadian Air Quality Management System in
2011 developed new BLIERs for NOx emissions from combustion turbines.
The Project will be required to meet these regulations. A summary of the Project design criteria
compared with these air emissions standards for boilers and combustion turbines is presented below in
Table 6-10.

Table 6-10: Comparison of Project’s Emissions with NOX Air Emissions Limits

Project
Regulations Emission
Equipment Regulated Activities Design
Limits
Criteria

Multi-Sector Air Alternative gas combustion


Boiler Pollutants with an efficiency higher 23 g/GJ ≤23 g/GJ*
Regulations than 90%(3)

≤25 ppmvd
Combustion Canadian BLIER 25 ppmvd at
Natural gas combustion at 15% O2
Turbine 15% O2 dry
dry

* If the boiler’s thermal efficiency is less than 80%, the air emission limit is reduced to 20.8 g/GJ for an alternative gas. If the
efficiency ranges between 80% and 90%, then the limit is linearly proportional to the efficiency and is bounded by the upper
and lower limit for an alternative gas, 23 g/GJ and 20.8 g/GJ respectively.

Threshold for Significance

The following evaluation criteria are used to determine whether a residual environmental effect on air
quality is significant, not significant or positive:
A significant adverse effect would occur should emissions increase pollution levels beyond regulated
limits, or show the potential to do so.
An adverse effect that does not exceed the above criteria is considered not significant.
A positive effect is one that enhances air quality.
A relative magnitude rating was established for air quality impacts. The following criteria are considered
when determining the significance of an effect:
High: An environmental effect that can increase pollution levels beyond regulated limits.
Medium: An environmental effect that shows the potential to increase pollution levels beyond

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-25


regulated limits (brings pollution concentrations to within 90%).
Low: An environmental effect that does not increase pollution levels beyond regulated limits, or show
the potential to do so.

6.1.4.2 Interactions and Potential Effects

Construction

As previously outlined, most of the site preparation work has already been performed. As a result, a
large part of the footprint of the Project has been established and additional construction related
emissions due to land clearing will be minimal. Further construction will include the installation of
foundations, equipment settings, ancillary equipment, piping and structures. Marine terminal works will
include the installation of a jetty platform, vessel berthing trestle, loading facilities, temporary wharf
and work surface and will require the installation of piles.
Project construction is projected to last approximately three (3) years. This would be classified as long
term construction and temporary increases in ambient noise levels would be expected. Construction
has potential to take place 24 hours a day, seven days a week. The various equipment used during
construction (combustion engines, cranes, backhoes, pavers, trucks, welders, generators, air
compressors, pumps, pile drivers, heavy construction equipment and workers personal vehicles) will
result in air emissions including NOX, SO2, CO, PM10, PM2.5, and VOCs. Short term emissions of air
pollutants will accompany this construction period; however, significant adverse impacts are not
expected.
Vehicle traffic during construction, as well as wind erosion of displaced soil (prior to paving and re-
vegetation) will result in fugitive dust emissions.

Operations - Air Emissions Inventory

An air emissions inventory was developed from the major elements of the Project for use in the air
emissions modelling. The model run benefitted from advanced studies conducted on the similar 8 mtpa
Magnolia LNG plant to be built in Lake Charles, Louisiana. Emissions data for Magnolia was adapted to
the Project, taking into account stream flows and their components outlined in the mass balance
developed for Bear Head. Estimated emissions from the Project were compared to the emissions
inventory for the Province of Nova Scotia. Table 6-11 summarizes the emissions sources. For more
detailed information on the inventory and how it was developed, as well as fugitive emissions modelled
and assumptions see Appendix G. The following documents were used to develop the air emission
inventory:
 Magnolia LNG Project Application to Federal Energy Regulatory Commission – dated 30 April
2014. Responses to FERC in September, 2014.

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-26


 Bear Head LNG Project’s Heat and Material Balance Sheet (Document BH-DP-10-001 rev C –
28 November 2014).

Table 6-11: Estimated Annual Emissions – Proposed Natural Gas Liquefaction Plant
(Tonnes/Year)
NOX CO VOC PMt PM10 PM2.5 SO2 NH3
Sources
t/y t/y t/y t/y t/y t/y t/y t/y
Continuous Sources (per train – 2 mtpa)

Gas Turbine A 118.6 72.2 4.6 8.5 8.5 8.5 0 N.A.


Gas Turbine B 118.6 72.2 4.6 8.5 8.5 8.5 0 N.A.
Thermal Oxidizer 10.0 7.2 3.2 1.2 1.2 1.2 37.9 N.A.
Auxiliary Boiler 18.9 13.0 0.13 2.6 2.6 2.6 0 N.A.
Ammonia Vent N.A. N.A. N.A. N.A. N.A. N.A. N.A. 0.52
Each LNG train 266.1 164.6 12.5 20.7 20.7 20.7 37.9 0.52
LNG Vessels (105 vessels/y) 85 10.1 4.3 1.3 1.3 1.1 2.3 N.A.
Fugitive Emissions
(Piping Components) 12.2 1.3

Total 8 mtpa 1149 669 66 84 84 84 154 3.4


Intermittent Sources
Warm Flare 7.5 40.6 0.65 0.82 0.91 0.91 0 0
Cold Flare 9.1 49.6 0.011 1.00 1.00 1.00 0 0
Marine Flare 0.13 0.71 0.0003 0.014 0.014 0.014 0 0
Emergency Generator (1 MW) 0.64 0.35 0.065 0.020 0.016 0.016 0.0005 0
Firewater Pump Eng. (250 kW) 0.21 0.18 0.021 0.011 0.009 0.009 0.0004 0
Seawater pump Eng. (600 kW) 0.77 0.42 0.077 0.024 0.020 0.020 0.0006 --
TOTAL 1213 788 69 90 90 89 160 3.4

Annual atmospheric emissions of major air contaminants from industrial and power installations in Port
Hawkesbury and Point Tupper are summarized in Table 6-12. Values are shown as reported to the
NPRI for the year 2013.

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-27


Table 6-12: Summary of Industrial Atmospheric Emissions in the Study Area (2013)2
Contaminants (metric tonnes per annum)
NPRI Sources
SO2 NOx CO VOC PMT PM10 PM2.5
ExxonMobil Canada Properties
- Point Tupper Fractionation
Plant na 32 42 81 Na 1.5 1.2
Nova Scotia Power Inc.
Point Tupper Generating
Station 6758 1,340 78 117 82 36
Port Hawkesbury Paper LP/
Port Hawkesbury Paper 237 442 421 333 112 61 21
Nova Scotia Power Inc.
Port Hawkesbury Biomass
Cogeneration Power Plant 47 774 251 na 81 62 33
Total 2013 7042 2588 792 414 310 207 91
Bear Head LNG (8 mtpa) 160 1,213 788 69 90 90 89
Total with Project 7178 3801 1580 483 400 297 180

Operations - Air Quality Modelling Methodology

Emission sources were modelled as point sources. The LNG facility, LNG vessels (during docking,
hotelling, and docking out) and emergency flaring emissions were all considered in the air emissions
modelling.
Modelling guidelines from Newfoundland and Labrador and Quebec were used, as specific air dispersion
modelling guidelines do not exist in Nova Scotia (DOEC, 2012; Leduc, 2005). The CALMET/CALPUFF air
dispersion modelling system was employed (EarthTech, 2000a, 2000b). It was selected over the
American Meteorological Society/Environmental Protection Agency Regulatory Air Dispersion Model
(AERMOD) due to the location of the Project in a coastal region. CALPUFF calculates the concentration
of pollutants at all receptors on an hourly basis, summing the individual contributions from each source
when multiple sources are present. The model requires inputs of:

 Gridded topographical and land use data.


 Hourly meteorological surface observations, upper air observation soundings (at least twice
per day) and/or 3D meteorological fields generated by an advanced prognostic meteorological
model (temperature, wind speed and direction, etc.).

 Source emission characteristics: emission rates of contaminants in the exhaust gas, the gas
exit temperature and velocity, stack coordinates, configuration, diameter and height.

2
Source: National Pollutant Release Inventory for 2013.

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-28


 Location and elevation of receptors.
 Dimensions and coordinates of buildings on-site that present wake effects causing plume
downwash.
For ground elevations of receptors, the Canadian Digital Elevation Model (CDEM, Natural Resources
Canada, 2013) topographic data was used. Land use classifications (circa 2000 – Vector) from Natural
Resources Canada Land Cover (NRC, 2014) were gridded for the CALMET meteorological domain.
Meteorological observations from Port Hawkesbury showed gaps in data completeness. CALMET
generated wind data was used instead as it showed good agreement with observed wind fields from
Port Hawkesbury.
The Weather Research and Forecast (WRF) meteorological model for the 2009 to 2013 period was used
to provide all meteorological information for CALMET, based on inputs from Lakes Environmental.
Results from the Port Hawkesbury monitoring site for the NAPS for SO2, NO2 and PM2.5 were used for
background concentrations of air pollutants. Monitoring results from the NAPS station in Sydney (Cape
Breton) were considered for CO. PMt was modelled as 4 times the PM2.5 concentration. Monitoring
results for the last available years (2010-2012) were considered, but year 2010 was not integrated
because of lower data availability (65% or less). The conversion of NO to NO2 was modelled using the
“ozone limiting method” (Cole and Summerhays, 1979).
More detailed information on the model run and air emissions parameters are available in the full report
contained in Appendix G.

Operations - Air Quality Monitoring Results

The model was run with the 2009 – 2013 meteorological data. Maximum predicted concentrations for
each year of the model run are in compliance with air quality guidelines when considered alongside
ambient pollutant concentrations, both during normal operation and with an LNG vessel hotelling. Short
term averaging conditions (24 hours or less) are closest to exceeding the AAQS, but remain within
guidelines. Table 6-13 presents maximum concentrations for each year of the modelling period during
normal operation and with an LNG vessel hotelling with consideration of ambient concentrations.
Maximum concentrations are localized to specific locations and do not occur over the entire modelling
domain. In order to illustrate this point, maximum concentration of NO2 and PM2.5 are shown in Figure
6-9 of the report contained in Appendix G, and are modelled over the entire domain. NO2 and PM2.5
were modelled as they are closest to exceeding guidelines.

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-29


Table 6-13: Maximum Predicted Concentrations in Ambient Air for the LNG Plant, including
LNG Vessel Hotelling and Background Concentrations at Normal Operation.

Maximum Predicted
(2009-2013) Background Total AAQS
Pollutant Period
(µg/m³)
(µg/m³) % AAQS (µg/m³) % AAQS (µg/m³) % AAQS

1h* 235 59% 24 6.1% 259 65% 400


NO2
Annual 26 26% 3.8 3.8% 30 30% 100

1h 118 13% 31 3.5% 149 17% 900

SO2 24 h 20 6.6% 16 5.2% 36 12% 300

Annual 3.9 6.5% 2.6 4.4% 7 11% 60

1h 203 0.59% 458 1.3% 661 1.9% 34,600


CO
8h 77 0.60% 458 3.6% 535 4.2% 12,700

24 h 9.0 7.5% 60 50% 69 58% 120


PMt
Annual 1.3 1.8% 26 37% 27 39% 70

24 h 9.0 33% 15 54% 23 87% 27*


PM2.5
Annual 1.3 14% 6.5 74% 7.8 88% 8.8*

*New Canadian Standard for 2020

Accidents and Malfunctions

In order to account for upset conditions at the plant, modelling was performed for the case where all
continuous sources for the LNG plant, an LNG vessel hotelling and flaring at maximum capacity at all
flares (hot, cold and marine flare) occur simultaneously. This situation is unlikely to occur, and would
only be for a short duration. As a result, only 1, 8, and 24 hour situations were modelled. Significant
increases are observed, but results remain below guidelines.

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-30


Temporal Boundaries

Temporal boundaries will include the construction and operation phases of the Project. Construction is
expected to last approximately 3 years, while operation emissions will span the life of the Project.

Administrative Boundaries

The Nova Scotia AQS under the Environment Act outlines maximum permissible concentrations for SO2,
NO2 and O3 and the Canadian Ambient Air Quality Standards (CAAQS) from the CCME outlines
maximum permissible concentrations for O3 and PM2.5. The Nova Scotia AQS and CAAQS are outlined in
Tables 6-8 and 6-9 respectively.

Table 6-8: Nova Scotia Air Quality Standards

Contaminant Averaging Period Maximum Permissible


Ground Level Concentration

µg/m3 pphm

Carbon Monoxide (CO) 1 hour 34,600 3,000


8 hours 12,700 1,100
Hydrogen Sulphide (H2S) 1 hour 42 3
24 hours 8 0.6
Nitrogen Dioxide (NO2) 1 hour 400 21
Annual 100 5
Ozone (O3) 1 hour 160 8.2
Sulphur Dioxide (SO2) 1 hour 900 31
24 hours 300 11
Annual 60 2
Total Suspended Particulates (TSP) 24 hours 120 -
Annual 70* -
* Geometric mean µg/m3 – micrograms per cubic meter phm – parts per hundred million

Table 6-9: Canadian Ambient Air Quality Standards


Pollutants Old Standards New Standards
2015 2020
3
PM2.5 annual - 10 µg/m 8.8 µg/m3
PM2.5 for 8-hour 30 µg/m3 28 µg/m3 27 µg/m3
Ozone for 8-hour 69 ppb 63 ppb 62 ppb
* ppb – parts per billion
Other emissions standards applicable to the Project are federal emissions standards from the Multi-
Sector Air Pollutants Regulations and the Canadian Base Level Industrial Emissions Requirements

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-24


(BLIER). These regulations impose mandatory performance standards on industrial equipment.
Specifically, the Multi-Sector Air Pollutants Regulations imposes limits on the amount of NOx that can be
emitted from boilers. A working group formed under the Canadian Air Quality Management System in
2011 developed new BLIERs for NOx emissions from combustion turbines.
The Project will be required to meet these regulations. A summary of the Project design criteria
compared with these air emissions standards for boilers and combustion turbines is presented below in
Table 6-10.

Table 6-10: Comparison of Project’s Emissions with NOX Air Emissions Limits

Project
Regulations Emission
Equipment Regulated Activities Design
Limits
Criteria

Multi-Sector Air Alternative gas combustion


Boiler Pollutants with an efficiency higher 23 g/GJ ≤23 g/GJ*
Regulations than 90%(3)

≤25 ppmvd
Combustion Canadian BLIER 25 ppmvd at
Natural gas combustion at 15% O2
Turbine 15% O2 dry
dry

* If the boiler’s thermal efficiency is less than 80%, the air emission limit is reduced to 20.8 g/GJ for an alternative gas. If the
efficiency ranges between 80% and 90%, then the limit is linearly proportional to the efficiency and is bounded by the upper
and lower limit for an alternative gas, 23 g/GJ and 20.8 g/GJ respectively.

Threshold for Significance

The following evaluation criteria are used to determine whether a residual environmental effect on air
quality is significant, not significant or positive:
A significant adverse effect would occur should emissions increase pollution levels beyond regulated
limits, or show the potential to do so.
An adverse effect that does not exceed the above criteria is considered not significant.
A positive effect is one that enhances air quality.
A relative magnitude rating was established for air quality impacts. The following criteria are considered
when determining the significance of an effect:
High: An environmental effect that can increase pollution levels beyond regulated limits.
Medium: An environmental effect that shows the potential to increase pollution levels beyond

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-25


regulated limits (brings pollution concentrations to within 90%).
Low: An environmental effect that does not increase pollution levels beyond regulated limits, or show
the potential to do so.

6.1.4.2 Interactions and Potential Effects

Construction

As previously outlined, most of the site preparation work has already been performed. As a result, a
large part of the footprint of the Project has been established and additional construction related
emissions due to land clearing will be minimal. Further construction will include the installation of
foundations, equipment settings, ancillary equipment, piping and structures. Marine terminal works will
include the installation of a jetty platform, vessel berthing trestle, loading facilities, temporary wharf
and work surface and will require the installation of piles.
Project construction is projected to last approximately three (3) years. This would be classified as long
term construction and temporary increases in ambient noise levels would be expected. Construction
has potential to take place 24 hours a day, seven days a week. The various equipment used during
construction (combustion engines, cranes, backhoes, pavers, trucks, welders, generators, air
compressors, pumps, pile drivers, heavy construction equipment and workers personal vehicles) will
result in air emissions including NOX, SO2, CO, PM10, PM2.5, and VOCs. Short term emissions of air
pollutants will accompany this construction period; however, significant adverse impacts are not
expected.
Vehicle traffic during construction, as well as wind erosion of displaced soil (prior to paving and re-
vegetation) will result in fugitive dust emissions.

Operations - Air Emissions Inventory

An air emissions inventory was developed from the major elements of the Project for use in the air
emissions modelling. The model run benefitted from advanced studies conducted on the similar 8 mtpa
Magnolia LNG plant to be built in Lake Charles, Louisiana. Emissions data for Magnolia was adapted to
the Project, taking into account stream flows and their components outlined in the mass balance
developed for Bear Head. Estimated emissions from the Project were compared to the emissions
inventory for the Province of Nova Scotia. Table 6-11 summarizes the emissions sources. For more
detailed information on the inventory and how it was developed, as well as fugitive emissions modelled
and assumptions see Appendix G. The following documents were used to develop the air emission
inventory:
 Magnolia LNG Project Application to Federal Energy Regulatory Commission – dated 30 April
2014. Responses to FERC in September, 2014.

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-26


 Bear Head LNG Project’s Heat and Material Balance Sheet (Document BH-DP-10-001 rev C –
28 November 2014).

Table 6-11: Estimated Annual Emissions – Proposed Natural Gas Liquefaction Plant
(Tonnes/Year)
NOX CO VOC PMt PM10 PM2.5 SO2 NH3
Sources
t/y t/y t/y t/y t/y t/y t/y t/y
Continuous Sources (per train – 2 mtpa)

Gas Turbine A 118.6 72.2 4.6 8.5 8.5 8.5 0 N.A.


Gas Turbine B 118.6 72.2 4.6 8.5 8.5 8.5 0 N.A.
Thermal Oxidizer 10.0 7.2 3.2 1.2 1.2 1.2 37.9 N.A.
Auxiliary Boiler 18.9 13.0 0.13 2.6 2.6 2.6 0 N.A.
Ammonia Vent N.A. N.A. N.A. N.A. N.A. N.A. N.A. 0.52
Each LNG train 266.1 164.6 12.5 20.7 20.7 20.7 37.9 0.52
LNG Vessels (105 vessels/y) 85 10.1 4.3 1.3 1.3 1.1 2.3 N.A.
Fugitive Emissions
(Piping Components) 12.2 1.3

Total 8 mtpa 1149 669 66 84 84 84 154 3.4


Intermittent Sources
Warm Flare 7.5 40.6 0.65 0.82 0.91 0.91 0 0
Cold Flare 9.1 49.6 0.011 1.00 1.00 1.00 0 0
Marine Flare 0.13 0.71 0.0003 0.014 0.014 0.014 0 0
Emergency Generator (1 MW) 0.64 0.35 0.065 0.020 0.016 0.016 0.0005 0
Firewater Pump Eng. (250 kW) 0.21 0.18 0.021 0.011 0.009 0.009 0.0004 0
Seawater pump Eng. (600 kW) 0.77 0.42 0.077 0.024 0.020 0.020 0.0006 --
TOTAL 1213 788 69 90 90 89 160 3.4

Annual atmospheric emissions of major air contaminants from industrial and power installations in Port
Hawkesbury and Point Tupper are summarized in Table 6-12. Values are shown as reported to the
NPRI for the year 2013.

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-27


Table 6-12: Summary of Industrial Atmospheric Emissions in the Study Area (2013)2
Contaminants (metric tonnes per annum)
NPRI Sources
SO2 NOx CO VOC PMT PM10 PM2.5
ExxonMobil Canada Properties
- Point Tupper Fractionation
Plant na 32 42 81 Na 1.5 1.2
Nova Scotia Power Inc.
Point Tupper Generating
Station 6758 1,340 78 117 82 36
Port Hawkesbury Paper LP/
Port Hawkesbury Paper 237 442 421 333 112 61 21
Nova Scotia Power Inc.
Port Hawkesbury Biomass
Cogeneration Power Plant 47 774 251 na 81 62 33
Total 2013 7042 2588 792 414 310 207 91
Bear Head LNG (8 mtpa) 160 1,213 788 69 90 90 89
Total with Project 7178 3801 1580 483 400 297 180

Operations - Air Quality Modelling Methodology

Emission sources were modelled as point sources. The LNG facility, LNG vessels (during docking,
hotelling, and docking out) and emergency flaring emissions were all considered in the air emissions
modelling.
Modelling guidelines from Newfoundland and Labrador and Quebec were used, as specific air dispersion
modelling guidelines do not exist in Nova Scotia (DOEC, 2012; Leduc, 2005). The CALMET/CALPUFF air
dispersion modelling system was employed (EarthTech, 2000a, 2000b). It was selected over the
American Meteorological Society/Environmental Protection Agency Regulatory Air Dispersion Model
(AERMOD) due to the location of the Project in a coastal region. CALPUFF calculates the concentration
of pollutants at all receptors on an hourly basis, summing the individual contributions from each source
when multiple sources are present. The model requires inputs of:

 Gridded topographical and land use data.


 Hourly meteorological surface observations, upper air observation soundings (at least twice
per day) and/or 3D meteorological fields generated by an advanced prognostic meteorological
model (temperature, wind speed and direction, etc.).

 Source emission characteristics: emission rates of contaminants in the exhaust gas, the gas
exit temperature and velocity, stack coordinates, configuration, diameter and height.

2
Source: National Pollutant Release Inventory for 2013.

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-28


 Location and elevation of receptors.
 Dimensions and coordinates of buildings on-site that present wake effects causing plume
downwash.
For ground elevations of receptors, the Canadian Digital Elevation Model (CDEM, Natural Resources
Canada, 2013) topographic data was used. Land use classifications (circa 2000 – Vector) from Natural
Resources Canada Land Cover (NRC, 2014) were gridded for the CALMET meteorological domain.
Meteorological observations from Port Hawkesbury showed gaps in data completeness. CALMET
generated wind data was used instead as it showed good agreement with observed wind fields from
Port Hawkesbury.
The Weather Research and Forecast (WRF) meteorological model for the 2009 to 2013 period was used
to provide all meteorological information for CALMET, based on inputs from Lakes Environmental.
Results from the Port Hawkesbury monitoring site for the NAPS for SO2, NO2 and PM2.5 were used for
background concentrations of air pollutants. Monitoring results from the NAPS station in Sydney (Cape
Breton) were considered for CO. PMt was modelled as 4 times the PM2.5 concentration. Monitoring
results for the last available years (2010-2012) were considered, but year 2010 was not integrated
because of lower data availability (65% or less). The conversion of NO to NO2 was modelled using the
“ozone limiting method” (Cole and Summerhays, 1979).
More detailed information on the model run and air emissions parameters are available in the full report
contained in Appendix G.

Operations - Air Quality Monitoring Results

The model was run with the 2009 – 2013 meteorological data. Maximum predicted concentrations for
each year of the model run are in compliance with air quality guidelines when considered alongside
ambient pollutant concentrations, both during normal operation and with an LNG vessel hotelling. Short
term averaging conditions (24 hours or less) are closest to exceeding the AAQS, but remain within
guidelines. Table 6-13 presents maximum concentrations for each year of the modelling period during
normal operation and with an LNG vessel hotelling with consideration of ambient concentrations.
Maximum concentrations are localized to specific locations and do not occur over the entire modelling
domain. In order to illustrate this point, maximum concentration of NO2 and PM2.5 are shown in Figure
6-9 of the report contained in Appendix G, and are modelled over the entire domain. NO2 and PM2.5
were modelled as they are closest to exceeding guidelines.

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-29


Table 6-13: Maximum Predicted Concentrations in Ambient Air for the LNG Plant, including
LNG Vessel Hotelling and Background Concentrations at Normal Operation.

Maximum Predicted
(2009-2013) Background Total AAQS
Pollutant Period
(µg/m³)
(µg/m³) % AAQS (µg/m³) % AAQS (µg/m³) % AAQS

1h* 235 59% 24 6.1% 259 65% 400


NO2
Annual 26 26% 3.8 3.8% 30 30% 100

1h 118 13% 31 3.5% 149 17% 900

SO2 24 h 20 6.6% 16 5.2% 36 12% 300

Annual 3.9 6.5% 2.6 4.4% 7 11% 60

1h 203 0.59% 458 1.3% 661 1.9% 34,600


CO
8h 77 0.60% 458 3.6% 535 4.2% 12,700

24 h 9.0 7.5% 60 50% 69 58% 120


PMt
Annual 1.3 1.8% 26 37% 27 39% 70

24 h 9.0 33% 15 54% 23 87% 27*


PM2.5
Annual 1.3 14% 6.5 74% 7.8 88% 8.8*

*New Canadian Standard for 2020

Accidents and Malfunctions

In order to account for upset conditions at the plant, modelling was performed for the case where all
continuous sources for the LNG plant, an LNG vessel hotelling and flaring at maximum capacity at all
flares (hot, cold and marine flare) occur simultaneously. This situation is unlikely to occur, and would
only be for a short duration. As a result, only 1, 8, and 24 hour situations were modelled. Significant
increases are observed, but results remain below guidelines.

622560-0001-T-4E-REP-000-0004 © SNC-Lavalin Inc. 2015. All rights reserved. Confidential 6-30


Table 6-14: Maximum Predicted Concentrations in Ambient Air for the LNG Plant with
Flaring, including LNG Vessel Hotelling and Background Concentrations at Normal
Operation.

Maximum Predicted
(2009-2013) Background Total AAQS
Pollutant Period
(µg/m³)
(µg/m³) % AAQS (µg/m³) % AAQS (µg/m³) % AAQS

NO2 1h 235 59% 24 6.1% 259 65% 400

1h 118 13% 31 3.5% 149 17% 900


SO2
24 h 20 6.6% 16 5.2% 36 12% 300

1h 1,711 5.0% 458 1.3% 2,169 6.3% 34,600


CO
8h 514 4.1% 458 3.6% 972 7.7% 12,700

PMt 24 h 10 8.5% 60 50% 70 59% 120

PM2.5 24 h 10 38% 15 54% 25 92% 27*

*New Canadian Standard for 2020


Again, maximum concentrations are localized and do not occur over the entire modelling domain.
Maximum concentrations of NO2 and PM2.5 can be seen in Figures 10-11 of the report contained in
Appendix G, modelled over the entire domain. NO2 and PM2.5 were modelled as they are closest to
exceeding guidelines.
There is potential for fires and explosions, vessel accidents, related spills and accidental releases of LNG
to occur, however these accidents are unlikely. These events would impact air quality, but the situation
would be rapidly controlled; the effects would be localized and temporary. Fires and explosions, vessel
accidents, related spills and accidental releases are not expected, and their occurrence is unlikely.
Significant effects on air quality from these events are not expected.

Decommissioning

A decommissioning plan will be developed prior to decommissioning that complies with all regulations
and best management practices at that time. Effects on air quality are expected to be similar to those
during construction. Mitigation measures proposed for the decommissioning phase would likely be
similar to those employed during the construction phase.

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6.1.4.3 Mitigation

Bear Head LNG is committed to ensuring that adverse environmental impacts from the Project are
avoided or minimized wherever possible. Mitigation measures for the potential effects described above
will be employed during construction, operation and decommissioning of the Project. Potential effects
described above that may require mitigation include:

 Fugitive dust emissions from activities such as vehicle traffic during construction periods and
the decommissioning (including demolition activities);

 Impacts to the airshed from exhaust emissions from LNG carrier vessels, compressors, gas
turbines and flares, during the operation of the LNG plant and marine terminal; and
 Impacts to the airshed from fugitive emissions related to plant operation.
The proposed mitigation measures are described below for construction, operation and
decommissioning.

Mitigation during Construction Phase

Mitigation measures during construction will include:

 Requiring that contractors meet all provincial air quality regulations and emission standards
applicable to their equipment. All construction equipment, including stationary (generators,
compressors, etc.) are mobile (heavy vehicle) equipment should be maintained in accordance
with equipment maintenance schedules to ensure exhaust emissions are representative of
good operational practices. Water or dust suppressants will be applied to disturbed areas, as
necessary, to reduce vehicle traffic dust. Oil will not be used as a dust suppressant.
 Covering open hauling trucks with tarps, as necessary.
 Using paved roads for construction vehicle traffic, wherever practical.

 Using best practices to limit track out onto paved sections.


 Limiting vehicle speeds as required, thereby reducing dust generation.
 Limiting unnecessary idling of vehicles and machinery. Diesel powered construction machinery
will not be permitted to idle unless required.
 Responding promptly to any significant particulate emission concerns that occur during
construction by evaluating the source of emissions and ensuring all practicable mitigation
measures are being implemented.
 Activities resulting in dust will cease and immediate dust suppression actions will be taken in
the event that visible dust extends beyond the property boundary.

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 Upon completion of construction activity, disturbed areas will be stabilized.
 A land based work plan, including dust control measures, will be updated as part of the EPP.

Mitigation during Operation Phase

Mitigation measures to minimize air quality effects during operation of the facility will include:
 All equipment used on-site will be properly maintained to ensure exhaust emissions are typical
for each piece of equipment;

 Current and future emissions standards for natural gas combustion engines will be met;
 Leak Detection and Repair program (LDAR) will be implemented (See Section 6.1.4.2);
 Normal industry practices reducing emissions, such as the use of auxiliary engines for LNG
tanker hoteling, will be employed. The International Marine Organization has developed limits
for NOx, SOx and VOCs. By 2016, marine diesel engines are required to reduce NOx levels by
80% compared to 2010 levels; and
 A Flare Management Plan will be developed as part of the EPP.

Mitigation during Decommissioning Phase

Impacts to air quality during decommissioning are expected to be similar to those expected from the
construction phrase. Therefore, mitigation measures imposed will also be similar. Full mitigation
measures will be outlined in a decommissioning plan.

6.1.4.4 Potential Residual Effects

Impacts to local air quality during construction and operation of the Project are not expected to be
significant. Short term emissions of air pollutants will accompany the construction period; but
significant adverse impacts are not expected. Due to the location of the site in an area zoned for
industrial use and far from local residents, businesses and schools, the impact to the public is expected
to be minimal. Emissions will comply with ambient air quality standards during normal operation
conditions as well as during potential upset conditions.

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Table 6-15: Potential Environmental Effects Assessment Matrix for Air Quality
Significance Criteria
Residual Effects
Activity Potential Effects Mitigation Magnitude Geographic Duration/Frequency Reversibility Eco/Socio Context
Significance
Extent
Construction and Commissioning
Site preparation (blasting,  Air emissions from  Best management practices Low > 10 km To the end of construction, Irreversible Emissions from construction equipment and Not significant
clearing, grading, est.) and equipment related to will be employed during approximately 3 years fugitive dust emissions are not expected to
construction of onshore combustion (NOX, SO2, CO, construction negatively impact air quality in the area
facilities and marine PM10, PM2.5, and VOCs), as
terminal well as fugitive dust  Activities resulting in dust will Due to the location of the site in an area zoned for
emissions cease and immediate dust industrial use and far from local residents,
suppression actions taken businesses and schools the impact to the public is
should site conditions cause expected to be minimal
the release of visible dust
beyond the property
boundary

 A dust contingency plan will


be developed
Operation and Maintenance
Plant operation  Air emissions from plant  All equipment used on-site Low > 10 km Life of the Project (approximately 25 Irreversible Emissions will comply with ambient air quality Not significant (Emissions will
operation are expected; will be properly maintained years). Air emissions will be constant standards during normal operation conditions as comply with ambient air
however, emissions will during this time well as during potential upset conditions quality standards during
comply with ambient air  Current and future regulated normal operation conditions
quality standards emissions standards for state Adverse effects to the community are not expected as well as during potential
of the art natural gas upset conditions)
combustion engines will be
met

 Normal industry practices will


be employed

 CAC monitoring during


operation

 LDAR Program
Accidents and Malfunctions
Flaring and venting  Modelling for flaring shows  LDAR Program Med (24 > 10 km Potential for accidents and malfunctions Irreversible Flaring and venting not expected during regular Not significant (Emissions will
significant increases in air hour exists through construction, operation operations comply with ambient air
Fires and explosions emissions, but results remain concentratio and decommissioning of the Project quality standards during
below guidelines ns of PM2.5) Flaring and venting are not expected The occurrence of fires and explosions, vessel normal operation conditions
Vessel accidents  Remaining events would during regular operations accidents, related spills and accidental releases are as well as during potential
impact air quality but unlikely and significant effects on air quality from upset conditions)
Spills and accidental significant effects on air them are not expected
releases quality are not expected and
their occurrence is unlikely
Decommissioning
Expected to be similar to  Air emissions from  Mitigation measures similar Low > 10 km Decommissioning plan to be developed Irreversible Emissions from decommissioning equipment and Not significant (Emissions will
construction. A detailed equipment related to to construction will be prior to decommissioning fugitive dust emissions are not expected to comply with ambient air
plan will be developed prior combustion (NOX, SO2, CO, employed Decommissioning negatively impact air quality in the area quality standards during
to works being undertaken PM10, PM2.5, and VOCs), as plan to be developed prior to Due to the location of the site in an area zoned for normal operation conditions
well as fugitive dust decommissioning industrial use and far from local residents, as well as during potential
emissions businesses and schools the impact to the public is upset conditions)
expected to be minimal

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6.1.4.5 Monitoring and Follow-up

Monitoring of the main stacks will be conducted as per federal guidelines and emission standards.
The Bear Head LNG facility will have the capability to measure energy flows and emissions. The
following monitoring programs will be implemented:
 Gas turbines (33 MW output capacity)
 Monitoring or energy flows including fuel consumption, electricity and shaft power;
 Regular monitoring of fuel properties including heating value;

 NOx emissions will be measured for each gas turbine as part of the initial
commissioning; and

 Once annually, one gas turbine per train will be monitored.


 Auxiliary Boiler (89 GJ/h input heat)
 Regular monitoring of fuel properties including heating value;
 Federal regulations require an initial stack testing for boilers less than 105 GJ/h (each
auxiliary boiler) comprised of 3 tests of at least 30 minutes in 48 hours, for a steady-
state operation of at least 60% of its rating capacity;
 During each test run, the concentration of NOx (ppmvd) and oxygen (%) must be
measured simultaneously;

 The average of the 3 test runs must comply with regulated emissions intensities; and
 If the selected boiler has a rating capacity of more than 105 GJ/h, then a stack
monitoring campaign will be repeated on an annual basis, as per federal regulations.
 Thermal Oxidizers
 Monitoring of energy flows including fuel consumption, electricity and shaft power;

 Regular monitoring of fuel properties including heating value and sulfur content of the
stream to be incinerated; and
 Initial stack testing for each oxidizer similar to auxiliary boilers.
An LDAR will be implemented to monitor fugitive emissions. Results of the LDAR will be provided with
the annual atmospheric emissions sampling report to Environment Canada and NSE. Components of
the LDAR Program include:

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 Quarterly measurements (from April 1 to December 31) for pump, compressor and agitator
seals and once a year for all other parts;

 Bear Head LNG will repair any major leakage within a prescribed 45 day period. Its objective
will be to repair any major leak within 5 days;
 Bear Head LNG will consider a major leak one that is of more than 10,000 ppm;
 If repairing the leak requires the interruption of an on-going process, the repair will be
carried out no later than the next scheduled shutdown of the process involved; and

 Several different leak detectors and monitoring equipment will be strategically placed to
detect LNG leakage and to facilitate a quick and efficient response. The LDAR aims to detect
micro leaks at much lower levels than those requiring an emergency response. Ammonia
leak detectors will be utilized.

6.1.5 Acoustic Environment

It is important to determine impacts to the acoustic environment associated with Project activities.
Sufficient scientific evidence exists to find that noise exposure can have negative health effects,
including hearing impairment, hypertension and ischemic heart disease, annoyance, sleep disturbance,
and decreased school performance (Passchier-Vermeer et al., 2000). Effects on the acoustic
environment will be considered as they relate to human health.

6.1.5.1 Boundaries and Threshold

Spatial Boundaries

Noise generated by Project activities has the potential to impact the Project site, the surrounding
communities of Point Tupper and Port Hawkesbury, and the rural area of Guysborough County (across
the Strait). The Project site is located in an area zoned for industrial use; the nearest residences are
located across the Strait, approximately 1.8 km from the site.

Temporal Boundaries

Temporal boundaries will include the construction and operation phases of the Project. Construction is
expected to last approximately 3 years, while operational noise emissions will span the life of the
Project.

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Administrative Boundaries

Permissible sound levels from the Project are governed by provincial and municipal noise assessment
criteria. Health Canada provides additional information to complement these regulations.
According to NSE noise criteria (NSE, 1989), sound shall not exceed the following levels:
 07:00 to 19:00 65 dBA
 19:00 to 23:00 60 dBA
 23:00 to 07:00 55 dBA
Municipal By-law #8 from Richmond County prohibits disturbing noise in the vicinity of any public
place. The bylaw also states that between the hours of 12:00 and 24:00 on any week day, loud
speakers, amplifiers or other sound transmitting device shall not be operated in the Municipality such
that the sound is projected beyond a distance of 300 feet.
The Guysborough County Noise Control By-Law prohibits disturbance of peace and tranquility, the
operation of sound systems that can be heard at neighbouring dwellings and continuous noise levels
that exceed when measured on any property:
 06:00 to 23:00 65 dBA
 23:00 to 06:00 55 dBA
Construction noise is permitted between 07:00 and 21:00. If NSE noise criteria are met, Noise Control
By-Laws from Guysborough County will also be met.
Health Canada has developed an approach to noise assessment that takes into account recognized
standards, including those from the U.S. Environmental Protection Agency and the International
Organization for Standardization. Useful Information for Environmental Assessments (Health Canada,
2010) is a document outlining steps to consider noise impacts. Some of the effects considered include
hearing loss, sleep disturbance, interference with speech, complaints and the change in the percent
highly annoyed of the community. Assessments of noise on human receptors should include and
consider:
 Distance of receptors to the Project site and the expectation of “peace and quiet”;

 Establishment of ambient baseline sound levels, both daytime (07:00 to 22:00) and nighttime
(22:00 to 7:00), of the area prior to the Project;

 Identification of potential noise sources, tonal, low frequency and impulsive types of noise
over the life of the Project;
 Prediction of Project sound levels;

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 Comparison of baseline sound levels with projected sound levels;
 An estimate of the expected duration of noise; and
 Evaluation of the severity of the predicted changes in noise.
As part of the Health Canada approach to noise assessment, a day-night (24 hours) sound level (Ldn)
is calculated to reflect the higher sensitivity of communities during the night. It is calculated by energy
averaging day and night time sound levels, with a bias of 10 dBA applied to night time sound levels.
Annoyance is calculated from the Schultz Curve (ISO1996-2, 2003). The percent highly annoyed
(%HA) is calculated for both the ambient and baseline sound levels and then the change in %HA
determined. When sound levels are in the range of 45-75 dBa the change in %HA should be < 6.5%.
If it is greater, or sound levels exceed 75 dBa, then mitigation methods should be proposed. For
temporary construction noise (<2 months) community consultation is advised. For short term
construction noise (2 – 12 months) mitigation should be proposed if levels are predicted to result in
complaints. For long-term construction noise (> 1 year), as well as operational noise where sound
levels are in the Ldn: 45 – 75 dBA range, the %HA should be used to evaluate the impacts. Finally, for
long-term construction or operational noise where sound levels are in excess of 75 dBA, the Ldn should
be used to evaluate the impacts. A summary of the Health Canada approach to noise assessment is
presented in Table 6-16.

Table 6-16: Health Canada Approach to Noise Assessment

Duration Criterion Limit


Temporary (<2 months) Community consultation is advised --
Construction noise lasts less than two
months at receptors
Mitigation should be proposed if the sound levels --
Short-term (2 - 12 months)
are predicted to result in widespread complaints
Construction noise lasts less than
based on U.S. EPA [U.S. EPA 1974, Michaud et
twelve months at receptors
al. 2008]
Long-term (> 1 year) % HA Predicted change
Construction noise lasts more than one in %HA is
year, and operational noise, where greater than
sound levels are in the range of 6.5 %
Ldn: 45 – 75 dBA.
Long-term (> 1 year) Ldn 75 dBA
Construction noise lasts more than one
year, and operational noise, where the
Project related sound level is in excess
of Ldn: 75 dBA.

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A noise assessment was performed to determine if noise generated by the Project will have any
adverse effects on human health and comply with relevant standards. Sound level changes were
evaluated with mitigation measures applied to determine residual impacts. The Noise Assessment is
provided in Appendix H.

Threshold for Significance

The evaluation criteria defined below are used to determine whether a residual environmental effect
on noise is significant, not significant or positive:
A significant adverse effect would occur if effects are expected to regularly cause increases in noise
above guidelines at sensitive receptors.
An adverse effect that does not exceed the above criteria is considered not significant.
A positive effect is one that minimizes nuisance noise.
A relative magnitude rating was also established for ambient sound impacts. The following criteria are
considered when determining the significance of an effect:
High: An environmental effect that can increase noise levels beyond regulated limits.
Medium: An environmental effect that shows the potential to increase noise levels beyond regulated
limits.
Low: An environmental effect that does not increase noise levels beyond regulated limits, or show the
potential to do so.

6.1.5.2 Interactions and Potential Effects

Construction

Most of the site preparation has been completed. Further construction will include the installation of
foundations, equipment settings, ancillary equipment, piping and structures. Marine terminal works
will include the installation of a jetty platform, vessel berthing trestle, loading facilities, temporary
wharf and work surface and the installation of piles. Project construction is projected to last
approximately 3 years. This would be classified as long term construction and temporary increases in
ambient noise levels would be expected. Construction hours will vary, but work will likely take place
on site twenty-four hours a day, seven days a week.
Noise levels depend on the number and type of equipment in operation, noise emission levels, usage
factors and the distance/topography between the noise source and receptor. The Roadway
Construction Noise Model (Federal Highway Administration, 2006) and information from the literature
were used to produce noise emission levels for modelling. Expected construction equipment,

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quantities and their related sound levels can be found in the Noise Assessment (Appendix H).
Construction noise levels at the site boundary are expected to exceed noise assessment criteria during
the day. The Project site is located in the Point Tupper / Bear Head Industrial Park, an area zoned for
Port Industrial (I-2) use including bulk terminals, marine terminals and fuel bunkering facilities.
It was assumed for modelling purposes that all construction equipment would be operating at the
same time. The closest receptors are located across the Strait, approximately 1.8 km from the Project
site. The potential impact of sound levels on sensitive receptors is shown in Table 6-17.

Table 6-17: LNG Facility Construction Sound Levels at Off-Site Receptors


LNG Existing
Combined NSE Criteria Expected Increase
Construction Baseline
Receptor
LAeq Ldn * Ldn Ldn
dBA %HA
(dBA) (dBA) (dBA) (dBA)
Construction at the facility site
R1 48 46 55 56 65 0.3 %
R2 56 54 55 58 65 1.5 %
R3 52 50 54 55 65 0.7 %
Construction with vibratory hammers at marine terminal
R1 48 46 55 56 65 0.3 %
R2 55 53 55 57 65 1.3 %
R3 52 50 54 56 65 0.7 %
Construction with impact hammers at marine terminal
R1 48 58 ** 55 60 65 3.3 %
R2 55 65 ** 55 65 65 10.4 %
R3 52 62 ** 54 63 65 6.9 %
* : Construction operating hours would take place from 7:00 to 19:00
**: +12 dBA correction was included for the highly impulsive nature of pile driving noise, in accordance with ISO 1996-2:2007.

The sound levels associated with pile installation at the marine terminal are presented in (LAeq,
Table 7). To mitigate noise levels, vibratory hammers will be used in the construction to the extent
possible. The sound level at the nearest receptors is lower than the noise assessment criteria for the
day period (65 dBA). The increase in Day-Night sound level is lower or equal to 2 dBA and the
predicted change in the percent highly annoyed (0.3 to 1.3 %HA) is lower than 6.5 %HA. In the event
that impact (drop) hammers are used, the sound level at the nearest receptors is lower than the noise
assessment criteria for the day period (65 dBA). Driving piles by the drop hammer method generates
highly impulsive noise, and a correction factor of +12 dB was included in the calculation of the Day-
Night sound level (Ldn), in accordance with ISO 1996-2: 2007. The increase in Day-Night sound level

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is high and the predicted change in the percent highly annoyed (up to 10.4 %HA) is higher than 6.5
%HA. The residual impact would be low, reversible and temporary. The significance of the residual
impact would be minor. Additional noise mitigation will be considered if required to attenuate noise.
Sensitive receptors are not expected to be impacted by noise from construction activities. Pile driving,
however, as part of the marine works is expected to create an adverse temporary effect (increase in
the percent highly annoyed). Mitigation measures will be employed during pile driving to reduce or
eliminate this as described below. Following the finalization of the design and construction techniques
are established, the noise assessment will be remodelled and the requirement for mitigation measures
will be further evaluated.

Operation

Operation of the LNG facility and associated marine infrastructure will generate noise. The LNG facility
has process equipment including gas and steam turbine compressors, BOG compressors, air coolers,
pumps, piping and utility equipment, most of which will be continuous sources of noise. Intermittent
sources of noise will also exist, including sounds generated by flaring and venting during emergency
operation. The main source of noise from marine activities will be the noise generated by the LNG
vessels.
Noise dispersion modelling of Project operations was performed using the International Organization
for Standardization Standard 9613-2 (ISO 1996) with SoundPLAN V7.3 software to simulate the
propagation of sound under favorable meteorological conditions. This methodology takes into account
sound wave divergence due to distance, atmospheric and ground absorption, reflection from objects
(buildings), and sound attenuation due to topography and barriers. The sound level is calculated for
individual receptors. The calculated sound level represents the “A” weighted continuous sound level
(LAeq). An absorption coefficient of 0.1 was used for area within the site boundary, 0.9 for areas
outside the boundary and 0.0 for water. Ambient conditions of 10 ˚C with 70% relative humidity were
used. Land topographic data was obtained from the Nova Scotia Geomatics Center (NSGC, 2011).
Manufacturer data, estimations based on similar equipment and data from the literature were used to
estimate noise emission levels of noise-producing equipment. The sound levels of primary noise
producing equipment, and the mitigation measures included in the modelling, can be found in the
Noise Assessment (Appendix H), Results of the modelling are shown in Table 6-18.
Predicted noise levels at the boundary of the Project site exceed noise assessment criteria for the day,
evening and night periods. The Project site, however, is located in the Point Tupper / Bear Head
Industrial Park, an area zoned for Port Industrial (I-2) use including bulk terminals, marine terminals
and fuel bunkering facilities.

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Table 6-18: LNG Facility Operation Sound Levels at Site Boundary and Off-Site Receptors
LNG
Existing Baseline Combined Expected Increase
Facility
Receptor
LAeq Ldn Ldn Ldn
%HA
(dBA) (dBA) (dBA) (dBA)
North Boundary * 70 NA NA NA NA
West Boundary * 68 NA NA NA NA
South Boundary * 64 NA NA NA NA
East Boundary * 68 NA NA NA NA
R1 38 44 55 55 0.2%
R2 46 52 55 57 1.1%
R3 42 48 54 55 0.5%
o
*: Relative to the Facility main axis, +25 from true north

Predicted noise levels at all sensitive receptors across the Strait of Canso are below noise assessment
criteria for the day, evening and night periods. The increase in Day-Night sound level is lower than 2
dBA and the predicted change in the percent highly annoyed (0.2 to 1.1 %HA) in the community is
lower than 6.5 %HA.
The results of noise modelling show that noise impacts from operations are not expected to
significantly affect sensitive receptors.

Accidents and Malfunctions

Flaring and venting will be required during start up and shutdown processes and during upset
conditions. These noise sources will be intermittent and occur over a short period of time. Noise levels
can be expected to be high during these times. Overall, impacts from accidents and malfunctions are
not expected to be significant.
Fires and explosions, vessel accidents, related spills and accidental releases of LNG are unlikely to
occur. These events would impact the acoustic environment, but would be rapidly controlled and the
effects would be localized and temporary. Fires and explosions, vessel accidents, related spills and
accidental releases are unlikely to occur; significant effects on the acoustic environment related to
these events are not expected.

Decommissioning

A decommissioning plan will be developed that will address noise related impacts. The effects of
decommissioning are expected to be very similar to those arising during construction. Overall, impacts
from decommissioning are not expected to be significant.

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6.1.5.3 Mitigation

Bear Head LNG is committed to ensuring that adverse environmental impacts from the Project are
avoided or minimized wherever practicable. Construction hours will vary but, during certain phases of
the Project, work will take place on site twenty-four hours a day, seven days a week. The nature of
the noise generated will also vary through construction and operation. Based on the results of the
acoustic modelling, consideration will be given during the FEED process on how best to incorporate
practices and mitigation measures into the design and operation of the facility to minimize annoyance
from noise and to ensure that all regulatory requirements with respect to noise levels are met at a
minimum.
During the design and selection of equipment, for example, noise ratings shall be taken into
consideration to meet noise assessment criteria. Enclosures, piping insulation and silencers may be
employed, and the feasibility of low noise designs will be explored. The EPP will incorporate the
mitigation measures and protocols necessary to address noise related matters and will also identify
the appropriate numbers that can be used to register noise related complaints.

6.1.5.4 Potential Residual Effects

Potential residual effects are summarized below in Table 6-19. Significant impacts to the acoustic
environment are not expected to occur during construction, operation, as a result of accidents and
malfunctions, or during decommissioning assuming proper monitoring and mitigation are employed.

6.1.5.5 Monitoring and Follow-Up

Follow-up monitoring will be performed during construction activities, in particular during pile driving
to determine whether sensitive receptors (residences across the Strait) are being negatively impacted.
If noise levels exceed assessment criteria, mitigation measures will be implemented.
Monitoring will also be performed during operation to ensure that sensitive receptors do not
experience noise that exceeds noise assessment criteria and to establish baseline noise levels for
reference in case of future developments.
If noise related complaints are received during construction or operation, additional noise monitoring
will be undertaken to verify these claims and to aid in meeting noise assessment criteria.

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Table 6-19: Potential Environmental Effects Assessment Matrix for the Acoustic Environment

Significance Criteria

Activity Potential Effects Mitigation Residual Effects Significance


Magnitude Geographic Duration/Frequency Reversibility Eco/Socio
Extent Context

Construction and Commissioning


 Increased noise levels.  Appropriate noise
Site preparation (blasting, Low (mitigation 1-10 km To the end of construction, Reversible Noise impacts mainly Not significant (noise levels experienced
Modelling predicts values muffling equipment used
clearing, grading, est.) and below assessment criteria  Equipment maintenance measures will reduce approximately 3 years. Construction occur in a developed at sensitive receptors are below
construction of onshore with the exception of pile  Possible acoustic noise from pile driving will take place 24 hours a day, seven area zoned for guidelines, with the exception of
facilities and marine driving shroud, or other to below guidelines) days a week industrial use annoyance related to pile driving.
terminal mitigation measures for Mitigation measures will reduce this
pile driving will be
impact)
evaluated if required

Operation and Maintenance


 Increased noise levels.  Noise will be considered
Plant operation Low Onsite Life of the Project (approximately 25 Reversible Noise impacts occur Not significant (noise levels experienced
Modelling predicts values in equipment selection
below assessment criteria  Enclosure of equipment years). Plant operation will be around in a developed area at sensitive receptors are below
at the nearest sensitive the clock zoned for industrial guidelines)
receptor use

Accidents and Malfunctions


 Increased noise levels  No mitigation proposed.
Flaring and Venting Low 1-10 km Intermittent over the life of the Reversible Noise impacts occur Not significant
over short durations. Flaring and venting not
Noise levels expected to expected during regular Project in a developed area
be high during these operations zoned for industrial
times use

Decommissioning
 Increased noise levels  - Plan will be developed
Activities similar to Low 1-10 km Noise will be limited to the duration of Reversible Noise impacts occur Not significant
similar to those prior to any works being
construction experienced during undertaken decommissioning in a developed area
construction zoned for industrial
 Pile driving will not be use
required

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6.2 Ecological Environment

6.2.1 Terrestrial Habitat

The terrestrial habitats on site consist mostly of mixed and coniferous forests and wetlands that
support plant and wildlife species typical of the area. Initial clearing and site preparation was
completed on the site in 2007, replacing the natural upland environments with a finished base pad in
preparation for the installation of LNG plant facilities. Two wetlands were modified in part and one
was infilled during site preparation; all necessary permits were attained from NSE and conditions
adhered to. The only additional displacement of natural habitat will involve a small intrusion into forest
stands in the south western corner of the site for a gas metering station and also on the south east
corner of the site for a future lay down area.
Wetlands are an important feature of the terrestrial environment, performing biological, hydrological,
social, cultural and economic functions. Wetlands support various species of plants and animals that
depend on wetland functionality for survival. Bear Head LNG does not anticipate further alteration of
any wetlands on site.

6.2.1.1 Boundaries and Threshold

Spatial Boundaries

The spatial boundary for the assessment of the terrestrial habitat is the Project site boundary as
depicted in Figure 1-1.

Temporal Boundaries

Terrestrial habitats including wetlands, forested areas and other vegetation communities are present
on the property site. There is, therefore, the potential for the Project to interact with the terrestrial
habitat on a continuous, year-round basis.
Wetlands are most sensitive during spring and early summer when they are wet and easily physically
disturbed. During this time, birds and herptiles use wetlands as breeding habitat and are also
susceptible to disturbance. Other wildlife, particularly birds, may be more susceptible to construction
activities in the spring and early fall when larger numbers of migrating birds feed and rest in
productive areas. Wetlands will be least sensitive to construction activities during the winter.

Administrative Boundaries

Terrestrial habitats such as wetlands are regulated by the Activities Designation Regulation under
Section 105(a) and 110(d) of the Nova Scotia Environment Act. As of 2011, the Environment Act

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required that an approval be attained for any activities that may impact a wetland. These activities are
referred to as wetland alterations and may include filling, draining, flooding or excavating (NSE,
2013). Vegetation species that are provincially or federally protected are listed under the Nova Scotia
Endangered Species Act or under SARA.

Technical Boundaries

Information on terrestrial habitat including wetlands and vegetation was derived from the previously
accepted environmental assessment (JWEL, 2004a) and by site visits completed in 2014 to verify the
status of significant biological resources in the vicinity of the site, specifically to determine if
conditions had changed since prior site activity.

Threshold

Evaluation criteria were used to determine whether a potential residual environmental effect on
terrestrial habitats was significant, not significant or positive. The following is a summary of the
criteria for each:

 A significant adverse effect would occur when there is a net loss of wetland or other
terrestrial habitat functions of significant value. Furthermore, a significant adverse effect
occurs when a population of a species is sufficiently affected causing a decline in abundance
and/or change in distribution beyond which natural recruitment would not return to the
population to its former level within several growing seasons.
 An adverse effect that does not exceed the above criteria is evaluated as not significant.
 A positive effect may enhance the quality, increase the species population/diversity, or
increase the area of wetland.
A relative magnitude rating was established for terrestrial habitats. The following criteria are
considered when determining the significance of an effect:
High: An environmental effect affecting a whole stock, population or definable group, or where a
specific parameter is outside the range of natural variability determined through research and local
knowledge over many seasons.
Medium: An environmental effect affecting a portion of population or one or two generations, or
with rapid and unpredictable changes in a specific parameter so that it is temporarily outside the
range of natural variability determined from local knowledge over many seasons.
Low: An environmental effect affecting a specific group of individuals in a population in a localized
area, one generation or less, or where rapid and unpredictable changes in a specific parameter occur
so that it is temporarily outside the range of natural variability determined through research and local
knowledge over many seasons.

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6.2.1.2 Interactions and Potential Effects

Construction and Commissioning

Terrestrial habitats may be lost as a result of the physical works associated with construction activity.
Minimal clearing, grubbing and grading of the site, as well as the installation of facility equipment,
may cause habitat loss as a consequence of tree removal, or possible erosion causing sedimentation
of wetlands, which could potentially alter their hydrology.
Clearing and grubbing will result in disturbed soil surfaces leaving them without cover or vegetation.
Exposed soil is susceptible to erosion from precipitation events and construction activities; erosion can
result in sedimentation of terrestrial habitats and wetlands. Construction activities, including increased
transportation near the site, also have the potential to generate dust. The deposition of dust on
vegetation in the area may affect photosynthesis, respiration and transpiration. The resulting effects
are potential decreased growth rates and reduced productivity of vegetation (Farmer, 1993).
During the construction phase, extensions to the existing security fencing will be installed along the
property boundary to augment security. This fencing will be located along the property line and will
likely pass through wetlands 2 and 6 and be located in close proximity to wetland 4. Its installation
may cause some physical disturbance to these wetlands; however, it will provide increased security,
inhibit unauthorized trespassing and keep large mammals away from the facility.

Operation and Maintenance

Everyday operation of the LNG facility has the potential to generate sediment and dust from increased
usage of the roads. Increased sedimentation and dust can affect wetlands and other water bodies by
altering their hydrology which, in turn, could affect surrounding vegetation and associated habitats.
The orientation and layout of the infrastructure on site may alter local wind patterns which could
cause minor damage to vegetation and possible tree blow-downs.

Accidents and Malfunctions

Accidents and malfunctions may occur at any time and could affect the terrestrial habitats on-site.
Sedimentation and erosion can upset the regular hydrology of wetlands which may affect vegetation
and local habitats. Spills or leaks of hazardous materials may result in contamination of local habitats,
including wetlands. The eastern sedimentation pond is currently used to retain stormwater and
surface water runoff from the facility. This pond is designed to allow for treatment through settling
prior to manual discharge to Wetland 1. If a spill or leak occurs, the sedimentation pond is designed
to catch the runoff; depending on the circumstances, contaminated runoff may be discharged to
Wetland 1. A fire or explosion, should such an unlikely event occur, has the potential not only to
damage terrestrial habitats within the property boundary, but may also spread to adjacent properties.

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Decommissioning

Decommissioning activities are expected to present the same risks to terrestrial habitat as the
construction and commissioning phases. Decommissioning could result in habitat loss or alteration of
forested and vegetated areas as well as soil erosion and the sedimentation of wetlands. Potential
effects to terrestrial habitat as a result of decommissioning will be considered and addressed in a
decommissioning plan which would be developed when the facility nears the end of its life; this plan
will incorporate relevant standards and regulations.

6.2.1.3 Mitigation

The Bear Head LNG Project site was carefully selected and developed to minimize interactions with
sensitive ecological features and terrestrial habitats, particularly wetlands. In most cases there is a
buffer area of approximately 30 m between the wetlands and the developed areas of the site.
Recently, the orientation of the gas metering station was changed due to a concern that it had the
potential to impact a small 0.06ha treed Black Spruce and Sphagnum slope/basin swamp discovered
during a site visit in December 2014. Bear Head LNG does not anticipate any further wetland
alteration on site. Minimal additional clearing and grubbing is required to complete construction.
During the installation of the perimeter fencing that may interact with wetlands 2, 4 and 6, the fence
will not be buried (keyed in), thereby minimizing disturbance to the wetland. Construction will take
place in winter, and vehicles will avoid the wetlands; small tracked vehicles may be used if conditions
are acceptable. Any heavy equipment will skirt around the wetland only where feasible during
installation. Clearing of vegetation along the fence line where it passes through the wetland habitat
will be kept to a minimum (JWEL, 2004b).
Mitigation measures to protect terrestrial habitat, specifically wetlands will be detailed in the EPP. The
EPP will include detailed procedures and provide information pertaining to erosion and sedimentation
control, surface water control, and spill and leak management.
During construction and operation, erosion control methods will be applied wherever there is potential
for surface water runoff, from rainfall and running water, to protect steep slopes and erodible soils.
The amount and duration of exposed soil shall be kept to a minimum to prevent erosion at the source;
this will reduce the amount of sediment to be managed. Sedimentation ponds will be established to
capture runoff from the site and allow for settling of solid particles. Whenever possible, sediment
controls will prevent sediment from leaving the site. The prudent maintenance of vegetation cover on
site throughout the operational phase of the Project will help to minimize the effects of erosion and
potential sedimentation of sensitive habitats.
The current design of the Bear Head facility incorporates secondary containment berms to restrict the
distribution of chemicals and harmful liquids in the case of an accidental spill or leak. These have been

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included in the design to minimize impacts on the terrestrial ecosystems on-site and adjacent to the
site.
Construction activities and associated vehicle traffic will result in the generation of dust emissions
which could have an effect on terrestrial habitat and vegetation. Mitigation measures will include the
application of water or dust suppressants, the stabilization of exposed ground and will include speed
limits to reduce the overall displacement of dust.
Care shall be taken to minimize the potential introduction of invasive plant species into the wetlands
and other vegetated parts of the site. All equipment should be cleaned prior to being transported to
the site to reduce the potential transfer of invasive species. Cleared areas should be re-vegetated with
native species following construction activities.

6.2.1.4 Potential Residual Effects

Provided that the recommended mitigation measures are implemented throughout the life of the
Project, no significant adverse residual environmental effects on the terrestrial habitat are likely to
occur. Table 6-20 provides a summary of the potential residual environmental effects and
recommended mitigation measures to be adhered to for terrestrial habitat protection.

6.2.1.5 Monitoring and Follow-up

Throughout the construction and operational phases of the Project, walk through assessments will be
undertaken to observe and assess the general health of the terrestrial habitat as part of the
environmental management program.

6.2.2 Terrestrial Fauna

Due to concern with biodiversity, ecological importance and regulatory protection for species at risk,
terrestrial fauna have been identified as a VEC. This encompasses mammals (including bats),
herptiles (amphibians and reptiles) and birds (both land and sea).

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Table 6-20: Potential Environmental Effects Assessment Matrix for Terrestrial Habitat

Significance Criteria
Residual Effect
Activity Potential Effect Mitigation
Magnitude Geographic Duration/Frequency Reversibility Eco/Socio Significance
Extent Context

Construction and Commissioning

 Habitat Loss or alteration*  Development and Implementation of EPP


Clearing, grubbing and grading (majority of which is
 Soil Erosion in general
complete)  Introduction of invasive plant species  Erosion and sedimentation controls as
 Habitat alteration specified in EPP
Increased Road Traffic
 Sedimentation of wetlands  Stormwater is to be retained in two To the end of construction, The site has been
Construction and installation of equipment,  Alteration of wetland hydrology sedimentation ponds and treated prior to approximately 3 years. affected by human
 Dust generation discharge Onsite (within
infrastructure buildings and piping Low Construction hours will Reversible activity and is located Not significant
 Direct mortality (associated with  Avoid wetland and terrestrial habitats property boundary)
sensitive flora) whenever practical take place 24 hours a day, within an industrial
Onsite assembly of the liquefaction modules and
 Use of invasive non-native species for seven days a week park
construction of the LNG storage tanks
reclamation will be avoided
Installation of Security Fencing along property  Use of water and dust suppressants as
boundary well as management practices outlined in
the EPP to reduce dust generation

Operation and Maintenance

 Sedimentation of wetlands  Stormwater Management Plan


Operation of LNG liquefaction trains, supporting The site has been
 Noise  Erosion and sedimentation controls as
infrastructure and LNG storage  Tree Blow Down specified in EPP affected by human
Onsite (within Life of the Project
 Surface water management as specified Low Reversible activity and is located Not significant
Increased Road Traffic property boundary) (approximately 25 years)
in EPP within an industrial
Facility orientation can effect wind patterns park

Accidents and Malfunctions

 Sedimentation of wetlands  Stormwater is retained in sedimentation


Sedimentation or erosion, particularly during
 Alteration of wetland hydrology ponds and treated to government
construction. Eastern sedimentation pond will receive  Habitat loss or alteration* standards prior to discharge (through
Mostly onsite with the Potential for accidents and The site has been
runoff which is directed to Wetland 1  Direct mortality (associated with settling)
sensitive flora)  Emergency response and contingency potential to spread to malfunctions exists through affected by human
Spills or accidents. If required, the eastern plan as specified in the EPP Low habitats nearby in the construction, operation and Reversible activity and is located Not significant
sedimentation pond could receive contaminated runoff  Spill management plan as specified in the case of a fire, leak or decommissioning of the within an industrial
which is directed to Wetland 1 EPP sedimentation Project park
 Erosion and sedimentation controls as
Accidental release of LNG, fires or explosions specified by EPP
 Secondary containment walls

Decommissioning

 Habitat Loss or alteration*  Mitigation measures similar to


Effects expected to be similar to construction. Activities
 Soil Erosion construction will be employed
would include: decommissioning of equipment, piping The site has been
 Introduction of invasive plant species  Decommissioning Plan would be Decommissioning strategy
and buildings and restoration of terrestrial habitats.  Habitat alteration developed prior to decommissioning affected by human
Onsite (within and duration to be
Impacts to be determined with development of a  Sedimentation of wetlands activities Low Reversible activity and is located Not significant
property boundary) determined prior to
decommissioning plan  Alteration of wetland hydrology  Ensure cleared areas are re-vegetated within an industrial
 Dust generation where appropriate decommissioning
park
 Direct mortality (associated with  Use of invasive non-native species for
sensitive flora) reclamation will be avoided

*Wetland alteration is not anticipated.

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6.2.2.1 Boundaries and Threshold

Spatial Boundaries

The spatial boundary for the assessment of terrestrial fauna includes the Project area as shown in
Figure 1-1. Both the developed and undeveloped portions of the site provide suitable habitat for a
variety of mammals and herptiles. Bird species could frequent any location within the property
boundary as well as associated marine areas.
Areas on the site may be critical to specific bird species. Birds are sensitive to disturbance around their
nest sites. Some aquatic birds may gather in large numbers during their migration in feeding and
resting areas. This assessment considers the potential effects on bird species within two distinct areas,
i.e., the facility footprint and marine terminal, and the coastal waters along the approach route to the
terminal site.

Temporal Boundaries

Most of the terrestrial fauna identified on site would be present in the area year-round. Some species
would be particularly sensitive to disturbance during certain times of the year depending on migratory
patterns, seasonal movement/hibernation or mating/breeding seasons.
Herptile species may be most sensitive to disturbance when they mate and lay eggs in wetland habitats
during the spring and summer (April through July). Mammals are mostly non-migratory and may be
present within the Project area year round, but some species may be more sensitive during harsh
winter conditions or hibernation periods. Migratory birds may occupy habitats in the vicinity of the
Project area during critical points in their life cycle, while others are residents of the site year-round.
The breeding season, typically April to August for most species, can be the most critical period for bird
species that are sensitive to habitat destruction and general disturbance (JWEL, 2004a).
Though temporal boundaries will vary for some species, this assessment will consider the potential
effects of the Project on terrestrial fauna on a year-round basis.

Administrative Boundaries

In general, the Nova Scotia Endangered Species Act and the federal SARA offer legal protection to those
species that are considered endangered, threatened, and vulnerable or of special concern.
All mammal species which are not designated as game animals or harvestable wildlife under the
provincial Wildlife Act and Regulations are protected at all times of the year. Herptiles which are hunted
for food are protected from hunting outside of defined seasons. Other herptiles have no legislative
protection unless they are considered a species at risk or are found in a protected area. The NS
provincial Wildlife Act and Regulations protect all non-game bird species that are not considered pests
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(JWEL, 2004a). Migratory bird species are protected under the Migratory Birds Convention Act, 1994
which was most recently amended in 2010.

Technical Boundaries

Information regarding terrestrial fauna at or near the Bear Head LNG facility site was derived from the
previously accepted environmental assessment, the knowledge of the consulting team, the ACCDC data
base (ACCDC, 2014) and the Maritime Breeding Birds Atlas database (MBBA, 2013).
Data received from ACCDC identifies rare and/or endangered flora and fauna within both a 5km buffer
area surrounding the Project site and a 100km buffer area. It also identifies whether any location
sensitive species are known within 5km of the site.
Data from the Maritimes Breeding Bird Atlas database identifies bird species with the potential to breed
in the vicinity of the Project site based on presence of suitable habitat. Bird species associated with both
water habitats and terrestrial settings are presented in the data. Data was obtained for the 10 x 10 km
survey area that encompasses the Project site.

Threshold

Evaluation criteria were used to determine whether a potential residual environmental effect on
terrestrial fauna was significant, not significant or positive. The following is a summary of the criteria for
each:
 A significant adverse effect occurs when the population of a species is sufficiently affected
to cause a decline in abundance and/or a change in their distribution beyond which natural
recruitment (such as reproduction and immigration) would not return the population to its
former level within several generations. A significant adverse effect on sensitive/critical wildlife
habitat is defined as any adverse environmental effect that results in a net loss of habitat
function.
 An adverse effect that does not exceed the above criteria is evaluated as not significant.
 A positive effect occurs when Project activities help increase species populations and/or
diversity or enhance habitat.
A relative magnitude rating was established for terrestrial fauna. The following criteria are considered
when determining the significance of an effect:
High: An environmental effect affecting a whole stock, population or where a specific parameter is
outside the range of natural variability determined by research and measurement based on local
knowledge over several seasons.
Medium: An environmental effect affecting a portion of a population, or the environmental effect may
be where there are rapid and unpredictable changes in a specific parameter so that it is temporarily

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outside the range of natural variability determined by research and measurement based on local
knowledge over several seasons.
Low: An environmental effect affecting a specific group in a population in a localized area, or where
there are distinguishable changes in a specific parameter, but that parameter is within the range of
natural variability determined by research and measurement and local knowledge over several seasons.

6.2.2.2 Interactions and Potential Effects

Construction and Commissioning

During the construction and commissioning phase, clearing and grubbing may result in habitat removal
and fragmentation for various species of terrestrial fauna.
Herptiles and amphibians may be affected by the potential diminution of general function of wetlands
and riparian areas as a result of clearing and grubbing, erosion and dust generation causing
sedimentation and changes in hydrology. This may affect the general suitability of some wetlands as
breeding habitats on the site.
Mammals may be adversely affected by the fragmentation and habitat loss due to clearing and grubbing
and disturbance by human activity. The extension of the security fence around the Project site may
inhibit the movement of larger mammals. It is likely that some mammal species will migrate to similar
habitats nearby, away from the Project site.
Land birds may be impacted by the loss of nesting and foraging habitats due to clearing and grubbing
activities. To avoid harming nesting birds, any additional clearing will be conducted prior to the breeding
season (May 1st to August 31st).
In addition to habitat loss, temporary effects from the generation of construction noise may affect
terrestrial fauna, especially birds and mammals. Construction noise can interfere with normal bird
behavior such as feeding, breeding and migrating. Noise may create stressful nesting and living
environments for wildlife which may result in species displacement, whereby individuals leave the
Project area and settle in less favourable habitats.
Increased vehicle traffic associated with the construction of the LNG facility could adversely affect
terrestrial fauna as a result of collisions with vehicles. It is expected that collisions would involve small
mammals, various land bird and herptile species. Amphibians would be most sensitive to road kill during
the spring when they migrate to nesting sites, whereas some reptile species, such as snakes, would be
susceptible during early spring and late fall when they bask on roads to increase body temperature
(JWEL, 2004a).

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Operation and Maintenance

The operation of the facility will generate noise and related disturbance which may affect terrestrial
fauna on or near the site. The degree of impact will differ between species; most will likely continue to
occupy adjacent habitat.
The LNG facility will be equipped with lighting for safety and security purposes and flares will be
installed for specific operational purposes. The facility, for example, will be equipped with two process
flares, a warm flare and a cold flare in the northern portion of the site. A third totally enclosed ground
flare will be installed at the marine terminal. These flares are not required under normal operating
conditions, but are designed to dispose of streams released during start-up, shutdown and plant upsets
or emergency conditions. Structures, flares and lighting all pose a risk of attraction and possible collision
to aggregations of birds, particularly to migrating birds. Birds can be attracted to lights and can die
either directly or from exhaustion when circling them for an extended period.
Since the flares will only be operational in specific circumstances and detailed flare management
procedures will be in place, they are unlikely to have a significant adverse effect on migrating birds and
bats.

Accidents and Malfunctions

Accidents and malfunctions during either the construction or operational phases could affect terrestrial
fauna; accidents may include erosion and sedimentation, fires and explosions, and leaks or spills.
Erosion resulting in sedimentation is most likely to occur during the construction and commissioning
phases of the Project due to increased ground disturbance. The site has been designed with two
sedimentation ponds for stormwater and surface water runoff control during rain events or increased
activity on the site. In the event that these controls fail or are not working properly, it is likely that
nearby wetlands, which are home to various species of herptiles and sources of food for other terrestrial
fauna, could be affected.
A fire or an explosion, should such an unlikely event occur, could result in terrestrial and wetland
habitat loss or alteration and direct mortality of mammals, birds and herptiles.
A spill or leak of hazardous materials could also occur on or near the Bear Head LNG facility as
chemicals used in the liquefaction process are transported, stored and used on site. A spill or leak could
cause the pollution of terrestrial habitats, including wetlands.

Decommissioning

Decommissioning activities are expected to present the same risks to terrestrial fauna as during the
construction and commissioning phase. Decommissioning could result in habitat loss or alteration,
specifically of forested and vegetated areas, as well as soil erosion and sedimentation of wetlands; in
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turn, this would adversely impact terrestrial fauna. Noise associated with the decommissioning of the
LNG facility could also disturb terrestrial fauna. The potential effects to terrestrial fauna during
decommissioning will be considered and addressed in a decommissioning plan which would be
developed as the facility nears the end of its life. This plan would include references to the standards
and procedures in place at the time. Depending on the future use of the site, the removal of the
security fence and re-vegetation of the site could allow for the re-introduction and possible re-
population of species that may then consider the site a suitable habitat, or may have inhabited the site
prior to development.

6.2.2.3 Mitigation

During construction it is important to limit the extent of the Project footprint and temporary work areas
as much as possible and to restrict clearing and grubbing to the necessary areas.
Dust prevention and abatement measures will be detailed in an EPP. Construction and operations staff
will maintain proper housekeeping practices and ensure that food and garbage items are properly
disposed of in a designated location to avoid attracting predators that may disturb or cause injury to
wildlife and birds.
The enhanced security fence planned for installation around the perimeter of the property will be chain
link; it will not be buried which will facilitate easy passage for small mammals. Although the fence may
restrict access for medium to large sized mammals, there will be areas that will allow passage along the
shoreline where the fence meets the water.
Vegetation clearing and grubbing must be avoided during the nesting season (May 1 to August 31).
Buffer zones will be placed around nests that are found, and clearing will only take place outside these
buffer zones. All construction equipment should contain noise-muffling devices to minimize noise
disturbance. Noise and light disturbance will be minimized and restricted to those areas where it is
necessary. The highest risk periods for migrating birds are from May 1 to mid-June and from mid-
August to mid-October, the periods of peak spring and fall migration. Birds would be most at risk
during foggy nights during these periods.
As part of an EPP and Stormwater Management Plan, specific methods will be discussed on how best to
manage erosion and sedimentation during construction and operation of the facility. Frequent inspection
of surface water runoff controls will be made to ensure that they function efficiently. Inspections will
take place before and after heavy precipitation events to identify whether erosion and sedimentation
control measures have failed; if failure occurs, repairs will be immediately undertaken. Details regarding
ongoing maintenance, inspections and repair of erosion and sedimentation controls will be specified in
the EPP. It is unlikely that a failure of erosion and sedimentation control measures would cause a
significant effect on terrestrial fauna. Strict adherence to the procedures specified in the EPP and
frequent inspections will inhibit the likely occurrence of a serious incident.

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The current design of the Bear Head facility incorporates secondary containment berms to restrict the
distribution of chemicals and harmful liquids in the case of an accidental spill or leak. These have been
included in the design to minimize impacts on terrestrial fauna onsite.
An emergency response and contingency plan will be developed to address the unlikely event of a
hazardous spill, fire or explosion. The plan will detail procedures to respond to incidents and to restrict
the dispersion of fire fighting chemicals and any other spilled substances that may adversely affect
terrestrial fauna.
Vehicle traffic associated with the operation of the facility is not expected to be high, and it is therefore
unlikely that wildlife populations will be significantly affected by mortality as a result of collisions. The
incidence, however, can be reduced by maintaining low speed limits on all roads.
Lighting at the facility during its operation will be on an as required basis to ensure for safe and
effective operations. The facility will be lit during night hours to ensure proper usage of the security
cameras and the general health and safety of personnel. Low intensity lighting will be used wherever
possible, and mounted lighting will be kept at low heights to the extent possible to reduce interference
with migratory birds and bats.
As discussed, there will be two land flares associated with the liquefaction trains; these flares will only
be used under specific circumstances during plant operation or shut-down. A flare management plan
will be developed as part of the EPP to reduce the overall effects that flares may have on terrestrial
fauna, specifically birds and bats. This plan will include detailed procedures on overall flare operations
and management, especially during adverse weather conditions. It will include detail on operating
times (during daylight hours/night hours). It is not likely that the flare will have serious effects on birds
and bats assuming mitigation measures are followed.

6.2.2.4 Potential Residual Effects

Provided that the recommended mitigation measures are implemented throughout the life of the
Project, no significant adverse residual environmental effects on terrestrial fauna are likely to occur.
Table 6-21 provides a summary of the potential residual environmental effects and recommended
mitigation measures that will be adopted to protect terrestrial fauna.

6.2.2.5 Monitoring and Follow-up

As discussed, the EPP will include a specific flare management plan to mitigate the potential effects of
flares on birds. In addition, a monitoring program may be developed to determine the overall residual
effects of the flare on local bird and bat populations. Monitoring programs will be developed in
consultation with NSE, NSDNR and the Canadian Wildlife Service.
Throughout the construction and operational phases of the Project, walk through assessments will be

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completed to observe and assess the general health of terrestrial fauna located on site as part of the
environmental management program.
Furthermore, any incident involving wildlife found on-site that appears to be in distress or agitated will
be reported to NSDNR in order to ensure that the animal receives proper care. The interaction of
construction and operations activities and staff with terrestrial fauna and their respective habitats will be
kept to a minimum to decrease the likelihood of potential habituation.

6.2.3 Freshwater Fish and Fish Habitat

Freshwaters (lakes, ponds, and streams and open water wetlands) have the potential to support fish
and other organisms which are important both ecologically and have social significance in supporting
commercial, recreational and Mi’Kmaq fisheries. Although there are several streams in the vicinity of the
Project site, they are all small, first order watercourses and for the most part not fish-bearing. The
streams do not at present, or are not likely to support significant numbers of fish, and are not likely to
support recreational, commercial or Mi’Kmaq fisheries. Overall, the probability of freshwater fish and fish
habitat, as well as their fisheries, being affected by the Project is low, and possible impacts of the
Project, although negative, are minor. Construction of the base pad was completed on the site in 2005-
2006; its construction did not remove or impact the streams on site. Current and future indirect effects
would be due to contributions from managed surface runoff into freshwater ditches and detention
ponds, affecting the magnitude of flows and water.

6.2.3.1 Boundaries and Threshold

Spatial Boundaries

The spatial boundaries for the assessment of freshwater fish and fish habitat include the Project site
indicated on Figure 1-1 and those portions of the streams that flow between the site and the Strait of
Canso.

Temporal Boundaries

Fish habitat is nearly always present in streams. There is therefore always the potential that Project
activities could impact both fish and fish habitat. Streams and associated fish habitat are most sensitive
to contamination during low flow periods (July-August) and to physical damage from extreme flows in
the spring summer and fall.

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Table 6-21: Potential Environmental Effects Assessment Matrix for Terrestrial Fauna

Significance Criteria
Residual Effect
Activity Potential Effect Mitigation
Magnitude Geographic Extent Duration/Frequency Reversibility Eco/Socio Significance
Context

 Habitat Loss  Implementation of EPP in general Onsite (within property To the end of construction, The site has been
Clearing, grubbing and grading (majority of which is
 Fragmentation  Minimize area and ground disturbance boundary) approximately 3 years affected by human
complete)  Disturbance and maintain connectivity between Construction will take place activity and is located
 Noise similar habitats where possible twenty four hours a day, within an industrial
Increased vehicle traffic
 Dust  Clearing and grubbing to be completed seven days a week park
Construction and installation of equipment,  Mortality outside of breeding season
 Erosion and Sedimentation of  Avoid wetland habitats where practical
infrastructure buildings and piping: Generation of
Wetlands (effecting herptiles)  Erosion and sedimentation controls as
noise, dust and light  Light (if required for construction specified by EPP Low Reversible Not significant

Onsite assembly of the liquefaction modules and activities)  Minimize duration of noise disturbance.
Use noise muffling devices on
construction of the LNG storage tanks: Generation construction equipment where possible
of noise, dust and light  Minimize use of lighting to greatest
extent possible. Use low intensity
Installation of Security Fencing along property
lighting and install at low heights to
boundary avoid bird migratory paths

Operation and Maintenance


 Disturbance of terrestrial fauna  Implementation of EPP in general Onsite (within property Life of the Project The site has been
Operation of LNG liquefaction trains, supporting
 Noise  Stormwater Management Plan boundary) (approximately 25 years) affected by human
infrastructure and LNG storage leading to increased  Light causing disorientation for  Ensure cleared areas are re-vegetated activity and is located
personnel on site birds where appropriate within an industrial
 Flare Management Plan as part of EPP park
Increased vehicle traffic  Use noise muffling devices on Low Reversible Not significant
equipment where possible
Increased security lighting and potential use of
 Minimize use of lighting to greatest
flares extent possible. Use low intensity
lighting and install at low heights to
avoid bird migratory paths
Accidents and Malfunctions
 Sedimentation of wetland  Implementation of EPP including the Mostly onsite with the Potential for accidents and The site has been
Sedimentation or erosion, particularly during
 Alteration of wetland hydrology following plans: potential to effect fauna malfunctions exists through affected by human
construction  Habitat Loss  Emergency Response and Contingency off the site in the case of construction, operation and activity and is located
 Direct Mortality Planning Low a fire, leak or decommissioning of the Reversible within an industrial Not significant
Spill, Leak or accident
 Stormwater Management Plan sedimentation spreading Project park
Accidental release of LNG, fires or explosions  Spill Management Plan
 Secondary containment walls
Decommissioning
 Habitat Loss  Mitigation measures similar to Onsite (within property Decommissioning strategy The site has been
Effects expected to be similar to construction.
 Fragmentation construction will be employed boundary) and duration to be affected by human
Impacts to be determined with development of a  Disturbance  Decommissioning Plan would be determined prior to activity and is located
decommissioning plan  Noise developed prior to decommissioning decommissioning within an industrial
 Dust activities Low Reversible park Not significant
 Mortality  Ensure cleared areas are re-vegetated
 Erosion and Sedimentation of where appropriate
Wetlands (effecting herptiles)  Use of invasive non-native species for
reclamation will be avoided

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Administrative Boundaries

Surface waters containing fish which are the object of aboriginal, commercial, and recreational fisheries
may not be disturbed without authorization from DFO; Watercourse Alteration Approvals are required
from NSE for any work undertaken in streams. A Coastal Approval may be required from NSDNR for
activities undertaken in streams below the High Water Mark. If there were fish species at risk in the
streams, approvals would be required under the Nova Scotia Endangered Species Act or SARA.

Technical Boundaries

Information on freshwater fish and fish habitat and recreational, commercial and Mi’Kmaq use was
derived from the consultants’ knowledge, recent site visits completed to verify the status of significant
biological resources in the vicinity of the site and to assess water chemistry; and the environmental
assessment undertaken in 2004 (JWEL, 2004a).

Threshold

Evaluation criteria were used to determine whether a potential environmental effect on freshwater fish
and fish habitat was significant, not significant or positive. The following is a summary of the
criteria for each:
A significant adverse effect would occur when there is a permanent net loss of freshwater habitat, or a
release of a deleterious substance into a watercourse in sufficient quantity to kill fish or reduce the
ability of the fish population to reproduce for one year or to induce a decline in abundance and/or
change in distribution beyond which natural recruitment would not return to the population to its
former level within several growing seasons.
High: A high effect would be one that removes all the fish from a site.
Medium: A medium effect one that induces a change (decline) of more than 2 standard deviations of
the normal average abundance of a particular species.
Low: A low effect one that has demonstrable effects on fish and fish habitat, such as loss of fish,
reduced condition, and removal of fish habitat, but does not meet the criterion for medium and high
effects.
An adverse effect that does not exceed the above criteria is evaluated as not significant.
A positive effect may enhance the quality, increase the species population/diversity, or increase the
area of freshwater fish habitat at the site, such as causing changes in the substrate or flow which make
the environment more suitable for fish.

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6.2.3.2 Interactions and Potential Effects

Construction and Commissioning

The pad for the facility has been prepared. Further physical activity at the site will involve above
ground construction and the mechanical assembly of the proposed facilities. Some additional forest
clearing may be required adjacent to the existing pad, but the impacts will be mitigated. Negligible
impacts on water quality and existing watercourses in the vicinity of the site are expected.
Clearing and Grubbing
Most of the onsite work of this type is complete; therefore any additional areas of the watershed
affected by new construction, e.g., construction of additional pads for buildings, or laydown areas, will
have only a minor, if any, impact on the streams at the site. Any effects will be mitigated by
appropriate runoff management and sedimentation controls. The degree of impact of these activities on
fish and fish habitat etc. with mitigation applied is low, and any effects while highly localized will be
short-term in nature.

Construction and Installation of Equipment, Buildings and Piping

Impacts from dust and air emissions generated by construction activities may be experienced in the
streams at the site. Similarly, the additional clearing and grubbing that is necessary will have minor, if
any, impact, on fish, fish habitat, and associated fisheries in the two intermittent streams on site.
Mitigation will be in place, and the impacts of these activities on fish, fish habitat and fisheries is likely
to be negligible.
Assembly of Liquefaction Modules and Construction of Storage Tanks
Impacts from dust and air emissions generated by construction activities may be experienced in the
streams on site. Similarly the additional clearing and grubbing that is necessary will have minor, if any,
impact on fish, fish habitat, and associated fisheries. Mitigation will be in place, and the impacts of
these activities on fish, fish habitat and fisheries is likely to be negligible.

Operation and Maintenance

The site will be operated to minimize dust from the use of roads, contaminant releases into runoff, and
air emissions. Contaminant releases may include oil and grease from equipment and vehicle operations,
salt from de-icing in winter, and reject and backwash from the demineralisation system. Freshwater
fish habitat will not be affected by activities related to the marine terminal and shipping.
Routine activities include the operation of the LNG liquefaction trains, supporting infrastructure and
LNG storage. The principal impacts from these activities will be changes to the runoff regime and
consequent flows (peak and minimum flows) in the streams; these will be moderated by the execution
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of a runoff management system and the monitoring of changes in the chemical characteristics of the
runoff. Any impacts from the residual contamination of runoff from site operations on fish are likely to
be minor. The site will not be available for use by locals for recreational purposes or for Mi’Kmaq use;
the site, however, was not a prime area for these uses in the past. Operations may result in air
emissions which could in turn lead to the contamination of waters, but the effects, if any, are expected
to be minor. Impacts from dust and air emissions generated by construction activities may be
experienced in watercourses at the site. Mitigation will be in place for these types of activities and the
overall effect will be minor.
Use of deicing chemicals such as road salt can potentially enter surface waters and change conditions.
The overall amounts that might be used cannot be predicted; however, the areas of open surface are
relatively small in relation to the area of the Project site and it is expected that any de-icing chemicals
used will be diluted significantly before entering the two small freshwater streams.

Accidents and Malfunctions

Accidents and malfunctions that may occur during construction or the operation of the LNG facility
could affect fish habitats and freshwater fish at the site. Accidental releases of hydrocarbons and fires,
and the emergency responses to them can generate contaminants in water and fluid flows which may
enter the runoff management system and potentially contaminate the streams.

Sedimentation or Erosion

Failure due to erosion of developed surfaces at the site, or structural failure of stormwater
management ponds under extreme flows, can damage streams exiting the site. The pad has been
designed and built such that failure is unlikely during exposure to extreme runoff events. Normal use of
settling ponds and prompt use of remediation measures to repair damage to erodible surfaces will
reduce the potential for sedimentation effects on streams and fish habitat.

Spills or Accident

Of the two freshwater streams at the site, the one located to the southeast drains most of the pad and
will be most seriously impacted in the event of any liquid spills and water used in cleanup of accidental
spills.

Accidental Releases of LNG, Fires or Explosion

The structural failure of LNG storage tanks and the responses to such an eventuality could overwhelm
the capacity of adjacent riparian areas to channel flow, and could disrupt the stream structure for
varying periods of time. The LNG itself will vapourize in the containment basin and will not reach the
streams and fish habitat. Accidental releases, fires, etc. and fluids used in emergency responses can

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generate contaminants and water and fluid flows which may enter the runoff management system and
contaminate the streams at the site.

Decommissioning

Decommissioning activities are expected to present the same risks to freshwater fish and fish habitat as
during the construction and commissioning phase. Impacts from dust and air emissions generated by
decommissioning activities may be experienced in watercourses at the site. Mitigation will be in place
for these types of activities and the overall effect will be minor.

6.2.3.3 Mitigation

The Bear Head LNG Project site and facility components have been carefully sited to minimize
interactions with freshwater fish and fish habitat and to avoid the two small first order water courses.
Both the present, and proposed, configuration of the site includes measures to minimise suspended
sediments and consequential changes to flow regimes in the streams. Further construction and
commissioning of the Project will not change the existing environmental protocols, which have been in
place and appear to have been working successfully to mitigate adverse effects on the streams.
Further mitigation measures for impacts on the freshwater fish and fish habitat will be detailed in the
updated EPP. This plan will include detailed procedures and information pertaining to erosion and
sedimentation control, surface water control and spill and leak management procedures.
The current design of the Bear Head LNG facility incorporates secondary containment berms for
restricting the distribution of chemicals and harmful liquids in the case of an accidental spill or leak.
These have been included in the design to minimize impacts on marine ecosystems including
freshwater fish and fish habitat on site and adjacent to the property.

6.2.3.4 Potential Residual Effects

Provided that the recommended mitigation measures are implemented throughout the life of the, no
significant adverse environmental effects on the freshwater fish and fish habitat are expected. Table 6-
22 provides a summary of the potential environmental effects and recommended mitigation measures
to be taken for the protection of freshwater fish and fish habitat, and recreational, commercial and
Mi’Kmaq fisheries.

6.2.3.5 Monitoring and Follow-up

Effluent, storm water and surface water monitoring will take place in accordance with the EPP to
ensure that TSS concentrations meet regulatory standards.

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Table 6-22: Potential Environmental Effects Assessment Matrix for Freshwater Fish and Fish Habitat
Significance Criteria
Effect Mitigation Magnitude Geographic Duration/Frequency Reversibility Eco/Socio Significance
Activity Extent Context
Construction and Commissioning
 Habitat Loss or alteration  EPP
Clearing, grubbing and grading (majority of  Habitat alteration of  Spill Management Plan
which is complete) streams; washout during  Stormwater is retained in two
extreme flows. sedimentation ponds and
Road Traffic  Sedimentation of streams treated prior to discharge
 Alteration of stream  Dust management
Construction and installation of equipment, hydrology
infrastructure buildings and piping Low Onsite 1/2 Reversible Developed Area Not significant

Onsite assembly of the liquefaction modules


and construction of the LNG storage tanks

Installation of Security Fencing along property


boundary

Operation and Maintenance


 Sedimentation of streams  Stormwater Management Plan
Operation of LNG liquefaction trains, from dust & erosion  Erosion and sediment controls
supporting infrastructure and LNG storage  Washout during extreme as specified in EPP
flows  Surface water management as
Low Onsite 1/25 Reversible Developed Area Not significant
Road Traffic  Change in hydrologic specified in EPP
regime
Facility structures can effect wind patterns

Accidents and Malfunctions


 Incidences of severe  Stormwater is retained in
erosion causing sedimentation ponds and
Spills or accidents. Potential of contaminants sedimentation and treated prior to discharge
to enter streams structural changes to (through settling)
streams  Emergency response and
Accidental release of LNG, fires or explosions  Failure of stormwater contingency plan as specified
management structures in the EPP High Onsite 1/100 Reversible Developed Area Not significant
 Fluid losses;  Spill management plan as
 Contaminants from fires specified in the EPP
and firefighting  Erosion and sedimentation
contaminate streams controls as specified by EPP
 Secondary containment walls

Decommissioning
 Habitat Loss or alteration  Decommissioning Plan
Effects expected to be similar to construction.  Habitat alteration of  EPP
Activities would include: decommissioning of streams; washout during  Spill Management Plan
equipment, piping and buildings and extreme flows.  Stormwater is retained in two
Low Onsite 1/2 Reversible Developed Area Not significant
restoration of terrestrial habitats. Impacts to  Sedimentation of streams sedimentation ponds and
be determined with development of a  Alteration of stream treated prior to discharge
decommissioning plan hydrology  Avoid streams
 Dust management

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6.2.4 Species at Risk

Information on SAR that may inhabit the Project site is detailed in Section 4.3. Terrestrial SAR which
have been recorded within 5 km of the site include 2 rare plants, 6 species of birds and the wood
turtle; the latter is not likely to be found on the Bear Head site. There are 6 additional avian species at
risk that are found in the near shore areas of the Scotian Shelf, but none are known to breed in
Chedabucto Bay. With the exception of the Ipswich Sparrow, they may occur in the Project area from
time to time. Marine SAR includes cetaceans, sea turtles and various species of marine fish. The
following sections focus on the terrestrial SAR, particularly the two plant species on site.

6.2.4.1 Boundaries and Thresholds

Spatial Boundaries

The spatial boundary for the assessment of SAR, particularly the Southern Twayblade and Northern
Comandra, is the Project area (Figure 1-1). Bird species considered at risk could frequent both the
Project site and the lands and waters at some distance from the Project site.

Temporal Boundaries

The two identified plant species are present on site year round. Other species of concern may or may
not be present. The bird species are considered migratory and may occupy habitats in the vicinity of
the Project site during critical points in their life cycle, while others may be residents of the site, or
adjoining lands, year-round. The breeding season, typically April to August, can be the most critical
period for bird species which are sensitive to habitat destruction and general disturbance (JWEL,
2004a).
Though temporal boundaries will vary by species, this assessment will consider the potential effects of
the Project on SAR on a year-round basis.

Administrative Boundaries

The Nova Scotia Endangered Species Act and the federal SARA offer legal protection to species that are
considered endangered, threatened, and vulnerable or of special concern. Birds which are hunted for
food are protected from hunting outside of defined seasons while others, not considered species at
risk, have no legislative protection unless found in a protected area. The NS provincial Wildlife Act and
Regulations protect all non-game bird species that are not considered pests (JWEL, 2004a). Migratory
bird species are protected under the Migratory Birds Convention Act.
Information regarding SAR at or near the Bear Head LNG facility site was derived from the previously
accepted environmental assessment, knowledge of the consulting team, a review of the ACCDC data

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base (ACCDC, 2014). Specific information on the distribution and abundance of birds has been
obtained through the Maritime Breeding Birds Atlas database (MBBA, 2013). ACCDC identifies
confirmed occurrences of rare and/or endangered flora and fauna in Nova Scotia, and a report is
provided which shows occurrences within a requested radius of a site, typically 5 km or 100 km.
The Maritimes Breeding Bird Atlas database identifies bird species with the potential to breed in the
vicinity of the Project site based on observations by birders in the area. Bird species associated with
both water habitats and terrestrial settings were presented in the data. Data was obtained for the 10 x
10 km survey area that includes the Project site.

Threshold

Evaluation criteria were used to determine whether a potential residual environmental effect on SAR
was significant, not significant or positive. The following is a summary of criteria for each:
A significant adverse effect occurs when the population of a species is sufficiently affected to cause
a decline in abundance and/or change in distribution beyond which natural recruitment (such as
reproduction and immigration) would not return the population to its former level within several
generations. A significant adverse effect on sensitive/critical wildlife habitat is defined as any adverse
environmental effect that results in a net loss of habitat function.
An adverse effect that does not exceed the above criteria is evaluated as not significant.
A positive effect occurs when Project activities help increase species populations and/or diversity or
enhance habitat.
A relative magnitude rating was also established for Species at Risk. The following criteria are
considered when determining the significance of an effect:
High: An environmental effect affecting a whole stock, population or definable group of organisms, or
where a specific parameter is outside the range of natural variability determined from local knowledge
over many seasons.
Medium: An environmental effect affecting a portion of population or one or two generations, or the
environmental effect may be where there are rapid and unpredictable changes in a specific parameter
so that it is temporarily outside the range of natural variability determined from local knowledge over
many seasons.

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Low: An environmental effect on: a specific group of individuals in a population in a localized area; one
generation or less; or where there are distinguishable changes in a specific parameter but the
parameter is within the range of natural variability determined from local knowledge over many
seasons.

6.2.4.2 Interactions and Potential Effects

Construction and Commissioning

During construction and commissioning, further clearing and grubbing of vegetation could result in
habitat loss and potential fragmentation of habitat for species of terrestrial flora that are considered at
risk or sensitive in the area.
The potential for sedimentation of wetlands is greater during this phase because larger areas of soil will
be exposed and physically disturbed. Sensitive species and SAR include Northern Comandra and
Southern Twayblade; these species may be affected by any increase flow of sedimentation to wetlands
from project works. Appropriate sediment control measures and the maintenance of a forested buffer
around both adjoining wetlands and the identified plant communities will prevent impacts to these
species.
Potential habitat for the Four-toed Salamander, a species at risk, exists in one of the wetlands though
the salamander has not been seen in the Project area. Should Project activities adversely impact the
wetland during construction, this could reduce the likelihood of finding this species on site.
Woodland birds, including those at risk or of concern, may be impacted by the loss of nesting and
foraging habitats due to additional clearing and grubbing activities. Measures prescribed by
Environment Canada (Canadian Wildlife Service), such as clearing outside breeding season (May 1st to
August 31st) will be employed throughout further construction in undisturbed environments to avoid
disturbing nesting birds.
In addition to habitat loss, temporary effects from the generation of construction noise may also affect
SAR, especially listed birds. Construction noise can interfere with normal bird behavior such as feeding,
breeding and migration.

Operation and Maintenance

An important concern during the operation of the facility is the potential impact to SAR birds as a result
of noise, lights and flares. Birds that are at risk could also be affected by increased vehicle traffic and
by the sedimentation of wetlands or physical disturbance associated with normal operating activities.
The LNG facility will be equipped with lighting for safety and security purposes. Security cameras
require lighting to view the facility operations at night. The facility lighting may attract migratory birds;

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and cause disorienting effects which may cause collisions leading to mortality. Facility lighting and noise
generated from operation may also disturb foraging routines for any bats in the area.
Three flares will be located on the Bear Head LNG site; two will be located within the terrestrial
developed footprint and the third, an enclosed ground flare, will be located near the marine terminal.
Flares have similar effects to lights in relation to migratory birds; they can also cause mortality to birds
and bats that are attracted to them. Bats aren’t necessarily attracted to the lights and flares, but could
be impacted if they accidentally stray into the flare along their flight path. The flares are not required
under normal operating conditions, but are designed to dispose of streams released during start-up,
shutdown, and plant upsets or emergency conditions. The land flares may attract migratory birds and
bat species which may be considered at risk; although enclosed, the marine flare on site may still
attract sensitive or at risk seabirds and coastal waterfowl.
Avian species at risk using the coastal waters at or in proximity to the Project site, or further out into
the waters of Chedabucto Bay, are unlikely to interact significantly with the marine facilities associated
with the Project.

Accidents and Malfunctions

Accidents and malfunctions resulting from the construction or operational phases of the LNG facility
that could affect identified SAR are likely to involve erosion and sedimentation, fires and explosions, or
leaks or spills.
Erosion leading to sedimentation would most likely occur during the construction and commissioning
phase due to increased ground disturbance. The site has been designed with two sedimentation ponds
for stormwater and surface water; these accommodate runoff control during rain events or increased
activity on the site. In the case that these controls fail or are not working properly, it is likely that
nearby wetlands and streams, and associated habitat for the two listed species of plants, could be
affected.
There is potential for fires and explosions associated with accidental releases of LNG while the facility is
in operation. Fire or an explosion could result in terrestrial habitat loss, or in the direct destruction of
sensitive habitat and plant groupings.
A spill or leak of hazardous materials could also occur on or near the Project site as chemicals used
throughout the liquefaction process will be transported and stored on site. Comparable to the effects
of fires and explosions, spills and leaks could cause pollution of terrestrial habitats, including wetlands,
which support the identified SAR flora.

Decommissioning

Decommissioning activities are expected to present the same risk to SAR as the construction and

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commissioning phase. Decommissioning could result in habitat loss or alteration of forested and
vegetated areas, and cause soil erosion and sedimentation of wetlands which could adversely impact
the identified flora at risk. Noise associated with decommissioning could disturb birds at risk if they are
present in adjacent forest and wetland areas. A decommissioning plan will be developed when the
facility nears the end of its life; this plan would include references to the standards and procedures in
place at the time. Depending on the future use of the site, a buffer area may be required around the
flora at risk to ensure their protection from physical disturbance.

6.2.4.3 Mitigation

Mitigation measures will be similar to those proposed for terrestrial habitat and terrestrial fauna. During
construction it is important to reduce the project footprint and temporary work areas as much as
possible and restrict clearing and grubbing to areas absolutely necessary to carry out the Project.
Physical disturbance to wetland and terrestrial habitats will be minimized where possible. A forested
buffer area approximately 30 m wide will be maintained around the Southern Twayblade and Northern
Comandra populations and construction or operational activities should not be undertaken within this
area.
Vegetation clearing and grubbing must be avoided during the nesting season (May 1 to August 31) to
protect all birds including those at risk. Buffer zones will be placed around any nests that are found,
and clearing will only occur outside of this zone. All construction equipment should contain noise-
muffling devices to minimize noise disturbance. Noise and light disturbance is to be minimized and
restricted to areas only where it is necessary.
As part of an EPP and Stormwater Management Plan, specific methods will be adopted to manage
erosion and sedimentation during both construction and operation of the facility. Frequent inspection of
surface water runoff controls will be made to ensure their efficient functioning. Inspections will occur
before and after any heavy precipitation events to identify whether erosion and sedimentation control
measures have failed, and repairs will be immediately undertaken if required. Details regarding ongoing
maintenance, inspections and repair of erosion and sedimentation controls will be specified in the EPP.
It is unlikely that a failure of erosion and sedimentation control measures would cause a significant
effect on SAR identified species; strict adherence to the procedures specified in the EPP and frequent
inspections will inhibit the likely occurrence of a serious incident.
The current design of the Bear Head facility incorporates secondary containment berms to restrict the
distribution of chemicals and harmful liquids in the case of an accidental spill or leak. These have been
included in the design to minimize impacts on the terrestrial and marine ecosystems on-site and
adjacent to the property, including SAR.
An emergency response and contingency plan will be developed to address the unlikely event of a
hazardous spill, fire or explosion. This plan will detail procedures to respond to these incidents and to

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restrict the dispersion of fire fighting chemicals and any other spilled substances that may adversely
affect the identified SAR.
Operational lighting at the facility will be on an as required basis. The facility will be lit during night
hours to ensure proper usage of security cameras and to ensure the general health and safety of
personnel. Low intensity lighting should be used wherever possible, and mounted lighting should be
kept low to reduce interference with migratory birds, including those of special concern.
There will be two land flares associated with the liquefaction trains and one flare associated with the
marine terminal. These flares will only be in use under specific operational circumstances. A flare
management plan will be developed as part of the EPP to reduce the overall effects that that flares may
have on various species including SAR. It is not likely that the flare will have serious effects on SAR if
identified mitigation measures are followed. The flares will be operational throughout the life of the
Project so minimal residual effects could result.

6.2.4.4 Potential Residual Effects

Provided that the recommended mitigation measures are implemented throughout the life of the
Project, no significant adverse residual environmental effects on SAR are likely to occur. Table 6-23
provides a summary of the potential residual environmental effects and recommended mitigation
measures to be taken for protection of at risk and sensitive species on the Project site.
The marine operations associated with the Bear Head LNG Project, including the transport of LNG
through coastal waters, will be conducted to high environmental standards; no harmful interactions
with marine life or marine SAR are expected.

6.2.4.5 Monitoring and Follow Up

An annual inspection of the site by an appropriately qualified ecologist will be undertaken to observe
the general abundance and health of the Southern Twayblade and Northern Comandra in their
respective wetland habitats. It will be pertinent to determine whether significant population changes
occur, and whether or not these changes could be related to Project activities. Similar studies may be
undertaken to observe and record bird species in and around the site to determine whether the variety
of species has changed and if any new SAR are encountered.
The EPP will include a specific flare management plan to help mitigate the potential effects that the
flare may have on birds, particularly SAR. Appropriate monitoring programs will be developed in
consultation with NSE, NSDNR and the Canadian Wildlife Service.

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Table 6-23: Potential Environmental Effects Assessment Matrix for Species at Risk

Significance Criteria
Residual Effect
Activity Potential Effect Mitigation
Magnitude Geographic Duration/Frequency Reversibility Eco/Socio Significance
Extent Context

Construction and Commissioning

 Habitat Loss  Implementation of EPP in general


Clearing, grubbing and grading (majority of which is complete)
 Fragmentation  Minimize area and ground disturbance and
Increased vehicle traffic  Disturbance maintain connectivity between similar habitats
 Noise where possible
Construction and installation of equipment, infrastructure  Dust  Ensure buffer area is established surrounding
buildings and piping: Generation of noise, dust and light  Mortality Southern Twayblade populations
To the end of construction, The site has been
 Erosion and Sedimentation  Clearing and grubbing to be completed outside
Onsite assembly of the liquefaction modules and construction of Wetlands (effecting of breeding season Onsite (within approximately 3 years affected by human
of the LNG storage tanks: Generation of noise, dust and light herptiles)  Avoid wetland habitats where practical Low property Construction hours will Reversible activity and is located Not significant
 Light (if required for  Erosion and sedimentation controls as boundary) take place 24 hours a day, within an industrial
Installation of Security Fencing along property boundary construction activities) specified by EPP seven days a week park
 Minimize duration of noise disturbance. Use
noise muffling devices on construction
equipment where possible
 Minimize use of lighting to greatest extent
possible. Use low intensity lighting and install
at low heights to avoid bird migratory paths
Operation and Maintenance

 Disturbance of terrestrial  Implementation of EPP in general


Operation of LNG liquefaction trains, supporting infrastructure
fauna  Stormwater Management Plan
and LNG storage leading to increased personnel on site  Noise  Ensure cleared areas are re-vegetated where The site has been
 Light causing disorientation appropriate Onsite (within affected by human
Increased vehicle traffic Life of the Project
for birds  Flare Management Plan as part of EPP
Low property Reversible activity and is located Not significant
Increased security lighting and potential use of flares  Use noise muffling devices on equipment (approximately 25 years)
where possible boundary) within an industrial
 Minimize use of lighting to greatest extent park
possible. Use low intensity lighting and install
at low heights to avoid bird migratory paths
Accidents and Malfunctions

 Sedimentation of wetland  Implementation of EPP including the following


Sedimentation or erosion, particularly during construction Potential for accidents and The site has been
 Alteration of wetland plans:
hydrology  Emergency Response and Contingency Onsite (within malfunctions exists through affected by human
Spill, Leak or accident
 Habitat Loss Planning Low property construction, operation and Reversible activity and is located Not significant
Accidental release of LNG, fires or explosions  Direct Mortality  Stormwater Management Plan boundary) decommissioning of the within an industrial
 Spill Management Plan Project park
 Secondary containment walls

Decommissioning

 Habitat Loss  Mitigation measures similar to construction will


Effects expected to be similar to construction. Impacts to be
 Fragmentation be employed
determined with development of a decommissioning plan The site has been
 Disturbance  Decommissioning Plan would be developed Decommissioning strategy
 Noise prior to decommissioning activities Onsite (within affected by human
and duration to be
 Dust  Ensure cleared areas are re-vegetated where Low property Reversible activity and is located Not significant
determined prior to
 Mortality appropriate boundary) within an industrial
 Erosion and Sedimentation  Use of invasive non-native species for decommissioning
park
of Wetlands (effecting reclamation will be avoided
herptiles)

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6.3 Ecological Environment: Marine

A wide range of marine and estuarine animals and plants utilize marine waters and the seabed, both in
the immediate Project area and in the waters of the Strait of Canso and Chedabucto Bay. Not only does
the environmental assessment undertaken in 2004 recognize the importance of this marine regime, but
Bare Head LNG, as indicated in Sections 4.6-4.10 has updated the marine biological data base. The
marine environment, however, is not the primary focus of this registration to NSE. As indicated in
Section 1.9, the proponent has met with the Canadian Environmental Assessment Agency, with DFO,
with Transport Canada and with others, has provided information on the parameters of the revised
Project and a determination has been made that CEAA no longer applies and that all approvals and
authorizations pertaining to the marine environment are either in place or are in the process of being
updated.
In the course of reviewing both the previously approved environmental assessment and the updated
data compiled through the latter half of 2014 and early 2015, the following marine VECs were
identified: marine habitat and marine life. These were subject to analysis, and Tables 6-24 and 6-25
provide the results. There will be no significant impact from the proposed Project on the marine
environment. The considerable work done to update the marine data bases, however, remains of
relevance as it will provide an invaluable reference in the preparation of subsequent documentation
including the marine terminal EPP.

6.4 Socio-Economic Environment

The socio-economic environment encompasses the communities, the residents and businesses that will
accommodate and support the Bear Head LNG facility. The Municipality of the County of Richmond in
collaboration with others, including the Province of Nova Scotia, has already designated the lands at
Point Tupper for industrial development. The proposed use is appropriate to the land use designation.
The consequences of the Project’s further construction, commissioning and operation will have
consequences for the surrounding communities, the Province and beyond. The more significant of
these are referenced in the sections that follow. Table 6-26 provides an overview of the socio
economic consequences of the proposed Project at the end of the section.

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Table 6-24: Potential Environmental Effects Assessment Matrix for Marine Habitat
Significance Criteria
Effect Mitigation Magnitude Geographic Duration/Frequency Reversibility Eco/Socio Significance
Activity Extent Context
Construction and Commissioning
Construction of Marine Terminal including vessel berth  Habitat loss or  EPP
and trestles alteration  Spill Management Plan
 Sedimentation and
Installation of dolphins and associated pile driving seabed erosion Medium Onsite Short-term Reversible Undeveloped Area Not significant
 Sediment and water
Construction of marine equipment and vessels contamination
 Underwater Noise
Operation and Maintenance
 Sediment and water  EPP
Increased marine traffic with operation of terminal contamination  Spill Management Plan
including tankers and support vessels  Lights and Flare  Marine Safety Plan

Low Onsite Duration of Project Reversible Undeveloped Area Not significant


Marine Flare operation

LNG Pipeline Operation

Accidents and Malfunctions


 Sediment and water  EPP
contamination  Spill Management Plan
Spill or Leak – from tankers and vessels  Habitat alteration  Marine Safety Plan
 Secondary containment Low Onsite 1/100 Reversible Undeveloped Area Not significant
Accidental release of LNG, fires or explosions walls (land based portion of
facility)

Decommissioning
 Habitat loss or  EPP
Effects expected to be similar to construction. Activities alteration  Spill Management Plan
would include: decommissioning of equipment, piping  Sedimentation and
and buildings and restoration of disturbed coastline and seabed erosion Low Onsite Short-term Reversible Undeveloped Area Not significant
marine habitat if possible. Impacts to be determined  Sediment and water
with development of a decommissioning plan contamination

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Table 6-25: Potential Environmental Effects Assessment Matrix for Marine Life
Significance Criteria
Effect Mitigation Magnitude Geographic Duration/Frequency Reversibility Eco/Socio Significance
Activity Extent Context
Construction and Commissioning
 Underwater Noise  EPP
Construction of Marine Terminal including vessel berth  Collisions and  Spill Management Plan
and trestles Entanglement  Marine Mammal / Sea
 Hydrocarbon & Turtle Monitoring
Low On-site Short-term Reversible Undeveloped Area Not significant
Installation of dolphins and associated pile driving Contaminant Spills

Construction of marine equipment and vessels

Operation and Maintenance


 Lights and Flare  EPP
Increased marine traffic with operation of terminal attract / harm  Spill Management Plan
including tankers and support vessels seabirds  Marine Mammal / Sea
 Collisions of Turtle Monitoring
Low 1-10 km Duration of Project Reversible Undeveloped Area Not significant
Marine Flare operation Tankers with
Whales & Sea
LNG Pipeline Operation Turtles

Accidents and Malfunctions


 Oiling of coastal  EPP
birds.  Spill Management Plan
Spill or Leak – from tankers and vessels  Spill response  Secondary containment
effects walls (land based portion of Low 1-10 km 1/100 Reversible Undeveloped Area Not significant
Accidental release of LNG, fires or explosions facility)
 Emergency Response Plan
for coastal colonies
Decommissioning
 Habitat loss or  EPP
Effects expected to be similar to construction. Activities alteration  Spill Management Plan
would include: decommissioning of equipment, piping  Sedimentation and  Marine Mammal / Sea
and buildings and restoration of disturbed coastline and seabed erosion Turtle Monitoring Low On-site Short-term Reversible Undeveloped Area Not significant
marine habitat if possible. Impacts to be determined with  Sediment and water
development of a decommissioning plan contamination

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6.4.1 Key Settlements, Land Use, Community Services and Infrastructure

A description of key settlements, land use, community services and infrastructure in the Point Tupper,
Port Hawkesbury and Richmond County areas is provided in Section 4.10.1. To facilitate the analysis
land use, community services, traffic demands, medical and emergency facilities, accommodations,
entertainment, and related infrastructure have been grouped and considered together; these
components are relevant and important to the communities, whose services and infrastructure
contribute to the successful accommodation of a new industry and future socio-economic growth in the
Strait region. Although the Bear Head LNG site has been partially developed and is located within an
industrial park zoned for heavy industrial use, its further construction and subsequent operation will
have an effect on many facets of the community and its infrastructure and services.

6.4.1.1 Boundaries and Threshold

The spatial boundaries of potential impact include the Project site as shown in Figure 1-1, the
communities surrounding the Strait of Canso and the Municipality of the County of Richmond. Indeed,
the construction and operation of the Project will impose demands on the services and facilities
provided in these areas, but at the same time the Project will also support the further economic well
being of these areas both directly and indirectly. The Project dimensions that may have impact on
these factors include, but are not limited to, the development and operation of the facility itself, project
labour, the direct and indirect spending power of that labour and their need for services; the
proponent’s need for services and goods locally and beyond; and travel patterns associated with the
Project through both construction and operation.
Work started at the site in 2004. The Project site has been cleared and a large portion of the site work
completed. Construction of the plant and associated marine terminal is predicted to take place over the
next 3 years and the operation of the facility is predicted to continue for at least 20 years. The
demands on land use, services and infrastructure by Bear Head LNG will change over time, but there
will be demands throughout construction, plant operation and ultimate decommissioning that will have
consequences for the regional area.
The Project site is located in the Point Tupper Industrial Park in the Municipality of the County of
Richmond. Port Hawkesbury is the nearest large town and will be the community that provides many of
the services and accommodates a large percentage of the labour force during the plant’s construction
and its subsequent operation.
The following factors need to be taken into account to determine whether or not a significant effect
on this group of considerations could occur:
 Whether or not the proposed facility poses an inordinate demand on the social infrastructure
of the surrounding communities with respect to schooling, medical services, municipal services

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etc.;
 Whether or not there is excessive demand on the local emergency response capacity and
health care system;
 Whether or not there is an excessive demand on local accommodations, entertainment and
food establishments;
 Whether the road networks and other transportation systems can accommodate the increased
demands being placed upon them;
 Whether or not there is a demand for new accommodations that put stress on local property
markets; and
 Whether demands for potable and process water can be accommodated without posing a
threat to supplies to neighbouring areas, particularly the Town of Port Hawkesbury that draws
its water from Landrie Lake.
If a demand on a service can be accommodated without undue pressure on the supplying or
responsible agency, it is not considered to be significant.
A positive effect is one that:
 Increases the potential for economic growth in the study area and Nova Scotia;

 Improves community infrastructure (including medical and health care services, food and
entertainment, roads, and municipal infrastructure); and
 Elicits broad social support.

6.4.1.2 Interactions and Potential Effects

Construction

The Project site is zoned for industrial use in the Point Tupper Industrial Park and is located some
distance from the nearest residence and from other industrial facilities with a significant daily labour
force. The nearest industrial activities include a wind farm and the NSPI ash dump. Construction activity
is therefore unlikely to cause disturbance to the abutting land uses. The LNG facility will be developed in
accordance with all municipal land use planning requirements. Construction traffic will certainly add to
the volumes that currently use Industrial Park Road from Trunk 4, but as detailed in section 4.10.1.7,
the traffic volumes using these roads have fallen over the past decade; there is therefore capacity
within the system to accommodate the construction traffic that is anticipated without posing an
unwarranted burden on the road authority.
As indicated in Section 2.9, it is anticipated that up to 700 jobs will be generated through construction.

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This labour force will be drawn from a wide catchment and many employees will drive to the site
individually or in car pools; some may seek accommodation locally. Point Tupper and the neighbouring
communities have accommodated construction labour forces of the same or greater numbers in the
past, e.g., for the construction of the mill and of fractionation plant; they will be able to do so again.
This labour force will place demands on local services, i.e., everything from food outlets, to grocery
stores and gas stations, but overall the impacts for the local community will be positive. At the same,
time there could be an increased demand on emergency and health care services in the area; again the
services exist in the local area and will adjust to the demands that arise. The likely increase of
population and activity in the area will increase demand on all services and may take up some of the
slack resulting from fluctuations in the local economy.

Operations and Maintenance

The principal aspects of the operation and maintenance of the Bear Head LNG facility that will have an
impact on the regional settlements, land use, community services and infrastructure include the
Project’s proximity to the settlements of the Strait region and its location within the Municipality of the
County of Richmond; the appropriateness of its development within an industrial park; the demands
that the labour force will place on the region’s services plus the direct and indirect spending that both
labour and Bear Head LNG will incur locally, regionally, nationally and internationally; and the demands
that the plant and its employees will make on infrastructure such as the roads, marine services,
electricity and other utilities.
As detailed, the Project is appropriately sited in an industrial area and is likely to strengthen the
dynamics and linkages that already exist both within the immediate area and in the Strait region as a
whole. The marine terminal will add an important dimension to the traffic that already uses the existing
Port and will generate more business to those who provide services and goods to the vessels. The
development and expansion of the commercial linkages that exist in an industrial area are essential to
its success and further expansion. After several years of disappointing economic activity around the
commercial waters in the Strait of Canso, the development of this facility could be an important catalyst
for further investment. Its development will be positive not only for the Municipality of the County of
Richmond, but Port Hawkesbury, Mulgrave and communities further afield.
The demands of community services and infrastructure will again change when the plant is
commissioned and in full operation. There will be fewer people employed directly, but the additional
largely technical and professional workforce will augment and complement the labour force that exists
in the region. Over time, it is likely that important lineages will be established with the NSCC, with Cape
Breton University and with other institutions of higher learning in the region and beyond. Bear Head
LNG have made commitments to work with representative labour groups, in the region, with First
Nations and with other stakeholders to ensure the success of their Project and to facilitate growth and
maximize benefits to the communities of which they have become part.

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Accidents and Malfunctions

As with all heavy industrial operations, there is potential for the accidental release of contaminants (POL
and chemicals) from equipment and vehicles, an increased potential for personal injuries and the
unlikely potential for a serious accidental event, such as fire or explosion at any time through the life of
the Project. This will place an increased demand on local first responders and services including fire,
police, emergency and medical services. As referenced in Section 4.10.1, the services in the area
respond to the needs of the Point Tupper Industrial Park. Bear Head LNG will also work collaboratively
throughout the life of the Project with representatives of all pertinent services to ensure that the
appropriate protocols are in place at the plant and in the broader area to ensure the safety of their
employees and others working and living in the immediate area.

Decommissioning

The potential effects of decommissioning process are expected to be comparable to those described in
for the construction and commissioning phase of the Project with the difference that mechanisms and
advisory services may be required to support those who would inevitably lose their employment.

6.4.1.3 Mitigation

As stated in previous sections, Bear Head LNG will develop their own contingency plans and will initiate
the necessary communications with local service providers to develop the response protocols for the
facility. These will be detailed in an Emergency Response and Contingency Plan. Bear Head LNG has
articulated its intent to be a responsible corporate citizen and to work collaboratively with the
representatives of the local communities and key organizations. These initiatives will be instigated and
will evolve over time.
Environmental management and contingency systems will be put in place to ensure the safe operation
of the Bear Head LNG facility and marine terminal. The proponent, and particularly the employees, will
forge a place for themselves in the communities of the region. The mitigation of any adverse impact
associated with the operation of the facility, or additional pressure, if any, on services, will be countered
by the contributions that a skilled labour force and their families will make to the communities in which
they live. This will include people who already live in the area and who will find employment at the
plant; it will also include those who come to the area for employment and who contribute to
associations and sporting events for the first time.

6.4.1.4 Potential Residual Effects

The development and operation of the proposed LNG facility and associated marine terminal will
strengthen the industrial fabric of the Strait region, will generate substantive employment and will
directly and indirectly contribute positively to the economy of the region. Although there will

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undoubtedly be some pressures exerted on services in response to specific demands, some totally
unforeseen, it is anticipated that these will be addressed through responsible collaboration between the
parties involved. The Point Tupper Industrial Park was designated and developed to accommodate this
type of development and investment, and the benefits will occur locally, regionally and provincially.

6.4.1.5 Monitoring and Follow-Up

The follow-up that is required is the maintenance and expansion of the dialogue that is taking place
between the proponent, the municipalities in the area, the service providers and other stakeholders.
This will evolve and develop over the next three years as the plant is constructed. Existing
collaborative relationships will be strengthened and new ones will be established that will ensure that
the plant is successfully commissioned and becomes a contributing industry in the Strait region.

6.4.2 Economic Development

Economic development is essential to the future well being not only of the Strait of Canso, but to the
Province. The need to generate new employment opportunities and to retain a greater percentage of
the provinces graduates has been well documented. Economic development is therefore seen as a
factor in this assessment.

6.4.2.1 Boundaries and Threshold

The Bear Head LNG Project will generate benefits to the economy of the Municipality of the County of
Richmond, Port Hawkesbury, other communities in the Strait Region and beyond, and the Province as a
whole. Indeed benefits will extend beyond the Province to Canada and elsewhere through the
distribution of direct and indirect spending and tax regimes.
Temporal boundaries encompass the construction period, i.e., approximately 3 years, the period of
operation, i.e., at least 20 years, and a shorter period associated with decommissioning.
The technical boundaries in many respects overlay the administrative boundaries with respect to the
regimes that influence the distribution of project expenditures including taxes. It is also true that the
development of this Project will have an economic impact not only beyond the boundaries of the Strait
region, but internationally. During construction, for example, highly specialized facility components will
be purchased in the US or elsewhere; this will also be true, but likely to a lesser extent, during the
plant’s operation.
A significant adverse effect on economic development is one that negatively impacts one of the
following economic factors:
 Regional employment and income levels;
 Regional economic activity;

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 Existing commercial and industrial activity; and/or
 Regional labour supply.

A positive effect is one that enhances the above-mentioned criteria.

6.4.2.2 Interactions and Potential Effects

It is estimated that through construction some $3.312 billion in gross product and 36,263 person-years
of employment will be generated overall (Perryman Group, 2015). As indicated in Section 2.9, this
likely to translate into a construction workforce of up to 700. It is through local expenditures on labour,
goods and services, and on municipal and other taxes that the benefits will accrue locally, regionally,
provincially and nationally.

Construction

The Bear Head LNG Project is expected to have a positive impact on regional employment, income and
local economic activity throughout the construction period. During the peak construction period,
approximately 600 to 700 jobs will be created. It is predicted that construction and preoperational
spending will likely generate a gain in business activity of about $2.415 billion in gross product and
24,302 person-years of employment.

Operations and Maintenance

Although the economic benefits associated with the operation of the facility will differ from those
experienced through the construction period, the operation of the Project will continue to have positive
impact on regional employment, incomes and gross economic activity. The operations and maintenance
phase will create between 45 and 70 permanent direct jobs for a period of 20 years and upwards of 175
indirect jobs. In addition, Bear Head LNG will pay taxes to all levels of government and continue to
purchase goods and services within the local community and beyond.

Accidents and Malfunctions

Not applicable.

Decommissioning

The economic consequences of decommissioning are two fold: a change in the manpower requirements
both in the short and long term and a demand for a different range of services and equipment during
the process. The long term consequences of loss of employment, related expenditures and taxes would
be significant particularly to the local municipalities.

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6.4.2.3 Mitigation

As a premise of being a good corporate citizen in the Strait region, Bear Head LNG has developed a
dialogue with the key business groups including those that represent businesses throughout Cape
Breton to ensure firstly that they are made aware of the services and skills that exist within the region,
and secondly to ensure that local providers are aware of the opportunities presented by the proposed
Project. Bear Head LNG are also in the process of developing a Benefits Plan with First Nations in
recognition of the skills and attributes that they can bring to the successful execution and operation of
the project. This outreach will continue as it is in the best interests not only of Bear Head LNG, but the
communities involved.

6.4.2.4 Potential Residual Effects

See section 6.4.1.4.

6.4.2.5 Monitoring and Follow-Up

See section 6.4.1.5.

6.4.3 Marine Navigation

Section 4.10.3 describes marine navigation and traffic, current procedures, and the ways that marine
traffic associated with the Bear Head LNG facility will be accommodated and handled within Chedabucto
Bay and the Strait of Canso waters. Marine traffic and infrastructure are important for the following
reasons:
 Will have an impact on existing patterns of marine transportation;

 May have an impact on navigation safety; and


 Changes in traffic may impact traffic of existing industries.

6.4.3.1 Boundaries and Threshold

Spatial boundaries relate to the waters of the Strait of Canso and Chedabucto Bay. The Harbour Limit,
as shown on Figure 4-35, stretches between Red Head and Janvrin Island. The Pilotage Limit stretches
between Red Head and Crichton Island Light. All anchorages are shown on Figure 4-35, including the
six east of the vessel track and the nine in the Inhabitants Bay and Lennox Passage area. The proposed
wharf facility is located approximately 1,260 m northwest of the Bear Head Light and will extend into
the Strait of Canso to a charted water depth of approximately 20 m.
There will likely be some vessel movements associated with the development of the wharf facilities, but
LNG tankers are associated with the operation of the facility. Vessel movement will be a year round

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activity. It is expected that Bear Head LNG activities will result in 80 to 130 LNG vessels per year
servicing the needs of the facility. This represents the arrival of a vessel approximately every 2-3 days.
These LNG vessels reach an average sea speed of 19.5 knots, but will reduce to 15 knots before
reaching the Pilot Boarding Station.
The following acts, regulations, and guidelines will apply to the LNG vessel movements:
 Canada Shipping Act and Regulations, Transport Canada, 2001, c.26

 Vessel movement;
 Promote well-being of individuals and crews who participate in marine transportation;
 Promote safety and protect environment from damage;
 Promote efficient vessel movements and harmonization of marine practices; and

 Regulations, inspection, and enforcement program, including Regulations for the


Prevention of Pollution from Ships and Dangerous Chemicals
 Oceans Act and Regulations, 1996, c.31
 Vessel movement;
 Coast guard services;
 Navigation aids, marine communications and traffic management; and
 Channel maintenance (including ice breaking).
 Canadian Marine Act, 1998, c.10
 Vessel movement;
 Implementation of policies for, and management of, marine transportation and
infrastructure; and
 Promote success and growth in Canadian economy and trade;
 Pilotage Act and Regulations, 1985, C.P-14
 Vessel movement;
 Establish, operate, maintain, and administer the interests of safety and efficient pilotage
service; and
 Responsible for compulsory pilotage and other activities.
 Navigable Waters Protection Act, 1985, c.N-22
 Construction of the terminal and other marine infrastructure.
 International Maritime Dangerous Goods (IMDG) Code;

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 Classification of dangerous goods.
 International Maritime Organization (IMO) and Safety of Life at Sea (SOLAS)
With respect to marine navigation, the Canadian Coast Guard, the Atlantic Pilotage Authority and
Transport Canada all have jurisdiction over activity within the Strait of Canso and Chedabucto Bay
areas. Table 6-26 describes the roles of each of these authorities. The routing of vessels is monitored
by the Vessel Traffic Services (VTS), assisted by Pilots and permitted by Customs and Port Authorities.
Transport Canada Marine Services (TCMS) will form a technical review committee (TRC) to review the
TERMPOL document presented by Bear Head LNG. The scope of review will be defined by the Bear
Head LNG team, proponent agents, and the TRC.

Table 6-26: Roles of Marine Authorities within the Strait of Canso

Authority Duties and Responsibilities

 Verification that Aids to Navigation meets National Levels of Service Standards for all
Canadian Waters, including buoys and lights.
 MCTS services (ECAREG and Canso Traffic)
Canadian Coast
 Communication between vessels and authorities
Guard
 Emergency Preparedness and Response
 CSA Response Organization and Oil Handling Facilities Regulations (Point Tupper
Marine Services, PTMS)
 Pilotage in Canso Area
 Pilotage Act and Regulations
Atlantic Pilotage  Vessels LOA > 225.5 m can embark pilot at Compulsory Pilotage area D ( Fox Island
Authority and Green Island) with outer pilotage station at 4524N 6101W
 Vessels LOA < 225.5 m can embark pilot at Compulsory Pilotage area C (Red Head
and Crichton Island Light) with inner pilotage station at 4529N 6111W
 Canadian Marine Act and Regulations
 Responsible for safety of operations in Port Hawkesbury Public Harbour and the
seabed within the area (construction of terminal)
Transport Canada  Harbour Limits:
o Southern: Red Head and Janvrin Island
o Northern: Canso Causeway and Pirate Harbour
 Harbour Master designates vessel movements, anchorages, and safety of operations

A significant adverse effect on marine navigation would arise if:

 An increase in cost results to the regulating bodies for marine navigation in the area,
including costs associated with accidents and spills; and
 A reduction in safety or service for the increase vessel traffic for the Strait of Canso and

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Chedabucto Bay areas, leading to non-compliance with the Acts and Regulations discussed in
the Administrative Boundaries section.

6.4.3.2 Interactions and Potential Effects

Construction

During the construction phase of the Project, there may be an increase in marine vessel traffic to the
area to deliver materials to the Project site. The potential effects are possible disruption to existing
marine traffic and the release of chemicals or POL from equipment, spills or accidents.

Operations and Maintenance

Operations of the Bear Head LNG facility will run 24 hours each day, and, as referenced above, there is
the possibility that a vessel may dock once approximately every 2-3 days. The potential effects arising
from this traffic are obstruction and interference with existing traffic and the release of chemical or POL
from equipment, spills or accidents.

Accidents and Malfunctions

The potential effects from accidents and malfunctions that could arise from LNG shipping activities
include potential spills of contaminants (POL and chemicals) from equipment and vessels, marine vessel
accidents, and potential equipment malfunction onboard the vessel leading to an explosion or release of
gas.

Decommissioning

Decommissioning would involve the cessation of LNG vessels entering the Strait at the Bear Head LNG
terminal.

6.4.3.3 Mitigation

To mitigate the potential negative effects from additional marine traffic during the construction, all
vessels will comply with the Canada Shipping Act and the Oceans Act. All vessel movements will also
be managed by the MCTS, which can inform the other users of the harbour and infrastructure of the
upcoming movement. Any spills from equipment will be addressed by the Risk Assessment Plan and
EPP. Spill kits will be available on site and defined cleanup procedures will be followed.
To mitigate the potential negative effects from additional marine traffic during the operations phase of
the Project, the following measures will be taken:
 All crew on LNG vessels will be qualified to a minimum set of standards as prescribed by the

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IMO (including training and certifications);
 All LNG vessels will meet the required standards for vessels carrying hazardous materials;

 ECAREG will issue Notices to Shipping;


 An area-designated Pilot will take all LNG vessels to berth;
 Inspections will be carried out by Transport Canada Marine Safety Inspectors;
 Tugs will be used for berthing; and
 Terminal will be constructed in accordance with the Navigation Protection Act and will include
all prescribed marine navigational aids.
To mitigate the potential negative effects of accidents and malfunctions at the marine terminal and on
LNG vessels, spill cleanup procedures will be followed and cleanup kits will be on hand. The
implementation of the EPP, including emergency response, contingency and spill management planning
will support effective mitigation.

6.4.3.4 Potential Residual Effects

Because the terminal is being built on a relatively small portion of the Strait of Canso, and by
implementing the advocated mitigation measures, of the Project on marine navigation will be negligible.
It is possible that Project activities may have an overall positive effect as the increase in marine traffic
may allow for opportunities to enhance safety zones and navigational aids.

6.4.3.5 Monitoring and Follow-Up

As referenced in Section 1.8, TERMPOL documentation is being updated and the review process is
underway. Through this process, Transport Canada, Bear Head LNG and the TRC will ensure that all
navigation and safety protocols and associated regulations are addressed during the planning process.
This review process will encompass necessary monitoring to address the anticipated increase in marine
traffic in the Strait of Canso and Chedabucto Bay areas.

6.4.4 Fisheries, Aquaculture and Marine Harvesting

Fisheries, aquaculture and marine harvesting have both an economical and cultural significance to
maritime communities, and have been selected as a VEC.

6.4.4.1 Boundaries and Threshold

The assessment of commercial fisheries takes into account all fisheries within DFO Unit Area 4Wd,
encompassing the Strait of Canso (east of the Causeway) and Chedabucto Bay. The assessment
considers recreational fishing that takes place within the Strait of Canso and those aquaculture

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commercial operations and foreshore lease holdings within the Strait of Canso and Chedabucto Bay.
Temporal boundaries will include the construction and operation phases of the Project.
DFO assumes responsibility for management of the fish stocks within DFO Unit Area 4Wd.
Effects will be considered significant if Project activities result in a reduction in the incomes or
profitability of commercial fisherman within a particular fishery or community. To be significant the
change would need to be measurable at the community or fishery level and outside of the normal
variability of the fishery. This could occur from effects on target marine fish populations, damage to
fishing vessels or gear or loss of access to fishing grounds.
A reduction in incomes or profitability of commercial aquaculture operations would also be considered
significant if it was outside of the natural variability of the operation and can shown to be a direct
result of Project activities. This could occur from loss of lease areas, effects on farmed species or
equipment damage.
If the Project enhances profitability of commercial aquaculture or fisheries operations or increases catch
levels of recreational fisherman than this would be deemed a positive effect.

6.4.4.2 Interactions and Potential Effects

Construction

The construction of marine works will restrict both commercial and recreational fisheries, but activities
in the immediate area are not intensive. Construction activities will attempt to avoid peak fishing
periods and minimize the degree of interference. There may be a loss to existing fishing grounds (from
construction activities and related increases in vessel traffic), but adjustments in fishing locations should
prevent loss of income in most instances. Effects to the marine environment could have potential to
impact fisheries, and loss of gear or vessel damage related to Project activities could occur.
Interaction with commercial aquaculture activities is not expected as these activities do not take place
in the vicinity of the Project site. The distances between the two are large enough that effects are not
expected.

Operation

Operation of the marine terminal and the associated increases in marine traffic could result in a loss of
existing fishing grounds in the immediate vicinity of the wharf. Increased marine traffic may also affect
the distribution and migration patterns of marine species such as mackerel. These impacts could
decrease catches or increase fuel costs. Loss of gear or vessel damage related to Project activities could
also occur.

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Interaction with commercial aquaculture activities is not expected as these activities do not take place
in the vicinity of the Project site. Separation distances between the two are large enough that effects
are not expected.

Accidents and Malfunctions

Accidents and malfunctions involving spills of contaminants (POL and chemicals) from equipment and
vessels, marine vessel accidents, and potential equipment malfunction onboard vessels causing an
explosion or release of gas could impact fisheries and aquaculture.

Decommissioning

Decommissioning would involve the cessation of LNG vessels entering the Strait at the Bear Head LNG
terminal and would negate any possibility of impact with the fisheries or with aquaculture.

6.4.4.3 Mitigation

Construction

Mitigation measures employed during construction will include:


 Communication and dialogue will be established with the fishing industry to limit impacts to
fishing grounds;
 Effort will be made to time construction activities around those periods when fishing efforts
are limited;
 All necessary navigation safety procedures will be followed; and
 A program to minimize the impact of gear loss or vessel damage sustained by fishers due to
Project related activities will be determined through discussion with local fishers.

Operation

Mitigation measures to be employed during operation include:


 Following necessary navigation safety procedures;
 Use of pilots and established shipping lanes;
 Notices to Mariners will be issued regarding the location and scheduling of activities and other
potential hazards;
 Participation in the TERMPOL process; and
 Discussion with local fishers to identify further measures to minimize impacts on fisheries in
the local area.

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Accidents and Malfunction

To mitigate the potential negative effects from accidents and malfunctions at the marine terminal and
on LNG vessels, spill cleanup procedures will be followed and cleanup kits will be on hand. The
implementation of the EPP, including emergency response, contingency, and spill management planning
will assist in mitigation. Also, all crew on LNG vessels will be certified to the minimum standards as
prescribed by the IMO, or by other more stringent applicable requirements. Ensuring that necessary
safety procedures are implemented, use of pilots and participation in the TERMPOL process will aid in
limiting the possibility and severity of accidents.

Decommissioning

Mitigation measures employed during decommissioning will be developed along with the future
decommissioning plan.

6.4.4.4 Potential Residual Effects

Assuming recommended mitigation measures are implemented, residual effects on the fishery and
aquaculture are not predicted. The physical area impacted by the marine terminal is small compared to
the 4Wd fishing area; commercial aquaculture activities do not take place in the vicinity of the Project
site.
The impact on lobster fishers is limited to a small number of individual fishers who can compensate by
adjusting their fishing patterns to minimize impact. The amount of catch from the wharf area is small in
comparison to the overall fishing area even of an individual fisher, so the impact on incomes is not
considered to be significant.

6.4.4.5 Monitoring and Follow-Up

Communications will be established with local fishers prior to construction and will be maintained with
the local fisheries industry, particularly with those individual fishers who have leases in the vicinity of
the proposed wharf. These communications will be maintained as circumstances warrant through the
life of the Project.

6.4.5 First Nations Land and Resource Use

6.4.5.1 Boundaries and Threshold

The MEKS considered a 5 km radius surrounding the proposed area of development; it was determined
that Mi’kmaq land and resource use had occurred in this area within living memory. Because of the
nature of the site, it was deemed unlikely that long-term occupation had occurred. The Project site and

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surrounding area would, however, have formed an important travel route between the mainland and
Cape Breton (Unama’kik) as Mi’kmaq use and occupation of the area east of Bear Head is known to
have occurred.
The Mi’kmaq have interests in the lands and waters in the vicinity of Bear Head that extend through all
phases of the Project’s development, operation and decommissioning.
A significant adverse impact of First Nations Land and Resource Use would occur if they relied
substantially on the lands and waters of the Project site for their livelihood, or if these lands and waters
had a special historical meaning to them, and they were denied access.
A positive impact would occur if First Nations people, particularly First Nations youth, were able to
benefit directly or indirectly in the realisation of their goals as a consequence of the development and
operation of the Project.

6.4.5.2 Interactions and Potential Effects

From the work done to date through the MEKS undertaken in 2004, the current updated MEK (2015)
(Appendix I) and through discussion with representatives of KMKNO, there is no resource use actively
undertaken by the Mi’kmaq on the Project site at this time. There seems little likelihood that this area,
because of its exposure, was of central importance to the Mi’kmaq. The archaeological work that has
been undertaken on the site and beyond appears to confirm this conclusion.
In parallel to the work that has been done on site, representatives of Bear Head LNG, as referenced in
Section 3.2, have met with the Benefits Committee of KMKNO. A MOU is being negotiated. This is an
important step towards the preparation of a Benefits Agreement between Bear Head LNG and KMKNO.
A contract has been signed with the Waycobah First Nation to provide security services to the site.

6.4.5.3 Mitigation

Bear Head LNG has taken important steps to establish dialogue with First Nations and through the
establishment of a benefits Agreement with KMKNO is optimistic that First Nations will not only
contribute to the success of the Project, but will use their involvement in this enterprise as a catalyst
both for sustaining and strengthening their culture and way of life, and for creating new economic and
educational opportunities for their youth.

6.4.5.4 Potential Residual Effects

The finalisation of the Benefits Plan will enable First Nations to be actively involved and benefit from the
Project through not only construction, but the operating life of the Project. The potential residual effects
of this involvement could be great.

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6.4.5.5 Monitoring and Follow-Up

Bear Head LNG is committed to working collaboratively with First Nations. The signing of the MOU and
the agreement with the Waycobah First Nation are the first commitments in a relationship and dialogue
which will evolve and develop through the development and operation of the Project.

6.4.6 Archaeology

Research and field investigations undertaken in 2004 indicated that there were no sites of
archaeological worth within the Project footprint. Work was instigated and the greater part of the lands
necessary for the proposed facility cleared with no finds discovered. Nevertheless, there is always a
possibility that future construction activities will unearth something unexpected. It is also a subject of
great importance to First Nations. For these reasons, archaeology is considered a matter worthy of
consideration.

6.4.6.1 Boundaries and Threshold

The area of interest is the Project footprint at Bear Head, very specifically those areas that will be
disturbed and developed for the LNG facility and associated marine terminal. Should site activities
unearth artefacts or finds that went unrecorded, there is potential for an adverse effect on archaeology,
i.e., on attaining a full understanding of the history of the Project site.

6.4.6.2 Interactions and Potential Effects

Since no intrusive field investigations were undertaken in 2004, it is conceivable that further
disturbance of the site, no matter how small, could reveal something worthy of recording. That this did
not happen through the clearing and construction that has taken place to date would appear to confirm
the findings of the earlier research. Nevertheless, those responsible for further construction should be
made aware through the EPP of the procedures that should be instigated in the unlikely event of
something being found. It would be highly unlikely that there would be an archaeological find of
interest when the facility is operational.

6.4.6.3 Mitigation

In the unlikely circumstance that something is found during the further period of construction, Bear
Head LNG will report the find to the Nova Scotia Museum.

6.4.6.4 Potential Residual Effects

Given the work that has been completed and the fact that nothing has been found during the
construction that has taken place, the likelihood of potential residual effects is negligible.

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6.4.6.5 Monitoring and Follow-up

Apart from reporting any find, which is highly unlikely, there is no need for monitoring, or any other
follow-up.

6.5 Cumulative Effects

6.5.1 Cumulative Interactions and Potential Effects on VECs

The following sections discuss the potential environmental and socioeconomic cumulative interactions
and effects of the Bear Head LNG Project with other identified projects and activities.

Air Quality

The Maher Melford Terminal and the H-Energy LNG Project are anticipated to include dust and vehicle
emissions during construction and operation. These emissions could interact cumulatively with
emissions from the Bear Head LNG Project to increase the levels of suspended particulate matter within
the airshed. Suspended particulate levels are regulated for all facilities, as would be described in the
facilities’ Industrial (Division V) Approvals, and Bear Head LNG will conduct air monitoring at the
request of NSE to ensure compliance. Maher Melford Terminal’s provincial environmental assessment
approval requires an air quality and dust management plan and this will likely be a requirement for the
H-Energy LNG and the Bear Head LNG Projects.
Construction of the tie-ins and rights-of-way may also interact cumulatively with the Project and result
in increased dust and vehicle emissions should there be temporal overlap between the construction
phases. These emissions would be temporary, localized and reversible; therefore significant cumulative
environmental effects are not likely.
The mitigation measures described in sections 6.1.3.4 and 6.1.4.4 are also important in the context of
cumulative environmental effects. Bear Head LNG will contribute to the management of cumulative
regional air quality effects by participating in future regional airshed monitoring and management
programs at NSE’s request. Existing regional levels of suspended particulates, NOx and SOx are within
federal and provincial regulatory limits, and the Projects are not anticipated to cumulatively exceed
regulated thresholds.

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Table 6-27: Overview of Socio-economic Consequences of Bear Head LNG Project
Significance Criteria
Activity Observations & mitigation Significance
Magnitude Geographic Extent Duration/ Frequency Reversibility
Key Settlements, Land Use, Community Services & Infrastructure
 Demand on services and infrastructure from labour  Strengthen the commercial linkages that exist Medium Primarily Strait region,  Will vary through different Closure would have negative Positive Impact
and from facility, e.g., on roads, marine support in the region Particularly Port phases of the Project, but will ramifications for the region, but
services, social infrastructure, community  Likely to strengthen linkages with NSCC, Hawkesbury, Mulgrave exist throughout things would not revert to a current
infrastructure including accommodation and food Cape Breton University and other institutions and the Municipality of  Intermittent in response to status quo
services of higher learning the County of specific events i.e., if and when
 Increased potential for personal injuries and  Communicate labour and material Richmond they happen
demand on first responders and services: police, requirements to labour unions and local
fire and medical suppliers in advance of tenders
 Demands for skills training etc.  Establish and maintain dialogue with service
providers and responders
 Develop Emergency Response & Contingency
Plan

Economic Development
 Direct and indirect employment  Maintain and strengthen dialogue with all High during Regional, Provincial and  Will vary through different Closure would have irreversible Positive impact
 Direct and indirect spending levels of government construction national phases of the Project, but will negative ramifications
 Contribution to local, provincial & national tax  Maintain dialogue with labour representative Medium through exist throughout
regimes organizations, including First Nations Project operation

Marine Navigation
 Increased vessel movements, i.e., one every 2 -3  All vessels entering the area need to comply medium Strait of Canso and Demand will be less through Shipping to site would cease Positive Impact
days with the Canada Shipping Act and the approaches through construction and decommissioning,
 Demands on pilotage and related marine services Oceans Act Chedabucto Bay but greater and more constant for the
 Vessel movements controlled from the duration of Project operation
Sydney MCTS and through TERMPOL

Fisheries, Aquaculture & Marine Harvesting


 Potential loss of access to fishing licenses in the  Communication and dialogue with fisher low Within 1000 m of the Life of the Project Reversible Not significant
vicinity of the marine terminal associations marine terminal
 Area of the marine terminal is small relative
to available fishing area within 4Wd

First Nations Land & Resource Use


 General access to Project site for resource use not  Confirmation through MEKS and engagement Low Project Footprint Duration of Project Reversible Not significant
available that Project site not regularly accessed
 More favourable areas for resource use in
region

Archaeology
 Remote possibility of finding artifacts of value  Most clearing has been undertaken Low Project Footprint Duration of Project Reversible Not significant
 Notification procedure

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Climate

Increased GHG emissions from the Bear Head LNG Project will interact cumulatively with emissions
from other fossil fuel-burning projects in the province, Canada and abroad, overlapping both spatially
and temporally, with similar environmental effects.
The Bear Head LNG Project will represent approximately 10.3% of Nova Scotia’s and 0.3% of Canada’s
GHG emissions. The contribution on a national or global scale is not considered to be significant, but at
a provincial scale the contribution is considered to be an adverse environmental effect.
When operational, the Maher Melford Terminal is estimated to contribute approximately 93,000 tonnes
CO2 eq annually, or 0.39 percent of the total provincial GHG emissions (AMEC 2008). The Goldboro LNG
Project is estimated to contribute approximately 3,778 kt of CO2 annually, which would result in an
increase in CO2 emissions of approximately 15% to Provincial levels and 0.5% to Canadian levels (AMEC
2013). Estimated emissions from the H-Energy LNG Project are not available, but at full capacity of
13.5 mtpa, it can be assumed that emissions will exceed those of the 10 mtpa Goldboro LNG Project.
The defined mitigation measures are also pertinent for decreasing cumulative environmental effects and
minimizing GHG-related climate change. The efficiency of the OSMR® technology employed for the Bear
Head LNG Project inherently mitigates Project-related effects to air quality and climate by minimizing
the Project’s relative contribution to GHG emissions in comparison with most other LNG export Projects.
Although the Project will contribute to an increase in provincial GHG emissions, the OSMR® technology
results in a reduction of GHG emissions of approximately 16% relative to most other proposed or
operational LNG facilities.
Bear Head LNG is working actively with NSE’s Climate Change Directorate to develop a GHG
Management Plan to ensure adherence to applicable provincial and federal GHG regulations and policies
throughout the Project lifecycle. The plan will:
 Include an accounting of anticipated GHG emissions;
 Explain how the Bear Head LNG Project is employing the best-available technology for GHG
mitigation;

 Demonstrate how the Project’s carbon intensity is aligned with best-in-class;


 Provide details on GHG emissions monitoring and reporting; and
 Describe ongoing GHG management and abatement practices.
Bear Head LNG is endeavouring to comply with the Province’s new GHG policies for the LNG industry
(currently in development) within the framework of the 2007 Environmental Goals and Sustainable
Prosperity Act. Bear Head LNG understands that other LNG proponents are also working with NSE to
minimize GHG emissions and decrease carbon intensities.

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Terrestrial Habitat, Freshwater Fish and Fish Habitat

Construction of the pipeline, water and electrical tie-ins and rights-of-way may interact cumulatively
with the Bear Head LNG Project to result in potential effects on terrestrial habitat and freshwater fish
and fish habitat. The LNG facility was sited with consideration for avoidance of wetlands and freshwater
habitats, and no wetlands or streams are anticipated to be affected by Project construction. An updated
EPP and Stormwater Management Plan are being developed to control potential sedimentation of, and
discharge to, freshwater habitats on the site. Mitigation measures for potential accidental events such
as spills will also be detailed in the EPP.
It is anticipated that routing, siting and construction of any facilities in the vicinity of the proposed
Project will adhere to environmental standards, planning and mitigation measures that are similar to the
Project, including careful design and management of watercourse crossings, identification of any
particularly sensitive habitats, determination of any special mitigation measures in consultation with the
applicable regulators, and potential wetland compensation where avoidance may not be possible.
Given the preference to route and site to avoid wetlands, the proven effectiveness of erosion and
sediment controls for watercourse crossings, and the attention to spill prevention and contingency
planning, cumulative effects on wetlands and freshwater fish and fish habitat are not predicted to be
significant.

Terrestrial Fauna

Cumulative effects to seabirds may result from the Project-related increase in vessel traffic in
combination with other marine-based projects in the Strait. Increased vessel traffic may cause
disturbance and changes in foraging behaviour and habitat, and increase the risk of oil spills due to
potential vessel collisions. Potential cumulative interactions and mitigation measures related to
navigation are discussed in the Marine Navigation and Marine Life sections.
Construction of the Strait pipeline crossing, if it coincides with marine construction at the LNG Terminal,
could present a minor incremental risk (insignificant) to seabirds from disturbance and spills. This
Project would be limited in duration and subject to regulatory approvals and environmental
management processes.
It is assumed that the other marine projects will adhere to similar mitigation measures. Significant
cumulative effects to seabirds are not anticipated.
The primary Project-related issue of concern for terrestrial fauna is the potential for direct mortality of
birds and possibly bats from operation of the flare stack. Canaport LNG has been charged under the
federal Migratory Birds Convention Act and the Species at Risk Act after an estimated 7,500 songbirds
flew into the gas flare at the Saint John, NB import facility during a foggy and overcast night in
September 2013. The environmental assessment approval for the Goldboro LNG Project (2014) includes

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the following condition related to flaring:
“The Approval Holder must monitor and undertake research on the impacts of gas flaring on birds and
bats through radar and onsite monitoring. Methodologies and the approach to research, and monitoring
for assaying the impacts on birds and bats must be developed in consultation with NSE, NSDNR and
CWS. Based on the results of the monitoring program, the Approval Holder must make necessary
modifications to mitigation plans and/or operations to prevent any unacceptable environmental effects,
to the satisfaction of NSE.”
Bear Head LNG is actively coordinating efforts with regional radar and weather monitoring sources, and
developing a program to further mitigate flaring at sensitive times, such as during known migrations
and when additional risk factors are anticipated to align (e.g., suitable weather conditions at night).
With regards to flaring-related cumulative effects, H-Energy LNG Project plans are not known at this
time, however it can be assumed that flaring will also be a component of that project. The potential
cumulative effect of multiple flares in the area is unknown, however diligent planning, monitoring and
adaptive mitigation for each project will help minimize the likelihood of significant cumulative adverse
environmental effects.

Marine Navigation

The Bear Head LNG Project and the Maher Melford Terminal are anticipated to result in an increase in
vessel traffic in the Strait of up to approximately 28 percent and 40 percent, respectively, for a
cumulative increase in vessel traffic of almost 70 percent. Vessel numbers are not known for the
H-Energy Project, but given the similarity of the projects, could be estimated to be in the order of Bear
Head LNG vessel traffic, for an additional 30 percent increase. Increased traffic has the potential to
increase the risk of vessel collisions.
As per Canada Shipping Act requirements, the Transportation Safety Board of Canada (TSB) maintains
records of specific accidents and incidents occurring in Canadian waters. Their records indicate that in
the area covered by CHS chart, LC 4335, there were 31 accidents and reportable incidents over the
past 10 years, none of which resulted in a pollution incident (JWEL, 2004a). Given the low incidence of
accidents involving LNG vessels, the number of accidents and reportable incidents in the Strait of Canso
is unlikely to increase.
Should the construction of the marine pipeline crossing overlap temporally with the marine aspects of
the Bear Head LNG Project, a minor cumulative increase in vessel traffic is predicted. This additional
traffic could increase the cumulative risk of vessel collisions, though this cumulative increase is not
anticipated to be significant.

Marine Habitat

The temporary wharf and work surface required for the Bear Head LNG Project will result in a loss of
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fish habitat. This habitat loss has been previously compensated for, as detailed in the Fish Habitat
Compensation Plan associated with the Project’s existing Fisheries Act authorization. The minimal
benthic footprint of the piles associated with the permanent wharf is offset by the piles themselves, as
they provide vertical fish habitat. Their hard surfaces are ideal for colonization and will eventually
provide a reef effect, perhaps even significantly increasing the biodiversity in the immediate area.
Mitigation measures specific to the LNG Project include development and implementation of an EPP and
Stormwater Management Plan, silt curtains and debris booms (as required), temporary tenting and
confinement to catch sand blasting debris and paint-over spray, and adherence to applicable
regulations, guidelines and conditions of permits.
The Maher Melford Terminal will also result in a loss of fish habitat, and a Habitat Compensation Plan
was previously developed for the Project, thereby mitigating this effect. It is likely that the H-Energy
Project will result in benthic habitat loss. However, it is anticipated that the Project will be subject to
similar environmental standards, with possible offsetting of impacts to Commercial, Recreational and
Aboriginal fisheries productivity.
The location for a potential pipeline crossing the Strait is likely to be within the current pipeline corridor,
but it is assumed at this time that spatial overlap with the Project’s small marine footprint is unlikely.
The overall cumulative effect on marine habitat is predicted to be not significant.

Marine Life

Temporal overlap of marine construction-related activities of the Bear Head LNG Project, Maher Melford
Terminal and H-Energy Project is possible. It is uncertain if there will be a temporal overlap of marine
construction activities involving the pipeline crossing.
Minimal, localized increases in turbidity are predicted during marine construction activities for each of
the marine-based projects (Bear Head LNG Project, pipeline crossing, Maher Melford Terminal and
H-Energy Project), and there may be temporal overlap between these activities. However, the spatial
separation of the Projects reduces the likelihood of turbidity-related cumulative effects on marine life.
Underwater noise can result in noise-related adverse effects on marine mammals such as avoidance,
changes in migration, changes in feeding and reproductive behavior, and possibly communication
marking (interference in communication between marine mammals). Of particular concern is the noise
associated with pile driving, and it is likely that all three Projects will include this activity. Bear Head
LNG is committed to conduct pile driving in late fall and winter in order to avoid sensitive periods,
complete pile driving within a 60 day window, and halt pile driving when a whale is sighted within 500
m of the area, resuming pile driving only once the whale has left the area.
The Maher Melford Terminal identified ramped warning signals and bubble curtains (noise masking) as
possible mitigation measures during construction (AMEC, 2008). It is anticipated that the H-Energy

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Project will adhere to similar mitigation measures as the other projects. With each Project employing
applicable mitigation measures, and in consideration of the temporary and localized nature of Project
activities and separation distance between the Projects, significant cumulative effects on marine
mammals due to pile driving are not anticipated.
The projected cumulative increase in operation-related vessel traffic associated with the Bear Head LNG
Project, Maher Melford Terminal and H-Energy Project also has the potential to cumulatively affect
sensitive marine mammals through increased noise disturbance, possible vessel collisions and marine
spills. However, given the established standard vessel operation procedures to be followed for all
Projects, including slow vessel speeds and avoidance of marine mammals, and the high probability that
marine mammals will avoid the area during marine construction, significant cumulative effects on
marine mammals are not anticipated.
A potential increase in vessel traffic may lead to an increase in the number of vessel collisions with
whales; however, collisions tend to be of particular concern where shipping lanes intersect with known
concentrations of whales, such as in the Bay of Fundy. No information has been located on historic
numbers of vessel collisions with whales in the Strait of Canso, however the Strait is not known as an
area with high concentrations of whales on a seasonal basis. Whales are only occasional visitors to the
Strait, and rarely does a whale with conservation status appear in the Strait. Furthermore, vessel
collisions with whales are less likely when vessels travel at slower speeds, as required in the Strait.
Therefore, the cumulative increase in vessel traffic is not anticipated to result in a commensurate
increase in vessel collisions with whales.

Species at Risk

Any Project-related or cumulative adverse effect on a species at risk is, by definition, significant;
therefore, consideration of likelihood is particularly important for assessing significance on species at
risk.
Rare plant populations found in the Bear Head LNG Project site have the potential to be adversely
affected, if the utility corridors are constructed within or in close proximity to these populations. As the
locations of these species are now known and avoided by the Project, these locations are expected to
be factored into the regulatory approval of the tie-ins and final corridor routes.
Previously unknown populations of rare plants could be affected by clearing of the corridors, however it
is expected that rare plant surveys will be a requirement of the associated regulatory approval
processes. It is also expected that mitigation measures will be developed for the corridors, to minimize
adverse effects on any rare plant populations that may be encountered. Given these factors and
mitigation measures, no cumulative effects on terrestrial species at risk are anticipated.
The area is absent of rare mammals and sensitive mammal habitat. The Bear Head LNG Project is not
anticipated to further affect wetlands, and the utility corridors will likely avoid these to the extent

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possible, therefore cumulative adverse effects are not anticipated on wetland species such as the four-
toed salamander.
As discussed in the Terrestrial Fauna section, flares associated with the Bear Head LNG Project and,
presumably the H-Energy Project, have the potential to adversely affect birds and bats. Mitigation
measures described in the Terrestrial Fauna section will also decrease the likelihood of cumulative
adverse effects to bird and bat species at risk.
Potential effects on marine fauna are addressed in the Marine Life and Marine Navigation sections, and
these mitigation measures will also decrease the likelihood of cumulative adverse effects to marine
species at risk.

Community Services and Infrastructure

Temporal overlap between the construction and operation of all the identified Projects is possible, and
the anticipated Project sizes and the locations of the Projects could result in a cumulative burden on
local roads, emergency response services and on-going support services. However, the Strait area has
successfully accommodated other large scale construction Projects, and with proper communications
and planning with local emergency response and other service providers, a significant cumulative
adverse effect on community services and infrastructure is not anticipated.

Economic Development

The identified major Projects have the potential to result in positive cumulative effects on economic
activity in the immediate area, Nova Scotia and Canada. Should the Projects be constructed
simultaneous, it is possible there could be competition for labour and equipment; however with proper
planning and communication with local labour organizations and equipment operators, these cumulative
adverse effects are not expected to be significant.

Fisheries and Aquaculture

The increase in overall vessel traffic from the marine-based Projects has the potential to result in
cumulative adverse effects on fisheries within the Strait. It is possible that fishing activities may be
limited by the increased vessel traffic, and that incidents of loss of fishing gear may increase.
Bear Head LNG consulted with the fishing industry prior to Project initiation in the mid-2000s, and has
reinitiated consultation for this phase of the Project. A Fisheries Compensation Plan is being developed
to establish compensation available should Project activities result in damage to fishing gear or vessels.
The Maher Melford Terminal has developed a similar mechanism for compensation, and it is expected
that H-Energy would also be subject to this requirement. With each Project compensating for any
potential associated losses, cumulative effects on fisheries and aquaculture are not anticipated.

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6.6 Effects of the Environment on the Project

It is important to not only consider impacts of the Project on the environment, but also those of the
environment on the Project. Instances of extreme weather, sea ice, climate change, sea level rise and
seismic activity can all adversely affect the Project and need to be considered in Project design.
Examples of adverse effects could include damage to Project infrastructure, stoppages or delays in
construction, stoppages in production and operation or dangerous conditions for workers. Effects of the
environment on the Project and how they will be addressed is discussed further in this section.

6.6.1 Extreme Weather

A study by Beaumont et al., 2011 examined the impact of climate change on some of the world’s most
exceptional ecoregions. It determined that of the 132 terrestrial and 53 freshwater ecoregions
examined, 86% of terrestrial and 83% of freshwater ecosystems will be exposed to climactic conditions
considered extreme in 1961 – 1990 (greater than 2 standard deviations in average monthly
temperature). Extreme weather events have also shown increases in Nova Scotia, with greater
increases predicted. This includes a warmer and wetter future climate with increased storm activity
(Richards and Daigle, 2011). Extreme weather includes cases of extreme temperatures, precipitation,
winds and storm events. Due to the potential impacts coupled with the fact that instances of extreme
weather are expected to increase, it is important to consider the related effects on the Project.
Historical temperatures recorded at Eddy Point vary from 33.3 ˚C to -25.6 ˚C. Typical of Nova Scotia
coastal regions, this temperature range is wide but not extreme. Average yearly precipitation is 1349.3
mm, with an extreme daily rainfall of 78.6 mm and an extreme daily snowfall of 63 cm. Model results
from Richards and Daigle, 2011 predict increases in temperature for the climate station in Deming (with
the magnitude of temperature increases increasing with time). They also show increases in
precipitation, indicating a warmer and wetter climate with time. Annual average temperatures are
predicted to increase by 0.9˚C from 1980 values by 2020, 2 ˚C by 2050, and 3.1 ˚C by 2080. Annual
precipitation is expected to increase by 27 mm from 1980 values by 2020, 35.5 mm by 2050, and 71.6
mm by 2080.
Although wind speeds in the 54 – 72 km/h range have been recorded at Eddy Point, this is not
considered normal. Average wind speeds are around 20 km/h during summer months and between 12-
15 km/h during winter, with wind direction being predominantly from the west and northwest during
winter and from the south and south west in warmer months. Extreme winds can produce high waves,
stormy seas, blowing sea spray/foam and cause reduced visibility. Frozen sea spray which can cause
unsafe working conditions is also an issue during colder months, with February being the worst for ice
build up on vessels. Storm surge accompanying strong storms can increase water levels, potentially
causing issues with loading and unloading procedures. Strong currents can impact vessel navigation
and docking.

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The Project is located in an area that will be susceptible to increases in storm events (Forbes et al.,
1997). Hurricane Juan is an example of a hurricane that hit the Maritimes in 2003 causing massive
damage to local infrastructure. The possibility of damage due to more frequent and severe storms is a
possibility given the Project location in a coastal region.
Reduced visibility can occur throughout the year due to fog; however it is most likely to occur in late
spring and early fall when the greatest difference between the coastal water and air temperature exists.
Reduced visibility can cause marine navigation issues and increase the risk of accidents.
The Project will be designed to withstand instances of extreme weather as described above. Wind
loads, harshest recorded conditions, and predictions of future conditions will all be taken into account
during the FEED process. The facilities will be designed with a safety factor that accounts for variability.
Policies and procedures will also be in place to protect against extreme weather. For example, vessels
typically do not dock in winds that exceed a set speed (usually 25 knots). Weather forecasts will be
monitored on a daily basis. Project activities will be suitably adjusted when extreme weather is
expected and the work area secured to the extent possible in advance of predicted extreme weather
events. It is not expected that extreme weather will have a significant impact on the Project.

6.6.2 Sea Ice

The Strait of Canso is an extremely deep and ice free harbour, however this was not always the case.
Prior to the construction of the Canso Causeway in 1955, sea ice was prevalent. Ice cover was heavy
enough that planes were able to use it as a runway, ice flows frequently put ferries between Mulgrave
and Port Hawkesebury miles off course and vessels would break away from wharves due to the strong
currents. Since construction of the Canso Causeway created a barrier between ice packs on the north
side the characteristics of the Strait have been altered, and the south side remains ice free year round
(Strait of Canso Superport Corporation, n.d.). As a result, sea ice is not expected to impact Project
construction or operations.

6.6.3 Climate Change and Sea Level Rise

It is predicted that sea level rise due to climate change in the Guysborough County, Canso Harbour
area will be in the magnitude of 0.16 m +/- 0.03 m by 2025, 0.45 m +/- 0.15 m by 2055, and 0.86 m
+/- 0.36 m by 2085. Extreme estimates put these values at 2.96 m +/- 0.23 m by 2025, 3.25 m +/-
0.35 m by 2055, and 3.66 m +/- 0.56 m by 2085 (Richards and Daigle, 2011). This rise in sea level has
the potential to impact the Project, particularly the Marine terminal and associated works.
The Project will consider sea level rise due to global warming. This will involve consideration of sea
level rise and incorporating safety factors during Project design at the FEED stage to ensure impacts
are avoided. Sea level rise is not expected to negatively impact the Project given proper consideration.

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6.6.4 Seismic Activity

Seismic activity is limited on the East Coast of Canada, with no important historical earthquakes listed in
Nova Scotia (Natural Resources Canada, 2013c). The closest two important earthquakes listed include a
magnitude 5.7 earthquake in New Brunswick in 1982 and a 7.2 magnitude earthquake in the Grand
Banks in 1929 (Natural Resources Canada, 2013d). No major damage was caused by the 1982
earthquake in New Brunswick, although many people were woken up, it was felt outdoors and small
and unstable objects were overturned or moved (Bashman et al., 1984). The Grand Banks earthquake
occurred approximately 250 km south of Newfoundland. It was felt as far away as New York and
Montreal and generated a tsunami that resulted in 28 deaths in Newfoundland. Vibrations were felt in
Cape Breton that caused minor landslides and knocked down or cracked chimneys (Natural Resources
Canada, 2013d). Historically, most seismic shocks recorded in Atlantic Canada are below magnitude 5,
with the exception of those mentioned above (Rast et al., 1979).
Project design will take into account seismic activity. All buildings will be constructed to the National
Building Code of Canada and LNG storage tanks will be designed for the regions seismic rating under
CSA Z276‐11.

6.6.5 Security

However unlikely, the possibility of a terrorist attack on the facility would be extremely hazardous and
should be addressed. The site will have a security team in place and surveillance equipment. The
perimeter of the site will be fenced and access to the site will be through a security gatehouse.
Design of the facility will comply with the Marine Transport Security Regulations (MTSR). The MTSR
outlines operator and personnel roles and responsibilities in developing and implementing security
plans, provides a process to conduct security assessments establishes security protocols, proper
documentation and reporting procedures and allows TC to oversee compliance of marine transportation
security systems. Discussions have already been held with TC officials regarding the MTSR and its
application to the Project.

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