


97918-GEN-EMP-N-001-R2 14 June 2010

Revision Summary

Revision Date of Issue Purpose

A 11 January 2007 DRAFT internal review

B 23 January 2007 DRAFT issue for client review

C 17 May 2007 DRAFT issue for client review

D 25 July 2007 Issue for client review

0 15 January 2008 Final for Issue

1 4 August 2009 Re-issue for client review

2 14 June 2010 Re-issue for client review




97918-GEN-EMP-N-001-R2 14 June 2010

Distribution List

Agency Project Manager (12) Sydney Tar Ponds Agency

David Wilson Project Director

Don Shosky Project Director

Shawn Duncan Environmental and Regulatory Lead

Ray Rice Project Manager

Stephen Pinto Environmental Coordinator

Bruce Noble Deputy Project Manager

Dan MacDonald Engineering Manager

Robert Jones Quality Assurance Manager

Andrew McIntosh Regulatory Lead

File Copy CBCL Central Records

File Copy AECOM Library




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97918-GEN-EMP-N-001-R2 14 June 2010

TABLE OF CONTENTS

1.0 INTRODUCTION ................................................................................................................................................. 1

1.1. PROJECT OVERVIEW ..................................................................................................................................... 2

1.2. HISTORICAL BACKGROUND .......................................................................................................................... 2

1.3. PROJECT ENVIRONMENTAL MECHANISM ...................................................................................................... 3

1.4. OBJECTIVES OF THE EMP ............................................................................................................................. 4

1.4.1. Content of the Environmental Management Plan ....................................................................................... 5

1.5. MAINTENANCE OF THE EMP AND CHANGE PROTOCOL DOCUMENT ............................................................. 6

1.6. ENVIRONMENTAL POLICY, GUIDING PRINCIPLES AND COMMITMENT TO MITIGATION ................................. 7

2.0 REMEDIAL MANAGEMENT PLAN ................................................................................................................ 9

2.1. PROJECT DESCRIPTION .................................................................................................................................. 9

2.2. TAR PONDS ................................................................................................................................................. 10

2.3. COKE OVENS .............................................................................................................................................. 10

2.4. ELEMENT DESCRIPTION AND LAYOUT ........................................................................................................ 11

2.4.1. TP6A – Flow Diversion............................................................................................................................. 11

2.4.2. TP6B – Solidification/Stabilization (S/S) and Channel Construction ....................................................... 12

2.4.3. TP6C – Ferry Street Bridge Construction ................................................................................................ 13

2.4.4. TP6D – Construction of Access Roads ..................................................................................................... 13

2.4.5. TP2 – Material Processing Facility .......................................................................................................... 13

2.4.6. TP7 – Tar Ponds Surface Cap .................................................................................................................. 13

2.4.7. CO1 – Coke Oven Brook Connector Sediment Removal and Disposal .................................................... 14

2.4.8. CO2 – Solidification/Stabilization (Tar Cell) ........................................................................................... 14

2.4.9. CO5 – Vertical Cutoff Walls ..................................................................................................................... 15

2.4.10. CO6 – Coke Ovens Surface Cap ............................................................................................................. 15

2.4.11. CO7/CO8 – Coke Oven Brook Water Treatment & Ground Water Collection ...................................... 16

2.5. CONCEPTUAL SITE MODELS ....................................................................................................................... 17

2.6. SEQUENCING OF PROJECT ELEMENTS ......................................................................................................... 17

2.7. PROJECT SCHEDULE AND MILESTONES ....................................................................................................... 19

2.7.1. Project Milestones .................................................................................................................................... 19

3.0 REGULATORY APPROVALS, AUTHORIZATIONS AND PERMITS ...................................................... 19




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3.1. FEDERAL GOVERNMENT OF CANADA ......................................................................................................... 20

3.2. PROVINCIAL GOVERNMENT OF NOVA SCOTIA ............................................................................................ 20

3.3. MUNICIPAL GOVERNMENT – CAPE BRETON REGIONAL MUNICIPALITY ..................................................... 21

4.0 ENVIRONMENTAL MANAGEMENT TEAM ORGANIZATION, STRUCTURE AND

RESPONSIBILITIES ................................................................................................................................................ 22

4.1. ORGANIZATION AND STRUCTURE ............................................................................................................... 22

4.2. ENVIRONMENTAL MANAGEMENT COMMITTEE ........................................................................................... 24

4.3. MANAGING PARTNERS ................................................................................................................................ 26

4.4. NOVA SCOTIA DEPARTMENT OF ENVIRONMENT ......................................................................................... 26

4.5. SYDNEY TAR PONDS AGENCY .................................................................................................................... 27

4.5.1. Agency Project Director ........................................................................................................................... 27

4.5.2. Safety, Health and Environmental Coordinator ....................................................................................... 27

4.6. AECOM AND CBCL .................................................................................................................................. 28

4.7. INDEPENDENT ENGINEER ............................................................................................................................ 29

4.8. CONTRACTORS ............................................................................................................................................ 30

4.9. ANALYTICAL LABORATORY ....................................................................................................................... 31

4.10. INDEPENDENT QUALITY ASSURANCE CONSULTANT ................................................................................... 31

5.0 MANAGEMENT PLANS ................................................................................................................................... 32

5.1. WATER MANAGEMENT PLAN ..................................................................................................................... 32

5.1.1. Management of Runoff from Precipitation................................................................................................ 32

5.1.2. Management of Watercourses during Construction ................................................................................. 33

5.1.2.1. Sources of Water ........................................................................................................................................... 33

5.1.2.2. Water Management ....................................................................................................................................... 34

5.1.3. Water Collection and Treatment ............................................................................................................... 34

5.1.3.1. Sources of Water ........................................................................................................................................... 36

5.1.3.2. Permanent Water Treatment (CO8) .............................................................................................................. 37

5.1.3.3. Treatment Processes ...................................................................................................................................... 38

5.1.4. Compliance under the Federal Fisheries Act ........................................................................................... 38

5.1.5. Coke Oven Brook Groundwater Quantity and Discharge Chemistry ....................................................... 40

5.2. TRANSPORTATION MANAGEMENT PLAN ..................................................................................................... 41

5.2.1. Transportation Infrastructure ................................................................................................................... 43




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5.2.2. Street Access to the Sydney Tar Ponds and Coke Ovens Sites .................................................................. 44

5.2.3. Study Area Traffic Volumes and Vehicle Collisions ................................................................................. 45

5.2.4. Traffic Generators .................................................................................................................................... 50

5.2.5. Impacts on Transportation Infrastructure ................................................................................................ 52

5.2.6. Environmental Impacts ............................................................................................................................. 52

5.2.7. Contractor Traffic Responsibilities ........................................................................................................... 53

5.2.8. Conclusions and Recommendations .......................................................................................................... 54

5.3. LAND USE AND INSTITUTIONAL LAND CONTROLS ...................................................................................... 55

5.3.1. Land Use Designation ............................................................................................................................... 56

5.3.2. Future Land Use in the North End of Sydney ........................................................................................... 56

5.4. QUALITY ASSURANCE QUALITY CONTROL MEASURES PROGRAM ............................................................. 57

5.4.1. Quality Management Plan ........................................................................................................................ 58

5.4.2. Quality Control Plan ................................................................................................................................. 59

5.4.3. Independent Quality Assurance Plan ........................................................................................................ 60

6.0 ENVIRONMENTAL PROTECTION PLANS ................................................................................................. 61

7.0 MONITORING PLANS ...................................................................................................................................... 63

7.1. BACKGROUND............................................................................................................................................. 63

7.2. CONSTRUCTION/MITIGATION MONITORING ................................................................................................ 64

7.2.1. Purpose and Objective .............................................................................................................................. 64

7.2.2. Real Time Air Monitoring ......................................................................................................................... 65

7.3. AIR MONITORING – NOT IN CONTRACT (NIC) ............................................................................................ 65

7.3.1. Real-time Air Monitoring .......................................................................................................................... 65

7.3.2. Real-time Monitoring ................................................................................................................................ 66

7.3.3. Target Emissions ....................................................................................................................................... 67

7.3.4. Monitoring Duration and Frequency ........................................................................................................ 68

7.3.5. Monitoring Location ................................................................................................................................. 69

7.3.6. Real-time Protocols and Equipment ......................................................................................................... 69

7.3.7. Weather Conditions .................................................................................................................................. 70

7.3.8. Site Action Levels ...................................................................................................................................... 70

7.3.9. PM10 Action Levels and Measures ........................................................................................................... 70

7.3.10. TVOCs Action Levels and Measures ....................................................................................................... 72




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7.3.11. Noise Monitoring .................................................................................................................................... 74

7.3.12. Surface Water Monitoring ...................................................................................................................... 76

7.3.13. Short Term Cap Monitoring .................................................................................................................... 78

7.3.14. Visual Inspection ..................................................................................................................................... 79

7.3.15. Environmental Inspection Logs............................................................................................................... 79

7.3.16. Adaptive Management............................................................................................................................. 80

7.4. REGULATORY COMPLIANCE MONITORING.................................................................................................. 81

7.4.1. Battery Point/Sydney Harbour .................................................................................................................. 82

7.4.2. Effluent Discharge .................................................................................................................................... 82

7.4.3. Air Emissions ............................................................................................................................................ 82

7.5. ENVIRONMENTAL EFFECTS MONITORING ................................................................................................... 82

7.5.1. Ambient Air Monitoring ............................................................................................................................ 83

7.5.2. Surface Water Monitoring ........................................................................................................................ 86

7.5.3. Aquatic Monitoring in Sydney Harbour .................................................................................................... 86

7.5.4. Avifauna Monitoring ................................................................................................................................. 87

7.6. LONG TERM MONITORING .......................................................................................................................... 88

7.6.1. Cap Monitoring Plan ................................................................................................................................ 88

7.6.2. Groundwater Monitoring Plan ................................................................................................................. 89

7.7. MONITORING RESULTS REPORTING ............................................................................................................ 90

8.0 CONTINGENCY AND EMERGENCY RESPONSE PLANS ........................................................................ 91

8.1. EMP CONTINGENCY PROTOCOLS ............................................................................................................... 91

8.1.1. Failure to Comply Contingency Plan ....................................................................................................... 91

8.1.2. Fuel and Hazardous Material Spills Contingency Plan ........................................................................... 93

8.1.3. Malfunctions and Accidents Contingency Plan ........................................................................................ 97

8.1.4. Fire Response Contingency Plan .............................................................................................................. 98

8.1.5. Environmental Contingency Plan ........................................................................................................... 100

8.1.6. Restricting Public Access Contingency Plan .......................................................................................... 104

8.1.7. Erosion/Sedimentation to Surface Water Contingency Plan ................................................................... 105

8.1.8. Dewatering Contingency Plan ................................................................................................................ 107

8.1.9. Archaeology and Heritage Resource Contingency Plan ......................................................................... 107

8.1.10. Unexpected Site Conditions Contingency Plan ..................................................................................... 111




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8.1.11. Cumulative Effects Contingency Plan ................................................................................................... 113

8.1.12. Key Contact List .................................................................................................................................... 115

8.2. CONTINGENCY PLANNING IN DETAILED EPPS .......................................................................................... 115

8.3. IMPLEMENTATION RESPONSIBILITIES ........................................................................................................ 116

9.0 ENVIRONMENTAL AWARENESS TRAINING ......................................................................................... 117

9.1. SPECIFIC ENVIRONMENTAL AWARENESS PROGRAMS ............................................................................... 119

9.1.1. Decontamination ..................................................................................................................................... 119

9.1.2. Spills Response........................................................................................................................................ 120

9.1.3. Fire Response.......................................................................................................................................... 121

9.1.4. Discovery of Unexpected Site Conditions ............................................................................................... 121

9.1.5. Archaeology and Heritage Resources ..................................................................................................... 122

10.0 COMMUNICATION AND REPORTING .................................................................................................... 122

10.1. COMMUNICATION ..................................................................................................................................... 122

10.2. PUBLIC REPORTING PROTOCOL ................................................................................................................. 123

10.2.1. Reporting Results .................................................................................................................................. 124

10.2.1.1. Areas Subject to Public Reporting .............................................................................................................. 124

10.2.1.2. Reporting Guidelines for Monitoring Results ............................................................................................. 126

10.2.1.3. Monitoring Parameters ................................................................................................................................ 127

10.2.1.4. Reporting Frequency ................................................................................................................................... 128

10.2.1.5. Communication Methods ............................................................................................................................ 128

10.3. REPORTING ............................................................................................................................................... 129

10.4. DOCUMENT CONTROL ............................................................................................................................... 130

10.5. ENVIRONMENTAL AUDITS ........................................................................................................................ 130

11.0 REFERENCES ................................................................................................................................................ 132

Tables

Table 1: Operational Discharge Criteria………………………………………………………………….. 35

Table 2: Water Sources and Management .................................................................................................. 36

Table 3: Annual Average Daily Traffic Volumes for Study Area Roads ................................................... 46

Table 4: Seasonal Variation in Average Daily Volumes ............................................................................ 48

Table 5: Five Year (1999 to 2003) Collision Data for Study Area Roads .................................................. 49




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Table 6: Estimated Project Vehicle Volumes ............................................................................................. 51

Table 7: Selected Business Industrial Locations, Corridors and Nodes in the CBRM Former and Proposed

Land Uses ................................................................................................................................................... 56

Table 8: Quality Management Metrics from the QMP ............................................................................... 58

Table 9: Summary of Project Real-Time Action Levels PM10 .................................................................. 71

Table 10: Summary of Project Real-Time Action Levels for TVOC ......................................................... 73

Table 11: Summary of Real-Time Action Levels and Action Measures .................................................... 73

Table 12: Spill Report Requirements .......................................................................................................... 96

Table 13: Cumulative Effects, Mitigations Measures and Significance ................................................... 114

Table 14: Monitoring Parameters ............................................................................................................. 127

Table 15: Monitoring Report Frequencies ................................................................................................ 128

Figures

Figure 1: Design Organizational Chart ....................................................................................................... 23

Figure 2: Construction Organizational Chart .............................................................................................. 24

Figure 3: Fish Removal ............................................................................................................................... 40

Figure 4: Access Locations ....................................................................................................................... 475

Figure 5: Major Transportation Access Facilities & Traffic Volumes ....................................................... 47

Figure 6: Baseline Noise Monitoring Locations ......................................................................................... 75

Figure 7: Adaptive Management Procedure ............................................................................................... 81




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Appendices

Appendix A Project Site Overview

Appendix B Change Protocol Document

Appendix C Conceptual Site Models

Appendix D Summary Base Project Schedule

Appendix E Quality Assurance Procedure Audits

Appendix F Environmental Inspection Log




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Acronyms used in Report

CQCP Contractor Quality Control Plan

AADT Annual Average Daily Traffic

AHASP Assignment Health and Safety Plan

All Tech All Tech Environmental Consultants

AMEC AMEC Earth and Environmental

AMP Air Monitoring Program

ASTM American Society for Testing and Materials

BTEX Benzene, Toluene, Ethylbenzene, Xylene

C&D Construction and Demolition Debris

CAEAL Canadian Association of Environmental Analytical Laboratories

CBCL CBCL Limited

CBRM Cape Breton Regional Municipality

CBRMC Cape Breton Regional Municipality Council

CEAA Canadian Environmental Assessment Act

CEPA Canadian Environmental Protection Act

CO1 Coke Oven Brook Connector Sediment Removal and Disposal

CO2 Tar Cell Solidification/Stabilization

CO5 Vertical Cutoff Walls

CO6 Coke Ovens Surface Cap

CO7/CO8 Coke Oven Water Treatment Plant & Groundwater Collection

COC Chemical of Concern

CPT Cooling Pond Treatment

CQC Contractor Quality Control

CQCP Construction Quality Control Plan




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CRA Conestoga Rovers and Associates

CSM Conceptual Site Model

DFO Fisheries and Oceans Canada

EA Environmental Assessment

EEM Environmental Effects Monitoring

EHS Environmental, Health and Safety

EIS Environmental Impact Statement

EM Environmental Monitor

EMC Environmental Management Committee

EMP Environmental Management Plan

EPP Environmental Protection Plan

GAC Granular Activated Carbon

GCL Geosynthetic Clay Liner

GCS Groundwater Collection System

GDC Groundwater Discharge Chemistry

GFP Groundwater Field Program

GNS Government of Nova Scotia

GOC Government of Canada

HASP Health and Safety Plan

HDPE High-Density Polyethylene

IE Independent Engineer

IQAC Independent Quality Assurance Contractor

IQAP Independent Quality Assurance Plan

JDAC Jacques Whitford, Dillon Consulting, ADI Limited and CBCL Limited

JRP Joint Review Panel




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LTM Long term monitoring

MHASP Master Health and Safety Plan

MOA Memorandum of Agreement

NAPS National Air Pollution Surveillance

NSE Nova Scotia Department of Environment

NSTIR Nova Scotia Department of Transportation and Infrastructure and Renewal

PAH Polycyclic Aromatic Hydrocarbon

PCB Polychlorinated biphenyl

PDO Property Damage Only

PIP Project Implementation Plan

PM Particulate Matter

PMC Project Management Committee

POLs Petroleum, Oils or Lubricants

PPE Personal Protective Equipment

PRP Public Reporting Protocol

PWGSC Public Works and Government Services Canada

QA/QC Quality Assurance/Quality Control

QC Quality Control

QCP Quality Control Plan

QMP Quality Management Plan

RAER Remedial Action Evaluation Report

RFP Request for Proposal

RMP Remedial Management Plan

S/S Solidification/Stabilization

SPAR Sydney Port Access Road




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SSP Steel Sheet Piles

Agency Sydney Tar Ponds Agency

TMP Transportation Management Plan

TP2 Material Processing Facility– Construction and Operation

TP6A Flow Diversion

TP6B Solidification/Stabilization (S/S) and Channel Construction

TP6C Construction of Ferry Street Bridge

TP6D Construction of Access Roads

TP7 Tar Ponds Surface Cap

VEC Valuable Ecosystem Components

VOC Volatile Organic Compound

WMP Water Management Plan

WTP Water Treatment Plant




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Units used in Report

m3 cubic metres

ppm parts per million

NTU Nephelometric Turbidity Units




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1.0 INTRODUCTION

The Government of Canada and Province of Nova Scotia have committed to remediate the Sydney Tar

Ponds and Coke Ovens Sites, a project to be managed and implemented by the Sydney Tar Ponds Agency

(The Agency). There are two (2) goals of the remediation effort. First is to reduce the health and

ecological risks to area residents and the environment from existing soil, sediment and water

contamination. Second is to enhance the development potential of the land to drive economic investment

in the Cape Breton Regional Municipality (CBRM). Figure 1 in Appendix A shows the Project site

Overview.

This EMP has been developed and updated to protect the environment during activities associated with

the Remedial Design and Construction Oversight of the Sydney Tar Ponds and Coke Ovens Sites (the

Project), by communicating to all project participants and stakeholders the commitment and efforts to be

undertaken to manage and minimize potential environmental impacts. As the proponent, the Agency is

required to complete an EMP prior to submitting an application for Part V Approval(s) under the

Environmental Act (Government of Nova Scotia [GNS], 1995a) to conduct remediation work. As the

EMP is a living document, it is updated on a routine basis to address situations that may not have been

identified in previous revisions.

The overall objective of the EMP is to provide a comprehensive strategy for ensuring compliance with the

relevant environmental legislation, policies and permitting requirements, to provide a Project

Environmental Management Plan and to ensure that the environment is protected throughout the life of

the Project. This EMP complies with the Nova Scotia Department of Environment‟s (NSE)

Environmental Assessment (EA) Approval Terms and Conditions under Part IV of the Environment Act

(GNS, 1995a).

The document will also promote the implementation of Panel Recommendations as agreed to by

governments.




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1.1. Project Overview

The Agency is the management and implementation Agency, acting under a Memorandum of Agreement

(MOA) between the Government of Canada and the Province of Nova Scotia. The Agency‟s mandate is

to remediate the Sydney Tar Ponds and Coke Ovens Sites in the Cape Breton Regional Municipality.

Detailed definition of the project and related work activities are being developed during the detailed

design engineering phase of the project. This includes a broad range of activities primarily based on

solidification/stabilization (S/S) over an eight (8) year period. The work itself will be performed in

accordance with the Project Description and associated Work and Management Plans developed for the

Agency. Construction activities will be directly contracted to the Agency under the oversight of

AECOM/CBCL (the Consultant). Accordingly, this Project EMP and associated Project Environmental

Protection Plan (EPP) provided under a separate cover, serve as umbrella documents to guide

environmental protection aspects of all relevant site activities during the tenure of the remediation project.

The development and maintenance of environmental management planning initiatives are an integral part

of the scope of work. This includes remedial management plans, air, groundwater and cap monitoring

programs, environmental effects monitoring (EEM) programs and mitigative measures and monitoring

plans; in addition to a Health and Safety Plan (HASP) (submitted under separate cover).

Detailed construction-phase activity specific EPPs, for design engineering and construction activities

alike, will be developed as tasks/activities are fully defined during the design portion of the project and

submitted with the 75%, 95% and 100% design submissions.

1.2. Historical Background

The Tar Ponds and Coke Ovens Sites are a legacy of the steel and coking industries that operated in

Sydney for most of the 20th Century. The former Coke Ovens provided coke for the local steel

manufacturing industry, while the by-products, such as tar and ammonia were used to manufacture

various other commercial products. Historic by-product and waste management practices, including the

storage of tars in tanks and lagoons, disposal of wastewaters to brooks and the adjacent estuary and site

backfilling/land reclamation practices have resulted in significant impacts to soil, surface and

groundwater and sediment at the Site.

Growing understanding of contamination and its impacts, combined with the steel industry‟s financial

difficulties, led to some drastic changes. Efforts to modernize the steel plant were undertaken but failed




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and the plant subsequently closed, while a series of ongoing site studies and proposed solutions set the

stage for the current cleanup plans. In fact, numerous previous studies have contributed to the

Remediation Plan for the Tar Ponds and Coke Ovens Sites.

The Muggah Creek tidal estuary, otherwise known as North and South Tar Ponds, covers an area of

approximately 34 hectares. This tidal estuary contains over 700,000 tonnes (550,000m3) of Polycyclic

aromatic hydrocarbons (PAH) and metals-contaminated sediments which relate to the adjacent historic

steel mill and Coke Ovens operation. Approximately 5% of the sediments encountered in the Tar Ponds

also contain Polychlorinated biphenyls (PCBs) at concentrations exceeding 50ppm.

The 68 hectare Coke Ovens Site operated from 1901 to 1988. An estimated 560,000 tonnes (280,000m3)

of soil at the Coke Ovens Site has been contaminated with petroleum hydrocarbons, PAHs and metals.

An additional 1,300 tonnes (1,000m3) of PAH-contaminated sediment has been identified in Coke Oven

Brook and connector and 25,000 tonnes (12,500m3) of contaminated soil is located in the in-ground Tar

Cell at the Coke Ovens Sites.

1.3. Project Environmental Mechanism

On May 12, 2004, the Minister of Public Works and Government Services Canada and the Premier of

Nova Scotia signed a MOA to jointly remediate the Tar Ponds and Coke Ovens Sites in Sydney, Nova

Scotia. This Project was subject to an EA pursuant to the Canadian Environmental Assessment Act

(Government of Canada [GOC], 1992a) and provisions of Part IV of the Nova Scotia Environment Act

(GNS, 1995a). A Joint Review Panel was established under the Agreement for the Joint Panel Review

(Canadian Environment Assessment Agency & NSE, 2005) of the Sydney Tar Ponds and Coke Ovens

Sites Remediation Project.

To satisfy the EA, an Environmental Impact Statement (EIS) was prepared by AMEC Earth &

Environmental (AMEC, 2005a) in association with Jacques Whitford Limited and ADI Limited on behalf

of the Agency and submitted to the Joint Review Panel and relevant regulatory authorities for the

Remediation of Sydney Tar Ponds and Coke Ovens Sites.

AECOM completed a preliminary engineering and cost estimation project (“the Pre-design”) as part of

the overall remediation of the Tar Ponds and Coke Ovens Sites. The Pre-design followed on the

publication of the Project Description (AMEC, 2005b) tailored to meet the requirements of the Canadian

Environmental Assessment Act and the Nova Scotia Environment Act (GOC, 1992a; GNS, 1995a). The




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Project Description (AMEC, 2005b) is an assemblage of remediation options, for each of the Tar Ponds

and Coke Ovens Sites selected from those presented as being acceptable following the earlier Remedial

Action Evaluation Report (RAER) process (CBCL & ENSR, 2003).

Subsequently, in the Fall of 2006 the Agency retained the Consultant to complete the Design and

Construction Oversight Services for Remediation of the Tar Ponds and Coke Ovens Sites. The proposed

Remediation Program will focus on two (2) primary sites, identified as the Coke Ovens (including Coke

Oven Brook Connector running from Victoria Road to the South Tar Pond) and the Tar Ponds (including

both the North and South Tar Ponds). The remedial strategy focuses on the S/S of contaminated materials

within both of the Tar Ponds and Coke Ovens Sites.

1.4. Objectives of the EMP

This EMP will apply to all Project elements, span the life of the Project and provide a framework for the

environmental management of the entire Project. The Project-wide environmental management approach

is defined in the EMP; however, more detailed environmental management provisions will be outlined in

the Project and Detailed EPPs. While the EMP is meant to provide the Project with stable and consistent

environmental guidelines, should changes in scope of the Project occur, or if changing or unexpected

conditions are encountered during construction activities, the EMP will be reviewed and modifications

made to ensure the EMP remains comprehensive. Any revisions to the EMP will be reviewed and issued

in the form of an addenda in accordance with Section 1.5.

The specific objectives of the EMP are to:

Clearly state the environmental protection policies and philosophy to be followed on the Project.

Set the appropriate environmental objectives and framework.

Identify the relevant legislative, regulatory and approval requirements for the Project and review

these requirements for each element to ensure that all approvals and permits are obtained in advance.

Identify applicable mitigation measures and follow-up requirements provided in the EIS document.

Provide a framework for the development of the Project EPP and the element specific Detailed EPPs

during the construction phase of the Project and long term EEM Plans. Detailed construction specific

environmental protection plans will be presented in the element EPPs.




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Establish contingency and response procedures related to the discovery of unexpected site conditions

(i.e.: archaeology artifacts, spills).

With respect to environmental protection, establish clear roles and responsibilities for the engineering

team and Contractor(s), including work accountability and institution of regular reporting protocols.

Ensure that potential environmental problems are anticipated; and, contingency and emergency

response plans for dealing with unplanned events such as spills are developed and implemented.

Ensure safe, rapid and effective response to unexpected and emergency situations.

Establish procedures for the appropriate control and management of materials, vehicles and

equipment, noise, etc.

Require the implementation of environmental awareness training to ensure that all on-site personnel

understand the importance of environmental protection, the causes of environmental damage, proper

environmental protection practices and their obligations to ensuring that the environment is protected.

Establish a compliance monitoring program to verify that the environmental protection measures

outlined in the EMP and associated documents are being properly implemented and maintained.

Establish protocols for activity and long-term specific EEM Programs.

Establish contributory initiatives to federal follow-up monitoring requirements.

Ensure that proper records are maintained and monitor the effectiveness of the EMP.

Establish a process for analyzing the results of inspection and monitoring and review with

management.

Develop and implement an environmental Quality Assurance/Quality Control (QA/QC) Program to

ensure that environmental protection measures are properly implemented.

Establish communication and reporting protocols.

1.4.1. Content of the Environmental Management Plan

With these objectives in mind, the Environmental Management Plan (EMP) addresses the following main

components:

Remedial Management Plan;




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Regulatory Approvals, Authorizations and Permits;

The Environmental Management Team Organization, Structure and Responsibilities;

Management Plans;

Environmental Protection Plans;

Monitoring Plans;

Contingency and Emergency Response Plans;

Environmental Awareness Training; and

Communication and Reporting.

In addition, the EMP sets standards for the QA/QC requirements necessary to ensure that environmental

quality is achieved throughout all phases of the Project.

Once approved, this EMP and its amendments will be a binding environmental plan for the Project and

along with the EPPs, will set the environmental protection requirements to be incorporated into the

construction contract documents.

1.5. Maintenance of the EMP and Change Protocol Document

The EMP has been designed to reflect the proposed construction activities and identified environmental

conditions at the Site. Over the course of the Project, the scope of work may change, be expanded or

modified to accommodate lessons learned, or be revised to confront unforeseen environmental conditions.

Any of these occurrences could change what guidelines are necessary in the EMP. In such an event, the

EMP will be reviewed to ensure that the EMP adequately addresses these new considerations from an

environmental perspective. If it is determined that the EMP does not address the potential environmental

implications of these changes, an amendment to the EMP will be issued. Any significant revisions to the

EMP will be reviewed by the Agency, Environmental Management Committee (EMC) and NSE as per

the provincial Conditions of Approval. Issuance of the EMP and any amendments will be documented in

the Change Protocol Document found in Appendix B.




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1.6. Environmental Policy, Guiding Principles and Commitment to Mitigation

The Agency is committed to ensuring that the following environmental policies are adhered to:

The Project is constructed in accordance with sound principles of environmental stewardship and

regard for the sustainability of the earth‟s ecosystem.

The Project construction activities are carried out in compliance with existing environmental laws,

regulations, guidelines, practices and procedures.

The Project remedial design and construction activities will conform to best management practices

and industry standards.

The Project construction activities will implement, monitor and maintain the mitigation measures

identified as part of the EA/Joint Panel Review (JPR) Process.

The Project remedial design and construction activities will provide for the protection of human

health and environment.

The EMP is based on the following guiding principles to ensure environmental protection:

Commitment – The Contractor(s), as defined in Section 4.8, will be committed to ensuring that their

operations are conducted in a manner consistent with this EMP and their own Environmental Policies.

The Agency will be accountable for ensuring that all aspects of the EMP are implemented.

Environmental Responsibility – Environmental protection is everyone‟s responsibility. All

construction personnel and staff directly involved in the Project will be informed of this responsibility

and will be trained and given authority to undertake the necessary actions to protect the environment.

To this end, all staff shall be made familiar with the incident reporting and response protocols for

reporting environmental incidents, as laid out in Section 8, Contingency and Emergency Response

Planning. Staff environmental protection initiatives will be recognized by the Agency, while failure

to fulfil environmental protection obligations will not be tolerated.

Continuous Improvement – This EMP is based on a philosophy of continuous improvement of

environmental protection practices through a program of inspection, monitoring and review.

Proactive Communication – Agency, the Consultant and the Contractor(s) are committed to

identifying various means of working proactively with regulatory agencies and the public to address

potential environmental concerns throughout the process, not just when issues arise.




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Integrated Approach – Agency, the Consultant and the Contractor(s) will employ an integrated

management approach so that environmental concerns are integrated into the planning and

implementation phases to avoid or minimize the environmental impacts of construction.

These environmental principles are the cornerstone against which all activities will be tested during

construction.

This EMP confirms that the Agency, the Consultant and the Contractor(s) are committed to mitigating

adverse environmental impacts associated with construction of the Project through the following

principles:

All materials (hazardous and non-hazardous) will be handled so as to protect human health and the

environment.

Activities will be planned and implemented and equipment will be managed and maintained in a

manner that minimizes impacts on the environment.

EPPs will be developed prior to and implemented during construction and post construction. Long

term environmental effects monitoring will be developed and implemented to ensure appropriate

identification of impacts and to enable corrective and mitigative action.

Measures will be put in place and implemented in order to prevent the accidental discharge of

contaminants into soils, surface water and/or groundwater. Any accidental contamination will be

reported by the Owner (Agency) to NSE by contacting the environmental emergencies reporting

centre by telephone at (902) 426-6200 and cleaned up as per Provincial requirements. In the event of

a spill in the estuary/marine environment, the reporting agency is the Canadian Coast Guard Regional

Operations Centre Nova Scotia 1-800-565-1633 (twenty-four (24) hour emergencies).

Hazardous wastes produced will be managed in accordance with applicable laws and regulations.

Erosion control measures will be designed, implemented and maintained to ensure that there is no

increased sediment loading to surface waters and/or sewer systems leaving the Project site. Given the

importance of natural habitats for sustaining plant, animal and aquatic life, the Contractor(s) will be

responsible for implementing control measures to adequately protect natural habitats.

The Contractor(s) will be responsible for carrying out mitigation measures as prescribed and approved by

the Agency including, but not limited to the following:




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Environmentally sensitive designs intended to lessen or eliminate potential adverse effects.

Environmentally responsible and sound construction practices.

Strict adherence to federal, provincial, municipal and other applicable regulations, guidelines,

standards, policies, permits and authorizations and implementation of all mitigation measures

identified through the EA/JPR Process.

Environmental impacts attributable to the Contractor shall be rectified, at the Contractor(s)‟s expense, to

the satisfaction of the Agency and the Consultant, as per the Contract.

2.0 REMEDIAL MANAGEMENT PLAN

The EMP‟s Remedial Management Plan (RMP) lays out the scope of the Sydney Tar Ponds and Coke

Ovens Remediation Project and provides a general overview of the Project components, sequencing and

timelines. The Project involves two (2) distinct areas (Tar Ponds and the Coke Ovens) to undergo

remediation activities. Work in each of these areas is divided into several separate design elements.

These distinct areas are described within the RMP and a brief description of each Project element is

provided. In addition, the RMP sets out the sequencing with which each element is to be completed,

accounting for environmental contamination considerations and what Project elements must be completed

for others to continue. Finally, the RMP outlines the Project Schedule and Key Project Milestones.

2.1. Project Description

The Agency, in conjunction with the Federal and Provincial governments, developed a proposed cleanup

plan for the Project by utilizing numerous engineering and scientific studies and by consulting extensively

with the public since 1996. Through these thorough research methods, a remediation strategy was

developed for the Tar Ponds and Coke Ovens Sites consisting of the following key components:

Controlling surface water and groundwater at the Tar Ponds and Coke Ovens;

Treating in-place selected contaminants;

Containing remaining contaminants;

Site surface restoration ; and

Developing long-term monitoring and maintenance plans.




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The main components that will be involved in implementing the proposed remediation strategies for the

Tar Ponds and Coke Ovens Sites are provided below:

2.2. Tar Ponds

The strategies that will be involved in the remediation efforts of the Sydney Tar Ponds include:

a) Control Water: Watercourse diversion utilizing pump stations and pipelines will redirect surface

water flowing through the Tar Ponds. This will isolate brooks and streams from contaminated Tar

Ponds sediments. Groundwater will be controlled through trenches to be constructed in the Tar Ponds

area.

b) Treat Selected Contaminants In-place: Sediments will be solidified and stabilized in-place with a

binder, such as Portland cement, using excavation, augers or grout injection systems.

c) Contain Residual Contaminants: A containment system will be designed and constructed to reduce

human and ecological exposure to contaminants and to prevent the movement of contaminants off-

site. The containment system will consist of an engineered cap and the installation of low

permeability barrier walls or liners around the perimeter of the Tar Ponds, if required.

d) Site Surface Restoration: The Site surfaces will be restored in a manner compatible with natural

surroundings and future site use(s).

e) Long-term Monitoring and Maintenance Plan: Long-term monitoring and maintenance plans will be

developed for the Site to cover the twenty-five (25) year period following completion of the Project.

As a part of these plans, cap, surface water discharges and groundwater monitoring will be conducted.

As per the MOA, following the twenty-five (25) year period after construction, monitoring becomes

the responsibility of the Federal Government and the Provincial Government of Nova Scotia.

Monitoring of Sydney Harbour will become the responsibility of the Federal Government with the

input of the Agency.

2.3. Coke Ovens

The strategies that will be implemented in the remediation efforts of the Sydney Coke Ovens include:

a) Control Water: Diversion channels and barrier walls will be installed to reroute groundwater and

surface water flowing through the Site. This will facilitate the removal and cleanup of contaminated

materials, prevent contamination of surface water and minimize water treatment requirements.




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b) Treat Selected Contaminants: The Tar Cell materials will be solidified and stabilized ex-situ with a

binder, such as Portland cement, using excavation, augers or grout injection systems.

c) Contain Residual Contaminants: A containment system will be designed and constructed to reduce

human and ecological exposure to contaminants and to prevent the movement of contaminants off-

site. The containment system will consist of low permeability vertical walls installed at various

locations around the perimeter of the Coke Ovens and a soil cover designed to facilitate future site

use(s).

d) Site Surface Restoration: Site surfaces will be restored in a manner compatible with natural

surroundings and future site uses.

e) Long-term Monitoring and Maintenance Plan: Long-term monitoring and maintenance plans will be

developed for the Site to cover the twenty-five (25) year period following completion of the Project.

As a part of these plans, cap, surface water discharges and groundwater monitoring will be conducted.

As per the MOA, following the twenty-five (25) year period after construction, it is the responsibility

of the landowner to investigate changes in site conditions in consultation with regulatory bodies.

2.4. Element Description and Layout

A general conceptual description of each element is provided in this section. Detailed construction and

remediation activities for each element can be found in the individual Detailed EPPs and design

documents prepared specifically for each Project element. Each Detailed EPP also includes a task-focused

RMP to guide the sequencing and construction activities of each task.

2.4.1. TP6A – Flow Diversion

During TP6A activities, flows from Coke oven Brook and Wash Brook are diverted from the Tar Ponds

through the use of temporary pumping stations. This approach allows for S/S work to take place without

the influence of the water from these sources or influence from tidal action through the use of cut-off

walls.

The Flow Diversion includes the following scope:

Inlet and outlet structures for bypass pumping;

Construction and operation of pumping stations;

Pipelines to convey the redirected flow;




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97918-GEN-EMP-N-001-R2 14 June 2010

Cut-off walls to assist with management of groundwater;

Outfall modifications; and

Temporary drainage ditches.

TP6A will be divided into three (3) phases: (I) South Tar Pond, (II) The Narrows and (III) Battery Point.

Upon isolation of each phase, the TP6B Contractor will mobilize to the area and begin the S/S process.

Activities will progress as follows:

Isolate the South Tar Ponds at Ferry Street to allow for control of conditions within the South Tar

Pond;

Isolate work area around Ferry Street and realign the sewer line at Ferry Street;

Install steel sheet piling (SSP) or equivalent along the east bank of the Tar Ponds to act as a barrier to

redirect migration of groundwater from the adjacent SYSCO property;

Pump standing water in the South Tar Pond into the North Tar Pond and provide on-going pore and

maintenance pumping to water treatment facility to keep the South Pond dewatered for construction;

Isolate Ferry Street to North Pond Narrows. Complete pump around of water from Ferry Street to

North Pond downstream of Narrows; and

Isolate the North Pond at Battery Point Barrier; repeat the previous process for the isolated section

from the North Pond narrows to Battery Point Barrier to allow for control of conditions within the

North Tar Pond.

2.4.2. TP6B – Solidification/Stabilization (S/S) and Channel Construction

Solidification, Stabilization and Channel Construction includes the following scope of work:

S/S recipe development;

In-situ S/S treatment of sediment in the North and South Tar Ponds; and

Construction of a new clean channel through the North and South Tar Ponds.

The S/S recipe development includes bench scale and pilot scale work. S/S of sediment involves the in-

situ treatment of the Tar Ponds sediments through mixing of the sediments with other materials which

result in a solidified material having properties that meet or exceed the criteria (strength, permeability and

containment) for the Project. The channel design will permanently convey water from Wash Brook and




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Coke oven Brook to Sydney Harbour. The channel will take into account the need to accommodate the

numerous outfalls that populate the shorelines of the ponds, as well as considerations for fish passage at

low tide. In addition, the channel will also capture a portion of local overland flows and pressure relief

wells to reduce pressure at the underside of the channel.

2.4.3. TP6C – Ferry Street Bridge Construction

The bridge construction will include the construction of a new bridge structure, widening the channel

opening in the existing causeway and maintaining the existing sanitary sewer that runs along Ferry Street.

2.4.4. TP6D – Construction of Access Roads

The access roads construction element will include creation of access roads for Tar Ponds and Coke

Ovens elements.

2.4.5. TP2 – Material Processing Facility

TP2 is comprised of a Material Processing Facility and includes a contractor‟s compound area. The

processing facility will handle materials excavated from the Tar Ponds that will not be going directly into

an isolated Pond area for S/S treatment. The material will be sorted, classified and returned to the

designated area for S/S (if 200mm or less); and if not acceptable material for the S/S recipe, the material

will be sorted, cleaned and either recycled, sent to a licensed facility or the SYSCO landfill. There will be

a structure and amenities block for all the contractor‟s trailers, personnel vehicles, site vehicles and

lunchroom. There will be utility hookups available for sewer, water, hydro and communications. The

wastewater will be directed to a licensed water treatment plant for treatment.

2.4.6. TP7 – Tar Ponds Surface Cap

Following the S/S treatment of Tar Ponds sediments in TP7, further containment and protection will be

provided by capping the treated sediments.

Element TP7 will involve the following activities:

Excavation and installation of a network of groundwater control trenches through the solidified

sediments and into the underlying till unit;

Installation of an HDPE liner or equivalent between the granular trench backfill and the solidified

sediments, to minimize groundwater contact with the sediment (not to extend into the till zone);




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Installation of groundwater sampling wells near the channel end of each trench to allow recovery of

groundwater samples in the post-construction period;

Installation of the Surface Cap over the North and South Tar Pond sites, following the S/S treatment

of the sediments, consisting of a GCL Liner bedding, GCL Liner, a drainage layer, a clay/till fill and a

topsoil and vegetative cover; and

Provide a cap interface between the realigned channel and the S/S sediments, which will be

constructed during the capping process.

During the maintenance phase of the project, the cap will be inspected (by Agency or their designee) for

settling by completing a topographic survey. The cap will also be inspected (by Agency or their

designee) on an annual basis for integrity. Maintenance details can be found in the cap maintenance and

monitoring plan provided in the Project EPP.

2.4.7. CO1 – Coke Oven Brook Connector Sediment Removal and Disposal

The upper section of Coke Oven Brook Connector covers the area from the upstream end of the culvert

under Victoria Road and then downstream approximately 400m, to just above the rail bridge crossing of

the Coke Oven Brook Connector. The lower section of Coke Oven Brook Connector includes the area

from the rail culvert above SYSCO Gate No.3 to the South Tar Pond. The total area covers

approximately 900m. This element focuses on the removal of contaminated bottom sediments and the

protection of the Coke Oven Brook Connector from coal tar contamination from the SYSCO Site. During

excavation and removal of contaminated material, connector flow will be temporarily diverted from the

construction area. Removal of the contaminated sediments will be based on visual observations at the

time of excavation but will not exceed 1m based on the Project description (practical limit of GCL and

subsequent 1m of backfill). Following excavation, a GCL liner system will be installed under the brook

to prevent tar from entering the brook. A 1m clean layer of backfill will be applied and covered with a

geotextile and a scour protection layer. A low flow channel will be integrated into the bottom

reconstruction for fish passage. A weir will be installed between SYSCO Gate No.3 and Inglis Street

Culvert to allow for fish passage as this area sees a 1.5m drop.

2.4.8. CO2 – Solidification/Stabilization (Tar Cell)

The contaminated material in the Tar Cell on the Domtar Site will be subjected to S/S treatment as a

means of creating a structurally enhanced, low permeable mass that immobilizes contaminants in place.




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The purpose is to provide increased structural strength for capping and to decrease the mobility of

containments. Method of S/S treatment currently being considered is ex-situ treatment under a temporary

structure to enclose mixing operations and control emissions. In-situ mixing is not viable in the Tar Cell

area due to the large number of buried objects, such as concrete footings and abandoned site services. In

addition, the consistency of the material and need to add additional material to the matrix as defined in the

bench scale work require an ex-situ mixing approach. Construction water will be collected and

transported to a water treatment plant for treatment.

2.4.9. CO5 – Vertical Cutoff Walls

The Coke Ovens Site is located in a 3.5km long, 500m wide east-west trending valley within the Muggah

Creek Watershed. The groundwater flow is generally west-northwest down the valley and off-site to the

west. This groundwater flow regime can result in relatively clean groundwater entering the Site and

contacting contaminated material. In addition, groundwater can migrate off site and degrade groundwater

quality off site. Therefore, vertical cutoff walls have been designed to manage these conditions by

diverting clean groundwater around the Coke Ovens Site. The CO5 element includes the following

activities:

Rough grading and excavation of trenches along the north, west and south sides of the Coke Ovens

Site into the underlying clean till;

Installation of sub-drains on the south side (upgradient) of the southwest cutoff wall directed to the

realigned channels;

Stockpiling of excavated material, until transport to the Tar Ponds for S/S treatment is available;

Backfilling the trench with compacted clay/till bentonite/soil slurry up to within 0.5m of the surface;

Backfilling of the remainder of the trench with 0.3m clean clay and 0.2m of topsoil; and

Removal and storage of any subsurface infrastructure encountered during trench excavation for the

construction of the cutoff wall.

2.4.10. CO6 – Coke Ovens Surface Cap

Capping activities undertaken in this element will extend over a large portion of the Coke Ovens and Tar

Cell Sites to create a barrier to contaminated materials and assist with surface drainage. This is essentially

an earthworks job, with grading and installation of an impermeable liner and a topsoil layer being placed




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over the Site. Contouring, runoff, reduction of infiltration and vegetation management will be considered

during the detailed design of this element.

The activities that are generally associated with the construction of the Surface Cap include:

Manage the interface of the Surface Cap with Cut-off Walls, Coke Oven Brook Channel and

Realigned Channels;

Remove wooden culvert from the Domtar Site;

Install surface cap over the Coke Ovens Site;

Contour grading layer to ensure proper surface water drainage;

Re-vegetation of surface cap by hydroseeding; and

Initiate short term Cap Monitoring Program.

2.4.11. CO7/CO8 – Coke Oven Brook Water Treatment & Ground Water Collection

Elements CO7/CO8 must be completed prior to completion of element CO1 so that the remediated

section of the Cook Oven Brook Connector is not recontaminated by untreated upstream

flows/discharges. In CO7, new groundwater collection lines will be installed along the west side of the

Domtar Site to collect the groundwater flowing west from the Domtar Site and along the Coke Oven

Brook interceptor line to collect groundwater from the Coke Ovens Site. The groundwater collection

system (the interceptor lines) will flow by gravity into a pump station, which will direct the groundwater

to a raw water equalization tank, feeding the CO8 Coke Oven Water Treatment Plant (WTP). The

construction of CO7 will require coordination with CO8 activities. The groundwater will flow by gravity

via the CO7 interceptor lines into a pump station constructed as part of CO7 which will direct the

groundwater to the CO8 Water Treatment Plant (WTP).

Water treatment requirements for the Coke Ovens Site over a twenty-five (25) year period include the

contaminated groundwater from the groundwater collection system to be installed under the Coke Oven

Brook as part of Element CO7. Expected contaminants of concern include petroleum hydrocarbons,

PAHs and metals. The mass transport and hydrology models, expertise and historical information will be

used to determine contaminant concentrations and flow rates from each area. The collected water will

need to be treated to meet the acute lethality test to be in compliance with the Fisheries Act and NSE.




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The treatment considerations for the Coke Ovens Site by itself and in combination with the Tar Ponds

water treatment requirements, will be reviewed and approved by the regulators.

2.5. Conceptual Site Models

Conceptual Site Models (CSMs) have been prepared to describe, in general terms, how Project activities

may contribute to the release of contaminants of concern, how they may be transported and what

receptors those contaminants may reach. These CSMs provide the framework for the development of

Detailed EPPs and mitigation strategies for each activity. Two (2) site wide CSMs have been developed,

one (1) for the Tar Ponds and one for Coke Ovens, showing the numerous Project elements and receptors

that apply. In addition, a detailed CSM has been developed for each element. The CSMs can be found in

Appendix C.

2.6. Sequencing of Project Elements

The sequencing of construction activities for individual project elements is of great importance for the

Project. Sequencing must allow each element‟s progression to fit within the limitations of other work, as

the commencement and continuation of several major Project activities face physical restrictions for

cleanup due to work that must be completed under separate Project elements. In addition to appropriately

sequencing elements for the purposes of maintaining the overall Project Schedule, the staging of

construction activities must be such that cleaned areas are not re-contaminated by further work.

Ultimately, carefully planned sequencing creates a logical succession of element implementation. The

following paragraphs outline the sequencing of Project elements and construction tasks that must be

completed before the commencement of other remediation activities.

The Cooling Pond Treatment and Pilot Scale activities will be the first element. This includes the S/S

treatment of the Cooling Pond and six (6) cells in both the North and South Tar Ponds to demonstrate the

effectiveness of S/S treatment.

Element TP2 (Material Processing Facility) will begin early in the Project construction sequencing as it

will accept materials from many elements. It will be completed to allow for site controlled egress by

means of a central decontamination facility and will also serve various elements by accepting, sorting and

decontaminating debris, waste and oversize materials. An amenities block will be provided allowing

personnel from various elements to change into “dirty” work clothes in the morning and clean clothing

after work hours, as well as providing shower areas.




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CO5 (Vertical Cutoff Walls) will be one of the first elements to start on the Coke Ovens Site. It consists

of the excavation and installation of cutoff walls on the Site in order to manage the groundwater in the

area and to minimize groundwater contact with the most contaminated areas of the Site project.

CO2 (Tar Cell Solidification/Stabilization) consists of ex-situ solidification/stabilization (S/S) treatment

of the Cell on the Domtar Site. CO2 must be completed prior to the progression of CO6 over the Tar Cell

as the Coke Ovens Surface Cap will cover the entire Domtar Site, including the S/S material in the Tar

Cell area.

TP6D (Construction Access Roads) will be completed prior to the commencement of the TP6A (Flow

Diversion) and CO7/CO8 (Coke Ovens Water Treatment Plant & Ground Water Collection). As the

roads will be used to access work areas for those elements and subsequent elements (e.g. TP6B).

TP6A (Flow Diversion) will commence prior to TP6B (S/S and Channel Construction) in order to isolate

sections prior to S/S treatment. TP6A and TP6B will take an estimated four (4) years to complete during

which element TP6C (Ferry Street Bridge Construction) will commence.

CO8 (Coke Ovens Water Treatment Plant) will be commissioned prior to the completion of CO7

(Groundwater Collection System) in order to treat the contaminated groundwater from the groundwater

collection lines to be installed as part of CO7 activities. CO7 will include the construction of the Coke

Oven Brook groundwater collection line and the collection of the Domtar interceptor trench flow and

direct it to CO8. CO7 is also closely linked to TP2 for the processing and disposal of debris. CO7/CO8

must be completed prior to the initiation of CO1 and the commissioning the TP6B channels.

CO6 (Coke Ovens Surface Cap) consists of installation of the surface cap over the Coke Ovens Site.

CO6 must include proper grading at the interface with CO7. Elements CO5, CO2 and CO7/CO8 must be

completed prior to the progression of CO6 in each of those areas.

The Coke Ovens elements are driven by the need to protect downstream areas from upstream

contaminants. Therefore, to protect the Coke Oven Brook Connector, CO1 (Coke Oven Brook Connector

Sediment Removal and Disposal) will only start after CO7/CO8 are completed.

TP7 (Tar Ponds Surface Cap) will begin following the S/S treatment of the Tar Ponds (TP6B).




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2.7. Project Schedule and Milestones

The Sydney Tar Ponds Project is anticipated to extend into the year 2014; follow the general sequencing

described in Section 2.6. The Summary Base Project Schedule, outlining the anticipated commencement

and conclusion of the individual Project elements, can be found in Appendix D. As shown in the figure,

Project Management Services will extend throughout the life of the project. Project Management

includes all Project communication procedures, local benefits programs, project guidelines and controls,

the Project HASP and implementation plans, including this EMP. Timelines for design, construction and

initiation of long-term monitoring for element-specific activities have also been predicted and the

timelines of specific tasks under each element can be derived from the Project Schedule as well. Project

Milestones are discussed in Section 2.7.1.

2.7.1. Project Milestones

In order to undertake construction and remediation activities, detailed engineering design plans are

required for the various elements to guide task management decisions. As the Consultant,

AECOM/CBCL has been contracted by the Agency to prepare and submit 75%, 95% and 100% Design

Reports in addition to tender review documents for each element. The 75% and 95% reports along with

the tender review documents are then reviewed by the Agency, regulatory agencies and the Independent

Engineer (IE) for approval before the commencement of active remediation construction works.

3.0 REGULATORY APPROVALS, AUTHORIZATIONS AND PERMITS

The Project is regulated under various federal and provincial legislation as well as related policies and/or

guidelines and industry codes of practice. These requirements, in Canada and Nova Scotia, have evolved

over a number of years to increasingly provide environmental protection and sustainable development and

ensure that environmental implications of projects are considered during the planning phase.

The list provides an overview of the regulatory requirements of the Project. While this is not intended to

be an exhaustive list of pertinent federal and provincial legislation and policies, it does provide an

overview of key regulatory requirements for Project planning and implementation. Depending on the

final scope of work as determined in the detailed design, additional relevant legislative, regulatory and

approval requirements may be necessary and will be identified during completion of the detailed design

elements and associated Detailed EPPs. In addition, regulatory requirements will be reviewed on an on-

going basis to ensure that all approvals and permits are obtained in advance of Project activities. A




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regulatory permits and approvals binder will be maintained and updated regularly to serve as a reference

document for all Contractors and Consultants during construction activities.

3.1. Federal Government of Canada

FISHERIES ACT: A permit from DFO to collect fish prior to construction activity in waters frequented by

fish will be required to comply with Section 30(1) and Section 32 of the Fisheries Act. This will ensure

fish are not exposed to degraded construction waters as the deposit of a deleterious substance cannot be

permitted as mandated by Section 36(3). This will be accomplished by performing a permitted fish

rescue. This permit will be applied for and obtained by each element‟s Contractor.

TRANSPORTATION OF DANGEROUS GOODS ACT AND REGULATIONS: All waste and/or contaminated

materials transported from the Site must be managed and handled as per the requirements of the

Transportation of Dangerous Goods Act and Regulations (GOC, 1992b).

CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA): All construction activities must be conducted

within the limitations as set out in the CEPA (GOC, 1999). Pollution control, waste management and

control of toxic substances are just some of the regulations found in this Act that must be followed.

3.2. Provincial Government of Nova Scotia

ENVIRONMENT ACT, ACTIVITIES DESIGNATION REGULATIONS: An Approval under the Activities

Designation Regulations (GNS, 1995b), will be required for specific work conducted at the Site. The list

of permits and approvals will include, but not be limited to, the following for the NSE:

Industrial (Division V);

Water (Division 1) Approval; and

Watercourse alteration permit.

ENVIRONMENT ACT, ENVIRONMENTAL ASSESSMENT REGULATIONS: Approvals under the Environmental

Conditions of Approval (GNS, 2003), will be required for specific work conducted at the Site. The

Minister of Environment must approve the project environmental assessment for the project to proceed.

All additional required permits and approvals must be required before initiating any construction

activities.

ENVIRONMENT ACT, AIR QUALITY REGULATIONS: Adherence to the Air Quality Regulations (GNS,

2005) will be required for any site remediation or construction activities.




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97918-GEN-EMP-N-001-R2 14 June 2010

ENVIRONMENT ACT, PETROLEUM MANAGEMENT REGULATIONS: Adherence to the Petroleum

Management Regulations (GNS, 2002) will be required for the storage of fuels or refuelling on-site.

ENVIRONMENT ACT, EMERGENCY SPILLS REGULATIONS: Adherence to the Emergency Spills

Regulations (GNS, 1995d) will be required for the remedial and construction activities on-site and shall

be covered by the Emergency Response and Preparedness Plan and site-specific HASPs.

DANGEROUS GOODS MANAGEMENT AND DANGEROUS GOODS TRANSPORTATION REGULATIONS: All

waste materials and/or dangerous goods stored and/or transported from the Site must be managed and

handled as per the requirements of the Provincial Dangerous Goods Management and Dangerous Goods

Transportation Regulations (GNS, 1995e; GNS, 1989a).

NOVA SCOTIA SPECIAL PLACES PROTECTION ACT: An Archaeological Research Permit from the

Department of Tourism and Culture will be required to conduct archaeological surveys or for any activity

that threatens or disturbs sites declared special places under the Special Places Protection Act (GNS,

1989b).

BEACHES ACT: A clearance under the Beaches Act (GNS, 1989c) from the Department of Natural

Resources will be required for works seaward of the ordinary high water mark such as sampling or

remedial activities that take place between the high and low tide mark of a marine or estuarine

environment.

Specific regulations to be applied to the Project will be determined in consultation with the NSE and

provided in the individual Project element EPPs to provide clear guidance to on-site construction

personnel.

3.3. Municipal Government – Cape Breton Regional Municipality

MUNICIPAL GOVERNMENT ACT: The Municipal Government Act (GNS, 1998) grants power to

municipalities to pass by-laws and to govern. Adherence to the following CBRM permits or by-laws will

be required:

Building By-Law and Permits;

Noise By-Law; and

Sewer Use By-Law.




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4.0 ENVIRONMENTAL MANAGEMENT TEAM ORGANIZATION, STRUCTURE

AND RESPONSIBILITIES

The EMP will be managed and implemented by the Agency and the Consultant to ensure that the

activities associated with the remedial design and construction oversight services are undertaken in a way

that protects and sustains the ecosystem and meets the spirit and letter of all applicable legislated

requirements and commitments. Contractor(s) also share in these environmental responsibilities and shall

be responsible for implementing the applicable components of the EMP.

It is the responsibility of the Agency, the Consultant and the Contractor(s) to develop, coordinate and

implement the environmental protection plans, monitoring, contingency plans, emergency response

components and QA/QC during the design and construction of the Project. All organizations will work

together to ensure that all environmental issues or problems are identified and resolved as quickly and

effectively as possible and the appropriate documentation filed.

The following is an outline of the management structure associated with the Project and the

responsibilities associated with the various positions. As the Project evolves, the management structure

may be altered and responsibilities may be added or taken away from these positions and allocated to

others. In addition, field specific roles and responsibilities shall be outlined in more detailed site-specific

environmental protection plans as they are developed.

4.1. Organization and Structure

Figures 1 and 2 provide an overview on the approvals and implementation paths that will be followed

over the life of the Project in order to carry out the remediation activities in accordance with the

procedures outlined in the EMP. The Project involves many individuals and organizations that will be

responsible for implementing the EMP. Further specifications on the general roles and responsibilities of

those involved in the Project follow in the subsequent Sections.




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97918-GEN-EMP-N-001-R2 14 June 2010

Figure 1: Design Organizational Chart




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97918-GEN-EMP-N-001-R2 14 June 2010

Figure 2: Construction Organizational Chart

4.2. Environmental Management Committee

On May 12, 2004, the Minister of Public Works and Government Services Canada and the Premier of

Nova Scotia signed a MOA, which outlined the required agreements pertaining to the Sydney Tar Ponds

and Coke Ovens Remediation Project description, governance, financial accountabilities and EA. To

implement the federal and provincial agreements respecting the Project, a Project Management

Committee (PMC) was convened with authorities described in the cost share agreement. This Project

Management Committee later initiated the creation of the EMC. The purpose of the EMC is to inform the

PMC on all environmental aspects of the Project as they relate to the pre-construction, construction and

operation phases of the Project. In this regard, the EMC is responsible for providing guidance to the




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97918-GEN-EMP-N-001-R2 14 June 2010

Agency during the development and implementation of this EMP. In addition, the EMC will consider

and implement, as appropriate, decisions of the PMC involving non-regulatory environmental issues. The

EMC will continue to operate after Project completion for a period of time to be determined by the PMC.

The EMC serves as a forum for information exchange between federal and provincial regulatory and

expert departments on all matters pertaining to the environmental management of the Project.

Specifically, the EMC is responsible for the following:

Auditing and evaluating the development and implementation of the EMP by the Implementing

Agency, including a critical review of the EMP and component documents.

Preparing a results-based evaluation of the environmental plans during the implementation phase.

The EMC will be expected to provide the Agency with expert advice concerning the effectiveness of

these plans throughout the life of the Project.

Informing the PMC on the Agency‟s progress in meeting EMP requirements.

Coordinating federal and provincial interests respecting the mitigation of adverse environmental

impacts.

Participating in the development and implementation of a (mandatory) follow-up program pursuant to

the CEAA.

Liaising with the IE on environmental issues associated with their oversight role for the Project.

Representatives on the EMC include:

Environment Canada;

Health Canada;

Fisheries and Oceans Canada;

Public Works and Government Services Canada;

Transport Canada;

The Nova Scotia Department of Environment and Labour;

Nova Scotia Department of Health Promotion and Protection;

Nova Scotia Department of Transportation and Infrastructure and Renewal;

Natural Resources Canada;




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97918-GEN-EMP-N-001-R2 14 June 2010

Enterprise Cape Breton Corporation;

IE, Ex-officio; and

Agency, Ex-officio.

4.3. Managing Partners

The Minister of Public Works and Government Services Canada (PWGSC) is the designated federal

management lead on the Project with the responsibility of negotiating agreements and protocols with the

Province of Nova Scotia. Through the MOA signed by the Minister of PWGSC and the Premier of Nova

Scotia, the PWGSC is accountable for the management of federal project funds, including the

development of oversight mechanisms to manage these funds with due diligence. In addition, PWGSC is

responsible on behalf of the Government of Canada for liaison with First Nations, public and stakeholder

groups in respect of the Project, as well as the management of federal reporting, submission and

communication requirements.

The Nova Scotia Department of Transportation and Infrastructure and Renewal (NSTIR) is partnering

with PWGSC under the MOA and is responsible for overseeing the implementation of the Project through

a single purpose entity, the Agency. NSTIR administers provincial funds in respect of the Project and is

party to most federal/provincial agreements ensuing from the MOA. As such, NSTIR is accountable for

the provisions of the MOA on the part of the Province.

In order to implement the federal and provincial agreements respecting the Project, the PWGSC/NSTIR

PMC was convened. The PMC is responsible for:

Ensuring that the Project is implemented in accordance with the MOA and its ancillary Agreements.

Providing leadership in areas including, but not limited to, issues related to First Nations, the

environment, community consultation and regional economic development opportunities.

Ensuring that the Project is carried out in a manner that ensures the protection of the environment.

Assisting in the implementation of the EMP on behalf of both levels of government and associated

regulatory authorities.

4.4. Nova Scotia Department of Environment

As summarized on the Canada News Centre Web Site (GOC, 2007), the NSE will act as the lead agency

for regulatory oversight of the remediation project through the conditions of the Environmental




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97918-GEN-EMP-N-001-R2 14 June 2010

Assessment approval and subsequent approvals required under the Environment Act (GNS, 1995a).

Throughout the Project, it is the responsibility of the NSE to review and evaluate the remediation process,

ensuring that all remediation efforts are falling within regulatory guidelines set for air emissions, waste

disposal, water treatment, etc. The Minister of Environment and Labour will also be responsible for

establishing an independent Remediation Monitoring Oversight Board, which will serve to monitor the

regulatory management of the project. Twenty-five (25) years following the completion of the

construction phase of the Project, Nova Scotia will take ownership of the Sites and will be responsible for

all future maintenance and monitoring thereof.

4.5. Sydney Tar Ponds Agency

The Agency is a provincial special operating agency that has been set in place as the implementing

agency for the Project, pursuant to the MOA signed by the Federal and Provincial governments. The

Agency is to provide balance between government accountability and private sector efficiencies.

The Agency‟s fundamental role is to direct, procure and implement the services needed to complete the

Project while protecting the interests of the partners. The Agency is responsible for ensuring that the

cleanup is conducted in an environmentally sound manner through the design and implementation of

monitoring programs that evaluate air and water quality and other environmental parameters. The

purpose of environmental monitoring is to ensure the environmental integrity of the Project and to protect

the public. In addition, the Agency is accountable in acquiring and adhering to any and all required

permits and approvals for the Project.

4.5.1. Agency Project Director

The Agency Project Director (or their designee) is responsible for the overall implementation of the EMP.

This will include having mechanisms in place to ensure that the safety, health and environmental policies

and procedures are being adhered to by contractors and by staff engaged on the project.

4.5.2. Safety, Health and Environmental Coordinator

The Agency has appointed a Safety, Health and Environmental Coordinator who is responsible for safety,

health and environmental management. The following functions fulfill this responsibility:

Coordinate all safety, health and environmental management functions.

Report on safety, health and environmental matters to the Agency Project Manager.




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Monitor compliance with relevant safety, health and environmental standards.

Ensure all project participants have received the required training and any refresher training programs

throughout the duration of the Project.

Document all training programs and certifications.

Act as a spokesperson on safety, health and environmental issues.

4.6. AECOM and CBCL

In support of the overall Remediation Program for the Sydney Tar Ponds Site, AECOM and CBCL were

retained as the Consultant to conduct the Remedial Design and Construction Oversight of the Sydney Tar

Ponds and Coke Ovens Site. The role of the Consultant includes the development of engineering designs

for the remediation elements defined in the Project Description (AMEC, 2005b) and also the gathering of

information related to hydraulic conductivity and S/S and quantity surveys. Specific responsibilities of the

Consultant include:

The completion and verification of detail design documents.

The preparation and completion of all forms and document identified in the Design Plan.

The management of the Design Agency‟s engineering team and approval of all design drawings and

documents produced (providing professional seal as required).

Ensuring the Design Agency is in compliance with Quality Program and Project Quality Plan.

Reviewing and approving Design Agency quality documents.

Performing all architectural related tasks and documents by preparing design drawings and

documents as identified in the Design Plan.

Performing all civil engineering related tasks and documents by preparing design drawings and

documents as identified in this Design Plan. Provides professional seal, when required.

Performing all structural engineering related tasks and documents by preparing design drawings and


Performing all mechanical engineering related tasks and documents by preparing design drawings and





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97918-GEN-EMP-N-001-R2 14 June 2010

Performing all electrical engineering related tasks and documents by preparing design drawings and


Performing all process equipment engineering related tasks and documents by preparing design

drawings and documents as identified in this Design Plan.

Preparing Environmental, Health and Safety (EHS) documents.

Reviewing and approving EHS-related documents.

Verifying EMP/EPPs are implemented.

In addition to these specific tasks, the Consultant is responsible for construction oversight and contract

administration of the project elements and the execution of quality management activities. It is the

responsibility of the Consultant to coordinate, oversee and monitor construction and installation activities

by the Contractor and conduct inspections of the work as required, ensuring quality of each Contract

Work Package according to the provisions established in the Project Independent Quality Assurance Plan

(IQAP) and Quality Control Plan (QCP). The Consultant shall assign full time Site representatives,

assisted by both resident and non-resident engineering staff as required, to oversee the on-site activities.

AECOM is responsible for maintaining records of all Consultant-related activities at the Site including

construction oversight, field inspections, field instructions, shop drawing reviews, photographs, meeting

minutes (as required), correspondence, manuals, test results and other pertinent information. The

Consultant will maintain a copy of these records on-site at all times.

AECOM representatives will attend regular site meetings with the Contractor and will manage all change

processes with the Contractors, including Instructions to Contractor, Requests for Field Change, Notices

of Major Field Change and Field Change Records.

The Agency may identify additional measures over those noted herein at any time during the

implementation of the project elements.

4.7. Independent Engineer

The NSTIR, acting on behalf of the federal and provincial governments, has retained the services of an

independent engineer to act in the capacity of the IE. The role of the IE is to ensure that all design and

remediation activities are conducted in accordance with the conditions of the MOA and its

implementation agreements.




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97918-GEN-EMP-N-001-R2 14 June 2010

In this capacity, the IE will act as an unbiased third party monitoring the implementation activities,

schedules and expenditures of the Agency and its contractors and the consultants. The IE will, amongst

other things, review procurement documents, schedules, cost estimates and full computational checks of

designs. It is not the IE‟s role to participate in any direct way in the design, construction, or QA/QC of

the Project; nor is the IE to take on the task of correcting any identified deficiency. Any deficiencies

identified by the IE will be directed to the Agency for consideration and resolution.

4.8. Contractors

All contractors and subcontractors working on the Site will be responsible for implementing, enforcing

and maintaining their activities in accordance with the EMP and associated EPPs for the duration of their

contractual activities at the Site. The Contractor(s) holds specific quality management responsibilities in

the planning, execution and management of the activities involved in each project element. The

Contractor(s) are responsible for the preparation of a Contract Work Package for each project element.

The Contract Work Package is to include a Construction Quality Control Plan (CQCP), which documents

the Contractor‟s processes and quality control (QC) procedures for delivering the quality objectives and

standards established for the project, confirming that the requirements of the Agency and regulatory

agencies are satisfied. Additional details on the Contract Work Package and CQCP is provided in the

Project QCP (provided under separate cover).

The Contractor shall also be required to develop a corrective action plan which ensures identified non

conformances, defects and errors are documented and corrected.

Each contractor and subcontractor responsible for the construction of an element will designate an

Environmental Monitor (EM) to ensure that work is being performed in compliance with the EMP and

EPPs. The contractor/subcontractor will ensure that the EM has appropriate training to comply with the

QC requirements of the contract, including all technical provisions. The Contractor‟s staff must be of

sufficient size and have the qualifications necessary to ensure contract compliance, whether work is

performed by the prime contractor or by subcontractors or vendors. The Contractor shall provide proof of

certification, where applicable.

In addition to the above obligations, the Contractor will allow (but does not require or obligate) the

Agency to do its own tests and inspections through an Independent Quality Assurance Consultant

(IQAC). The Contractor is required to accommodate this testing, allow access to Work and provide the




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97918-GEN-EMP-N-001-R2 14 June 2010

equipment necessary to facilitate inspection. This testing is solely for the benefit of the Agency and does

not relieve the Contractor of its quality control and testing obligations.

The Contractors are required to engage any required specialized inspection/testing agencies for inspecting

and/or testing portions of the work as indicated in the Construction Documents. Cost of such services will

be borne by the Contractor and the contractor shall not employ Inspection agencies or labs utilized by the

IQAC.

4.9. Analytical Laboratory

Where laboratory analysis is required as part of quality control, laboratories shall carry the relevant

certification for the analysis. Laboratories will be authorized to operate in Province of Nova Scotia with

qualifications to meet basic requirements of ASTM E35 and shall be accredited by the Canadian

Association of Environmental Analytical Laboratories (CAEAL). These requirements shall also be

included as part of the Contractor‟s specifications. Laboratories shall be required to notify the

Consultant(s) and Contractor(s) of observed irregularities or deficiencies of Work, equipment or material

and promptly submit written report of each test and inspection to each Consultant, Contractor and the

Agency.

4.10. Independent Quality Assurance Consultant

The IQAC shall be retained by the Agency to hold the responsibility for the implementation of the IQAP.

The IQAC shall verify that the Contractor's activities and Quality Control Programs are in compliance

with the contract plans and specifications and report all findings, whether positive or negative, directly to

the Agency. The IQAC shall establish specific reporting mechanisms with the Agency according to their

contract. If the IQAC discovers, to their discretion, any deficiencies in the implementation of the IQAP,

these deficiencies shall be reported immediately by phone to the Contractor for correction and to the

Agency. With respect to the IQAP, the IQAC will be responsible for communicating any instructions

from the Agency to the relevant Contractor(s) and/or other Project management personnel, via the

Contractor‟s or Project management personnel‟s preferred method of on-site communication.

The IQAC is responsible for all activities necessary to manage, control and document activities involved

in the IQAP. The IQAC responsibility includes ensuring adequate quality assurance services are provided

for work accomplished on and off-site by its organization, sub-consultants, technical laboratories and

suppliers. The work activities will include and conform to the requirements as set forth in the IQAP and




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97918-GEN-EMP-N-001-R2 14 June 2010

the contract documents. The IQAC shall engage independent inspection/testing agencies if the IQAC is

unable to independently carry out required inspections or tests as indicated in the IQAP and the contract

documents.

5.0 MANAGEMENT PLANS

While the purpose of the Project EMP as a whole is to communicate to all project participants and

stakeholders the commitment and efforts related to the prevention, management and minimization of

potential environmental impacts during the implementation of remediation efforts, the purpose of the

following Management Plans is to develop strategies to ensure that the goals of the EMP are met.

Management Plans outline specific areas of concern that are associated with major Project components

and propose mitigative measures and programs that will control associated environmental impacts. The

following plans have been developed in association with Agency and regulatory requirements to outline

the Project-wide control measures associated with site activities. The ultimate responsibility for

implementation and maintenance is held by the Agency.

5.1. Water Management Plan

The implementation of the Project will require the management of runoff during precipitation events and

the removal and, in some cases, treatment of surface and groundwater during construction and post

construction. The purpose of this Water Management Plan (WMP) is therefore to manage surface water

runoff and coordinate the pumping around, collection and/or treatment of water from the multiple project

elements to protect the environment by limiting exposure to potentially hazardous substances. This WMP

will be supplemented by more specific water management, collection and discharge details to be provided

in the Detailed EPPs and design documents prepared for individual project elements. The procedures,

guidelines and provisions outlined in this WMP and those described within the element specific EPPs will

be implemented by the Contractor‟s Site Supervisor and supervised by the Agency.

5.1.1. Management of Runoff from Precipitation

Surface water runoff will be managed by the installation of specific diversion control structures such as

berms or ditches. Surface runoff will be intercepted and re-directed to a desirable collection or discharge

point, as required in each element of the Project. Accumulated water through precipitation will be

decanted during circumstances in which the ground has not been disturbed and collected and treated in

circumstances in which the ground has been disturbed (e.g. trenching activities), S/S treatment occurring




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97918-GEN-EMP-N-001-R2 14 June 2010

in area or the runoff is suspected as contaminated through contact with contaminated material or

equipment.

Specific diversion control measures will be installed prior to and used during construction activities. They

shall not be removed until all areas have been sufficiently stabilized. The removal of control measures

will only be undertaken on the authorization of the Construction Site Supervisor, once environmental

inspections have confirmed that the erosion and sedimentation and contamination control performance

objectives have been met.

5.1.2. Management of Watercourses during Construction

Management of watercourses for each element differs, depending on where the watercourse is located

relative to the other activities occurring on Site.

5.1.2.1. Sources of Water

Many of the project elements involve a temporary (for construction purposes) or permanent change (as

part of the remedial design) in the surface or groundwater flow regime. These include:

TP6A and TP6B: Construction of a new permanent channel and groundwater flow management

within the treated Tar Ponds area. Temporary pump stations will collect surface waters from the

Coke Oven Brook and Wash Brook, divert water around the Tar Ponds in three stages as identified in

Section 2.4.1. Ditches will be constructed along the edges of the Tar Ponds to intercept CBRM

stormwater outfalls and temporarily redirect their water flow to the temporary pump station. The

stormwater outfalls will be permanently redirected to the newly constructed permanent channel.

CO1: Coke Oven Brook will be temporarily diverted around the excavation construction site on a

segment by segment basis using gravity and/or pumps as well as a bypass pipe to allow for

construction in the dry.

CO5: A cut-off wall will be installed below grade to redirect groundwater away from the

contaminated soil within the Coke Ovens Site and also contain the groundwater within the Site. Sub-

drains will be installed on the south side (upgradient side) of the southwest cutoff wall which will be

directed to the realigned channels.

CO7/CO8: A groundwater collection system will be installed at the Coke Ovens Site and Coke Oven

Brook. Fredrick Street and Cagney Brook will have structures removed and the channel filled in as




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97918-GEN-EMP-N-001-R2 14 June 2010

water is no longer flowing at these locations (realigned in 2006). Groundwater collection system and

permanent (twenty-five (25) year) treatment plant. CO7: The Groundwater Collection System (GCS)

will manage the groundwater contamination of the Coke Oven Site. The GCS will be designed to

capture contaminated groundwater and convey it by gravity to a wet well using two existing

interceptor lines and two (2) new groundwater collection lines. The water will be pumped to the

permanent water treatment plant for treatment prior to discharge into Coke Oven Brook.

5.1.2.2. Water Management

In some cases, a simple diversion into the ponded areas will be implemented. In other cases, a pump

around the work construction site will be implemented. Regardless of method and whether it will be a

temporary or permanent removal of surface and/or groundwater, all site-specific requirements identified

in the construction plans, conditions of the DFO work permits and all erosion and sediment control

measures shall be implemented by the Contractor and monitored. Surface and groundwater construction

waters as identified in Section 5.1.3 below, will be collected for treatment and subsequent discharge.

5.1.3. Water Collection and Treatment

Construction water includes any water found within the intrusive work area of the construction zone,

including pore water, precipitation, groundwater infiltration, waste water produced from ongoing,

continuous construction activities, such as decontamination and maintenance pumping. Prior to any

removal, release or discharge from the Site the treated construction water that is intended for discharge

from a temporary water treatment facility to a discharge location must meet the operational and/or

compliance discharge criteria developed by AECOM/CBCL and accepted by NSE. The compliance

discharge criterion is bioassay for acute toxicity based on a ninety-six (96) hour LC50 test. The

operational discharge criteria were developed based on CCME Canadian Water Quality Guidelines for the

Protection of Aquatic Life (CCME FWAL) and include values from the Massachusetts Remediation

General Permit (RGP) guidelines (as noted using “EPA” in the text). The operational discharge criteria

are provided in the following table:




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97918-GEN-EMP-N-001-R2 14 June 2010

Table 1: Operational Discharge Criteria

Parameter Freshwater Discharge

Criteria

Marine Discharge

Criteria

Organics

Polycyclic Aromatic Hydrocarbons (PAHs)

EPA (Group I Carcinogenic)

Benzo(a)antharacene - -

Benzo(a)pyrene - -

Benzo(b)fluoranthene - -

Benzo(k)fluoranthene - -

Chrysene - -

Dibenzo(a,h)anthracene - -

Indeno(1,2,3-cd)pyrene - -

SUM 10 10

EPA (Group II Probable Carcinogenic)

Acenaphtene - -

Acenapthylene - -

Anthracene - -

Benzo(g,h,i)perylene - -

Fluoranthene - -

Fluorene - -

Naphthalene 20 20

Phenanthrene - -

Pyrene - -

SUM 100 100

Total Petroleum Hydrocarbons

EPA 5 mg/L 5 mg/L

BTEX

Benzene 5 5

Ethylbenzene - -

Toluene - -

Total BTEX 100 100

Inorganics

Aluminium 100 NC

Arsenic 5 12.5

Cadmium 0.017 0.12

Total Chromium 8.9 56/1.5

Copper 2-4 3.7

Iron 1000 1000

Lead 7 8.5

Mercury 0.026 0.016

Molybdenum 73 NC

Nickel 150 8.2

Selenium 1 71

Silver 0.1 2.2

Zinc 30 85.6

Cyanide 5 NC

TSS

30 mg/L 30 mg/L




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97918-GEN-EMP-N-001-R2 14 June 2010

Parameter Freshwater Discharge

Criteria

Marine Discharge

Criteria

pH (pH units) 6.5-9.0 7-8.7

Misc. Organics

PCBs - -

Phenols 4 NC

All parameters are ug/L unless otherwise indicated

NC = Not Calculated

- = No criteria established

Construction water can also be collected and treated using a licensed water treatment facility, in which

case the discharge criteria would be as per the facilities permit and approval.

5.1.3.1. Sources of Water

Source construction waters for treatment and/or management include:

TP6A & B: Prior to the solidification/stabilization (S/S) treatment of the sediments in the Tar Ponds,

dewatering will be required. Surface water in areas of the Tar Ponds that have not yet been treated

will be decanted from the surface to either the ditches and in turn the pump around system or other

Tar Pond areas not yet remediated. Sediment laden/pore water in the treatment zone will be collected

and treated. The water removed through pore and maintenance pumping during the

solidification/sedimentation process will be treated by a WTP. Table 2 details water management for

TP6A and TP6B activities.

Table 2: Water Sources and Management

Source* Treatment Zone Active Zone Non-Active Zone

Precipitation Collect & Treat Decant Decant (as required)

Upwelling Collect & Treat Decant Decant (as required)

Side Infiltration Collect & Treat Decant Decant (as required)

Standing Water at time of isolation N/A – decanted when

classified as Active Zone Decant No Action

Pore Water Use in mix / Collect & Treat

Excess No Action No Action

Equipment Decontamination Collect & Treat Collect &

Treat Collect & Treat

Dust Control Water Use in mix / Collect & Treat

Excess No Dust Control

Decant (pond area)/ Direct to sediment

capture areas (on land)




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97918-GEN-EMP-N-001-R2 14 June 2010

Perimeter ditch outfall (storm drain) collection Collect & Treat Decant Decant

Pump capability bypass from brooks Collect & Treat Decant Decant

Overland Flow Collect & Treat Decant Decant

Notes:

Collect and treat Water is collected and treated to meet established operational and compliance discharge criteria prior to release.

Decant

Water is conveyed to Non-active zones, energy dissipation structure or areas of perimeter ditch with erosion control measures. Water which is to discharge to Non-active zones following treatment of sediment there, energy dissipation structure or areas of perimeter ditch will be done so in a manner to prevent visual evidence of re-suspension of fines.

Use in mix / collect and treat excess Water is included in the matrix of the S/S mixture; excess water is collected and treated.

No Action No action is taken to collect / treat / or otherwise deal with water.

No Equipment No equipment is present in the area

No Dust Control No dust control is undertaken in the area

TP2: Waste water will be generated from material washing, vehicle decontamination and site

personnel washing. The waste water stream will discharge into a collection chamber within the TP2

Processing Area, after passing through a sediment trap and an oil water separator. The water will be

collected and treated by a licensed WTP. Waste water generated from the washroom facility will be

collected and discharged to the Cape Breton Regional Municipality sewer system.

TP7: Water which has contacted the S/S sediments, despite surface water diversion measures, prior to

capping will be collected for treatment in a WTP.

CO1, CO5, CO7 and CO8: Contaminated water will be collected from the construction site and

equipment decontamination area and will be treated at a WTP. Groundwater infiltration into the

construction work area may be pumped to dissipation ponds located on pre-approved locations on the

Coke Ovens site. Dissipation ponds would be excavated on the Coke Ovens site to hold water until it

either dissipated into the ground or was pumped and treated through a WTP.

Numerous project elements involve the pumping of waste water to treatment facilities, both temporary

and permanent. These elements include:

5.1.3.2. Permanent Water Treatment (CO8)

The permanent water treatment facility will be located on the Coke Ovens Site and will treat

contaminated water collected by the Coke Ovens groundwater collection system as part of element CO7.

Contaminated groundwater will be collected and pumped to the water treatment plant. Initial batch testing




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97918-GEN-EMP-N-001-R2 14 June 2010

will be completed to ensure compliance, followed by continuous discharge with compliance testing. The

permanent WTP and associated delivery systems will be designed and maintained to operate well past a

twenty-five (25) year operating life. Flow rates will be determined by the Consultant, reviewed with NSE

and the Agency and approved by NSE. Preliminary and final estimates of flow velocities shall be

included in the Detailed EPPs.

5.1.3.3. Treatment Processes

It is the treatment process in the permanent WTP (CO8) will consist of an oil water separator to remove

free product, sand/clay filters and/or clarifiers to remove suspended solids, ion exchange to remove metals

and granular activated carbon (GAC) filters to remove organics such as PAHs, BTEX and other

hydrocarbons. If these treatment processes are implemented, exhausted ion exchange resin and GAC

media will be returned to the supplier for regeneration and the exhausted sand filters will be landfilled.

Clarifier sludge will be landfilled. However, treatment and disposal methods will ultimately be

determined by the type of contamination and effluent discharge criteria as approved by NSE. Once

treated, groundwater will be discharged to Coke Oven Brook. Treatment and disposal methods shall be

finalized in the element design documents and reflected in the Detailed EPPs.

5.1.4. Compliance under the Federal Fisheries Act

Appropriate treatment and subsequent compliance testing of waste water the permanent WTP will ensure

that liquid effluent discharges to fresh water are compliant with the pollution prevention requirements of

the Fisheries Act. Chemistry of the treated waste water will be monitored according to NSE‟s Part 5

conditions of approval to verify that treatment continues to meet the standards set.

During barrier and pumping station inlets and outlets construction within the Wash Brook and Coke Oven

Brook and within and along the shoreline of the Tar Ponds, there is the potential to directly injure or kill

fish with machinery (i.e., diversion pumps), or to indirectly injure them through smothering with excess

sediment laden water.

To minimize potential fisheries impacts and water quality impacts during construction of the flow

diversion, all site-specific requirements identified in the construction plans, conditions of the DFO work

permits and procedures in the ESCP procedures shall be followed. In addition, excess material, fuels,

controlled materials and construction debris, shall be stored at the temporary materials storage pad area or

in a designated area on gradients that will not allow a spill to easily enter a watercourse.




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Fish must also not be harmed by the pumping stations themselves. To protect fish from both the suction

force and actually entering the pumps, a hydraulic dissipater and series of mechanical screens will be

installed around the pump intake. These will serve to allow the fish to overcome the flow generated by the

pumps and provide a final barrier to prevent their access to the equipment. Fish barriers also prevent

debris larger than 9mm from entering the pump area.

The scale of impact of pumping fresh water into Sydney Harbour will depend on the volume of water

discharged. Mitigation will include discharging as close to the current opening of Battery Point Barrier as

possible into the first of the three energy dissipation outlet structures to effectively mix the water with

seawater. In addition, energy dispersion and silt control will be designed at the discharge location to

minimize erosion and scour.

All fish management work will be guided by fisheries specialists retained by the Contractor(s) to remove

as many fish from the construction areas as possible. The Contractor(s), under the guidance of a fisheries

specialist, shall follow the subsequent procedure to remove fish from the construction as follows:

1. Place a turbidity curtain along the shoreline;

2. Drag one end of a turbidity curtain loosely along the bottom of the pond to create an area devoid of

fish along one shoreline to the construction position (see Figure 3);

3. By starting at the other end and ensuring a relatively good seal, the Contractor(s) shall gently drag the

opposite side of turbidity curtain along the shoreline to the respective construction location;

4. Once the curtain has been fully deployed, the area between the shore and curtain should be void of

fish; and

5. Fish collected in the turbidity curtain shall be relocated away from any other activity taking place at

the site, either further upstream if relocated within the brooks, or downstream of the barrier or to the

completed channel if within the Tar Ponds.




40

97918-GEN-EMP-N-001-R2 14 June 2010

Figure 3 – Fish Removal

In case all fish are not captured during the removal phase, when water diversion is taking place, the

Contractor(s) will monitor for fish and remove accordingly. This will require:

a) Screens of adequate mesh size (9mm) installed on or around pumps to prevent the removal of fish by

pumps;

b) A net with a long pole or equivalent equipment to be used to capture and release any remaining fish;

and

c) Routine monitoring of pump inlet areas within the Wash Brook and Coke Oven Brook and upstream

transfer of stranded or crowded fish.

5.1.5. Coke Oven Brook Groundwater Quantity and Discharge Chemistry

A Groundwater Investigation Program (GIP), which included groundwater as surface water, was

completed to verify the discharge quantity and chemistry of Coke Oven Brook. The Program involved

sampling seven (7) brook and underdrain locations under three (3) flow conditions (low, moderate and

high). Full results of the GIP are provided under separate cover in a document entitled Groundwater

Investigation Program dated October 4, 2007, and a summary is provided in element CO7‟s Design

Report Appendix entitled Rational for Groundwater Discharge Chemistry. Based on the findings of the

report, the following conclusions were provided:




41

97918-GEN-EMP-N-001-R2 14 June 2010

The North and South Underdrains will continue to discharge into Coke Oven Brook (ie., the drainage

swale to be constructed in the current brook channel). This flow will not be collected and treated.

The groundwater collection system will be designed to pump up to 150L/min to the Water Treatment

Plant (CO8). This flow is based on the estimate of long term moderate groundwater discharge to the

Coke Oven Brook Groundwater Collection Line and the Domtar Interceptor Trench. Flow in excess

of 150L/min will be allowed to overflow into the Coke Oven Brook drainage swale, on the basis that

the overflow will be substantially diluted by elevated surface water flow at these times.

The on-site section of Frederick Street Brook will be backfilled as part of CO7 grading activities and

the upstream reach will be re-directed into the North Channel.

The Cagney Brook Underdrain will be exposed and backfilled, as part of CO7 grading activities.

Flow from the North and South Channels will continue to discharge into Coke Oven Brook (ie., the

drainage swale to be constructed along the current brook channel). This flow will not be collected

and treated.

The chemistry of upstream surface water coming onto the CO7 contract boundary via Coke Oven

Brook will be acceptable for inclusion in the Coke Oven Brook drainage swale. This flow will not be

collected and treated.

Runoff from precipitation events, over the Coke Ovens Site and CO6 cap will be flow into Coke

Ovens Brook and will not have been exposed to contaminated materials.

5.2. Transportation Management Plan

The preparatory work, construction activities and post-construction work during remediation of the Tar

Ponds and Coke Ovens Sites will require the use of personal transportation vehicles and the intensive use

of heavy construction vehicles, both on and off-site. The use of transportation machineries will result in

extra traffic to local roadways, noise, diesel and other exhaust emissions and airborne particulate matter

(PM) in the form of dust. As such, the purpose of the Transportation Management Plans (TMP) are to

establish controls that will mitigate these impacts Site-wide and to the surrounding area prior to the

commencement of construction activities. Each element will develop a TMP in order to minimize

transportation impacts, consideration is to be given to providing a comprehensive transportation

management strategy, updated as the project evolves. In addition, the TMP assigns specific responsibility




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97918-GEN-EMP-N-001-R2 14 June 2010

to ensure that these controls are implemented successfully and that all Health and Safety Protocols under

HASP are followed.

The Transportation Management Plan includes reviews and recommendations on:

Infrastructure impacts;

Transportation routes;

Timing/Scheduling;

Dust Management/Air Pollution/Noise;

Safety issues and containment measures; and

Monitoring and reporting.

The TMP includes easily accessible mechanisms and proposed mitigation measures to offset any adverse

impacts to the surrounding road network.

During the Project construction phase, noise and/or air quality impacts (e.g., dust, odour) associated with

construction vehicle movement may temporarily pose a nuisance to the nearby residents and

transportation infrastructure. Existing commercial enterprises, within the Sydney downtown core in

particular, could experience similar temporary nuisances.

The primary concerns regarding the potential adverse effects of the Project on transportation

infrastructure include:

a) Traffic Impact on Adjacent Road Networks: Worker and equipment movement associated with the

Sydney Tar Ponds and Coke Ovens Sites will increase traffic volumes on local road networks and

possibly residential or commercial streets.

b) Safety Impact: Worker and equipment movement associated with the Sydney Tar Ponds and Coke

Ovens Sites may cause traffic congestion or increase collision potential at Study Area intersections.

c) Air Pollution Impact: Preparatory work and intensive use of heavy vehicles during construction will

result in diesel exhaust and airborne PM. Based on prevailing wind directions onsite, proximity to

downwind neighbourhoods and condition of onsite transportation routes (dryness); the Agency

through the use of Provincial government personnel and equipment will ensure dust control measures




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97918-GEN-EMP-N-001-R2 14 June 2010

(e.g. water truck, magnesium chloride) are used as required, which may include their use several

times a day.

d) Noise Impact: During the construction phase, the use of heavy construction vehicles could increase

ambient noise levels attributed to traffic on local roads. As such, the Contractor(s) shall mitigate

noise impacts by implementing noise control measures, as described in Section 5.2.6.

5.2.1. Transportation Infrastructure

The Sydney area is undergoing a transition from industrial land use, dominated by heavy industries (coal

and steel), to commercial land use, dominated by tertiary industries (e.g., services). As a part of this

transition, a 325-acre corridor between the Harbour Side Industrial Park (formerly known as the SYSCO

Business Industrial Park) and Emera Piers and Highway 125 has recently been converted to a

transportation corridor by the CBRM, in anticipation of the remediation of the Coke Ovens Site (AMEC,

2005a). A highway linking the Harbour Side Industrial Park to Highway 125 was also constructed to

facilitate the transformation of the former SYSCO Site into a business/industrial park.

Transportation infrastructure includes existing streets, roads and railroads in the Study Area that may be

used or impacted by the Project.

Access to the east, west and south of the Site can be provided via:

Lingan Road: Access to/from the east & north;

Trunk 28 (Victoria Road): Access to/from the north;

Grand Lake Road: Access to/from the east; and

Highway 125: Access to/from the west & south.

The Project will affect transportation infrastructure during the construction, operation and

decommissioning phases of the Project, which are scheduled to occur between 2006 and 2014. The

impact of the ongoing operation of the Tar Ponds and Coke Ovens Sites beyond 2014 will be minimal and

requires no further assessments.

The streets and roads that will be used by the Project are under the authority of either the CBRM or the

NSTIR. Truck weights and dimensions permitted on streets and roads are regulated by Weights and

Dimensions of Vehicles Regulations of the Nova Scotia Motor Vehicle Act.




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97918-GEN-EMP-N-001-R2 14 June 2010

A review of the physical description of the routes, road design, study area traffic volume data and

collision rate statistics, as well as project information, provided by the design engineers, was completed as

part of this task. As engineering details are finalized, a comprehensive transportation management

strategy, including a Traffic Management Plan, will need to be further enhanced and updated as the

Project moves forward.

5.2.2. Street Access to the Sydney Tar Ponds and Coke Ovens Sites

Access to the Sydney Tar Ponds and Coke Ovens Sites is possible via numerous locations. These

locations are shown in Figure 4 (adapted from EIS (AMEC, 2005a) and include:

a) Terminal Road provides Site access from Prince Street just east of the railroad crossing. Left turns are

prohibited for vehicles exiting from Terminal Road to Prince Street.

b) Inglis Street provides a direct connection from Prince Street to the Agency office; however, there is a

slight distance restriction on Prince Street caused by a crest just east of the intersection.

c) Victoria Road at the Cape Breton Street ramps: Ramps and a Victoria Road underpass at Cape Breton

Street allow access; however, ramp widths and available turning radii restrict use by heavy

equipment.

d) Ferry Street currently links George Street to the Sydney Port Access Road (SPAR) via Inglis Street

(east and west shoreline areas) and facilitates sewage rerouting. The dam, located at the end of

Sydney‟s Ferry Street, separates South and North Pond. However, the bridge along Ferry Street will

be closed during the construction phases and the traffic will be rerouted through Prince Street via

George Street.

e) George Street is a collector Street under the jurisdiction of the CBRM providing access from the

South Shoreline Area neighbourhoods/businesses to the west and south via Prince Street and

Highway 125. During the construction phase, George Street will also provide access to/from the north

and east, as a result of the temporary closure of Ferry Street bridge crossing.

f) Sydney Port Access Road:

Vehicles from the Whitney Pier area of Sydney can access the Site at the Lingan Road/SPAR

intersection. This intersection is controlled by traffic signals and rail crossing protection lights and

arms are provided for railroad crossings on Lingan Road and SPAR.




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97918-GEN-EMP-N-001-R2 14 June 2010

For the eastern and western areas of CBRM, the Site can be accessed via connections onto the SPAR

from the Highway 125/Grand Lake Road intersection.

g) The Coke Oven Site is accessed from Teak Street at the east end of the Site. Access from Teak Street

is via Welton Street (Trunk #4).

Figure 4: Access Locations

5.2.3. Study Area Traffic Volumes and Vehicle Collisions

In order to determine the extent of possible transportation impacts on the surrounding street system, an

understanding of the current conditions is fundamental. The NSTIR has periodically obtained traffic

counts on the Study Area highway sections using automatic traffic counters. Historical count data

indicates that traffic volume growth rates are between 1.5% and 2.0% per year. Estimated 2005 and

projected 2015 annual average daily traffic (AADT) volumes for Study Area roads are reported in

Table 3.

Access to/from

Whitney Pier Traffic Signals

& Rail Crossing

Access to/from

East/West/South

HIGHWAY 125




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97918-GEN-EMP-N-001-R2 14 June 2010

Table 3: Annual Average Daily Traffic Volumes for Study Area Roads

Road Section

Estimated and Projected AADT Volume

(vehicles per day)

2005 2015 (1)

Lingan Road - 0.5 km east of former Sydney City Limit 2,340 2,600

Lingan Road - 0.5 km west of Trunk 28 2,070 2,300

Lingan Road - 0.5 km east of Trunk 28 2,160 2,400

Trunk 28 - just east of Lingan Road 7,560 8,300

Trunk 4 (Grand Lake Road) - 3 km east of Highway 125 21,600 23,000 (2)

Trunk 4 (Grand Lake Road) - just west of Highway 125 26,700 29,000 (2)

SPAR - just north of Trunk 4 6,600 12,000 (3)

SPAR - north of BURNAC retail site 3,800 6,500 (3)

Highway 125 -just west of Trunk 4/SPAR intersection 18,000 20,000

Highway 125 - between George St. and Alexandra St. 24,000 26,000

Highway 125 - between Frenchvale Rd. And Sydney River 13,800 15,000

Source: (AMEC, 2005a))

NOTES: (1) An annual growth rate of 2.0% has been used, except as indicated in Notes 2 and 3.

(2) An annual growth rate of 1.5% was used for Trunk 4 volumes.

(3) Volumes have been estimated based on proposed retail and site access development on BURNAC retail sites

Recorded traffic volumes along the study area road network are also depicted in Figure 5 (adapted from

EIS (AMEC, 2005a)). In essence, historical traffic volumes provide the basis for comparison to truck and

passenger vehicle estimates associated with construction activities. Similarly, the impact of any increased

use of transportation infrastructure due to construction activities can only be estimated if compared to

existing conditions.




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97918-GEN-EMP-N-001-R2 14 June 2010

Figure 5: Major Transportation Access Facilities & Traffic Volumes

SEASONAL VARIATION IN STUDY AREA TRAFFIC VOLUMES

Through the use of permanent counters and vehicle classification stations throughout the Study Area, the

NSTIR is able to derive seasonal traffic volume variations, as indicated in Table 4. Daily volumes tend to

fluctuate from one (1) time of year to another, with volumes typically higher in the summer and lower in

the winter. In addition to the estimated average daily traffic volumes discussed at the beginning of Section

5.2.3, major transportation access facilities are also shown in Figure 5.

2,340/2,600

6,600/7,300

21,600/23,000

3,800/6,500

28,700/29,000 24,000/26,000 (George/Alexandra)

6,600/12,000

18,000/20,000




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97918-GEN-EMP-N-001-R2 14 June 2010

Table 4: Seasonal Variation in Average Daily Volumes

Season Average Daily Volume as a Percent of AADT

Winter (December, January, February, March) 0.82

Spring/Fall (April, May, October, November) 0.96

Summer (June, July, August, September) 1.11

Source: (AMEC, 2005a)

VEHICLE COLLISIONS

Due to a number of uncontrollable variables, such as personal negligence, sudden equipment malfunction

and poor weather conditions, there is an inherent probability that vehicle accidents may occur along

public transportation routes. Collisions on local roads may lead to injury of both workers and members of

the public. As such, protocols shall be put in place to minimize the likelihood of collisions resulting from

mitigable factors, such as routine equipment maintenance and driver training sessions for on-site workers

traveling off-site.

The relative safety of sections of highway within the Study Area has been discerned by comparing

average collision rates within the Study Area to the average collisions rates for all similar highways in the

Province, as shown in Table 5. Collision rates are generally expressed as the number of collisions per

hundred million vehicle kilometres.




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97918-GEN-EMP-N-001-R2 14 June 2010

Table 5: Five Year (1999 to 2003) Collision Data for Study Area Roads

Road Section

Number of Collisions by Severity Collision Rates by Severity

PDO1 Injury Fatal Total PDO1 Injury Fatal Total

Trunk 4 (Grand Lake Road) Sections

Trunk 4 - Old Sydney Limit to Hwy 125 24 17 0 41 47.9 33.9 0.0 81.8

Trunk 4 - Hwy 125 to Reserve Mines 178 189 2 369 45.8 48.6 0.5 94.9

Trunk 4 - Combined Rates 46.0 46.9 0.5 93.4

Trunk 28 Sections

Trunk 28 - Dominion to New Waterford 22 18 0 40 19.2 15.7 0.0 34.9

Highway 125 Sections

Highway 125 - Frenchvale to Sydport 9 10 1 20 8.6 9.6 1.0 19.1

Highway 125 - Sydport to Sydney River 50 40 3 93 62.6 50.1 3.8 116.4

Highway 125 - Sydney River to Alexandra St. 21 9 1 31 34.7 14.9 1.7 51.3

Highway 125 - Alexandra St. to George St. 29 17 3 49 27.2 15.9 2.8 46.0

Highway 125 - George St. to Grand Lake Rd. 17 21 1 39 14.8 18.3 0.9 34.0

Highway 125 - Combined Rates 27.0 20.8 1.9 49.8

Provincial 1999 to 2003 Average Collision Rates for Road Classes in the Study Area

100 Series - Two Lanes - Full Access Control (most of Highway 125) 21.9 11.0 0.9 33.8

Trunk Highway - Four Lanes - No Access Control - Not Divided (Trunk 4) 129.7 69.2 0.3 199.3

Trunk Road - Rural (Trunk 28) 46.9 28.4 0.9 76.2

Local or Collector Route - Two Lanes (most of Lingan Road) 59.5 32.8 0.5 92.8

Source: (AMEC, 2005a)

(1) PDO = Property Damage Only

While collision rates for Trunk 4 and Trunk 28 are generally lower than provincial average rates for

similar road classes, collision rates on Highway 125 are higher than the provincial average rates. Property

Damage Only (PDO) collision rates on Highway 125 are about 25% higher than average; however, the

injury and fatal collision rates are about twice the provincial average rates.




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97918-GEN-EMP-N-001-R2 14 June 2010

COLLISIONS RESULTING IN SPILLS

Any spills resulting from off-site collisions are anticipated to be localized and minor, due to the nature of

the materials being transported (mostly dry construction materials). Appropriate traffic management

procedures surrounding a spill site shall be implemented at the discretion of local authorities and shall be

abided by the Contractor(s) and personnel involved. The Agency is to be notified immediately and other

regulatory authorities shall be notified by the Agency, as necessary. If a collision involving the spill of

sediments or other controlled substances should occur, the area shall be contained and barricaded until

appropriate decontamination procedures have been undertaken, as developed by the Agency in

association with the Consultant. The remedial activities will be supervised by the Agency and/or the

Consultant. Regulatory authorities could require testing of a spill area following the event, which shall be

supervised by the Agency or their Consultant.

5.2.4. Traffic Generators

The construction activities being undertaken on Sydney Tar Ponds and Coke Ovens Sites, generate higher

levels of traffic than normally observed on local routes. Increased traffic volume is the result of heavy

vehicles associated with construction (large trucks and buses) and personal vehicles (cars, vans, SUVs

and light trucks), which could potentially impact local transportation infrastructure, noise, emissions and

traffic volumes. It has been determined that the primary impact from construction activities with respect

to transportation will be increased traffic volumes from trucks and passenger vehicles on existing roads

(AMEC, 2005a). Historically, the average vehicle classification counts for Grand Lake Road traffic at

eight intersections in the Study Area included 97% passenger type vehicles and 3% heavy vehicles

(AMEC, 2005a). Increased traffic volumes, especially when attributed to heavy construction vehicles,

could impact the length of time required for local commutes and possibly increase the number of

collisions observed.

Table 6 provides a summary of the estimated vehicle volumes, as discussed in the EIS (AMEC, 2005a), in

addition to recent details on both truck and passenger volumes.




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97918-GEN-EMP-N-001-R2 14 June 2010

Table 6: Estimated Project Vehicle Volumes

Project Component Activity

Estimated Vehicle

Affected Areas Notes Daily

Volume

Peak

(# per hour)

All project

components Site Worker Access 180 70

Distributed to access streets

and roads

100 workers day time; 25

night time; 1.4 persons per

vehicle

All project

components

Vertical Cutoff Walls

Solidification/

Stabilization

Concrete Trucks 10 2 SPAR and regional roads

from concrete batch plant

5 loaded and 5 empty trucks

per day; assume 20% during

peak hr; 5 days per week

CO6: Coke Ovens

Surface Cap &

TP7: Tar Pond surface

Cap

Capping Material

Trucks 150 15

SPAR and regional roads

from source of capping

material

75 loaded and 75 empty

trucks per day; assume 10%

during peak hr; 350 to 400

days

TP1, TP6, CO1, CO7 Excavated Sediment

Shipping 27 (1) 4

Construction access roads/

shore roads east and west of

the Tar Ponds

TP6: Solidification/

Stabilization Deliveries 5 (1) 1

Distributed to access streets

and roads

TP2: Material

Processing/Constructi

on/Operation

Deliveries 10 1 Distributed to access streets

and roads

(1) assuming 100,000 m

3 demand per year

HEAVY CONSTRUCTION VEHICLES

All major construction and cap materials, including cement, backfill and sediments, will be transported to

and from the Site by highway-licensed tandem, triaxle and tractor trailer trucks, which, especially during

peak periods, can greatly impact transportation infrastructure. For example, the EIS (AMEC, 2005a),

Section 7.10.5, indicates that for the purposes of capping the Sydney Tar Ponds and Coke Ovens Sites,

150 daily truck trips (75 loaded and 75 empty) would be observed daily. An additional ten (10) concrete

trucks per day are also anticipated. While construction vehicles are scheduled to use the SPAR to access

the Project site, the source of capping materials and cement required for solidification activities has not

yet been confirmed; thus, an assessment of potential impacts to other roads cannot be completed at this

time.




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97918-GEN-EMP-N-001-R2 14 June 2010

An additional ten (10) concrete trucks per day are also anticipated. The movement of these trucks and

other construction related vehicles during peak traffic flow periods, is a determining factor in potential

adverse effects on transportation infrastructure. While these vehicles are slated to use the SPAR for

accessing the Project site, the source of either the capping materials or the cement required for

solidification activities has not yet been decided, thus making an assessment of impacts on other roads

difficult.

PASSENGER VEHICLES

Based on the projected employment of one hundred (100) daytime workers and twenty-five (25) night

time workers, approximately 180 site worker vehicle trips per day at the Tar Ponds and Coke Ovens Sites

(ninety (90) in each direction) can be anticipated. According to the EIS (AMEC, 2005a), it is anticipated

that passenger vehicle trips would not have any significant effect on existing traffic, as any potential

effects on transportation could be kept to non-significant levels through traffic management.

5.2.5. Impacts on Transportation Infrastructure

The number of construction related vehicles moving during morning and afternoon peak hours on streets

and roads that access the Site, as well as on regional streets and roads, is the most important determining

factor when considering the potential for adverse effects on transportation infrastructure. Construction

activities will include about seventy (70) passenger vehicles and twenty-one (21) truck movements on

access streets and roads to the Tar Ponds and Coke Ovens Sites during the peak hours (Table 5).

The seventy (70) worker vehicles accessing the Tar Ponds and Coke Ovens Sites will disperse to various

site access streets. The twenty-one (21) concrete and capping material trucks will likely use SPAR.

5.2.6. Environmental Impacts

DUST AND AIR POLLUTION

Potential sources of air emissions associated with the Project are identified in Section 7.4.1. However, in

order to contain air pollution effect associated with the transportation aspect of the project, the following

mitigation measures shall be considered:




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97918-GEN-EMP-N-001-R2 14 June 2010

Minimizing the distance for transport ;

Applying dust suppressants to the loaded material;

Implementing speed restrictions;

Using completely enclosed or tarped vehicles;

Increasing vehicle maintenance regimes to prevent leaks;

Installing wash stations at site exits to capture particulate before vehicle departure;

Limiting or suspending work during periods of high winds;

Controlling the speed and distance during loading/unloading;

Paved roads: flushing or vacuum sweeping will be conducted, as required; and

Unpaved roads: Usage of a dust suppressant (e.g., water and magnesium cloride) when required

(depending on weather conditions), as applied by Provincial government personnel and equipment.

NOISE POLLUTION

To mitigate the effects of noise associated with large construction vehicles, the following key measures

shall be employed by the Contractor(s) when organizing vehicles to be sent off-site:

Routing shall be reviewed to ensure noise impacts are diverted from residential or small commercial

areas to approved provincial highways, designated industrial areas or construction roads, as

appropriate.

Scheduling shall be such that increased average ambient noise levels resulting from heavy

construction vehicles is limited to daytime hours.

5.2.7. Contractor Traffic Responsibilities

All Contractors must develop and implement their own Traffic Management Plan which provides policies

and procedures that aims to minimize health and safety risks to the general public that are posed by

increased road traffic associated with their element, as well as the safety of their own employees. The

traffic management plan must be accepted by the Agency.

Components of the plan should include, but not be limited to; implementation and enforcement of safety

standards, that may include:




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97918-GEN-EMP-N-001-R2 14 June 2010

Collaboration with Agency to promote public awareness of Project activities, such as signage

regarding large trucks and public information regarding traffic patterns and safety issues.

Enforcement of all local and national traffic laws for large vehicles (if any) and/or other safety

standards.

Requiring a valid driver‟s license for all vehicle operators.

Transport during daylight and low-traffic periods as is reasonable and practical.

Transport of dangerous materials during non-peak hours.

Police cars or other warning systems for public when appropriate.

Liaison with Agency to ascertain traffic patterns and sizes of transport vehicles.

Transportation of workers where necessary and/or practicable to minimize undue excessive local

traffic.

Management of road access and temporary road closure issues, including advance notification for

communities and provision of alternative routes.

Scheduling transportation activities that involve increased noise levels (such as unloading of supplies)

that are sensitive to local community quiet times.

Providing additional safety and defensive driving training for vehicle operators.

5.2.8. Conclusions and Recommendations

Based on an evaluation of the construction and operational activities on-site, the following conclusions

and recommendations are provided with respect to Project traffic management:

a) The number of construction related vehicles moving during morning and afternoon peak hrs on streets

and roads that access the Site, as well as on regional streets and roads, is the most important

determining factor when considering the potential for adverse effects on transportation infrastructure.

b) The operation phase is not expected to have a significant adverse impact on transportation

infrastructure.

c) The decommissioning work is not expected to have any significant residual adverse effects on

transportation infrastructure.




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97918-GEN-EMP-N-001-R2 14 June 2010

d) There is no follow-up or monitoring recommended with respect to Project effects on transportation

infrastructure.

e) In order to offset/minimize the transportation impacts of the Project, the Agency shall monitor the

implementation of:

Traffic Route Restrictions: To ensure that truck traffic is limited to the provincially maintained

highways and that the Site is being accessed via the SPAR, if possible.

Contractor Traffic Responsibilities: To ensure that Contractors abide by all traffic and

transportation policies and management plans designed for the Project.

The Motor Vehicle Act (GNS, 1989d): To ensure that truck weights and dimensions permitted on

streets and roads are being implemented, as regulated by the Weights and Dimensions of Vehicle

Regulations under the Motor Vehicle Act.

g) All Tech Environmental Consultants (All Tech), the Air Quality Monitoring Consultant, shall monitor

air quality to ensure that appropriate air pollution measures (as discussed in Section 5.2.6) are being

implemented by the Contractor(s). Mitigation measures used to control dust or other air pollution

concerns shall be recorded by the EM as part of the daily Environmental Inspection Log

(Appendix F).

5.3. Land Use and Institutional Land Controls

Given the nature of the remediation works proposed with respect to both the Tar Ponds and Coke Oven

Sites, there is a necessity to ensure that the structural integrity of the implemented works are not

jeopardized by inappropriate future use on any of the Site(s). There exists a recognized need to put in

place the appropriate institutional and regulatory controls that will protect the Sites in perpetuity. This

will involve consideration not only of the future uses proposed for various parts of the remediated lands,

but ultimate land ownership and the determination both of the governance issues involved and the

alternative regulatory mechanisms, e.g., zoning or development agreements, that may be used pursuant to

the Municipal Act and/or common law mechanisms in property law such as covenants. The identification

of appropriate uses for these areas will likely be determined over the balance of 2007 as various studies

are completed and as detailed engineering proceeds. The determination of appropriate land use controls

will be determined in a comparable timeframe.




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97918-GEN-EMP-N-001-R2 14 June 2010

5.3.1. Land Use Designation

In the CBRM planning strategy the Coke Ovens Site has a special land-use classification, as the Coke

Ovens Site Reserve Zone. To the east, the land is zoned for purposes of utility

generation/treatment/disposal and is currently characterized by industrial developments including the

municipal waste incinerator; the former municipal landfill site, an abandoned railway line and the balance

is vacant land. To the west of the Coke Ovens Site, the vacant SYSCO Industrial Park Zone connects the

Coke Ovens Site to the Tar Ponds Site. To the north of the Coke Ovens Site, across the SPAR, the land is

zoned for residential (Whitney Pier) and rural purposes. To the south of the Coke Ovens Site, a residential

area and a business corridor zone have developed. There are residences within 1km of the Site.

5.3.2. Future Land Use in the North End of Sydney

The North End of Sydney may change land use by proposition of the CBRM to redevelop the industrial

land along the Tar Ponds. It is expected that the remediation of the Tar Ponds will dominate the area for a

few years, but residents hope that in the future this part of the North End of Sydney will be primarily a

green belt available for public use and enjoyment combined with new housing developments (Cape

Breton Regional Municipality Council [CBRMC], 2005).

Sydney and area is completing a transition from industrial land use, dominated by heavy industries (coal

and steel), to commercial uses dominated by tertiary industries (e.g., services). Within the CBRM, a

number of sites exist that have potential for industrial or other uses. CBRM have proposed future land use

for these sites as shown in Table 7. A description of each proposed site is provided in the CBRM Draft

Secondary Planning Strategy of the North End of Sydney (CBRMC, 2005).

Table 7: Selected Business Industrial Locations, Corridors and Nodes in the CBRM Former and

Proposed Land Uses

Location Size / Value Existing or Former Use Proposed Use

Victoria Junction Coal

Treatment Plant 750 acres Coal treatment complex Regional Market

Sydney Airport (Reserve

Mines) 1,600 acres Airport Businesses

Point Aconi, Boularderie

Island 1,870 acres

Prince Mine & Point Aconi

power generating facility Industry with outside markets

Lingan Industrial

Corridor, New Waterford 1,200 acres Industrial use

Industrial business/regional utility/regional tertiary service

projects with minimal truck traffic




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97918-GEN-EMP-N-001-R2 14 June 2010

Location Size / Value Existing or Former Use Proposed Use

Coxheath/Westmount $7 million

Keltic Drive Business corridor

linking Sydney with Northside

housing regional service,

wholesale and warehousing

distributors

_

Eastern side of Sydney

Gabarus Highway $1 million Business/Industrial _

Glace Bay 370 acres Former Atomic Energy of Canada

Limited site _

Gardiner Mines near

Warbutan Rd. 65 acres DEVCO lands _

Mitchell Ave. & Neville

St. (Dominion) 140 acres DEVCO lands Regional Market

Reserve Mines 40 acres DEVCO lands _

The North End of the Sydney peninsula‟s business/industrial corridor has experienced decay over the past

years because of its location near the SYSCO property. According to the CBRM Draft Secondary

Planning Strategy (CBRMC, 2005), this area could be revitalized subsequent to the dismantling of the

steel mill and the remediation of the associated lands. The remediation of the Tar Ponds, the gradual

revitalization of downtown Sydney‟s waterfront and the demolition of the dry-dock facility, will all

facilitate urban renewal. The efforts of the old Sydney Society involve establishing a complex of

museums in the neighbourhoods located in proximity to downtown Sydney.

Plans are underway to develop an overall trail policy within the CBRM. This would include a green space

system linking the waterfronts and downtowns of the major urban communities with their undeveloped

outlying areas via existing watercourses. According to the CBRM Draft Secondary Planning Strategy

(CBRMC, 2005), the Council will authorize the preparation of a report on a concept of urban open space

for unorganized recreational use.

5.4. Quality Assurance Quality Control Measures Program

The QA/QC Measures Program is designed to ensure that standard procedures are followed throughout

the life of the Project with respect the integrity of work, reporting, analytical testing and other parameters.

The QA/QC Measures Program consists of three independent documents, provided under separate cover,

the Project‟s Quality Management Plan (QMP), the QCP and the IQAP. The QMP addresses the QA/QC

measures that are relevant during the design phase of the Project, as well as sets out the preliminary

guidelines for QA/QC measures to be followed during the construction phase. The QCP and IQAP add




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more detail to the procedures that shall be put in place during the construction phase of the Project, to

ensure that work quality is ensured through all Project activities. The three plans are summarized as

follows:

5.4.1. Quality Management Plan

The QMP was created to address the assurance requirements outlined in the Agency‟s Request for

Proposal (RFP) document and in the Engineering Agreement for Design and Construction Oversight

Services for Remediation of the Tar Ponds and Coke Oven Sites Project. The goal of the QMP included

the proper identification of quality objectives, the specification of quality-related activities, outlining the

activities necessary to achieve desired levels of quality, prescribing independent verification activities and

devising a system to implement, document and verify needed corrective actions.

The QMP establishes management roles and responsibilities and a process of management review,

including the specification of peer reviewers for each Project element (See Appendix E). This system of

verifying work quality is shown in Table 8:

Table 8: Quality Management Metrics from the QMP

Parameter Measure Metric

AECOM Assignment Health and

Safety Plan

Submission of draft and final

versions. Acceptance by the Agency.

Project Implementation Plan

including Environmental

Management Planning



Project Master Health and Safety

Plan



Design Reports and EPPs 75%, 95% and 100% milestones. 100% Design Reports Delivered in the time

stipulated.

Bid documents in addition to

copies provided with Design

Reports

Available for tender. Delivered in the time stipulated.

Construction Contract Documents Available for Contract placement. Delivered in the time stipulated.

Plain Language Report Draft and Final versions. Delivered in the time stipulated.

Post Construction and Long Term

Monitoring Reports and Bid

Documents

Draft and Final versions. Delivered in the time stipulated.

Local Economic Benefits

Model outputs on design

development and construction

including direct, indirect and induced

LEB‟s.

Monthly/Regular progress reports.




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Parameter Measure Metric

Schedule WBS milestone versus

Actual.

LD dates on design reports.

Construction completion by April 16, 2014.

Design Oversight Conforming to approved QMP.

Completion/closure of QMP process:

● Audits completed.

● Non conformances addressed.

5.4.2. Quality Control Plan

The QCP outlines the scope of the overall Quality Control Program, defines the related roles and

responsibilities of the Agency, Design & Construction Oversight Consultant, the Contractor(s) and the

IQAC. The objective of the QCP describes the quality management process, the quality control measures

including monitoring, inspection and testing, and the corresponding documentation for review by the

Agency. The Agency has outlined that Construction Quality Control involves the monitoring of results to

ensure compliance with relevant quality standards and the objective of the QCP is to document the

approach and procedures used to ensure this conformance with set standards throughout the execution of

the Project. Ultimately, it is the Contractor‟s responsibility to ensure that all products/services conform to

the contractual requirements and to initiate appropriate corrective actions.

Any Contractors who will be constructing the Construction Work Packages for each project element or

providing specialized services are also responsible for the preparation and implementation of Contractor

Quality Control Plans (CQCP) to ensure the quality objectives and standards established for the Project

will be achieved and that the requirements of the Agency and regulatory agencies are satisfied. In addition

to procedures for QC activities during construction, including test methods, location, frequency and

similar requirements, the CQCP shall include:

Contractor‟s quality personnel and organization/structure of QC personnel;

Training qualifications for QC personnel;

Plan for interface with and list of subcontractors and suppliers;

Description of inspection plan and control procedures;

Description of material testing plan and control procedures;

Procedure for corrective action for non conformances;

Contractor‟s data/document management systems for all control documents; and




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List and description of all records/documents to be maintained.

The QCP also gives direction to the Contractor to develop a clear protocol for confronting non

conformances, which is defined as a project deliverable that does not meet the contract requirements,

established policies or Agency requirements. Documentation procedures are outlined in detail, including:

a) Inspection Data Sheets: identification of various inspection details including type of inspection,

procedures, recorded observations and tests, necessary calculations, personnel involved and results of

inspection activity.

b) Daily Field Reports: to be completed by all field and Contractor Quality Control (CQC) personnel,

such as the EM, when they are on-site within a field book or on standard field data sheets.

c) Progress Reports: summaries to be provided at time intervals established at the pre-construction

meeting that detail the quality characteristics being evaluated during inspections or tests, work

activities, test results and any construction situations, deficiencies, defects and problem resolutions

during the reporting period.

d) Final Documentation: includes a final CQC report for the project element containing all appropriate

documentation, daily reports, sample locations, test results, record drawings, photographic

documentation and any modifications to the design.

5.4.3. Independent Quality Assurance Plan

The IQAP outlines the scope of the independent quality assurance program, defines the responsibilities of

the IQAC and describes the minimum quality assurance monitoring, inspection and testing requirements

to implement the plan. The IQAP plays an important part in fulfilling the requirements and guidelines

established in the overall QMP.

It is the responsibility of the IQAC‟s role to undertake material testing and inspection services during

remediation of the Tar Ponds and Coke Ovens Sites. This includes a variety of tests and inspections to

independently verify element aspects outlined in the detailed design documents during construction. In

the event of non conformance, the IQAC is required to monitor the Contractor‟s Corrective Action Plan,

which ensures identified non conformances, defects and errors are documented and corrected.

The IQAP sets out written documentation tracking requirements during construction of the project

elements. In addition to specifying specific formatting requirements for this documentation, the IQAP

states that the monthly reporting document shall contain:




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A summary of work activities accomplished during the progress reporting period.

Identification of areas or items inspected and/or tested during the reporting period addressed by the

report.

A summary of the quality characteristics being evaluated, with appropriate criteria for each inspected

characteristic.

A summary of inspection and test results, failures and retests.

A summary of construction situations, deficiencies and/or defects occurring during progress reporting

period.

A summary of other problem resolutions and dispositions.

In addition to the monthly reports, it is the responsibility of the IQAC to issue a final report for all details

of the respective project element that fall within their scope of work. As such, the final report is to

contain: all appropriate documentation, daily reports, sample locations, test results, record drawings and

photographic documentation.

6.0 ENVIRONMENTAL PROTECTION PLANS

Project and Detailed EPPs have been developed by the Consultant as part of the overall remedial design

of the Project. EPPs have been designed to contain important field information for Contractors and site

personnel and have been based on a review of the specific environmental conditions of the Project area,

identification of the potential Project-environment interactions, identification of the potential changes to

the existing environment from the proposed construction activities and identification of the necessary

environmental protection measures to avoid/prevent, minimize, or reduce the potential adverse

environmental effects.

The Detailed EPPs are intended to be implemented by the Contractor(s) as per their contract with Agency

and in parallel with the Contractor(s)‟s more specific Contractor‟s Environmental Protection Plan

(CEPP), Assignment Health and Safety Plan (AHASP), Contingency Plans and Emergency Response

Plans. All of these provisions shall be designed to protect the integrity of the environment and the safety

of on-site workers and visitors.

Typical sections of a Detailed EPP include: description of the activity and associated concerns, required

permits and approvals, definition of responsible authority, reporting procedures, documentation




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requirements and mitigation measures. It is the Contractor‟s responsibility to review and follow the EPPs

and to develop environmental protection measures for any additional construction activities, as necessary.

In the event that an EPP conflicts with Contractor-designed protocols, which have been approved by the

Agency, the Contractor‟s protocols shall be implemented.

The Project EPP includes broad-scoped plans that cover all potential Project activities. Also contained

within the Project EPP are environmental effects monitoring (EEM) plans. Project-wide EPP protocols

have been developed for the following environmental elements:

Erosion and Sediment Control;

Dust, Volatile Organic Compounds (VOCs) and Odour Control;

Product Handling and Storage;

Equipment Maintenance and Fueling;

Building Transportation Infrastructure;

Site Generated Waste Disposal;

Well Decommissioning Environmental Protection Procedure;

Clearing, Grubbing and Refurbishing;

Excavation and Transportation of Sediment;

Archaeology and Heritage Resources;

Restricting Public Access;

Training and Education;

Spill Response;

Dewatering;

Water Management;

Monitoring and Reporting;

Communication and Reporting;

Noise; and

Contingency Plans.

The Detailed EPPs are designed for each Project element and will be included within the 75%, 95% and

100% design reports for each design element.




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7.0 MONITORING PLANS

7.1. Background

As described in the EIS Report (AMEC, 2005a), the Project is to include the implementation of

comprehensive monitoring programs. The objectives of these programs are to:

a) Ensure that the operational requirements and objectives of the remediation works are met;

b) Confirm effectiveness of the mitigation measures proposed in the EIS;

c) Ensure proper implementation of the mitigation measures outlined in the EIS;

d) Determine the need for new mitigation strategies as required to address unanticipated adverse effects

and/or ineffective mitigation;

e) Ensure compliance with regulatory permits, approvals and requirements; and

f) Assist in verifying effects predictions of the EIS.

Although the types of monitoring to address objectives b) to f) were described in the EIS as either

Environmental Compliance Monitoring or Environmental Effects Monitoring, during the more detailed

planning of these programs in this detailed design phase, there is further categorization of monitoring

types into the following areas:

Performance Monitoring, to address a);

Construction/Mitigation Monitoring, to address b), c) and d);

Regulatory Compliance Monitoring, to address b) through e);

Environmental Effects Monitoring, to address f); and

Long Term Monitoring and Follow-up Monitoring, to address f).

Performance monitoring is addressed through Project design and is discussed fully in the Quality

Assurance/Quality Control Plan for the Project.

Construction/mitigation monitoring is focussed on activities within specific elements and is generally

site-specific. This type of monitoring is instantaneous and is intended to identify immediately if

mitigation measures are effective.




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Regulatory compliance monitoring will provide regulators with the information required to determine if

legislation and/or permits are adhered. This monitoring information will be compiled into regular reports

to be disseminated as described in the Reporting Protocol, Section 10.3 of this EMP.

The EEM Program is a tool to determine if effluents are causing effects on ecosystems. Effects are

assessed using regular cyclical monitoring and interpretation phases. Impacts on the same endpoints and

locations are recorded periodically every two (2) to six (6) years, depending on the program, thereby

providing both a spatial characterization of potential effects and a record through time to assess changes

in receiving environments.

The EEM Program for this Project differs from the Long Term Monitoring (LTM), as the EEM can be

discontinued if results show the predictions of the EIS are confirmed prior to the end date of the LTM,

which is twenty-five (25) years.

All monitoring results will be used to facilitate an “adaptive management approach”, to ensure that

corrective action is taken when deficiencies in the Project implementation are identified. The Monitoring

Programs themselves will be subject to re-evaluation and adjustments as Site conditions evolve or the

need to focus on specific operational aspects or issues changes.

The following subsections briefly describe each Monitoring Program, the purpose, objectives and

rationale. Further details for each Program; such as, sample sites, frequencies, methodologies and

inspection protocols are provided in the Project EPP and/or the Detailed EPPs for each element.

7.2. Construction/Mitigation Monitoring

7.2.1. Purpose and Objective

During construction, Contractors shall monitor their construction activities for environmental impacts to

determine whether the impact-minimizing measures developed for the activity are effective. The main

purpose of Construction/Mitigation Monitoring is to identify the source of air and/or water contaminants

before any contaminants impact the receiving environment.

The Conceptual Site Models, as shown in Appendix B, show potential impacts to receptors as a result of

various activities that will occur as part of the Remedial Design for the Project. This information was

used in the development of each Detailed EPP for each element. The Detailed EPPs contain specific

mitigation measures to minimize impacts by identifying potential impacts related to each activity and

providing general and activity specific protective procedures. In addition, these plans provide real time




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air monitoring, noise and surface water monitoring within the Project site to immediately assess the

effectiveness of the mitigation, thereby providing the information required for immediate action if

measures are ineffective. Various element-specific Contingency Plans are also provided in the Detailed

EPPs.

The objective of the Construction/Monitoring Plans is to provide the necessary information to the

Contractor, so that immediate decisions can be made to ensure mitigation is effective, preventing impacts

to the public and/or the environment. EEM is a tool to determine if predictions made in the EIS are valid;

however, with this type of monitoring there is a time lapse which does not allow immediate response.

Data collected through the EEM Programs for ambient air, surface water, aquatics and avifauna in

addition to the long term monitoring data collected for groundwater will all be used to assess the

effectiveness of mitigative measures for the Project.

7.2.2. Real Time Air Monitoring

The Agency‟s Air Quality Monitoring Consultant (AQMC) is responsible for collecting the real time air

monitoring data and providing this information to the Contractor for each element. This program includes

perimeter monitoring upwind and downwind from each construction activity to identify sources of VOCs

and/or dust. The objective of the Real Time Air Monitoring Program is to protect the general public and

on-site workers from health impacts as a result of remediation activities.

7.3. Air Monitoring – Not in Contract (NIC)

The AQMC is responsible for all ambient and real time air quality monitoring throughout the duration of

all construction activities. Details on ambient air monitoring protocols for the Project are provided in the

Ambient Air Monitoring Plan within the Project EPP. Only Real-time Air Monitoring is discussed as a

construction/mitigative Monitoring Program.

7.3.1. Real-time Air Monitoring

The independent air quality consultant (IAQC) on a contract basis will provide air monitoring services.

The IAQC will collect time weighted (twenty-four (24) hour) ambient air samples at the six (6) existing

monitoring stations to satisfy environmental effects monitoring requirements during remediation. The

IAQC will also carry out real-time continual air monitoring along downwind and upwind fence line

remedial activity sources. Exceedances to real-time action levels will require appropriate corrective action

by the Contractor. The Contractor is responsible for overseeing the implementation of any mitigation




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measures deemed necessary by the Agency. The Contractor is also responsible for informing the Agency

of any intrusive work that will occur at a specific element in a timely manner, so the IAQC can prepare

for field work.

The Agency will be responsible for the supply of all discrete (twenty-four (24) hour) sampling equipment

including high volume samplers and Summa canisters. The IAQC will be responsible to subcontract all

necessary laboratory facilities required to analyze collected samples with one exception. The Agency

shall contract Environment Canada Air Toxics Section in Ottawa to provide VOC analytical support

including supply of VOC sampling equipment. The IAQC will be responsible for sample collection,

transportation, analyses of samples, data validation, QA/QC, interpretation, reporting and management of

monitoring results.

7.3.2. Real-time Monitoring

The real-time component of the AMP is critical to ensure the remediation work is carried out in a safe

manner without the release of harmful levels of air emissions. The primary objective of real-time

monitoring is to measure air quality, on a continual basis at downwind fence line perimeters. Monitoring

data are compared to approved, short term action levels developed to assist construction managers in

immediately modifying site activities and preventing exceedances of health based compliance criteria.

The real-time work will focus available resources on those contaminants that pose the most significant

health risks during remedial activity. The Real-Time Program has identified a number of target

compounds, or class of compounds, that can be monitored effectively on-site on a continual basis using

portable equipment. The target compounds have been selected based on a set of criteria:

Toxicity or unit risk factor of the particular compound;

Relative concentration of the contaminant present in the buried waste or soil;

The compound‟s volatility or rate at which the compound is emitted to the air;

The location and spatial coverage of the remedial activities; and

Limitations and effectiveness of real-time monitoring equipment in measuring the types of air

emissions typically released to the air by these activities.




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Rapid data turnaround is an important consideration in the selection of real-time monitoring equipment.

Turnaround times are critical when the monitoring data are being compared with short-term action levels

during remediation. A multi-level approach to real-time monitoring will be provided which includes:

Odours and visual (dust) by sensory detection;

Portable, continual reading, gas and aerosol monitors at perimeters; and

Colorimetric gas detection tubes to assess the relative contribution (volatiles) from benzene

emissions.

7.3.3. Target Emissions

Any remediation activity that moves or disturbs soil or waste at the site can potentially result in air

emissions of VOCs, naphthalene, and particulate matter (i.e., dust). Solid or liquid particles (aerosols) can

be released from remedial activity into the ambient air, including contaminated soil particles, heavy metal

particulates and droplets of organic compounds. Control of particulate emissions at the remediation

source will limit concentrations of heavy metals and PAHs/PCBs (as particulate-borne concentrations) in

the ambient air surrounding the Site. The disturbance of waste materials can also release liquid droplets

into the air from volatization of the contaminated waste. Volatile organic compounds and some PAH

compounds with higher volatilities can be released if adequate control measures are not initiated.

Total suspended particulate (TSP) and the PM10 fraction are considered more representative of dust that

can be generated by earthworks. Particulate matter less than 2.5 microns (PM2.5) is typically not

monitored around earthworks, despite its greater potential health impacts. The smaller fraction is

normally emitted by combustion sources. The PM10 fraction is considered more protective of human

health than TSP and has been selected as the most appropriate dust parameter to monitor on a continual,

real-time basis.

VOCs and PAHs are among the most common type of contaminant of concern at remediation sites. Based

on the relative volatility, sediment concentration (in-situ) and toxicity of the compound, each VOC and

PAH was screened to determine which chemicals posed the most significant risks. A group of VOCs,

known as aromatics, include the BTEX compounds (benzene, toluene, ethylbenzene, xylenes), which are

considered to be of key importance due to their volatility and concentration. Benzene and naphthalene is

considered to pose the greatest risk and has been selected as a conservative indication of overall

VOC/PAH impacts. Benzene, due to its higher volatility, will likely be emitted into the ambient air before




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other VOCs and at potentially higher concentrations than most other VOC species. Benzene is a known

carcinogen with a “severe” toxicity rating.

Real-time monitoring of individual VOC and PAH species is complicated. The current state of technology

can provide continual measurement of VOCs using photoionization detection (PID) instruments. Most of

the portable real-time monitors react with entire classes of compounds and tend to not be specific for a

given compound. PIDs for example are very sensitive to aromatic hydrocarbons (BTEX compounds) but

significantly less sensitive to aliphatic hydrocarbons. In addition, PIDs cannot differentiate between

benzene and toluene if both compounds are present. In some instances, action levels are set based on total

response, as if the instrument readings were due solely to benzene and not other aromatic compounds.

To address PID monitoring limitations, a screening strategy will be employed where total volatiles

(TVOC) will be monitored on a continual basis and compared to established action levels. These levels

have been preset to ensure public protection against benzene and naphthalene exposure at the perimeter.

The established action levels are summarized in Table 9 and Table 10.

In addition to using TVOC emissions as an indication of air impacts due to volatilization, naphthalene is

also considered a target compound, due to its low odour threshold level (450μg/m3) and volatility.

Toxicological studies are ongoing to determine whether exposure to the compound has carcinogenic

effects on humans. Naphthalene, with its low odour threshold and strong characteristic odour

(“mothballs”), will provide an early warning of potential VOC emissions being released into the air from

remedial activity. In the event sustained (ten (10) minute) naphthalene odours are detected by the IAQC,

the Contractor in consultation with the Consultant and the Agency, will assess the situation and determine

the most appropriate corrective action(s).

7.3.4. Monitoring Duration and Frequency

Continual measurements for PM10 and TVOC will be taken downwind and upwind of remedial activity at

fence line perimeters. Fixed monitors will be positioned on stable tripod along exposed downwind

perimeters at the start of each work day. Each monitoring site will measure and record fifteen (15) minute

average concentrations (PM10 and TVOC) on a continual basis throughout the work day. Supporting data

management software package will be utilized to provide ongoing readout of concentrations over preset

averaging periods.

Real-time monitoring will be carried out using hand held instruments with PM10 and TVOC

measurements taken downwind of construction activities at a frequency of two (2) fifteen (15) minute




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readings per hour. The monitoring frequency for upwind of construction activities will be fifteen (15) one

(1) fifteen (15) minute reading per hour.

Benzene is a known carcinogen with a “severe” toxicity rating. Benzene detection will be initiated when

TVOC levels exceed the established site action levels at the fenceline perimeter, in order to determine the

relative contribution from benzene emissions.

7.3.5. Monitoring Location

All real-time measurements will be performed at predetermined locations, with exact locations selected

prior to start of each work day based on a review of the prevailing wind direction(s), wind speeds, type of

work activity and location of activity (source) in relation to downwind receptors. Fence line monitors,

fixed to tripods, will be positioned along downwind exposed perimeters to ensure adequate coverage and

protection is provided between adjacent neighbourhood(s) and remedial activity(s). The siting of monitors

will primarily be driven by location of remedial work relative to fenceline and wind direction.

Critical fence line perimeters have been identified based on an overall review of planned remedial

activity(s), site features, neighbourhood locations, terrain and meteorological conditions. Screening level

model exercises were used to assess likely air dispersion patterns from the remedial activity(s). Key

perimeters were identified downwind of Tar Pond and Coke Oven remedial sites.

Fixed locations along all downwind perimeters shall be located by the IAQC prior to start of any

scheduled remedial work. Positioning of handheld instruments will require sound judgment and careful

planning.

7.3.6. Real-time Protocols and Equipment

Hand-held instruments used to screen concentrations at the fenceline perimeter will include

photoionization devices (PIDs) for total VOCs and aerosol monitors for dust (PM-10). Real-time

monitoring of TVOCs will be carried out using portable real-time analyzers (photoionization detector),

sensitive to aromatic hydrocarbons like benzene, toluene, ethylbenzene and xylenes. PIDs and aerosol

monitors will be employed to carry out the perimeter monitoring requirements as well. Portable Units will

be mounted on tripods with weatherproof enclosure. Instrumentation shall be capable of logging

minimum, maximum and average concentrations over predetermined time intervals. Units will provide

real-time clock for time and date stamping of events. In addition, benzene concentrations will be screened

at the source using colorimetric gas detection tubes with a minimum detection limit of 0.125ppm




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(400μg/m3). Benzene detection will be initiated when TVOC levels exceed the established site action

levels.

7.3.7. Weather Conditions

On-site weather stations will be used to collect meteorological data for the current Air Monitoring

Program. The IAQC will collect real-time weather data including wind direction, speed, temperature and

relative humidity. The IAQC will obtain detailed twenty-four (24) hour weather forecasts prior to each

work day from Meteorological Services Canada.

7.3.8. Site Action Levels

Table 4-24 provides a summary of real-time action levels for fence line air monitoring. The site action

levels are based on an approach that considers the budgeting of emissions during the work day. The

budgeting of emissions takes into account shifting wind patterns.

7.3.9. PM10 Action Levels and Measures

PM10 action levels were calculated based on the twenty-four (24) hour average criterion of 50 μg/m3. As

determined by STPA, the action levels and measures previously determined for the Muggah Creek

Remediation Project will be implemented for the EPP. The following summarizes how the action levels

were determined, as outlined in the document, Proposed Air Quality Standards, Muggah Creek

Remediation Project (CRA, 2005).

The purpose of the PM10 emissions budget is to meet a daily average limit of 50 μg/m3 in the community.

As such, it was determined that the sum of the hourly PM10 results for a twenty-four (24) hour period

cannot be above an emissions budget of 1200 ug-hrs/m3 (50 μg/m3 * twenty-four (24) hours = 1200 μg-

hrs/m3). It was assumed that a ten (10) hour work day was required for the remediation activities. The

hourly PM10 concentration during the fourteen (14) hour period without construction activities was

assumed to be 15 μg/m3. As a result, the fourteen (14) hour time period without construction activities

will spend a maximum emissions of 210 μg -hr/m3 (fourteen (14) hours X 15 μg/m3 = 210 μg-hrs/m3).

Therefore, the PM10 emissions budget remaining for the ten (10) hour work day was calculated to be 990

μg-hrs/m3 (1200 – 210 = 990 μg-hrs/m3).

As a result, each hour has a limit for an hourly average of 99 μg/m3 (990 μg/m3 / 10 hours = 99 μg/m3-hr).

Furthermore, it was assumed that the PM10 background concentrations are an average concentration of 33

μg/m3 during the ten (10) hour work day, based on a maximum reading of 33 μg/m3 at the St. Anthony




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Daniel station in 2004. Accounting for the PM10 background concentration during the ten (10) hour work

day, the remaining PM10 emissions budget for the work day was calculated to be an hourly limit of 66

μg/m3 (99 μg/m3 – 33 μg/m3 = 66 μg/m3). The ten (10)-hour average incremental concentration of 66

μg/m3-hr was then used to develop a fifteen (15) minute action level. The fifteen (15) minute action levels

were calculated for using the reference document titled STB Technical Bulletin No. EES-1, Odour

Impacts – An Overview (Science and Technology Branch, MOE, February 1996). Action levels for each

of the fifteen (15) minute averaging time period was converted as a function of atmospheric stability

class. The derivation used a meteorological classification of E and F, which results in 0.167 for the

stability constant. The fifteen (15) minute action level was calculated to be 155 μg/m3. Table 9 below

summarizes the real-time action levels for PM10.

Table 9: Summary of Project Real-Time Action Levels for PM10

Time Period Action Levels(1)

Fifteen (15) minute action level at fenceline 155 μg/m3

Daily Budget Value (not to be exceeded) 990 μg/m3

Notes: 1 Source: Muggah Creek Remediation Project Sydney, Nova Scotia (Conestoga Rovers & Associates, 2005)

The following action measures will be implemented for the construction elements:

a) In the case where real-time PM10 concentration measure as 2/3 of the allowable maximum of 155

μg/m3, (i.e., 100 μg/m3), the Contractor(s) will be notified that the work activities should be closely

monitored and procedures revised to incorporate mitigative measures. This step is implemented as an

additional safeguard.

b) The “Dust Budget” will be monitored during the day by calculating hourly downwind averages for

each monitoring area, and adding together the hourly averages and adding the estimated background

for the remainder of the work day. When the expended budget to that point plus the remaining hours

in the work day multiplied by the background concentration reaches or exceeds 990 μg/m3, site

activities will be shut down for that day. In addition, when the expended budget to that point plus the

highest reading for that day multiplied by one(1) hour plus the remaining hours in the work day, less

one (1) hour, multiplied by the background concentration exceeds 990 μg/m3, site activities will be




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terminated for the day. The formula for the calculation of the Daily Dust Budget (as reported in the

CRA letter report titled “Proposed Air Quality Standards, Muggah Creek Remediation Project,

Sydney, Nova Scotia” dated April 20, 2005) is as follows:

990 μg/m3 > (Budget to that point) + (Highest hourly average reading that day x 1 hour) + (33

μg/m3 x remaining work hours). Where remaining hours = 10-((number of hours monitored

before exceedance)+1)

This formula indicates 990 μg/m3 as the total daily “Dust Budget” (CRA, 2005).

7.3.10. TVOCs Action Levels and Measures

TVOCs action levels and measures have been adopted from:

The Proposed Work Management Decision Criteria for Sydney Tar Ponds and Coke Ovens Clean Up

Project (AMEC, 2009); and

The document, “Proposed Air Quality Standards, Muggah Creek Remediation Project” (CRA, 2005).

Currently, there are no jurisdictional air criteria for TVOCs. Therefore, site specific action levels have

been developed for TVOC monitoring results. The action levels use an approach based on budgeting of

emissions. The daily budget value for TVOCs is based on assuming that the volatiles at the fence line are

100% benzene or 100% naphthalene. Thus, a daily budget value of 8 ppm for TVOCs is used assuming

two (2) fifteen (15) minute readings every hour at a downwind fence line location. Furthermore, the real-

time action level for TVOCs over a fifteen (15) minute period has been adopted as 0.66 ppm.

As determined by STPA, the fifteen (15) minute action levels and measures previously developed for the

Muggah Creek Remediation Project will be implemented for the EPP. In addition, the daily budget value

as outlined in the March 2009 report for proposed work management criteria will be implemented. Table

10 below summarizes the action levels.




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Table 10: Summary of Project Real-Time Action Levels for TVOC

Time Period Action Levels

Fifteen (15) minute action level at fenceline 0.66 ppm(1)

Daily Budget Value (not to be exceeded) 8 ppm(2)

Notes:

1 Source: Proposed Air Quality Standards, Muggah Creek Remediation Project, Sydney, Nova Scotia (Conestoga Rovers &

Associates (CRA), 2005)

2 Source: Proposed Work Management Decision Criteria for Sydney Tar Ponds and Coke Ovens Clean Up Project (AMEC, 2009)

The following action measures will be implemented for the construction elements:

When the TVOC action level of 0.66 ppm is exceeded, the IAQC will contact the contractor and

notify them that work activities are to be closely monitored and possibly adjusted. The IAQC will

sample benzene concentrations using a Draeger tube. If measurements continue to increase, a decision

to temporarily halt or shut down remedial operations will be considered. Contractor(s) will be

required to modify their work practices in order to reduce VOC emissions.

The “TVOC Budget” will be monitored during the work day. When the expended budget reaches or

exceeds 8 ppm, site activities will be shut down for that day.

Table 11 outlines the appropriate action levels and associated action measures for the work day.

Table 11: Summary of Real-Time Action Levels and Action Measures

Parameter Action

Level

Monitoring

Location

Averaging

Period

Action Required if Level Exceeded

PM10 100 μg/m3 @downwind

fence line

Fifteen

(15)

Minutes

Site continues to operate. IAQC notifies the

Contractor, AECOM/CBCL and the Agency. The

Contractor will investigate potential source of air

emissions. Visible dust plumes on-site and/or sensory

detection of organic odors shall be an early indicator

that immediate corrective measures may be warranted.

First line of defense measures such as the addition of

water sprays to control airborne dust or changing

activity locations may be implemented. The Contractor

will initiate appropriate measures to correct operations.




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Parameter Action

Level

Monitoring

Location

Averaging

Period

Action Required if Level Exceeded

PM10 155 μg/m3 @ downwind

fence line

Fifteen

(15)

Minutes

The Contractor, AECOM/CBCL and the Agency will

evaluate work practices and determine the appropriate

course of action. Temporary stop work practices will

be evaluated. If the PM10 action level is reached or

exceeded and the exceedances is due to site work

activities, site work will be temporarily suspended

until proper techniques are identified and

implemented. The Contractor is to initiate appropriate

control measures. Work will resume within a short

time period when corrective procedures are

implemented.

TVOC 0.66 ppm @ downwind

fence line

The IAQC will notify the Contractor, AECOM/CBCL

and the Agency. The IAQC will assess Benzene

concentrations using colorimetric gas detection tubes.

The results of the colorimetric tubes will be

communicated to the Agency, the Contractor and

AECOM/CBCL.

• The contractor will closely monitor work and

possibly implement mitigation measures. If

measurements continue to increase, a decision to

temporarily halt or shut down remedial operations will

be considered. Contractor(s) will be required to modify

their work practices in order to reduce VOC emissions.

PM10

990μg-

hrs/m3

@downwind

fence line

Daily

Emissions

Limit

If the daily emissions budget is reached, the IAQC

notifies the contractor, AECOM/CBCL and the

Agency. The contractor terminates site work for the

day. The Contractor, AECOM/CBCL and STPA will

discuss and examine remaining options available to

correct air emission exceedances. A course of action

will be developed for the next day of remedial activity.

TVOC 8ppm

Note: Upwind conditions are to be considered prior to shutting down site work activities. Work activities

are not to be terminated in the event that the action level is exceeded upwind and the downwind

concentrations are less than 10% of the upwind concentrations. The dust budget is to be similarly

managed, that only the background concentration to the budget is added in these situations.

The Contractor should note all air exceedances/incidents on the EIL located.

7.3.11. Noise Monitoring

Noise monitoring will be conducted by each Contractor responsible for each element of the Project to

assess if noise levels are within the Guidelines as described in the Detailed EPPs.




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97918-GEN-EMP-N-001-R2 14 June 2010

As part of the Remediation of Sydney Tar Ponds and Coke Ovens Sites Environmental Impact Statement

(EIS), AMEC Earth and Environmental Inc. completed a Noise Monitoring Program1 to establish baseline

noise conditions prior to the commencement of Project activities.

The Noise Monitoring Program included nine (9) locations close to residential receptors around the

Sydney Tar Ponds and Coke Ovens Sites, as indicated on Figure 62. Baseline conditions provide an

indication of noise attributable to factors outside construction, such as vehicular traffic, train movement,

and residential events.

Figure 6: Baseline Noise Monitoring Locations

Once each element‟s construction activities begin, noise monitoring specific to each element will begin.

Noise monitoring will be conducted at three locations along the Project site boundary (e.g., the fence line)

during active construction hours (typically between 0700-1900 hours). Measurements at the Project site

1 AMEC Earth & Environmental (2005). Remediation of Sydney Tar Ponds and Coke Ovens Sites Environmental Impact

Statement, Volume I, s.5, p.38. Sydney, NS: Sydney Tar Ponds Agency. 2 AMEC Earth & Environmental (2005). Noise Monitoring Locations in Sydney [Figure]. Remediation of Sydney Tar Ponds and

Coke Ovens Site Environmental Impact Statement, Volume I. Sydney, NS: Sydney Tar Ponds Agency.




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boundary shall take note of noise generated off-site (e.g., background noise) when considering the total

effects of construction activities.

Noise monitoring levels will be measured at the Project site boundary on a two (2) hour Leq (dBA) basis

during active daytime hours when construction equipment is operational. Once mobilization is complete,

construction noise monitoring will be completed three times per week, at three locations, for the first three

weeks and one per week, thereafter provided there are no noise issues or complaints. Should noise

complaints arise that may be attributed to the activities at the site, an assessment will be completed to

determine whether the noise is attributed to on-site construction activities and to determine compliance

with NSE‟s criteria. As part of the assessment, noise monitoring will be conducted at the nearest

receptors during construction hours. If the noise is attributed to site construction activities, noise

mitigation steps, will be considered to meet the NSE guidelines, within reasonable economic restraints.

All construction activities and equipment operation will comply with the CBRM noise by-law(s) and any

applicable provincial and federal guidelines as stipulated in the Environmental Impact Statement:

Guidelines for the Environmental Assessment of the Sydney Tar Ponds and Coke Ovens Sites Remediation

Project3. NSE has established the following noise criteria under the Guidelines for Environmental Noise

Measurement and Assessment4 document.

a) Leq,2hr < 65 dBA between 0700 to 1900 hours (Days);

b) Leq,2hr < 60 dBA between 1900 to 2300 hours (Evenings); and

c) Leq,2hr < 55 dBA 2300-0700 hours (Nights).

d) In accordance with applicable legislation, the Contractor(s) shall also monitor noise levels in the

construction work area and at the nearest receptors and take appropriate noise mitigation or PPE actions,

as required.

7.3.12. Surface Water Monitoring

Construction/mitigation surface water quality monitoring will be conducted every four (4) hours of active

construction, by the Contractor‟s EM when construction activities are within 30 m of a waterbody.

3 Public Works and Government Services Canada (2005). Environmental Impact Statement Guidelines for the Environmental

Assessment of the Sydney Tar Ponds and Coke Ovens Sites Remediation Project. 4 Nova Scotia Environment (1991). Guidelines for Environmental Noise Measurement and Assessment. Halifax, NS: Author.




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Sample site location and frequency depends on where and what type of activity is being carried out.

Typically the sample sites are upstream, midstream and downstream from the activity and compared

against the upstream background levels. .

Specific monitoring procedures, protocols and reporting requirements are to be consistent with NSE

requirements and standard operating procedures developed for the Groundwater and Surface Water

Sampling Program5.

Surface water monitoring is to be completed by the Contractor‟s EM or designee at a point roughly mid-

depth of the water column near the centre of the channel during flow events. Sample monitoring should

commence with the furthest downstream location and progress upstream to avoid any disturbances to the

sample. Field turbidity is to be monitored using an optical backscatter (OBS) nephelometer with an

underwater sensor and direct surface readout or another instrument having similar capabilities. Prior to

monitoring, all equipment and sampling devices are to be calibrated as per manufacturer‟s

recommendations.

The specific locations of monitoring points will change depending on the active working area. The

location of surface water testing will be determined at the time of testing by the Contractor‟s EM and

documented in the EIL.

The upper level criteria defined as a reportable event for turbidity will be 110% of background, when

background (upstream sample location) is greater than or equal to 80 Nephelometric Turbidity Units

(NTUs). When background is less than 80 NTU, a reportable event will be greater than an increase of 8

NTU above background6.

If an element‟s turbidity monitoring reveals that the upper level criteria have been exceeded, the

construction activities suspected of contributing to the exceedance (e.g., excavation) will be temporarily

halted until levels decrease to an acceptable level. During this time, all efforts will be made to rectify the

cause of the exceedance.

5 Dillon Consulting & ADI Limited, (2004). Groundwater and Surface Water Sampling Program. Sydney, Nova Scotia: Nova

Scotia Department of Transportation and Public Works

6 Canadian Council of Ministers of the Environment (2006). Water Quality Guidelines. Winnipeg: Author.




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The Contractor(s) shall then resume turbidity monitoring at an increased intensity level (hourly) to verify

that the source activity has been abated. Explanatory details documenting the exceedance and any

corrective measures taken will be documented.

7.3.13. Short Term Cap Monitoring

The Construction Phase Surface Cap Monitoring Plan is designed to monitor the state of the cap at both

CO6 and TP7, while construction activities are ongoing. Once construction of the cap has been

completed, the Cap Environmental Effects Monitoring Plan (EEM) found in the Project EPP and

described below in Long Term Cap Monitoring Section will take effect. The purpose of both the short

and long term plans is to study the integrity of the cap.

Short Term Cap Monitoring shall be completed by the Contractor(s) and include:

a) Daily overview inspections by the Contractors‟ Site Supervisor to ensure that grading and material

thicknesses have been constructed according to specifications and to check for any signs of erosion or

other potential cap installation problems. Should cap installation problems be identified, action will

be taken as soon as possible to rectify the situation;

b) The seal of the liner, where applicable, shall be inspected at the manufacturer‟s specified frequency to

meet manufacturer‟s recommended criteria. If manufacturer‟s specifications are not met, appropriate

action will be taken and may include liner replacement, if applicable;

c) Compaction testing shall be completed for the clay fill installation for every 0.3m lift per hectare.

Compaction shall meet 98% standard proctor density and will be measured using a nuclear

densometer by qualified personnel;

d) Detailed weekly inspections and documentation of the status of cap installation will be completed by

the Contractors‟ EM. Documentation shall be submitted to the Agency along with any other EILs for

CO6 and TP7 and shall include, but is not limited to, observations on the following:

Condition of hydroconductivity (impermeable/clay) layer, if applicable;

Evidence of erosion or differential subsidence;

Signs of gullies or rills; and

Germination of vegetation.




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e) If deficiencies are identified during the weekly inspections, appropriate action will be taken to

mitigate potential environmental effects; and

f) Once an area of the cap has been vegetated, monitoring of that cap shall be completed by others in

accordance with the long term cap monitoring plan provided in the Project EPP.

7.3.14. Visual Inspection

The Contractor‟s EM will also be conducting visual inspections every four (4) hours (exception for TP2

Operations and Maintenance, where it will be daily) at each active construction site and once daily during

inclement weather conditions during shut down periods, to ensure maintenance of the mitigative measures

and all environmental issues are addressed. In cases, where an unexpected long term shut down period

occurs, the EM shall inspect the site once weekly as a minimum. Environmental inspection is the primary

tool to ensure that the Contractor is implementing the environmental commitments of the EMP,

identifying where remedial actions may be required and taking the required actions in a timely fashion.

Through the actions of AECOM/CBCL as the Design and Construction Oversight Consultant, the

Contractor‟s compliance with the EMP and the Detailed EPPs will be monitored to ensure that

environmental protection objectives are being achieved in the field.

7.3.15. Environmental Inspection Logs

The Contractor will regularly inspect and evaluate environmental procedures and shall record the status of

each Project activity every four (4) hours in the Environmental Inspection Log (Appendix F). If a

problem or potential problem is identified by the Contractor, the Consultant and the Agency shall be

notified immediately. The Consultant shall oversee that the appropriate mitigative or restorative actions

are taken and shall immediately report the actions taken to the Agency along with a plan for future action.

As the Consultant is responsible for construction oversight, they will review the Contractor logs weekly

to verify environmental site conditions and send a Monthly Summary Report to the Agency. The IQAC

shall also prepare documentation of their activities to the Agency. The IQAC reports are to be reviewed

by the Agency directly and the Agency is to direct any remedial action required to the Consultant. This

procedure has been designed to provide an early detection and solution implementation mechanism for

emerging problems before they become serious or unmanageable.

By undertaking routine inspections and completing Environmental Inspection Logs every four (4) hours

as required in the detailed EPPs, a proactive approach aimed at identifying potential concerns before




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environmental impacts occur is achieved. In addition, inspections and other mechanisms of direct

reporting, such as telephone or email, serve to ensure that corrective actions occur immediately where

unsafe conditions have been identified. The inspection activities will act as a safeguard to ensure that the

environmental protection measures are functioning effectively.

To determine the ongoing effectiveness of environmental management and mitigation procedures, the

Contractor and IQAC are both required to submit a Monthly Environmental Inspection Report to the

Agency (and to the Consultant from the Contractor) for review. These reports shall also identify actions

needed to remedy situations of environmental concern. If environmental protection measures are

persistently proving to be ineffective at mitigating the impacts of construction activities, a revision to an

existing detailed or Project EPP may be required. Revisions to EPPs shall be subject to the procedures

outlined in the Change Protocol Document (Appendix B). Employees are to be trained in any new

procedures, as per the requirements in Section 9 of this EMP.

This adaptive management process of inspection/monitoring, analysis, review, policy revision and

training will ensure that the EMP is meeting Agency‟s environmental protection commitments.

7.3.16. Adaptive Management

Locations, timing, frequency, parameters and action triggers are provided in the element specific Detailed

EPPs for the Construction/Mitigation Measures Monitoring Programs. Visual observation provides

additional information to determine if protective measures are effective. With information obtained from

analytical and visual data collection, an assessment will be made whether further mitigation or

investigation is required. Steps to be taken by the Contractor and the Agency, or their designate, if

mitigation appears to be ineffective are:

Investigate and determine the source;

Identify and evaluate possible corrective actions;

Implement corrective action; and

Monitor the effectiveness of the corrective action.

Adaptive management involves mitigating and monitoring each activity, assessing effectiveness and if the

mitigation is not effective, reporting the incident to the Agency with further mitigation implemented. If

further mitigation is shown to be ineffective through monitoring results, the Agency must be notified and




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work is to temporarily cease until the issue is resolved. This process is graphically represented in

Figure 7.

Figure 7: Adaptive Management Procedure

7.4. Regulatory Compliance Monitoring

Various pieces of legislation apply to the Project, in addition to specific conditions of permits, as

provided in Section 3 of this EMP. Monthly compliance monitoring reports shall be submitted by the

Consultant and All Tech to the NSE and other regulators concerning:

Battery Point/Sydney Harbour surface water;

Effluent discharge from element CO8, Coke Oven Water Treatment Plant, to surface water;

Air emissions from element TP2, the Materials Processing Facility;

Air emissions from element CO8, Coke Oven Water Treatment Plant; and,

Other compliance monitoring stipulated by NSE as part of Conditions of Approval.

In the event that analytical test results taken from compliance monitoring locations are found to

unexpectedly exceed provincial or federal limits, these results will be reported immediately to the

Agency, NSE and other regulators, and an investigation of cause will be carried out. Additional details on

compliance monitoring programs are provided in the Project EPP.




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Continuous real-time data will be available as it is generated and provided to the Agency and other

stakeholders, as required. The Air Quality Environmental Effects Monitoring Plan identifies the use of

continuous reading perimeter monitors connected to a central data management system onsite where the

appropriate real-time summary data can be transmitted to the various stakeholders including the general

public.

7.4.1. Battery Point/Sydney Harbour

Turbidity, pH, conductivity, salinity and temperature will be monitored at Battery Point using an

automatic datalogger. Data will be downloaded and analyzed monthly, with the exception of heavy

precipitation events as described in the Compliance Monitoring Section of the Project EPP or if there is a

failure of an erosion control structure. This instrumentation will be the responsibility of the Agency or

their designate. In addition to retrieving and monitoring data at this location, if compliance is not

achieved, an investigation to determine the source is to be initiated by the individual who is tasked (by the

Agency) with the monitoring and maintenance of this datalogger.

Lab analyses of surface water for various parameters will be carried out under the EEM Program.

7.4.2. Effluent Discharge

Effluent discharge criteria in compliance with the Fisheries Act and NSE‟s approval will be the basis for

the design of the WTP (element CO8). Effluent from element CO8 will be monitored for the duration of

operations which is expected to be twenty-five (25) years.

A detailed monitoring plan with timing, frequency, parameters and action triggers will be provided in the

Project EPP.

7.4.3. Air Emissions

Approval from NSE for air emissions from the Materials Processing Facility (element TP2) and the WTP

(element CO7/CO8) will be acquired prior to operation of these facilities. This approval will contain the

levels of emissions allowed for various parameters. These emissions will be monitored as per the

Condition of Approval requirements for each of the two facilities.

7.5. Environmental Effects Monitoring

EEM programs are “early warning” tools to detect negative impacts on the environment and allow for a

review of the impacts and implementation of corrective actions, if they are required. EEM programs are




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listed in the subsections that follow and are typically carried-out over a period of several years. An

Ecological Risk Assessment of Sydney Harbour will be completed to provide additional information to be

incorporated into the EEM plans.

EEM Programs are to be implemented for:

Ambient Air Monitoring;

Surface Water Monitoring;

Aquatic Monitoring in Sydney Harbour; and

Avifauna Monitoring.

Monitoring methodologies, locations, parameters and frequency of sampling for all EEM Programs are

provided in the Project EPP. In addition, methods to assess, post data collection, the need for each

program to continue will also be provided in the Project EPP.

7.5.1. Ambient Air Monitoring

OBJECTIVES AND RATIONALE

Ambient air monitoring will provide cumulative information for various locations throughout the Project

site. Cumulative information for various locations throughout the Project and within the community will

be collected in accordance with the Environmental Effects Monitoring Plan. Baseline data has been

collected in previous years to characterize the local airshed, onsite and offsite. Air samples will continue

to be collected at the six (6) existing monitoring stations within the community during the Project with

results compared to baseline conditions in the airshed.

The baseline study has been on-going with services provided by All Tech Environmental Consultants.

Local air quality predictions made in the EIS will be confirmed with the data collected under this EEM

Program.

POTENTIAL SOURCES OF AIR EMISSIONS

Possibly of most concern to the public throughout the construction phase of the Project, is the impact of

construction activities on the quality of air in the vicinity of residential and commercial neighbourhoods

surrounding the Tar Ponds and Coke Ovens Sites. As the CSMs indicate, emissions could result in the

creation and inhalation of vapours and particulate matter, both by construction workers and the

surrounding community. To mitigate health concerns associated with air quality, each Project element, as




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described in Section 2.4, will be monitored for the effectiveness of the mitigation measures during the

construction phase. Potentially air-impacting construction activities include, but are not limited to:

Materials processing and handling;

Transportation operation and maintenance;

Building emissions, construction machinery operation and maintenance;

Soil transport and stockpiling;

Contaminant handling and excavation; and

S/S mixing.

These activities can result in an increase in fugitive dust, diesel emissions and the release of VOCs.

STUDY DESIGN

The study design for ambient air monitoring includes a number of basic steps that parallels EPA guidance

documents for ambient air monitoring around Superfund Sites. Basic steps considered in the study design

include:

Define program goals;

Select target compounds;

Select number and location of monitoring sites;

Select duration and frequency of monitoring;

Select monitoring methods;

Establish data quality objectives;

Establish QA/QC Program;

Establish data management and reporting systems;

Establish compliance criteria and site action levels; and

Establish Community Access Program.

The existing pre-remedial AMP was designed to collect baseline air quality data for a multiple number of

chemical compounds than could be present in the surrounding airshed. The database contains more than

five years of monitoring results for an extensive suite of contaminants (approximately 50 parameters),




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defining twenty-four (24) hour and annual average concentrations and trends prior to any significant level

of remedial activity occurring on-site. Based on this information and knowledge obtained during the pre-

remedial monitoring work, the AMP has been designed to monitor a number of target compounds using

proven sampling and analytical methods employed during the previous program.

The baseline database has been reviewed and a list of contaminants that were routinely detected during

the baseline study was identified. Factors that affect the magnitude of any health risk posed by a

particular contaminant include; the concentration of the compound in the buried waste or soil, the

compound‟s volatility or the rate at which the compound is emitted to the air, and the toxicity or unit risk

factor of the particular compound. The AMP focuses on available resources on these compounds that

pose the most significant risk during the remediation work.

The AMP includes a fixed network of point samplers located around the perimeter of the Tar Ponds and

Coke Ovens Sites. Generally, the factors that influence the required number and locations of sample

stations include:

The locations of potential on-site emission sources;

The locations of topographic features that affect the dispersion and transport of site emissions;

The variability of local wind patterns;

The location of sensitive receptors; and

The level of confidence needed to ensure that the maximum concentration levels are being monitored.

For determining concentration levels with respect to short-term effects, a fixed network of real time

sampling stations ideally should be located around the perimeter of the Sites, with additional real time

monitors located near working areas on-site and near sensitive receptors.

The AMP includes the appropriate time, duration and frequency of the sampling events. The baseline

program collects twenty-four (24) hour samples on a six (6) day NAPS schedule. Sampling periods

during remedial construction activity will be selected for compatibility with relevant regulatory and site

action level criteria. Compliance with long-term criteria is usually determined using twenty-four (24)

hour sampling periods.

The AMP is designed to ensure that sufficient valid data are collected to achieve the goals of the Program,

which are to protect the workers and public from health impacts and to verify the prediction of the EIS,

that with mitigation, there will be no significant air impacts from the Project.




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7.5.2. Surface Water Monitoring


The surface water environmental effects monitoring program will provide data to determine the migration

of any off-site contaminants on to the Project Site and the transport of contaminants in surface water that

have originated on-site and are being carried off-site. The data collected through this program will

confirm the prediction of the EIS that there will be no significant adverse effect of the Project

construction activities to surface waters.

POTENTIAL SOURCES OF POOR WATER QUALITY

As shown on the CSMs for the various elements where construction is to occur near watercourses, there is

a potential for sediment and other contaminants within the water column to be transported downstream

into Sydney Harbour. Road building, bridge construction, steel sheet piling, excavation of sediment from

isolated sections of streams in the project elements, may potentially result in impacts to surface water

quality. Protective procedures and Contingency Plans are provided.

STUDY DESIGNS

The study is designed to collect surface water quality data at the Project boundaries in streams for

parameters known to be contaminants of concern for this Project. Additional sites are to be located

downstream of construction activities.

Surface hydrology monitoring will be carried out in select locations to monitor flows during construction

and post construction. Of special interest is the location of discharge from the WTP (element CO8). A

stage-discharge curve (relationship) will be developed as soon as possible to enable fieldwork to be

conducted in the most efficient manner in future years.

Surface water quality and flow monitoring in the newly constructed channel environments will provide

information to verify the predictions made in the EIS of no significant effects.

7.5.3. Aquatic Monitoring in Sydney Harbour

Marine water, sediment quality and benthic/bivalve monitoring will be conducted at Battery Point within

Sydney Harbour to determine Environmental Effects at this location as a result of Project activities.




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A Contaminant Fate Modeling Study was conducted by AMEC as part of the EIS, Volume 7 (AMEC,

2005a) to model the rate of flux of Chemicals of Concern (COCs) prior to, during and post construction.

Flux studies conducted by Jacques Whitford, Dillon Consulting, ADI Limited and CBCL Limited (JDAC)

in (2002a, b) were used as the main basis for selected COCs to conduct this modeling. The Contaminant

Fate Model was run for a sixty (60) year period for each COC. During the first thirty-nine (39) years, the

contaminant flux rate was stable, at the rate that was measured by JDAC (2002a, b). In Year forty (40),

the contaminant flux rate was increased by five (5) times the standard rate to simulate release related to

remedial construction activities. In Years forty-one (41) to sixty (60), the flux rate was decreased by 10%

to simulate remediated conditions. Annual incremental increases in contaminant transport to the Harbour

are presented in the EIS for surface water quality and sediment quality. The EEM program will verify

these predictions.

POTENTIAL RELEASE OF CONTAMINANTS TO SYDNEY HARBOUR

COCs are currently being transported to the Harbour, however the rate of transport – the flux – will

increase during construction due to the remedial construction activities as described in the CSMs.

However, the incremental increase when compared to existing flux rates for various parameters is

predicted to be non-significant.

STUDY DESIGN

This program will confirm predictions made in the EIS. Surface water, sediment, benthic invertebrates

and other indicator or sensitive species may be monitored. The Ecological Risk Assessment will assist to

further define this program.

7.5.4. Avifauna Monitoring

Avifauna habitat survey and breeding bird surveys will provide effects monitoring information to confirm

the predictions of the EIS.

OBJECTIVE AND RATIONALE

Since wetland habitat – the Tar Ponds – will be reduced in size, there was a concern birds would be

negatively impacted. However, the conclusions of the EIS were that birds would not be negatively

impacted since they would habituate in a much cleaner environment post remediation. For this VEC,

construction monitoring is not practical and the EEM program is intended to begin post remediation.




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POTENTIAL PATHWAY OF CONTAMINANTS TO BIRDS

Some species of birds rely on obtaining the majority of their food from the Tar Ponds environment.

However, these species as adults do not spend all their time at the Tar Ponds as there are other habitats

available to them.

COC‟s from the Tar Ponds can enter food eaten by birds by ingestion or absorption. Aquatic species can

retain these contaminants in their organs while continually exposed to COCs or bioaccumulate these

COCs within their tissue. Whatever the mechanism, birds ingest the COCs by mouth as food. These

COCs can impact reproduction, growth and other life history functions.

STUDY DESIGN

The monitoring of the presence of bird and the increase in local bird populations provides some indication

of improved habitat quality. A direct study, such as assessment of contaminants present in chicks, will

provide a very good correlation between contaminants within the organism and contaminants remaining

in the Ponds post remediation, since some species of chicks rely solely on pond organisms for food.

7.6. Long Term Monitoring

Long term monitoring programs include the Cap Monitoring and Maintenance Plan and the Groundwater

Monitoring Plan. Both of these monitoring programs will continue for twenty-five (25) years.

7.6.1. Cap Monitoring Plan

The Cap Monitoring and Maintenance Plan presents specific monitoring procedures and general

maintenance and repair concepts associated with the two (2) caps to be constructed as part of the

Remediation of the Tar Ponds and Coke Ovens Sites. The caps include; the cap over the stabilized Tar

Ponds and the cap over the Coke Ovens Site

The caps are multilayer barriers designed to divert surface water away from certain areas to minimize any

potential transport of contaminants. The simplest consists of a low hydraulic conductivity layer to

minimize infiltration of storm water and a low maintenance layer to provide protection of the low

hydraulic conductivity layer.

The final cover caps are generally multilayer caps. For complex caps the layers may include (from the

bottom up) a grading layer, a low hydraulic conductivity layer (GCL, or low hydraulic conductivity soil),

drainage layer (geocomposite or high hydraulic conductivity soil with geotextile), a protective layer and a




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vegetative layer (topsoil and vegetation). For simple caps the layers may consist of a low hydraulic

conductivity layer (usually clay) and a protective layer (usually vegetated topsoil).

The objective of the cap is to limit and control the infiltration of storm water into the area below through;

surface drainage, installation of a low permeability layer or a combination of the two.

The objective of the monitoring and maintenance plan is to ensure that the integrity of the cap is not

compromised. Also included is guidance on the documentation of these activities and the reporting

requirements.

Visual inspection methods and frequencies, maintenance to control vegetation, as well as repair activities,

are provided in the Cap Monitoring and Maintenance Plan within the Project EPP. In addition, methods

to monitor the integrity of the monolith are provided.

7.6.2. Groundwater Monitoring Plan

The purpose of the Groundwater Monitoring Plan, as described in the EIS, is to assess and monitor the

following:

TAR PONDS SITE

Modification of groundwater flow field under the SYSCO High Dump and remainder of the eastern

shoreline;

Contaminated groundwater into the new channel;

Leaching of the solidified/stabilized Tar Pond sediments; and

Ensuring that remedial activities designed and implemented for the SYSCO Site do not alter or

negatively impact the remedial designs established for this Project.

COKE OVENS SITE

DNAPL transport pathway under the Coke Oven Brook Connector down to the South Tar Pond,

under Domtar Brook and behind the western cut-off wall;

Impact of modifying the groundwater flow field through installation of the cut-off walls;

The effectiveness of the groundwater collection system; and




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The effectiveness of the Coke Ovens WTP (CO8) in dealing with contaminated groundwater seeping

from several areas over the Site.

The objective of the Program is to provide on-going monitoring to supplement baseline data and confirm

the predictions in the EIS.

Groundwater monitoring locations for quality and level monitoring have been chosen strategically based

on the presence of existing wells with baseline data and their proximity to element activities. Frequency,

methodologies, sampling sites and parameters to be sampled are provided in the Project EPP.

7.7. Monitoring Results Reporting

An effective monitoring plan must generate accurate, verifiable reports in a timely manner. The data

must be defensible and must meet the criteria established in the QA/QC Plan for accuracy, precision,

completeness and typical representation. Establishing sound data management procedures and objectives

as the plan is being developed can be critical to its effectiveness. Monitoring design focuses on key

elements of data management including data acquisition, reduction, validation and reporting.

Follow-up monitoring is an integral element of the environmental assessment process. Compliance

monitoring data will therefore be provided to the Agency and provincial regulatory agencies, as required.

Monitoring reports will also be made available to federal, provincial, municipal agencies, stakeholder

groups and the general public.

It is important to ensure that the community is kept abreast of monitoring activities and results, as

indicated in the Public Reporting Protocol in Section 10.2. Results are currently and will continue to be

reported on the web. It is anticipated than an appropriate automated data management system established

onsite will be able to report exceedances in air quality within the hour the actual exceedance occurs.

There is a potential for measurements of certain parameters, such as ambient air, to exceed established

protocol standards beyond the boundaries of the Project Site. For instance, benzene, due to its toxicity,

volatility and relative in-situ concentration, is of prime importance during remedial monitoring and shall

have specific compliance criterion to ensure protection of the general public. In the event that ambient air

monitoring returns a result that indicates the public is at risk due to air quality, the public shall be

immediately notified by methods including, but not limited to, televised and radio broadcasts and/or visits

to surrounding neighbourhoods by local authorities. The Agency and provincial regulatory authorities

shall also be notified if ambient air monitoring indicates a threat to public health.




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In regards to reporting a breach or failure of the cap, in order for the Agency to report a cap failure within

twenty-four (24) hours of discovery, the contractor responsible for monitoring the caps shall be required

to provide verbal notification immediately upon discovery and follow up with written notification and

supporting documentation by the end of the work shift or as directed by the Agency.

Additional details on reporting protocols are provided in Sections 4, 10.3 and 10.4 of this EMP.

8.0 CONTINGENCY AND EMERGENCY RESPONSE PLANS

One of the necessary elements in ensuring that the EMP delivers on its commitment to protecting the

environment and public and worker health and safety, is to provide strategic response protocols in the

event of unforeseen issues and emergency events. Although extensive protocols and monitoring systems

have been established to limit the risk of emergency situations, in large multi-faceted remediation projects

there are always unanticipated events that have to be addressed.

To address the potential for unanticipated events, AECOM/CBCL has developed the following site-wide

contingency plans containing protocols to be followed in emergency situations or in the event of other

unforeseen occurrences. These contingency plans are supplemented by the Agency Master Health and

Safety Plan (MHASP) and the Consultant‟s AHASP, both prepared by the Consultant, which contain

specific requirements regarding Emergency Response Planning. In addition, for each individual Project

element, a Contractor‟s AHASP and more task-oriented contingency plans (within the Detailed EPPs)

have been developed. All these plans have to be developed in accordance with the NSE Contingency

Planning Guidelines (NSE, 1990) and/or the Canadian Standard Association‟s (CSA) Emergency

Preparedness and Response for Industry (2003).

The following EMP Contingency Protocols outline Project-wide emergency measures that shall be

followed in the event of unexpected events considered potentially dangerous or hazardous to people or the

environment that could occur given the nature of the Project activities. These protocols shall be used in

conjunction with more specific task-oriented contingency protocols as outlined in the Detailed EPPs.

8.1. EMP Contingency Protocols

8.1.1. Failure to Comply Contingency Plan

All on-site activities are subject to the protocol provisions found in numerous Project documents. While

strong communication and reporting procedures have been put in place to guard against the breach of




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these protocol documents, it is still possible that protocols could be overlooked during the course of the

Project construction and monitoring activities.

In the event that the Contractor or another responsible party has been found not to be in compliance with

the requirements established in this EMP, the Agency‟s MHASP, the Contractor‟s AHASP, the EPPs, or

other documents pertaining to the environmental integrity of the Site or the protection of workers and the

general public, immediate action will be required.

Any failure to meet established procedural protocols involving a Contractor or their designee will be

reported by the Consultant or IQAC to the Agency. If required, the incident will also be reported to other

appropriate government bodies (e.g. NSE or Fisheries and Oceans Canada (DFO)) by the Agency for

review. In the event of a failure to meet the protocols, the Consultant will issue to the Contractor

disciplinary documentation in the form of either a Request for Action (RFA) or a Non-Compliance Report

(NCR). An RFA is issued when there is risk of breach of the protocols or the breach was minor, while an

NCR is issued when there is a more significant non-compliance. These documents are then responded to

by the Contractor until the issue is resolved.

It is the responsibility of the Agency to develop disciplinary or response measures for particular incidents

should they arise, in conjunction with the Consultant and the EMC. These disciplinary measures could

include, but are not limited to:

a) Written warning from the Agency specifying the specific deficiencies observed in the Contractor‟s or

responsible party‟s environmental protection and management implementation techniques;

b) Requirement for the Contractor‟s EM to increase frequency of environmental testing, obligation to

provide daily monitoring reports directly to the Agency and increased surveillance by the Consultant

and IQAC;

c) Order to revise personnel training protocols to better address environmental protection protocols;

d) Temporary stop work order;

e) Thorough investigation of the qualifications of the Contractor‟s EM, which could lead to dismissal or

a requirement to employ additional EMs; and

f) Contract termination.




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8.1.2. Fuel and Hazardous Material Spills Contingency Plan

This Fuel and Hazardous Material Contingency Plan presents a response system in the event of the release

of petroleum, oils, or lubricants (POLs) or other hazardous liquids on-site. The objectives of the Plan are

to:

Generate awareness of potential spill situations;

Establish protocols to protect persons from danger and adverse health effects;

Ensure everyone is well trained and equipped in the event of a spill;

Minimize impairment to the quality of the natural environment (air, water or land);

Contain the extent of affected area and outline clear spill clean-up procedures;

Control degree of disturbance during the work;

Decrease risk of damage to property; and

Set out what notifications and reporting is required in the event of a spill.

In the event of an incident involving a spill or leak, spills or discharges of pollutants or contaminants

under the control of the Contractor and spills or discharges of pollutants or contaminants that are a result

of the Contractor's operations that cause or are likely to cause adverse effects, shall forthwith be reported

to the Agency by the Consultant according to the provisions outlined in the Agency‟s MHASP. Such

spills or discharges and their adverse effects shall be as defined in the Government of Nova Scotia

Emergency Spill Regulations (GNS, 1995d).

The Contractor‟s EM shall immediately report any unauthorized release of a contaminant listed in

Column 3 of Table 12, in quantities greater than those listed in Column 4, by calling the twenty-four (24)

hour spill reporting number: 1-800-565-1633. Using this number will ensure that both the federal and

provincial governments are made aware of the spill. The guidelines in Table 12 have been established in

the Nova Scotia Emergency Spill Regulations.:

The following information should be recorded in the event of a spill and reported to the twenty-four (24)

hour spill reporting centre:

Location of spill;

Time of observation of spill;

Reported by;




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Probable (or known) sources of the spill;

Probable (or known) time of the spill;

Nature of material spill;

Probable (or known) volume of spill;

Probable (or known) duration of spill;

Area affected;

Mobility of spill;

Weather, water, or geographic conditions;

Action being taken to contain and/or control the spill;

Personnel at the scene of the spill;

Resources threatened (e.g. water supply, bird colony, fish kills, etc.);

Other agencies contacted; and

Any other pertinent information.

In the event of a spill or leak, the following procedure shall be followed:

a) The activity causing the spill will be stopped. If the spill or leak is minor and the individual who

discovers the spill or leak is aware of the properties of the spilled substance, this individual shall

attempt to stop and contain the leak or spill. Following containment, arrangements for cleanup shall

be made by the Contractor„s Site Supervisor.

b) If the spill or leak is significantly large that it cannot be cleaned, controlled or contained by the

individual who discovers it or if this individual is unaware of the properties of the substance that has

leaked or spilled, that person shall immediately vacate the area and notify the Contractor‟s Site

Supervisor. Visible warnings, such as signs or pylons, shall be positioned surrounding the area of the

spill and all workers shall evacuate the area.

c) The on-site Contractor‟s EM will have the full authority to take appropriate action without

unnecessary delay.




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d) In the event that the spill or leak enters a freshwater body (with or without fish habitat), the

Consultant shall report the incident to the NSE, DFO and Agency and coordinate a cleanup by the

Contractor according to regulatory requirements, as dictated by the indicated regulatory authorities.

e) In the event that the spill or leak enters coastal waters, either directly or through freshwater discharge,

the Consultant shall notify the Canadian Coast Guard, NSE, DFO and Agency. The Contractor‟s Site

Supervisor shall work with the Consultant and the Canadian Coast Guard in coordinating a clean-up.

f) All spills, whether major (as identified in Table 9) or minor shall be documented by the Contractor‟s

EM in an EIL (Appendix F) and submitted to the Consultant forthwith, along with a mitigative

measures program. If the issue is not resolved in a reasonable period of time, as per the mitigative

measures program developed by the Contractor‟s EM, the Consultant shall contact the Agency. The

Consultant shall contact NSE immediately in the event of a major spill as outlined in this section.

g) In the event of a spill, leak or discharge, the Contractor‟s EM shall work with the Consultant and the

authorities (NSE and others, as required) in coordinating a clean-up, which will include the following

actions, where appropriate:

Deploy on-site personnel to contain the spilled material using absorbent material or booms, as

appropriate;

Assess site conditions and environmental impact of various clean-up procedures;

Choose and implement an appropriate clean-up procedure;

Deploy on-site personnel to mobilize pumps and empty drums (or other appropriate storage) to

the spill site;

Apply absorbents as necessary;

Remove any contaminated sediment/soil, as required;

Dispose of all contaminated debris, water, soil, cleaning materials and absorbents generated by

the clean-up operation to approved disposal site; and

Take all necessary precautions to ensure that the incident does not recur.

h) During on-site activities, the following spill response resources shall be available close to potential

sources of fuels and/or hazardous materials in readiness to respond to accidental releases:




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Absorbent materials (e.g., sorbent pads, Sorb-All, vermiculite);

Small hand equipment (e.g. shovels, tool kit, sledgehammer, buckets, tarpaulins, one (1) empty

drum, personal protective equipment (PPE); and

A fire extinguisher.

i) The Contractor„s EM shall follow all procedures outlined in the Agency‟s MHASP, Emergency

Response and any additional protocols outlined in the Contractor‟s AHASP. Work in the area shall

only resume once the spill has been cleaned or contained and the leak stopped.

In the event of personal injury or a near miss involving on-site workers, incidents are to be reported to the

Contractor‟s Site Supervisor, who will submit written documentation of the incident to the Consultant

who will pass the documentation on to the Agency and, if necessary, to NSE, according to the provisions

outlined Agency‟s MHASP. Any additional protocols outlined in the Contractor‟s AHASP shall also be

implemented, as required.

Table 12: Spill Report Requirements

Item

No.

TDGA

Class

Description of Contaminant Amount

Spilled

1. 1 Explosives any amount

2. 2.1 Compressed gas (flammable) 100 L

3. 2.2 Compressed gas (non-corrosive, non-flammable) 100 L

4. 2.3 Compressed gas (toxic) any amount

5. 2.4 Compressed gas (corrosive) any amount

6. 3 Flammable liquids 100 L

7. 4.1 Flammable solids 25 kg

8. 4.2 Spontaneously combustible solids 25 kg

9. 4.3 Water reactant solids 25 kg

10. 5.1 Oxidizing substances 50 L or 50 kg

11. 5.2 Organic peroxides 1 L or 1 kg

12. 6.1 Poisonous substances 5 L or 5 kg

13. 6.2 Infectious substances any amount

14. 7 Radioactive substances any amount

15. 8 Corrosive substances 5 L or 5 kg

16. 9.1

(in part)

Miscellaneous products or substances, excluding PCB mixtures 50 L or 50 kg

17. 9.1

(in part)

PCB mixtures of 50 or more parts per million 0.5 L or 0.5 kg




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Item

No.

TDGA

Class

Description of Contaminant Amount

Spilled

18. 9.2 Environmentally hazardous substances 1 L or 1 kg

19. 9.3 Dangerous wastes 5 L or 5 kg

20. none Asbestos waste as defined in the Asbestos Waste Management Regulations 50 kg

21. none Used oil as defined in the Used Oil Regulations 100 L

22. none Contaminated used oil as defined in the Used Oil Regulations 5 L

23. none A pesticide in concentrated form 5 L or 5 kg

24. none A pesticide [in] diluted form 70 L

25. none Unauthorized sewage discharge into fresh water or sensitive marine water 100 L

26. none Ozone depleting substances as defined in the Ozone Layer Protection Regulations 25 kg

8.1.3. Malfunctions and Accidents Contingency Plan

During the course of the work on the Project, there is a possibility that some of the following

malfunctions and accidents could occur:

a) Failure of heavy construction machinery or remediation equipment resulting in construction delays,

damage to remediation efforts and/or personal injury.

b) Failure of structural components during the course of site remediation activities (e.g. containment cell

breach during dewatering), resulting in construction delays, damage and/or personal injury.

c) Failure of site mitigation controls.

d) Off-site traffic accident resulting in personal injury, damaged equipment/vehicles and/or spillage of

fuel, construction materials or contaminated excavation materials.

e) On-site traffic accident resulting in personal injury, damaged equipment/vehicles and/or spillage of

fuel, construction materials or contaminated excavation materials.

To minimize the risk of the listed potential malfunctions and accidents, all those working on the Project

shall follow the following precautionary procedures:

a) All on-site equipment, machinery and structural components of the construction area are to be

routinely inspected and monitored to ensure proper working order.

b) The Contractor Traffic Management Plan (Section 5.2), will be followed to ensure that proper traffic

safety protocols are set out for all those operating motorized vehicles on or off-site. It is the

responsibility of the Contractor‟s Site Supervisor to ensure that the plan is followed.




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c) Specific Health and Safety Plans shall be completed and followed for all activities on-site, as

specified in the Agency‟s MHASP. These additional Health and Safety Plans shall be contained

within the Contractor‟s AHASP.

In the event of a vehicle or machinery malfunction or collision off-site:

a) The appropriate authorities shall be notified by the Contractor‟s Site Supervisor.

b) Any and all spilled construction materials or contaminant spills shall be dealt with in accordance with

the procedures outlined in Section 8.1.2.

In the event that a malfunction or accident occurs such that those working on or off-site are in the

immediate area are in danger, the following measures, in addition to the provisions established in the

Contractor‟s AHASP, shall be followed:

a) The area shall be immediately evacuated by the Contractor‟s Site Supervisor and appropriate

emergency personnel notified.

b) The Contractor‟s Site Supervisor shall ensure that all those working in the area are accounted for

following evacuation. Any persons missing shall be reported immediately to appropriate emergency

personnel.

c) No one shall re-enter the work area until notified by emergency personnel and the Contractor‟s Site

Supervisor that it is safe to do so.

d) Whether the malfunction and/or accident occur on or off-site, the Contractor‟s Site Supervisor shall

report the incident to the Contractor‟s EM, the Consultant, the Agency and NSE and all appropriate

emergency personnel. The Agency shall inform the regulatory authorities of the reported incident, if

warranted.

e) In the event of personal injury or a near miss involving on-site workers, all incidents are to be

reported to the Agency and NSE by the Contractor‟s Site Supervisor, according to the provisions

outlined in the Agency‟s MHASP. Any additional protocols outlined in the Contractor‟s AHASP

shall also be implemented, as required.

8.1.4. Fire Response Contingency Plan

There exists the potential for fires on all work sites that involve mechanical equipment and fuels;

however, mitigative measures can be taken to minimize the potential for fires at the work site. All




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precautions necessary shall be taken to prevent fire hazards when working at the Site. These include, but

are not exclusive to:

a) All flammable waste shall be removed on a regular basis and disposed of at an approved disposal site,

according to the Detailed EPPs.

b) All fire equipment on the work site are to be checked on a routine basis, in accordance with local fire

safety regulations, to ensure the equipment is in proper working order at all times.

c) All potential fire hazards are to be identified by the Contractor‟s Site Supervisor prior to beginning

work in an area. If a fire hazard exists, all on-site personnel working in the vicinity are to be property

notified and trained in how to mitigate the risk.

d) A meeting location (i.e. muster point) shall be established by the Contractor‟s Site Supervisor for

each working area, such that in the event of an emergency, on-site workers will know where to

gather.

e) Fire extinguishers shall be available at the work site. Such equipment shall comply with and be

maintained to the manufacturers‟ standards.

f) All workers shall be instructed in fire safety and emergency response protocols, as outlined in

Detailed EPPs and the Contractor‟s AHASP.

In the event that an incident involving fire does occur, the Agency‟s MHASP and Contractor‟s AHASP

shall be consulted. In addition, the following safety protocols shall be followed:

a) In the event of any fire, large or small, on-site personnel shall immediately notify the appropriate Fire

Department. The Contractor‟s Site Supervisor shall also be notified immediately.

b) If and only if, the fire poses no immediate threat to human safety and only after help from the fire

department is on the way, on-site personnel shall take immediate steps to extinguish the fire using the

appropriate fire extinguishing equipment.

c) If the fire cannot be contained, all on-site personnel shall vacate the area. All warnings shall be

delivered in such a way that the safety of vacating workers is not jeopardized.

d) On-site workers who have vacated the area of the fire shall gather at a safe location, identified by the

Contractor‟s Site Supervisor, who will also insure all workers who had been working in that area are




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accounted for. All missing persons shall be reported to the appropriate Fire Department personnel

upon their arrival to the scene.

e) No worker is to re-enter the vacated area until a safety clearance has been issued by Fire Department

personnel to the Contractor‟s Site Supervisor.

f) All incidents involving fire shall be reported by the Contractor‟s Site Supervisor to the EM, the

Consultant, the Agency, NSE and all appropriate emergency personnel. The Agency shall inform the

regulatory authorities of the reported incident, if warranted.

g) In the event that a fire event leads to a spill of contaminated material, the procedures and reporting

protocol outlined in Section 8.1.2. shall be implemented.

h) In the event of personal injury or a near miss involving on-site workers, all incidents are to be

reported to the Agency by the Contractor‟s Site Supervisor, according to the provisions outlined in

the Agency‟s MHASP. Any additional protocols outlined in the Contractor‟s AHASP shall also be

implemented, as required.

8.1.5. Environmental Contingency Plan

FLOODS

The likelihood of severe flooding that would materially affect the remediation efforts underway at the

Sydney Tar Ponds and Coke Ovens Sites is slim due to the flow regimes of the channels. Element-

specific concerns are outlined in the Detailed EPPs, as each area would be potentially affected by

different flooding types and sources.

All precautions are to be taken to ensure that in the event of severe weather, the integrity of the Project

and the safety of the workers will be maintained. These precautions include:

a) Consideration of the weather forecast for the Site.

b) All equipment and products are to be stored no closer than 30m from any watercourse or shoreline to

prevent shifting and associated environmental consequences in the event of the flooding.

Although flooding, were it to occur, would affect different site areas and Project activities in different

ways, the following general procedures shall be followed in flood conditions:

a) In circumstances where flooding is localized to specific areas, the Contractor‟s Site Supervisor will

instruct site workers to move vehicles and equipment out of low-lying areas prone to flooding for




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temporary work relocation. The same procedure shall be followed if flooding is expected to dissipate

in the short term.

b) All reasonable measures are to be taken by the Contractor‟s Site Supervisor to protect unfinished

Project elements remaining in the pathway of floodwaters from damage, either through the erection of

temporary flood barricades (e.g. sand bags) or by other means (e.g. tarps).

c) If extreme flooding occurs, all work shall be temporarily stopped. All workers shall vacate

potentially hazardous site areas and meet in a safe area established by the Contractor‟s Site

Supervisor.

d) Following a flooding event, the stability of the shoreline and work areas is to be investigated to

ensure safe working conditions and to assess any environmental impacts or damage to construction

elements. Only after the safety investigation has been completed by the Contractor‟s Site Supervisor

shall work resume in the affected area.

e) Any harmful environmental effects resulting from flooding shall be assessed and a restoration plan

developed, if necessary.

f) All incidents of flooding resulting in harmful environmental effects shall be reported by the

Contractor‟s Site Supervisor to the EM, the Consultant, the Agency, NSE and all appropriate

emergency personnel. The Agency shall inform the regulatory authorities of the reported incident.

SEVERE WEATHER

Severe weather conditions including high winds (when persistent wind gusts exceed 70 km/hr), heavy

rainfall (20mm within a twenty-four (24) hour period rain event), ice storms, lightning strikes and

extreme temperatures could effect on and off-site remediation activities. Impacts could include, but are

not absolutely limited to:

a) High winds could cause more medium and fine-grained particles to become airborne, leading to

difficult working conditions and potential health impacts, especially if contaminated sediments are

lifted.

b) High winds could also lower the stability of tall equipment, which could potentially lead to the

toppling of the equipment. As such, no workers should operate or be in the vicinity of tall equipment

during periods of high winds and the machinery shall be safely reconfigured to minimize height.




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c) Heavy rainfall may result in flooding and a high volume of overland sheet flow with potential effects

on-site work, exposure of contaminated materials and compromised decontamination procedures,

sedimentation and impacts to the aquatic environment.

d) Ice and snowstorms could affect the safety vehicular traffic on and off-site through compromised road

conditions and decreased visibility. Progress on project elements may slow or need to be ceased

entirely if the storm is severe enough.

e) Lightning strikes while operating machinery could affect the safely of on-site workers in the vicinity

of large conductive equipment. All site work shall be temporarily ceased if lightning is present and

all workers shall clear the work area to a safe location.

f) Severe weather may cause a loss of site power, which could affect the integrity of the Project. All site

work shall be temporary ceased and all workers shall meet in a safe location.

g) Extreme heat or cold could place added stress on outside site workers, requiring a greater degree of

worker self-monitoring and the provision of appropriate break areas.

All precautions are to be taken to ensure that in the event of severe weather, the integrity of the Project

and the safety of the workers will be maintained. These precautions include:

a) Ensuring that exposure of incomplete or ongoing structural elements is limited.

b) Designing active areas to include surface water drainage, erosion control swales and holding points.

c) Enclosing areas used for storage of contaminated or hazardous substances or, if not enclosed,

establishing containment structures sufficiently large to manage unusual storm events without

uncontrolled discharge to the environment.

In the event of a severe weather occurrence (excluding temperature), the following procedures shall be

followed:

a) The Contractor‟s Site Supervisor will monitor weather forecasts and shall be responsible for

communicating all severe weather alerts to on-site workers and ensure that proper storm preparation

is undertaken.

b) If the weather event is sudden and no warning was available, all work shall be temporarily, but

immediately, stopped. All workers shall vacate potentially hazardous site areas and meet in an area

established by the Contractor‟s Site Supervisor.




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c) If time allows, all areas under construction are to be covered or otherwise protected against the

impending storm prior to the onset of the severe weather event and the area vacated. Only after site

safety has been insured by appropriate personnel and the status communicated to the Contractor‟s Site

Supervisor shall work resume in the area.

d) Following all severe weather events, a thorough investigation of shoreline integrity and stability and

an assessment of the likelihood of a hazardous spill or leak, shall be conducted by the Contractor.

The findings of this investigation shall be compiled into a report.

e) In the event of personal injury or a near miss involving on-site workers, all incidents are to be

reported to the Agency and NSE by the Contractor‟s Site Supervisor, according to the provisions

outlined in the Agency‟s MHASP. Any additional protocols outlined in the Contractor‟s AHASP

shall also be implemented, as required.

f) In the event that flooding or hazardous spills occur as a result of a sever weather event, all appropriate

contingency plans and relevant guidelines set out for those occurrences shall be followed.

g) In the event of extremes in temperature, all precautions outlined in the Contractor‟s AHASP shall be

followed to protect worker safety and work will continue at an adjusted level. However, if the

Contractor‟s Site Supervisor feels that temperature extremes are such that working conditions are

unsafe regardless of added safety provisions, he or she maintains the right to call a temporary stop-

work order. If this occurs, all appropriate site contacts will be notified and a formal report submitted

to the Agency.

SEISMIC EVENTS

Based on the seismic activity generally experienced in the area of the Sydney Tar Ponds, it is unlikely that

seismic activity will have an adverse effect on Project construction elements and other related activities.

All construction activities and machine operations shall temporarily cease in the event of severe seismic

activities. A safety inspection will be carried out prior to recommencing activities and an incident report

will be filed.

CLIMATE CHANGE

Climate change, otherwise defined as the change in temperature, precipitation and wind speed averaged

over several decades or more, influences the frequency and severity of weather events and sea levels.

While temperatures in Atlantic Canada are expected to increase between 3 and 4°C over the next 100




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years, influencing both rainfall and storm surges, given the length of construction activities, the effects of

climate change are not expected to have manifested themselves to a degree that adversely effects the

implementation phase of the Sydney Tar Ponds and Coke Ovens Remediation Project. However, any

flooding and/or erosion shall be dealt with according to procedures outlined in Sections 8.1.4 and 8.1.7

and other relevant contingency plans.

8.1.6. Restricting Public Access Contingency Plan

As with any construction site, there exists a potential for vandalism, theft and trespassing on-site during

and/or after construction hours. The potential impacts of unlawful intrusion could include, but are not

limited to:

a) Theft of construction equipment, supplies or confidential information.

b) Damage to site barriers, including chain link fences and locks.

c) Disruption of construction area including tampering with equipment or supplies and general

disturbance of site re-vegetation efforts.

d) Personal injury as a result of trespassing, either to the trespasser or on-site workers.

If a trespasser is seen on-site:

a) The trespasser must be immediately escorted from site and the Contractor‟s Site Supervisor notified.

b) If the trespasser refuses to leave the site, the Contractor‟s Site Supervisor or night watchperson shall

immediately call the appropriate authorities and halt construction activities within the immediate area.

c) Once the trespasser has been cleared from the site, site activities shall resume and a site check shall be

initiated by on-site workers to determine if any damage was done to the site, equipment or site

barriers.

d) All incidents involving trespassing are to be reported by the Contractor‟s Site Supervisor or night

watchperson to the Agency, NSE and emergency personnel, if necessary. The incident shall be kept

on file by the Agency, which shall also insure that the any issues regarding site barriers are addressed,

if necessary.

If signs exist that a trespasser has been on the property (i.e. damage to site barriers, movement of

equipment or supplies, missing supplies or equipment, etc,) but no trespasser is currently on the property,

the following steps shall be taken:




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a) An attempt shall be made by the Contractor‟s Site Supervisor to determine where the trespasser

gained access to the Site. Appropriate signage shall be posted where suspected trespasser access

occurred.

b) All damaged barriers shall be repaired within forty-eight (48) hours or, if necessary, replaced within

seventy-two (72) hours. If barriers replacement is required, temporary barriers shall be erected. Any

damage locks shall be replaced within twenty-four (24) hours, inclusive of weekends and Statutory

Holidays.

c) On-site workers shall evaluate the condition of their equipment to ensure safe working order.

d) All missing or damaged equipment shall be reported to the Contractor‟s Site Supervisor, who will

then notify the appropriate law enforcement officials. The Contractor‟s Site Supervisor shall then

order replacement parts, supplies or repairs.

e) The night watchperson shall be notified of the intrusion and the suspect area where this intrusion

occurred.

f) If trespassing develops into an ongoing issue, further security measures, such as additional

watchpersons or movement-sensitive lights and/or cameras, shall be considered.

g) Again, all incidents involving trespassing are to be reported by the Contractor‟s Site Supervisor or

night watchperson to the Agency which shall keep the incident on file and insure that the any issues

regarding site barriers are addressed.

In the event of personal injury or a near miss involving either on-site workers or the trespasser(s), the

procedures outlined in the Agency‟s MHASP, Emergency Response shall be followed. Any additional

protocols outlined in the Contractor‟s AHASP shall also be implemented, as required.

8.1.7. Erosion/Sedimentation to Surface Water Contingency Plan

There is a possibility that a structural or equipment malfunction, accident, environmental event or

vandalism in construction areas could compromise the integrity of erosion control measures and/or slope

stability leading to surface water sedimentation and increased turbidity. Response protocols will depend

on the type of contaminants and the comparison of the contaminant level against the site-specific target

limits for surface water. The upper level criteria defined as a reportable event for turbidity will be an

increase by eight (8) Nephelometric Turbidity Units (NTUs) above background (upstream sample

location), when the background is between 8 and 80NTU. If background concentrations are greater than




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80NTU, then the upper level criteria defined as a reportable event for turbidity, will be 10% above

background (CCME, Water Quality Guidelines, 2006). The upper level criteria defined as a reportable

event for other surface water parameters are outlined in the surface water EEM.

In the event that the Consultant determines that erosion exceeds the provincial and federal

approvals/authorizations and/or the specifications as outlined in this Erosion/Sedimentation Contingency

Plan and the Contract are compromised, the Contractor shall:

a) Temporarily halt activities potentially contributing to the exceedance until levels decrease to an

acceptable level. During this time, all efforts will be made to rectify the cause of the exceedance.

b) Respond by:

Installing silt curtains around active cells and work areas;

Discontinuing or modifying water pumping rates and pre-treatment of discharged water;

Creation/repairing of sediment fences, Rip rap, check dams and/or settling ponds; and,

Repairing silt curtains and land based sediment and erosion control devices, as required.

c) Resume monitoring at the restart of the ceased activity at an increased intensity level (every fifteen

(15) minutes over a sixty (60) minute period) to verify that conditions have been abated.

d) Explanatory details documenting the erosion and any corrective measures taken will be documented

by the Contractor‟s EM in an EIL (Appendix F) and submitted to the Consultant for review.

e) Assess and record sedimentation effects on surrounding wildlife and natural habitats. If

environmental impacts are evident, efforts to restore natural habitats to pre-sedimentation conditions

shall be undertaken by the Agency or its representative. The NSE and other applicable regulatory

bodies shall also be contacted by the Agency in the event that natural habitats have been impacted by

sedimentation.

In addition, explanatory details documenting the exceedance and any corrective measures taken will be

documented by the Contractor‟ EM.

Should the upper level criteria be exceeded post-construction, responses include the evaluation of

potential contaminant sources and possible diversion or treatment.




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A list of contacts will be provided to assist site personnel in carrying out the stop-work process and other

requirements of the Contingency Plan. The list will be available at construction sites and will provide

contact information for internal personnel and external officials.

8.1.8. Dewatering Contingency Plan

Dewatering activities may be required depending on the specific element tasks. Detailed EPPs containing

dewatering contingency plans will be designed specifically for individual Project elements and shall

include:

The conditions in which dewatering activities will cease and the contingency plan will be

implemented.

The procedure to rectify dewatering issues and appropriate reporting protocols.

In the event of flooding, the procedures outlined in Section 8.1.5 should be followed.

8.1.9. Archaeology and Heritage Resource Contingency Plan

The Archaeology and Heritage Resource Contingency Plan sets out the process for preserving and

protecting historical materials uncovered by remediation activities on the Tar Ponds and Coke Ovens

Sites. The Plan‟s guidelines address what needs to be done when artefacts, First Nations and historical

features or skeletal remains are discovered and were developed to:

Prevent the destruction of archaeology and historical resource materials uncovered by construction

activity while maintaining archaeological conditions.

Ensure that artifacts or skeletal remains are properly removed or handled appropriately.

Protect all archaeological and historical discoveries in keeping with provincial regulations and

cultural practices.

Dr. Stephen Davis through Davis Archaeology Consultants was consulted and contingency plans of

Canadian municipal and provincial jurisdictions were reviewed in the development of these guidelines.

Guidelines balance project requirement for timely handling of unexpected discoveries and historic

preservation concerns.

Carrying out the Archaeology and Heritage Resource Contingency Plan will largely depend on the ability

of frontline construction personnel to recognize and value heritage resources. This makes it necessary to




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promote the nature and value of heritage materials clearly expressing their importance to the heritage of

First Nations and other historic groups within Nova Scotia. This will be done through:

Posting of an archaeology/heritage resource stop work notice at construction sites including

workplace contacts to notify when heritage material is encountered.

Creation of a short heritage awareness presentation for inclusion in the orientation provided for all

Consultant staff, construction workers and Contractor(s).

Inclusion of this Archaeology and Heritage Resource Contingency protocol in the EMP which is an

information resource for the Consultant and Contractor(s).

A list of contacts will be provided to assist site personnel in carrying out the stop-work process and other

requirements of the Contingency Plan. The list will be available at construction sites and will provide

contact information for internal personnel and external officials.

The following summarizes the procedure to be followed if an artifact, First Nations or historical feature is

encountered during construction:

a) Project personnel are directed to stop all work in the immediate area of the discovery and report the

finding to a supervisor. The Contractor will not restart work in the area of a discovery until clearance

has been given by cultural authorities from Heritage Division and First Nations.

b) The Project Manager/designee will instruct the Contractor to flag or fence off the discovery area and

take measures to protect it until it can be assessed by an Archaeologist.

c) The Project Manager/designee will report the discovery to the Manager of Special Places at the

Heritage Division, the Executive Director of the Union of Nova Scotia Indians and Mi‟kmaq Rights

Initiative (contact Roger Lewis). The information provided will include the nature of discovery,

location and how it was discovered.

d) An Archaeologist will be consulted to determine whether the discovery is isolated or completely

disturbed by prior construction activities or a significant archaeological resource requiring further

evaluation and will advise the Project Manager/designee regarding when to restart construction

activities. The Project Manager/designee will consult with provincial and First Nations

representatives with respect to restart requirements.




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e) An archaeological evaluation of the Site, if required, is to be done by the Archaeologist who is

approved by the Heritage Division, the Union of Nova Scotia Indians and Mi‟kmaq Rights Initiative

(contact Roger Lewis); provision of information about the discovery and its archaeological and

historical significance to provincial and First Nations representatives.

f) Documentation of the discovery to include:

Type of discovery – artifact or feature;

Composition – stone, wood, metal, ceramic, glass, etc.;

Location within the area of excavation – map;

Nature of the activity resulting in the discovery;

Time of discovery;

Name of person(s) who discovered the materials;

Extent of the area of discovery;

Measures to protect materials and the Site;

Photographs and profile drawings;

Present location of the material, if moved – storage, museum, university; and

Research questions associated with the discovery.

g) Carry out a plan, with the approval of Nova Scotia Museum and First Nations officials, to recover

historical resources from the archaeological site including removal and final placement.

h) Construction activities to resume upon the completion of the recovery plan and approval from Nova

Scotia Museum and First Nations officials; timely approval is needed to meet construction

requirements.

The discovery of human remains requires protective handling with respect and dignity. In the event that

skeletal remains are uncovered during the course of work, the following procedures shall be followed:

a) Project personnel will stop all work in the immediate area to keep at a minimum the disturbance of

bones and other associated materials; the site will be preserved and protected until burial concerns

have been resolved.




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b) The Project Manager will instruct the contractor to secure the site to make sure that vital data are not

destroyed and exposure to the weather and casual viewing are minimized; all artifacts found in the

burial area are to be considered grave goods and kept with the skeletal remains.

c) The Project Manager will contact the local police and coroner who will determine whether the

remains are human, part of a burial or crime scene; age at death, sex and cultural group to be

determined by a Forensic Anthropologist/Archaeologist who will also determine if any scientific

analysis of skeletal remains or grave goods will be conducted.

d) The Project Manager will inform the Manager of Special Places at the Heritage Division and

Cemeteries Regulations officials in the Heritage Division of the Nova Scotia Ministry of Tourism,

Culture and Heritage about the discovery.

e) If the remains are of Aboriginal peoples, the Project Manager will immediately consult with the

Union of Nova Scotia Indians and Mi‟kmaq Rights Initiative (contact Roger Lewis) to inform them

about the discovery and obtain permission to conduct scientific analysis of skeletal remains and grave

goods, if necessary.

f) Project Manager will inform the representative (religious, historical) of the deceased that are not

Aboriginal about the discovery and obtain permission to conduct scientific analysis of skeletal

remains and grave goods.

g) An Archaeologist shall be engaged to assist in the investigation of the nature and extent of the

discovery of the human skeletal remains and cultural associations; the Archaeologist will consider

bone condition and discoloration, artifacts around the discovery site, knowledge of known

archaeological sites in the area, presence/absence of a coffin, depth of remains, position of body and

presence of grave goods.

h) The Project Manager will obtain a declaration from Cemetery Regulations officials whether the Site

is an Aboriginal people‟s cemetery. A cemetery that is not Aboriginal will require the identification

of a representative of the deceased from the same religious or cultural affiliation. This representative

shall:

Oversee the removal of the remains to a designated resting place; an Aboriginal cemetery, other

existing cemetery or in an area on the Site.




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Negotiate with the Agency the costs of uncovering, removing and re-interning remains with

minimum damage while observing religious and other cultural requirements, processing

documentation and the cost of reburial.

i) Approval must be obtained by the Project Manager to restart construction activities from provincial,

local and relevant cultural authorities.

j) The Project Manager is responsible for the preparation of a report containing information on:

Location of discovery;

Nature of activity resulting in the discovery of the remains;

Time of discovery;

Name of person(s) who discovered the remains;

Measures to protect remains and the site;

Cultural association of the deceased, if available;

Boundaries and maps of the discovery area;

Style and manner of burial;

Description of artifacts;

Archaeological methods;

Local and Aboriginal knowledge; and

Present location of remains and grave goods.

k) A media representative from the Community Liaison Committee for the Project shall handle media

interest and ensure that photographs of skeletal remains are not publicly displayed, as this is

disrespectful to the deceased and offensive to the representatives of the deceased.

8.1.10. Unexpected Site Conditions Contingency Plan

While most conditions within the Project work area are known, it is possible that unanticipated site

conditions could be encountered. Proper management procedures, regarding the discovery of active

pipelines or utilities, or soil and/or groundwater impacts, are required to ensure the safety of on-site

workers.




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ACTIVE PIPELINES AND UTILITIES

It is the responsibility of the Contractor to ensure that any pipelines or utilities on site are located and are

inactive prior to the commencement of construction activities. However, should the Contractor uncover

an active pipeline or utilities during the course of construction activities, or a pipeline containing the

remnants of a suspected hazardous material, the Contractor is to notify the Agency and the Consultant

immediately for the arrangement of proper shut-off and/or removal.

UNANTICIPATED DISCOVERY OF MATERIAL OR SITE AREA CONTAMINATION

To more accurately predict the exact conditions of each construction or activity area, a pre-assessment of

site risk shall be conducted prior to the commencement of construction activities. All workers are to be

trained to recognize potential contaminants and the procedures to follow if unexpected conditions are

encountered.

EMERGENCY PROCEDURE

When responding to unexpected site conditions during construction, the following procedures shall be

followed:

All work in the vicinity of the discovery shall be immediately stopped and the site secured. The

Consultant shall ensure that the Site is secured and that the appropriate response is initiated.

A worst case scenario shall be assumed and personnel shall stay away from the work area. The scene

shall be cordoned off to prevent contact with the pipeline, utilities or hazardous materials, until it is

determined that it is safe to do so.

Sampling of contaminated soil is to be arranged, so that the degree of contamination can be

determined. The soil sample shall be submitted to a laboratory for chemical testing.

The Consultant shall provide the Project Manager with the approach developed for site clean-up. The

Project Manager shall review and approve the approach for clean-up prior to commencing.

The Consultant will implement the approved plan and provide the Project Manager with written

progress reports. A final report, summarizing all activities related to clean-up, shall be prepared by

the Consultant and submitted to the Project Manager and Agency.




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8.1.11. Cumulative Effects Contingency Plan

Cumulative effects may occur when the environmental impact of one Project element or activity

combines with the impact of other past, present and future Project elements and/or other

projects/activities in the area. If it is discovered during the course of environmental effects monitoring

that cumulative impacts associated in whole or in part with the Sydney Tar Ponds and Coke Ovens

Remediation Project are likely to exceed pre-defined definitions of significance as contained by the EIS,

or are likely to occur if the planned procedures are followed, then adaptive management must be

implemented to mitigate these effects. Appropriate response procedures will depend on the type of

exceedances that are witnessed or expected to occur. The EIS identifies four criteria that must be

considered when assessing whether cumulative effects may result from Project activities:

a) The status of another element or activity, whether it is past or existing, certain or planned, or

reasonably foreseeable.

b) The potential for overlap related to timing of the Project and or element activities.

c) The potential for overlap related to the type of effect, whether the impact of the activity is similar to

the Project-related residual effects.

d) The potential for spatial overlap of Valuable Environmental Components (VECs).

e) The EIS explores a number of implemented and planned activities on the Sydney Tar Ponds and Coke

Ovens Remediation Project and the likelihood that interaction between them will lead to cumulative

effects.

Mitigation for cumulative effects tend to be more regionally oriented, rather than spatially associated with

specific Project activities. The EIS has identified the likely cumulative effects and mitigation measures

required to result in minor adverse or beneficial residual effects, as shown in Table 13. The Contractor‟s

Site Supervisor shall be aware of possible cumulative effects as described in the EIS, in addition to

understanding and implementing the appropriate mitigative measures to result in insignificant or

beneficial environmental effects.




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Table 13: Cumulative Effects, Mitigations Measures and Significance

VEC Potential Cumulative Effect Mitigation/Enhancement

Residual

Cumulative

Effect

Significance

1 Groundwater,

Surface

Water, Soil

Quality

Resources

Potential for adverse cumulative effect:

Mounding of groundwater along

western shore of Muggah Creek

channels and groundwater

collection system along SYSCO

property with potential for changes

in local groundwater flow field

Coordination with

remediation designs for

adjacent properties

If required: design

refinements (groundwater

collection system, e.g.,

French drains)

Minor adverse

effect

(localized;

effective

mitigation

available)

Insignificant

Potential for beneficial cumulative

effect:

Overall reduction in contamination

levels in concert with other

remediation projects and

preventative works

No enhancement measures

required/identified

Beneficial

effect

Not

evaluated

2 Marine

Habitat and

Biota


Loss of marine habitat/estuary

habitat

Coordination of habitat

design of new channels

with habitat designs at

Battery Point Cofferdam

Beneficial

effect

Not

Evaluated


effect:

Overall reduction in contamination

levels in concert with other


preventative works

No enhancement measures

required/identified

Beneficial

effect

Not

Evaluated

3 Freshwater

Habitat and

Biota


effects:

Overall reduction of contaminant

levels and exposure of freshwater

biota to CoCs in concert with other


preventative works

Habitat enhancements

(buffer plantings) along

embankment of new surface

water channels;

Integration of new stream

channels into future

habitat/open space network

Beneficial

effect

Not

evaluated

4 Wildlife/

Vegetation


Loss of habitat and vegetation

communities typical for derelict

sites in urban environments

Re-creation of high-quality

diverse habitat in

remaining/future open

space

Linear habitat along water

courses

Minor adverse

effect (affected

features are

common and

easy to

recreate)

Insignificant

5 Labour and

Economy


Temporary construction-related

employment

Potential for sustained future

economic growth

Maximize use of local

supply and labour markets

Communication with local

economic development

department

Communication with

community at large

Beneficial

effect

Not

evaluated




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In addition to the long-term potential cumulative effects listed in Table 13, the interaction of several

Project components could impact regional air quality in the short term as well. As such, real time air

monitoring will be implemented to monitor air quality exceedances instantaneously. If results from this

program show an exceedance, as described in the Real Time Monitoring Program (provided in the

Detailed EPPs), an investigation to determine the source shall be immediately initiated by All Tech. If

the source is identified as being generated off-site, All Tech will notify the Agency, who will in turn

notify NSE and the CBRM. Any issues shall be resolved between the various parties without unnecessary

delay to the Project. Any data collected during this time must be documented, analyzed and included

within a written account of the investigation.

8.1.12. Key Contact List

As part of this assignment, it is important that communications occur in an efficient manner. This will

require that contact names and phone numbers of critical personnel and services are readily available at

all times. This is also important for key organizations and/or individuals that may be contacted during

emergency situations and/or regarding regulatory issues. The Emergency Contact List for this project

will be provided under a separate cover and updated on a monthly basis by the Agency‟s designate and

distributed to all affected parties.

8.2. Contingency Planning in Detailed EPPs

Contingency plans shall be included in the Detailed EPPs to address potential risks resulting from specific

element tasks. While the EMP provides an overview of contingency plan procedures, the Detailed EPPs

shall be consulted and kept on hand during site activities in the event of an incident requiring mitigative

action. The Detailed EPP and the Contingency Plans therein are to meet the following requirements:

a) Identify the physical and chemical properties and characteristics of the materials being used; where

they are located in relation to the surrounding area; and how they are stored, handled or transported.

b) Identify the potential concerns/problems or emergency scenarios associated with these construction

activities or release of the material (including both on-site and off-site) to determine what could go

wrong that would lead to an accident or emergency.

c) Develop and implement prevention measures in the construction activities or material use to reduce

the likelihood of an emergency occurring (i.e.; train staff, identify potential issues in current practices

and change them accordingly, etc.).




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d) Describe roles and responsibilities of key personnel and responders during an emergency.

e) Provide contact lists for emergency resource personnel and equipment.

f) For each potential accident or emergency, develop plans to address the “next steps” should the

prevention measures fail to work or emergency situations arise including measures to be taken to

notify members of the public who may be adversely affected by the emergency.

g) Document and communicate reportable incidents and establish clear callout and notification

procedures for all relevant agencies.

h) Review the Contingency and Emergency Response Plans with Agency and Project Manager to obtain

comment and revise accordingly.

i) Ensure that the Contractor‟s Site Supervisor who is responsible for implementing the finalized

Contingency and Emergency Response Plans is fully versed with all aspects of each plan.

j) Train all on-site personnel with the procedures contained in the Plans and integrate these procedures

into the EPPs for implementation.

k) Revise the Contingency and Emergency Response Plans as required throughout the Project to address

new issues as they arise and update on-site personnel appropriately.

8.3. Implementation Responsibilities

Once the Contingency and Emergency Response Plans have been developed and approved, the

responsibility for implementing them lies with the Contractor and Environmental Consultant. Specific

responsibilities of the Environmental Consultant include:

Reviewing the Contingency Plans and Emergency Response Plans and identifying any issues or

concerns to the Project Manager and providing suggested changes and updates.

Providing advice to construction staff on proper emergency response procedures.

Monitoring the Contractor(s)‟s response to events resulting in the activation of its Contingency Plans

and Emergency Response Plans and reporting to the Project Manager on the effectiveness of the

response.

Initiating actions to correct any response deficiencies identified through the audit process and

bringing this to the attention of the Project Manager.




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Documenting the implementation of the Contingency and Emergency Response Plans in emergency

response records for review by the Agency and the appropriate regulatory agencies.

Specific responsibilities of the Contractor(s) include:

Ensuring that all construction personnel are trained in Contingency Plan Implementation and

Emergency Response Techniques and that they have the appropriate equipment on hand.

Implementing Contingency and Emergency Response Plans when environmental situations, as

described in Section 8.1 of this EMP and in the Detailed EPPs, occur.

Documenting the implementation of the Contingency and Emergency Response Plans for review by

the Consultant, Agency and the appropriate regulatory agencies.

The emergency response records are to be incorporated into the monthly monitoring reports to identify

the response that had to be taken so that changes can be made to the appropriate EPP and the lessons

learned can be applied. For example, in the event of the failure of erosion and sediment control measures,

the results of the emergency response are to be documented in the Monthly Environmental Report, including

the nature of the failure, the preventive measures which could have been implemented to avoid the incident

(if possible), the emergency response measures taken to control the failure, the effectiveness of those

emergency response measures and the extent of the release of sediments.

9.0 ENVIRONMENTAL AWARENESS TRAINING

This section describes the approach to be taken by the Contractor(s) in developing and implementing

environmental awareness training to ensure that all on-site personnel are aware of the environmental

sensitivities associated with their actions; their roles and responsibilities in protecting the environment;

and, the mechanisms available to them to carry out their environmental protection responsibilities.

The Contractor(s)‟s Environmental Awareness Training Program must satisfy the following three main

goals:

a) Educate workers and visitors about the importance of environmental protection. While most

individuals may have some understanding of the importance of environmental protection, many

individuals may not fully understand or appreciate the relationship between their actions and

environmental degradation.




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b) Inform staff and visitors of their responsibilities regarding the environment and provides them with

the necessary educational tools to fulfill these responsibilities.

c) Provide workers with a firm understanding of the environmental sensitivities associated with the

Project and the role they play in protecting the environment, as outlined in this EMP (through

implementation tools such as the EPPs and Contingency and Emergency Response Plans).

The elements the environmental training program must include are:

Identification of the training needs based on the proposed construction activities;

Identification of each component of the training program;

Identification of the means by which employees/visitors will be trained;

Documentation of the information provided during training;

Evaluation of the effectiveness of the training received by each employee or visitor;

The basis for retraining employees/visitors; and

Identification of the means for implementing on-going training.

The Contractor in consultation with the Agency, must approve the training program before construction

starts. Once approved, the Consultant shall be provided with all training records and shall keep track of all

training completed. The Contractor is responsible for ensuring that all on-site personnel have undergone

environmental awareness training before working on the Site. Proof of completion of the training

program must be kept on file by the Consultant. The Consultant shall provide the Agency with training

records, upon request.

The awareness training must include, as a minimum, the following key factors:

The Project overview and timetable.

Overview of the environmental regulatory requirements: Overview of the existing environmental

conditions and sensitivities.

Identification of the construction activities that could negatively affect the environment; the resultant

environmental effects; and the required mitigation measures that must be implemented and

maintained to avoid or minimize these effects (e.g., proper installation and maintenance of erosion

and sediment control procedures).




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All aspects of the EMP and EPPs (including the roles and responsibilities of staff).

Environmental inspection and QA/QC procedures, roles and responsibilities.

Contingency and Emergency Response Plans.

Documentation and Reporting Procedures.

Refresher seminars are to be held as required to address any shortfalls identified during the QA/QC

program. Construction personnel are to be trained in all Contingency and Emergency Response Plans and

reporting procedures; Site visitors are to be made aware that Contingency and Emergency Response Plans

have been developed for specific potential events.

9.1. Specific Environmental Awareness Programs

As per the requirements of the Agency‟s MHASP, all personnel who are scheduled to perform work on

the Site must complete appropriate training sessions (i.e. orientation, medical surveillance, hazard

assessment and management and PPE) that commensurate with the activities and hazard level to which

the employee may be potentially exposed prior to commencement of activities. Site visitors do not

require such training; however, they may need to be accompanied by Agency personnel, or their

designate. Contractors will submit a training program as part of their AHASP for review and acceptance

by Agency.

The Contractor(s) is responsible for including specific environmental awareness programs for the various

Contingency and Emergency Response Plans in the Environmental Awareness Training of all on-site

personnel. The following sub-sections provide a brief overview of some of the considerations that must

be included in these specific environmental awareness programs.

9.1.1. Decontamination

The Contractor will address decontamination procedures for personnel, equipment and vehicles in the

Contractor‟s AHASP. Standard Operating Procedures for Decontamination shall be developed to

minimize the spread of contamination within different areas of the Site. Contractors are therefore

required to define, maintain and provide a clear delineation for the following contamination control

zones:

Exclusion Zone;

Contamination Reduction Zone; and




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Support Zone.

Contractors shall provide, as a minimum, the following:

Suitable PPE for decontamination activities;

Suitable containers for storage and disposal of used disposable PPE; and

Potable water and a suitable sanitation facility.

Contractors will be required to enforce the following provisions:

On-site personnel shall wear appropriate PPE at all times when entering or working in the Exclusion

or Contaminant Reduction Zones.

Used disposable PPE shall not be reused and when removed, shall be placed inside appropriate

containers provided for that purpose.

Soiled disposable outerwear shall be removed prior to entering the lunch area and prior to cleansing

hands.

On-site personnel shall thoroughly cleanse their hands and other exposed areas before entering the

smoking or lunch area and before leaving the Site.

All personnel in Level A or B PPE, or Level C depending on work conditions, will change to fresh

clothing after each working period or shift, prior to leaving the Site.

Water generated from washing and showering shall be stored or disposed of in accordance with

applicable regulations and standard practices.

Work boots shall be left at the Site at the end of each workday or cleaned/brushed to remove visible

dirt before leaving the Site. Grossly contaminated boots shall be left at the work site.

9.1.2. Spills Response

All employees of the Contractor(s) and its sub-Contractor(s) must aware of the provisions outlined in

Section 8.1.2 and be trained in proper spill response procedures including:

Spill prevention;

Worker safety and the handling of hazardous liquids;

Potential hazards involved in the Project;




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What to do when a spill is discovered;

Notification and reporting requirements;

Spill containment;

Emergency evacuation and First Aid;

Environmental regulations and appropriate government agencies; and

Spill cleanup and disposal.

9.1.3. Fire Response

In preparation for the possible event of a fire, all construction staff and sub-contractor(s) staff must be

aware of the provisions outlined in Section 8.1.4 and be trained in the proper fire response, including:

Fire prevention training, including the location and use of on-site fire-fighting equipment;

Explanation of the purpose of the Fire Response Plan and when the plan is triggered; and

Explanation of the roles and responsibilities and accountability for implementing the plan.

If it is anticipated that a fire or discharge thereof, is likely to impact surrounding neighbourhoods (i.e.

through smoke, vapours released), then the affected public shall be notified using emergency broadcasting

and neighbourhood evacuation techniques, such as police patrol. If adjacent work sites are likely to be

impacted by fire, a cease work notice shall be issued and, if necessary, the affected areas shall be

evacuated.

9.1.4. Discovery of Unexpected Site Conditions

All contractor(s) and sub-contractor(s) staff must be trained to respond appropriately in the event of the

discovery of unexpected site conditions, as described in Section 8.1.10, including:

Contaminated Site recognition;

The importance of stopping work and how to secure the site;

The importance of the proper management of contaminated materials;

Notification of appropriate personnel; and

Site clearance before re-starting work.




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9.1.5. Archaeology and Heritage Resources

All employees of the contractor(s) and sub-contractor(s) must be trained in the proper response to the

discovery of archaeology and heritage resources, as outlined in Section 8.1.9, including:

The importance of protecting archaeology and heritage resources;

Recognition of archaeology and heritage resources; and

Procedures for stopping work, notification and work start-up.

10.0 COMMUNICATION AND REPORTING

Additional communication protocols and procedures to those found herein are currently being developed

by communication personnel at various levels of government. As such, this Communication and

Reporting section is subject to revision to reflect updated information as it becomes available.

10.1. Communication

Part of the success of the Project will require clear lines of communication, both within the Project and

externally. A Public Communication Plan is being developed by the Agency to inform public of planned

activity and schedule, to ensure timelines and effectiveness of internal and external communication,

including communications with the community and media, addressing the complexity of issues associated

with the Project.

As an integral part of the Project Team, Agency staff will communicate directly with the other team

members on a regular basis through attendance at project meetings, through telecoms and correspondence

and involvement in key decisions.

The Agency communications team will be provided with current information on Project progress and

issues and with support required to manage communications with stakeholders and interest groups.

The primary contact for this assignment will be between the Consultant‟s Project Manager and the

Agency‟s Project Director. During the start-up phase of the Project, clear communication protocol

between both parties will be established. It is imperative that all communications follow the protocol

established. This protocol will be developed jointly by the Consultant and Agency.




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10.2. Public Reporting Protocol

The Sydney Tar Ponds Remediation Project will have an impact not only on the immediate Project area,

but also the surrounding neighbourhoods. Discharges to air, mitigation efforts regarding surface and

groundwater contamination and an influx of activity due to construction and remediation activities will be

monitored and results must be reported by the Agency to all those potentially impacted by these activities.

The purpose of the Public Reporting Protocol (PRP) is to establish which monitoring results and site

activities will be reported by the Agency, how this reporting will take place and the frequency with which

these reports will be issued. More specifically, the PRP sets out the details of which communication

methods the Agency will use to most effectively report results to individuals who are invested, involved

or interested in the Project or are members of the general public.

This Public Reporting Protocol has been developed to promote the following key principles:

PROTECTING PUBLIC HEALTH AND SAFETY

Health and Safety protocols are continuously implemented during on and off-site Project activities and

have been designed to protect the health and safety of both Project workers and the public. In addition,

resources have been dedicated to ensure that health and safety is integrated with all aspects of mitigation

and monitoring activities. From these mitigation and monitoring activities, the Agency is committed to

providing the public and all stakeholders with timely and useful information regarding the wellness of

their environment and the status of Project activities.

PROMOTING PUBLIC AWARENESS AND PARTICIPATION

The Agency is committed to promoting public awareness of the Project and ensuring that resources are

available to allow individuals to monitor the Project developments that affect them. More than just one-

way sharing of information, the Agency will set up feed-back mechanisms through the reporting mediums

selected that encourage open response and consultation with the community. These efforts will not only

add to the credibility of the Project, but also ensure that the community remains as committed to the

Project as other key Project proponents.

MAINTAINING PUBLIC ACCOUNTABILITY

Public reporting will clearly identify the agencies and companies involved in setting and fulfilling

monitoring requirements. This way, the public will be assured that proper care is being taken in the




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establishment of monitoring requirements and will have an avenue to follow if any questions arise

involving these requirements.

ENSURING THE EFFECTIVENESS OF MITIGATION MEASURES

Mitigation measures have been developed for each project activity. Commitment to public reporting will

ensure that mitigation measures are properly implemented, as the Project team is accountable not only to

regulatory and proponent agencies through the EMC, but also to the general public and other

stakeholders.

10.2.1. Reporting Results

10.2.1.1. Areas Subject to Public Reporting

The following areas of public interest will be subject to status reporting in accordance with the key

principles outlined in this PRP.

AIR MONITORING

Air monitoring reporting will be required to address the ongoing status of air quality, in addition to any

air quality issues and associated causes, arising from site-related operations. Air monitoring will mostly

be analytically based, but will also address any widespread public concerns or questions regarding air

quality that may be brought forward during the course of a reporting period. The PRP recognizes that air

quality reporting will be especially important to neighbourhoods situated adjacent to areas of project

activities.

NOISE MONITORING

Perimeter noise monitoring will be undertaken on-site whenever construction projects involving large

machinery or equipment is involved. Since excessive noise could become a nuisance to nearby residents,

noise monitoring results will be reported regularly to the public, accompanied by responses to concerns

that have been brought forward by local residents. Reports will also include references to the CBRM

noise by-laws and applicable Provincial and/or Federal guidelines, as verification that the Project

activities are within these limits.

GROUNDWATER MONITORING

Groundwater monitoring reports will be issued to the public that will address both the influence of the

channel on groundwater flow regimes and the status of potential contamination moving from off-site into




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the new channels. If a potential contaminant has been identified, mitigative measures to prevent negative

environmental affects will also be included in the Public Report.

SURFACE WATER MONITORING

Surface water monitoring results will be issued to confirm plans and activities regarding the cleanup and

stabilization of Site contaminants, in addition to the status of rehabilitation plans regarding water-based

creatures and marine habitats.

WASTE WATER MONITORING

Waste water monitoring will be ongoing, so the public will know the discharge rates and water treatment

processes that are occurring on-site. Information regarding discharge limits will also be available once

accepted by the NSE.

CAP MONITORING

Cap monitoring reports will be made available to all stakeholders, including the public, so that they are

able to understand the long-term capability of the cap to prevent the deterioration of the solidified masses

and potential migration of plant, animal, bacteria or other organisms into the capped area.

TRANSPORTATION MONITORING

Transportation monitoring is important to the public, as transportation of goods, waste, workers and

machinery to Site affects the traffic volumes, noise and air quality of surrounding neighbourhoods. To

assist the public in dealing with traffic issues and the effects of route changes, long-term major changes in

the Site transportation management regime will be reported to the surrounding public with notice. Public

feedback will be encouraged.

ACTIVITY REPORTING

Stakeholders will be made aware of all mitigation measures being implemented for specific Site activities.

In this way, they will be kept aware of what is being completed to monitor environmental effects, which

will then also be reported at the conclusion of the activity.

RESULTS OF SOLIDIFICATION AND STABILIZATION PILOT TEST

Reports monitoring the results from the solidification and stabilization pilot test will be available to the

public when completed.




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EMERGENCY REPORTING

Emergency response and alerts with respect to critical events, official actions and public protection

instructions are imperative. Notification will be issued if danger to the public exists as a result of any

occurrence on or related to Site activities, as determined by the Nova Scotia Ministry of Health.

LOCAL ECONOMIC BENEFITS REPORTING

The Agency is also committed to communicating the local economic benefits that will result to the public

as a result of the remediation work being undertaken at the Sydney Tar Ponds. Evaluations of local

prosperity directly related to Project work will be reported annually.

10.2.1.2. Reporting Guidelines for Monitoring Results

Since monitoring results will need to be seen and understood by a diverse group of stakeholders, the

following reporting guidelines for monitoring results will apply to any information that is released for the

purpose of communicating to the public:

DISTRIBUTION

Information will be distributed widely using various mediums to ensure that both key interest groups and

members of the public that are not represented by organized groups will receive knowledge of relevant

Project events and publicly reported monitoring results.

REPORTING STYLES

By using a number of reporting outlets, as described in subsequent sections of this PRP, easy access to

information by a variety of stakeholders will be maintained. For the purpose of public reporting, detailed

analytical results will be explained in plain text and supplemented with explanatory matrices, maps and

diagrams. Specialized report formats will also be available upon request to those with disabilities.

TWO-WAY COMMUNICATION

Following the PRP key principle to ensure public participation in the Project, reports will be organized

such that public comments on monitoring results are encouraged. The Agency will follow-up on public

responses received.




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ASSOCIATED COMMUNICATIONS GOALS

Along with reporting and keeping stakeholders aware of monitoring results, the overall intent of the PRP

is also to encourage a higher level of public awareness for the various Project components, their possible

effects and how to respond to emergency situations. As such, monitoring reports will also include

references to associated Project activities, the purpose of monitoring and potential effects and emergency

protocols.

10.2.1.3. Monitoring Parameters

There are a number of parameters that will be reported to the public and other stakeholders during the

course of construction and post-construction activities at Sydney. The following table, Table 14,

indicates the parameters that will be monitored during the Project, each further detailed in the Project EPP

and EEMs. The specific parameters that are monitored and reported will depend on the individual

element.

Table 14: Monitoring Parameters

Air Noise Sediments Groundwater Surface Water Marine

PARAMETERS PAH

VOCs including

benzene

Arsenic, manganese,

lead and benzene

Lower Explosive

Limit (LEL)

H2S

PCB

Dioxins/Furans

Particulates:

- PM2.5 , PM 10

(Dust)

- TSP

Wind Velocity and

Direction

Ambient

Noise

PAH

PCB

TOC

Arsenic,

cadmium,

copper,

mercury,

lead and zinc

Grain size

analyses

PAH, TPH,

BTEX

Metals

Inorganic

Chemistry

Water levels

PAH,

TPH/BTEX

Total Metals

General

Chemistry

Field

Turbidity

Flow

Water

PAHs

PCBs

General chemistry

Total metals

Field turbidity

Sediment

Grain size

PAHs

PCBs

Total organic carbon

(TOC)

Arsenic

Cadmium

Copper

Mercury

Lead

Zinc

Toxicity

Biota

PAHs

PCBs

Arsenic

Cadmium

Copper

Mercury




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Air Noise Sediments Groundwater Surface Water Marine

Lead

Zinc

Benthic

community

composition

10.2.1.4. Reporting Frequency

Different parameters require different reporting frequencies. In addition to three week notification of

transportation route changes and special task-specific reports, such as when pilot test results for

solidification/stabilization are complete, the following monitoring reporting frequencies (Table 15) will

be maintained:

Table 15: Monitoring Report Frequencies

FREQUENCY

Real Time Monthly Quarterly Annually

PA

RA

ME

TE

R

Air

Emergencies

Spills

Fires

Floods

Air

Noise

Surface water

Air

Noise

Groundwater

Sediment

Composite Samples

All monitoring results:

Including: Local

Economic Benefits

10.2.1.5. Communication Methods

Numerous mechanisms and support materials will be used to communicate monitoring results to the

public. These communication methods will include, but may not be excluded to, the following:

INTERNET WEB SITE

Air monitoring and other results will be posted on the Agency‟s Web Site, which will continue to expand

as new reports become available. The Agency Web Site will be reformatted so that it is made accessible

to people. In addition, interested parties will be able to sign up for updates on Project aspects, which will

then be forwarded electronically as they become available.




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NEWSLETTER

The Agency‟s quarterly newsletter will be available to every household and business in Sydney. The

purpose of these newsletters is to report quarterly monitoring results, provide some information on Project

activities and emergency protocols and to follow-up on issues and concerns raised by the public.

COMMUNITY FACILITIES

Hard copies of monitoring reports will be available annually at designated locations (i.e. Agency office)

for public review.

PROJECT FACILITIES

Monitoring results will be available at the Agency‟s office for any interested member of the public.

MEDIA

Summarized results and emergency notifications will be issued using print and radio media to instill

immediate public awareness and encourage public response. News from the Sydney Tar Ponds

Remediation Project will be communicated in a way that is dependent on the purpose of the message; for

instance, an immediate press release will be issued in local, regional and national media channels, as

appropriate, in the event of an emergency.

RESPONSE LINE

An automated telephone response line will be established to allow communication of views and opinions

from the public to the Agency. Public comments will be considered and responses sent when applicable.

MEETINGS

Members of the Agency will be available to meet with local groups upon request to explain monitoring

results and reports and respond to any concerns. In addition to providing immediate guidance on

questions posed at these meetings, all comments will be recorded, considered and responded to in writing,

where appropriate.

10.3. Reporting

Environmental reports will be generated monthly for the duration of the Project. Results of

environmental reports will be reviewed with the Project and Construction Managers to determine what

has worked and what actions need to be taken to remedy any identified environmental problems. This




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may involve revisions to the existing EPPs, or development of new EPPs as required. The Managers will

then ensure that the appropriate new policies/procedures or EPPs are developed and provided to the

Environmental Consultant or for implementation.

Maintenance of this EMP will be the responsibility of the Project Manager or designate to ensure that the

most current and comprehensive version of this EMP as well as EPPs are available to Project staff,

regulating agency representatives, stakeholders, interested parties and others.

This continuous improvement process of inspection/monitoring, analysis, review, policy revision and

training will ensure that the EMP is meeting Agency‟s environmental protection commitments.

10.4. Document Control

A Quality Management Plan (QMP) was prepared which documents details on the program that will be

implemented to address the specific quality assurance requirements outlined in the Agency‟s Request for

Proposal for Engineering Design and Construction Oversight Services for the Remediation of the Tar

Ponds and Coke Ovens Sites document and in the Engineering Agreement for Design and Construction

Oversight Services for Remediation of the Tar Ponds and Coke Ovens Sites. The QMP consists of a

quality assurance policy, program description, procedures, forms and effective quality control verified by

documented review, testing and inspection.

All documents produced for the Project will be subject to established control procedures as detailed in the

QMP (Appendix E). Documents will be clear, understandable and sufficiently detailed as to purpose,

method, assumptions, design input, references and units such that they may be reviewed and verified

without recourse to the originator. Templates/master copies of key documents will be made available

electronically to all team members and will be updated regularly showing evidence of the revision date or

level. Drawings will be produced electronically and will be based on the Project‟s CAD Document

Production Procedures identified in the Project Implementation Plan (PIP).

10.5. Environmental Audits

To assist in ushering in a consistent and correctly implemented EMP for the Project, an audit function

will be applied to the EMP and associated supporting plans. The audit function will be facilitated through

two existing auditing mechanism: the external QA function and the internal QC Plan.

The internal QC Program will address the implementation of the EMP and associated supporting

documents within the scope of the overall PIP, and will thereby provide an audit function related to




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overall EMP implementation.

Findings and corrective actions identified through the two audit functions will be addressed as outlined in

the Project‟s Quality Management Plan (QMP), the QCP and the IQAP.




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11.0 REFERENCES

AMEC Earth & Environmental, (2005a). Remediation of Sydney Tar Ponds and Coke Ovens Sites

Environmental Impact Statement. Sydney Tar Ponds Agency.

AMEC Earth & Environmental Limited, (2005b). Remediation of the Sydney Tar Ponds and Coke Ovens

Sites, Project Description. Sydney Tar Ponds Agency.

Canadian Council of Ministers of the Environment, (2006). Water Quality Guidelines. Author.

Canadian Environmental Assessment Agency & Nova Scotia Department of Environment and Labour,

(2005). Agreement Concerning the Establishment of a Joint Review Process for the Sydney Tar

Ponds and Coke Ovens Sites Remediation Project. Author.

Canadian Standards Association, (2003). Emergency Preparedness and Response, CAN/CSA –Z731-03.

Author.

Cape Breton Regional Municipality Council, (2005). Draft Secondary Planning Strategy of the North End

of Sydney. Author.

CBCL Limited & ENSR International (2003). Remedial Action Evaluation Report [RAER]: Tar Ponds

Site. Joint Action Group.

Government of Canada, (2007). Canada's New Government And Nova Scotia Invest $400 Million in the

Environmental Cleanup of Sydney Tar Ponds and Coke Ovens. Canada News Centre. Author.

Retrieved July 2007 from the World Wide Web:

http://news.gc.ca/web/view/en/index.jsp?articleid=271389

Government of Canada, (1999). Canadian Environmental Protection Act, c. 33. Department of Justice

Canada.

Government of Canada, (1992a). Canadian Environmental Assessment Act, c.33. Department of Justice

Canada.

Government of Canada, (1992b). Transportation of Dangerous Goods Act. Transport Canada.

Government of Canada, (1985). Fisheries Act, R.S., c. F-14, s. 1. Department of Justice Canada.

Government of Nova Scotia, (2005). Air Quality Regulations, N.S. Reg. 28/2005. Office of the

Legislative Counsel.




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97918-GEN-EMP-N-001-R2 14 June 2010

Government of Nova Scotia, (2002). Petroleum Management Regulations, N.S. Reg. 44/2002. Office of

the Legislative Counsel.

Government of Nova Scotia, (1998). Municipal Government Act, c. 18, s. 1. Office of the Legislative

Counsel.

Government of Nova Scotia, (1997). Water and Wastewater Facility Regulations, N.S. Reg. 83/97.

Office of the Legislative Counsel.

Government of Nova Scotia, (1995a). Environment Act, 1994-95, c. 1, s. 1. Office of the Legislative

Counsel.

Government of Nova Scotia, (1995b). Activities Designation Regulations, N.S. Reg. 47/95. Office of the


Government of Nova Scotia, (1995c). Environmental Assessment Regulations, N.S. Reg. 26/95. Office

of the Legislative Counsel.

Government of Nova Scotia, (1995d). Emergency Spill Regulations, N.S. Reg. 59/95. Office of the


Government of Nova Scotia, (1995e). Dangerous Goods Management Regulations. Office of the


Government of Nova Scotia, (1990). Pollution Prevention Workbook Appendix C: Contingency Plan

Criteria for Releases of Dangerous Goods and Hazardous Wastes. Nova Scotia Department of

Environment and Labour.

Government of Nova Scotia, (1989a). Dangerous Goods Transportation Act, R.S., c. 119, s. 1. Office of

the Legislative Counsel.

Government of Nova Scotia, (1989b). Special Places Protection Act, R.S., c. 438, s. 1. Office of the


Government of Nova Scotia, (1989c). Beaches Act, R.S., c. 32, s. 1. Office of the Legislative Counsel.

Government of Nova Scotia, (1989d), Motor Vehicle Act, R.S., c. 293, s. 1. Office of the Legislative

Counsel.




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Jacques Whitford, Dillon Consulting, ADI Limited, CBCL Limited, (2002a). Contaminant Loading

Study for Muggah Creek. Report to Nova Scotia Department of Transportation and Public

Works.

Jacques Whitford, Dillon Consulting, ADI Limited, CBCL Limited (2002b). Contaminant Flux from

Muggah Creek to Sydney Harbour. Transportation and Public Works.

Nova Scotia Department of Environment and Labour (2007). Environmental Assessment Approval:

Sydney Tar Ponds and Coke Ovens Sites Remediation Project. Sydney, Nova Scotia: Author.




97918-GEN-EMP-N-001-R2 14 June 2010

Appendix A

Project Site Overview




97918-GEN-EMP-N-001-R2 14 June 2010

Appendix B

Change Protocol Document

Remediation of the Tar Ponds and Coke Ovens Sites Design and Construction Oversight Services

Environmental Change Protocol

97918-GEN-PROT-N-001-RC.doc 29 October 2008

REMEDIATION OF THE TAR PONDS AND COKE

OVENS SITES

DESIGN AND CONSTRUCTION OVERSIGHT

SERVICES

ENVIRONMENTAL CHANGE PROTOCOL

97918-GEN-PROT-N-001-RC

Prepared by: Original Signed By Date: 29 October 2008

Janice Green

EMP/EPP Coordinator, AECOM

Reviewed by: Original Signed By Date: 29 October 2008

Shawn Duncan

Environmental Lead, AECOM

Approved by: Original Signed By Date: 29 October 2008

David Wilson

Project Director, AECOM




Revision Summary

Revision Date of Issue Purpose

A 17 May 2007 Initial Issue to Client

B 15 January 2008 Final Issue to Client

C 29 October 2008 Revision Issued to Client




Distribution List

STPA Project Manager (12) Sydney Tar Ponds Agency

David Wilson Project Director

Don Shosky Project Director

Shawn Duncan Environmental Director

Ray Rice Project Manager

John Fairclough Deputy Project Manager

Dan MacDonald Engineering Manager

Randy Pointkoski Construction OS Contract Admin. Manager

Jim Albury Construction Manager

Bruce Noble Design Coordinator

Robert Jones Quality Assurance Manager

Janice Green Project EMP/EPP Coordinator

File Copy CBCL Central Records

File Copy AECOM Library



TABLE OF CONTENTS

1. POLICY...............................................................................................................................................................1

2. PURPOSE............................................................................................................................................................1

3. SCOPE.................................................................................................................................................................1

4. INTERNAL REVIEW CHANGES ...................................................................................................................1

5. SCOPE OF WORK CHANGES........................................................................................................................2

6. APPROVED FOR CONSTRUCTION CHANGES.........................................................................................2

7. ENVIRONMENTAL RELATED CHANGE REQUIREMENTS..................................................................4

8. RESPONSIBILITIES.........................................................................................................................................5

9. REFERENCES....................................................................................................................................................5

i




1. POLICY

Environmental management, regulatory requirements or environmental protection measures (Environ-

mental related changes), will be implemented in a controlled manner to ensure that only authorized

changes are made and that the changes are issued to appropriate persons.

Environmental related changes will be fully documented and subject to review, coordination and approval

commensurate with the original design.

Environmental related changes will be described in such a manner as to facilitate incorporation into the

Environmental Management Plan (EMP), the Environmental Effects Monitoring Plan (EEM) and the En-

vironmental Protection Plan (EPP) documents in a timely manner.

2. PURPOSE

The purpose of this procedure is to provide guidelines to ensure environmental related changes are re-

viewed, implemented, checked and approved in a controlled manner.

3. SCOPE

This procedure applies to environmental related changes required by changes to the project scope of work

during the design phase; and, to design changes after the Approved for Construction design documents

have been issued for construction. This procedure also applies to any environmental related changes re-

quired as a result of permanent alterations in environmental protection measures employed resulting in

lessons learned. Any alterations made to the EMP or EPPs with respect to lessons learned, will also be

reflected in associated design documents.

4. INTERNAL REVIEW CHANGES

Changes made to environmental related documents, prior to each milestone peer review, will be consid-

ered as part of the iterative nature of the design process and will not be subject to formal change control.

1




5. SCOPE OF WORK CHANGES

Changes to the project scope of work that affect the environmental management, regulatory and protec-

tion requirements, will be documented on the Change Request Form QAF-020 and submitted to the

Environmental Manager for cost estimation and approval.

A record of all Change Requests will be recorded on the Scope Changes Log, QAF-021.

6. APPROVED FOR CONSTRUCTION CHANGES

This procedure applies to environmental related changes implemented after the Approved for

Construction (AFC) design documents for the Remediation of the Tar Ponds and Coke Ovens Sites pro-

ject, have been issued for construction.

All environmental related change requests by Contractors, the Sydney Tar Ponds Agency (the Agency) or

the Independent Engineer, including those for the EMP, EPPs or for terms and conditions of approvals

issues under Part V of the Provincial Environment Act, will be documented in a Request For Field

Change (RFFC) Form (QAF-032) completed by the originator of the change request and will be

submitted to the AECOM Environmental Coordinator, with additional information attached to clearly

describe the required change.

Environmental related change requests will be classified by AECOM Environmental Coordinator as either

minor or major. Major changes are defined as those affecting the results of:

• Remediation of the Sydney Tar Ponds and Coke Ovens Sites Environmental Impact Statement

(EIS) (AMEC, 2005a);

• Terms and Conditions for Environmental Assessment Approval, dated January 23, 2007, (Depart-

ment of Environment and Labour, Province of Nova Scotia);

2




• Government of Canada response to the Environmental Assessment Report of the Joint Review

Panel on the Sydney Tar Ponds and Remediation Project, December 2006 (Infrastructure

Renewal);

• Safety, regulatory or permitting requirements.

All other changes will be considered as minor.

Requests for field changes of a minor nature will be reviewed by AECOM Environmental Coordinator or

the Contract Administrator who will confirm the classification, before approval.

When the RFFC has been approved, a Field Change Record (FCR) Form (QAF-034) will be issued by the

AECOM Environmental Coordinator.

For environmental related change requests of a major nature, the Environmental Manager will coordinate

a formal review of the request for change, with the affected Design Leads, to confirm the need for and

implications of the change.

Consideration will be given to the following factors during the environmental related change review

process:

• the reasons and requirements for the changes;

• scope or complexity of change to determine extent of review;

• specific impact on EIS, Provincial Conditions of Approval, Federal Recommendations or Safety,

Regulatory or Permitting requirements;

• approval requirements; and

• assessment of proposed change will be carried out by AECOM and approved by the Agency,

NSE and the Environmental Management Committee (EMC).

3




If the need for the change is confirmed, the Environmental Manager will issue a Notice of Major Field

Change (NOMFC) Form (QAF-033) for authorization by the Project Manager of the implementation of

the change.

While the decision to approve major environment-related changes to the EMP or EPPs ultimately rests

with the NSE, these changes may also require approval from any or all of the following project

participants:

• The Agency Project Manager

• Independent Engineer (IE)

• EMC

When the required major change has been developed, a Field Change Record (FCR) Form (QAF-034)

will be issued by the AECOM Environmental Coordinator for acceptance by NSE, the Agency, IE and

EMC, so that necessary modifications to the project scope and budget can be executed and work

necessary to make the required change can proceed.

7. ENVIRONMENTAL RELATED CHANGE REQUIREMENTS

Environmental related change documents will be developed, as required, and coordinated with affected

interfaces, checked, approved, issued, distributed and controlled, to the same degree as the original

document.

When an environmental related change is approved, other than by revision to the affected documents,

measures will be established to incorporate the change into these documents where such incorporation is

appropriate.

Where an environmental related change is necessary because of an improved design, the design process

and verification procedures will be reviewed and modified, as required, as outlined in the Quality

Management Plan.

4




All documentation produced during the environmental related change process will be signed and dated, as

a record of the formal Quality Assurance process for ultimate retention in the project files. New revised

documents will be clearly named such that the revision number can be found within the document file

name.

8. RESPONSIBILITIES

The Environmental Manager is responsible for reviewing, classifying and responding to all Change

Requests and Requests For Field Changes, coordinating a formal review of requests for major environ-

mental related changes, with the affected Design Leads, to confirm the need for and implications of the

change, issuing a Notice of Major Field Change when the need for the major change has been confirmed

and issuing a Field Change Record when the change has been completed.

The Project Manager or Deputy Project Manager is responsible for coordinating necessary approvals from

other project participants and authorizing major design changes.

The Project Administrator is responsible for retention of environmental related change records in the

project file and maintaining a change log that indicates the status and disposition of requested changes.

The Quality Assurance Manager is responsible for monitoring the environmental related change process

to ensure quality requirements are met.

9. REFERENCES

A QAF-020 Environmental Related Scope Change Request

B QAF-021 Environmental Related Scope Change Log

C QAF-032 Request for Field Change Form

D QAF-033 Notice of Major Field Change Form

E QAF-034 Field Change Record Form

5





97918-GEN-EMP-N-001-R2 14 June 2010

Appendix C

Conceptual Site Models




97918-GEN-EMP-N-001-R2 14 June 2010

Appendix D

Summary Base Project Schedule

Activity ID Activity Name Start Finish

TP2 Materials Handling FacilityTP2 Materials Handling Facility 23-Jul-07 A 15-Sep-09

Confirm Design Basis & Complete Detailed DesignConfirm Design Basis & Complete Detailed Design 23-Jul-07 A 19-Jun-08 A

TP2DD0270 Submit 95% Design Report 23-Jul-07 A

TP2DD0320 Submit 100% Design Report 26-Sep-07 A

TP2DD0420 Submit Bid Documents to Regulatory Agencies 20-Feb-08 A 28-Apr-08 A

TP2DD0460 Prepare Addenda as Required and Tendering 09-Apr-08 A 06-May-08 A

TP2DD0480 STPA Review Period and Contract Award 05-Jun-08 A 19-Jun-08 A

Contract Administration & Construction OversightContract Administration & Construction Oversight 19-Jun-08 A 15-Sep-09

TP2 Materials Handling Facility OperationsTP2 Materials Handling Facility Operations 16-Apr-09 A 13-Mar-14

Operations DesignOperations Design 16-Apr-09 A 07-Aug-09

TP2OD0020 Submit 75% Design 16-Apr-09 A

TP2OD0040 Submit 100% Design 27-May-09 A

TP2OD0050 Prepare Addenda as Required and Tendering 25-Jun-09 23-Jul-09

TP2OD0070 STPA Review Period and Contract Award 24-Jul-09 07-Aug-09

OperationsOperations 07-Aug-09 13-Mar-14

TP6 (A)Pump AroundTP6 (A)Pump Around 17-Jun-08 A 17-Sep-12

Part "A" Flow DiversionPart "A" Flow Diversion 17-Jun-08 A 04-Mar-09 A

TP6DD0360 Submit 100% Design & Tender Documents (Flow Diversion) 17-Jun-08 A

TP6DD0400 Submit Bid Documents to Regulatory Agencies (Flow Diversion) 25-Sep-08 A 02-Dec-08 A

TP6DD0430 Prepare Addenda as Required and Tendering (Flow Diversion) 10-Oct-08 A 21-Jan-09 A

TP6DD0450 STPA Review Period and Contract Award (Flow Diversion) 12-Feb-09 A 04-Mar-09 A

Part "A" Contract Administration & Construction Oversight (Flow Diversion)Part "A" Contract Administration & Construction Oversight (Flow Diversion) 04-Mar-09 A 17-Sep-12

TP6 (B)Solidification, Stabilization & Channel ConstructionTP6 (B)Solidification, Stabilization & Channel Construction 02-Sep-08 A 09-Aug-13

Part "B" Approve Treatability (NSE) Portion of Work is on TP6 (S/S)Part "B" Approve Treatability (NSE) Portion of Work is on TP6 (S/S) 02-Sep-08 A 25-Jun-09

TP6DD0660 Submit 100% Design & Tender Documents (S/S) 02-Sep-08 A

TP6DD0800 Submit Bid Documents to Regulatory Agencies (S/S) 30-Jan-09 A 02-Apr-09 A

TP6DD0830 Prepare Addenda as Required and Tendering (S/S) 19-Dec-08 A 05-May-09 A

TP6DD0850 STPA Review Period and Contract Award (S/S) 28-May-09 A 25-Jun-09

Part "B" Contract Administration & Construction Oversight (S/S)Part "B" Contract Administration & Construction Oversight (S/S) 25-Jun-09 09-Aug-13

TP6 (C) Ferry Street BridgeTP6 (C) Ferry Street Bridge 08-May-09 A 12-Jan-12

Part "C" Ferry Street Bridge (Preliminary Dates)Part "C" Ferry Street Bridge (Preliminary Dates) 08-May-09 A 25-Jun-09

TP6CDD0270 Submit 95% Design Report 08-May-09 A

TP6CDD0320 Submit 100% Design Report 25-Jun-09

Ferry Street Bridge Abutments (C-1)Ferry Street Bridge Abutments (C-1) 06-Jul-09 16-Sep-09

TP6C1DD0460 Prepare Addenda as Required and Tendering 06-Jul-09 04-Aug-09

TP6C1DD0480 STPA Review Period and Contract Award 25-Aug-09 16-Sep-09

Part "C" Contract Administration & Construction Oversight (F.S. Bridge C-1)Part "C" Contract Administration & Construction Oversight (F.S. Bridge C-1) 16-Sep-09 03-Feb-10

Ferry Street Bridge Superstructure (C-2)Ferry Street Bridge Superstructure (C-2) 26-Apr-11 13-Jul-11

TP62CDD0570 Prepare Addenda as Required and Tendering 26-Apr-11 31-May-11

TP6C2DD0590 STPA Review Period and Contract Award 22-Jun-11 13-Jul-11

Part "C" Contract Administration & Construction Oversight (F.S. Bridge C-2)Part "C" Contract Administration & Construction Oversight (F.S. Bridge C-2) 13-Jul-11 12-Jan-12

TP6 (D) Construction RoadsTP6 (D) Construction Roads 07-Nov-08 A 30-Jul-09

Construction Roads (Approved)Construction Roads (Approved) 07-Nov-08 A 20-Jan-09 A

TP6DDD1010 Prepare Addenda as Required and Tendering 07-Nov-08 A 05-Dec-08 A

Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1Q2

2007 2008 2009 2010 2011 2012 2013 2014 2015


Remediation of the Tar Ponds and Coke Ovens Site

Project No. 97918

95% &100% Design Report Submittals with Approval,

Tender, Contract & Construction Periods

25-Jun-09

Primary Baseline

Actual Work

Remaining Work

Critical Remaining Work

Page 1 of 2

PRELIMINARYTASK filter: PIP 95%100% part 5 tender contract a.

© Primavera Systems, Inc.

Activity ID Activity Name Start Finish

TP6DDD1030 STPA Review Period and Contract Award 31-Dec-08 A 20-Jan-09 A

Contract Administration & Construction OversightContract Administration & Construction Oversight 20-Jan-09 A 30-Jul-09

TP7 Tar Ponds Surface CapTP7 Tar Ponds Surface Cap 17-Jun-08 A 31-Oct-13

Confirm Design Basis & Complete Detailed DesignConfirm Design Basis & Complete Detailed Design 17-Jun-08 A 17-Dec-09

TP7DD0270 Submit 95% Design Report 17-Jun-08 A

TP7DD0320 Submit 100% Design Report 03-Sep-08 A

TP7DD0420 Submit Bid Documents to Regulatory Agencies 25-Jun-09 01-Sep-09

TP7DD0460 Prepare Addenda as Required and Tendering 23-Sep-09 04-Nov-09

TP7DD0480 STPA Review Period and Contract Award 26-Nov-09 17-Dec-09

Contract Administration & Construction OversightContract Administration & Construction Oversight 17-Dec-09 31-Oct-13

CO1 Coke Ovens Bk Connector Sediment Removal & DisposalCO1 Coke Ovens Bk Connector Sediment Removal & Disposal 15-May-09 A 10-Sep-10

Confirm Design Basis & Complete Detailed DesignConfirm Design Basis & Complete Detailed Design 15-May-09 A 11-Dec-09

CO1DD0326 Submit 75% Design Report (Lower Reaches) 15-May-09 A

CO1DD0382 Submit 100% Design Report (Lower Reaches) 09-Jul-09

CO1DD0420 Submit Bid Documents to Regulatory Agencies 17-Jul-09 23-Sep-09

CO1DD0460 Prepare Addenda as Required and Tendering 30-Sep-09 29-Oct-09

CO1DD0480 STPA Review Period and Contract Award 20-Nov-09 11-Dec-09

Contract Administration & Construction OversightContract Administration & Construction Oversight 10-Dec-09 10-Sep-10

CO5 Vertical Cut-off WallsCO5 Vertical Cut-off Walls 11-Oct-07 A 17-Jul-09

Confirm Design Basis & Complete Detailed DesignConfirm Design Basis & Complete Detailed Design 11-Oct-07 A 11-Aug-08 A

CO5DD0270 Submit 95% Design Report 11-Oct-07 A

CO5DD0320 Submit 100% Design Report 18-Apr-08 A

CO5DD0420 Submit Bid Documents to Regulatory Agencies 25-Apr-08 A 28-Jun-08 A

CO5DD0460 Prepare Addenda as Required and Tendering 25-Apr-08 A 23-May-08 A

CO5DD0480 STPA Review Period and Contract Award 05-Aug-08 A 11-Aug-08 A

Contract Administration & Construction OversightContract Administration & Construction Oversight 11-Aug-08 A 17-Jul-09

CO6 Coke Ovens Surface CapCO6 Coke Ovens Surface Cap 01-Nov-07 A 29-Jun-11

Confirm Design Basis & Complete Detailed DesignConfirm Design Basis & Complete Detailed Design 01-Nov-07 A 14-Sep-09

CO6DD0270 Submit 95% Design Report 01-Nov-07 A

CO6DD0320 Submit 100% Design Report 06-Aug-08 A

CO6DD0420 Submit Bid Documents to Regulatory Agencies 14-Aug-08 A 21-Oct-08 A

CO6DD0460 Prepare Addenda as Required and Tendering 25-Jun-09 30-Jul-09

CO6DD0480 STPA Review Period and Contract Award 24-Aug-09 14-Sep-09

Contract Administration & Construction Oversight (Part A)Contract Administration & Construction Oversight (Part A) 14-Sep-09 29-Jun-11

CO7/CO8 COWTP & GWCSCO7/CO8 COWTP & GWCS 11-Jan-08 A 20-May-10

Confirm Design Basis & Complete Detailed DesignConfirm Design Basis & Complete Detailed Design 11-Jan-08 A 25-Jun-09

CO7/CO8DD0420 Submit Bid Documents to Regulatory Agencies 15-May-08 A 22-Jul-08 A

CO7/CO8DD0460 Prepare Addenda as Required and Tendering 26-Mar-09 A 13-May-09 A

CO7/CO8DD0480 STPA Review Period and Contract Award 05-Jun-09 A 25-Jun-09

CO7DD0270 Submit 95% Design Report 11-Jan-08 A

CO7DD0320 Submit 100% Design Report 13-May-08 A

Contract Administration & Construction OversightContract Administration & Construction Oversight 25-Jun-09 20-May-10

CO7/CO8 COWTP & GWCS OperationsCO7/CO8 COWTP & GWCS Operations 21-May-10 04-Mar-14

Operations (Not in Contract)Operations (Not in Contract) 21-May-10 04-Mar-14

Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1Q2

2007 2008 2009 2010 2011 2012 2013 2014 2015


Remediation of the Tar Ponds and Coke Ovens Site

Project No. 97918

95% &100% Design Report Submittals with Approval,

Tender, Contract & Construction Periods

25-Jun-09

Primary Baseline

Actual Work

Remaining Work

Critical Remaining Work

Page 2 of 2

PRELIMINARYTASK filter: PIP 95%100% part 5 tender contract a.

© Primavera Systems, Inc.




97918-GEN-EMP-N-001-R2 14 June 2010

Appendix E

Quality Assurance Procedure Audits

Remediation of the Tar Ponds & Coke Ovens Sites Design & Construction Oversight Services

Audit Procedure

97918-GEN-QAP-Q-004-RB 15 January 2008

REMEDIATION OF THE TAR PONDS AND COKE OVENS SITES

DESIGN AND CONSTRUCTION OVERSIGHT SERVICES

QUALITY ASSURANCE PROCEDURE

AUDITS

97918-GEN-QAP-Q-004-RB

Prepared By: Original Signed By Date: 15 January 2008 Karen Wilson Project Quality Coordinator

Reviewed By: Original Signed By Date: 15 January 2008 Robert Jones Quality Manager, Earth Tech

Approved By: Original Signed By Date: 15 January 2008 David Wilson Project Director, Earth Tech


Audit Procedure


Revision Summary

Revision Date of Issue Purpose A 18 October 2006 Initial draft for client review B 15 January 2008 General update


Audit Procedure

i


Table of Contents

1.0 PURPOSE ......................................................................................................................................................1

2.0 SCOPE ...........................................................................................................................................................1

3.0 AUDIT PROTOCOL ....................................................................................................................................1

4.0 RESPONSIBILITIES ...................................................................................................................................2


Audit Procedure

1


1.0 PURPOSE

The purpose of this procedure is to establish requirements for planning and conducting internal

audits and reporting of audit results. Internal audits of the Design Quality Assurance Program

shall be conducted to ensure compliance with the program requirements described in the Quality

Management Plan (QMP) and to evaluate effectiveness of the program.

2.0 SCOPE

This procedure applies to activities affecting quality during the design phase of the Remediation

of the Tar Ponds Coke Ovens Sites project.

3.0 AUDIT PROTOCOL

An audit plan will be developed and documented by the Quality Manager (QM) for each audit

identifying the following:

• Scope of audit

• Activities to be audited

• Applicable documents

• Objective evidence to be reviewed

• Audit schedule

Activities and program elements selected for the audit will be evaluated in terms of specified

requirements.

Objective evidence will be selected and examined to a depth necessary to determine effective

implementation of activities.

Internal audits will be scheduled to provide coverage of and coordination with, ongoing quality

assurance program activities at appropriate intervals during project implementation.


Audit Procedure

2


Nonconformances relative to program requirements will be documented as audit findings and

addressed as outlined in QMP Section 8.3.2: Nonconformances.

Appropriate corrective action will be taken by the responsible manager to address each

nonconformance identified and documented in the Nonconformance Report.

An audit report documenting the results of the audit will be prepared, signed and issued by the

QM. The report will provide a description of the audit scope and a summary of the results,

including a statement on the effectiveness of the quality assurance program. The audit report will

be distributed to ET/CBCL Project Lead and STPA’s Project Lead.

The audit report may include observations and concerns of the QM which will be discussed with

the ET/CBCL Project Lead and appropriately addressed at his/her discretion.

Follow-up reviews or surveillances will be performed by the QM to verify the implementation

and effectiveness of corrective actions taken to address nonconformances.

4.0 RESPONSIBILITIES

The Quality Manager is responsible for planning and conducting the audits, for preparing the

audit reports and for necessary follow-up activities.

The Project Lead, Deputy Project Manager, Design Manager, Design Coordinators and Design

Leads are responsible for providing the QM access to the records & documents to be examined

and for taking prompt corrective action, as required, to resolve audit findings.


Documentation Control Procedure

97918-GEN-QAP-Q-001-RE 15 January 2008

REMEDIATION OF THE TAR PONDS AND COKE OVENS SITES

DESIGN AND CONSTRUCTION OVERSIGHT SERVICES

QUALITY ASSURANCE PROCEDURE

DOCUMENTATION CONTROL 97918-GEN-QAP-Q-001 RE

Prepared By: Original Signed By Date: 15 January 2008 Karen Wilson Project Quality Coordinator Reviewed By: Original Signed By Date: 15 January 2008 Robert Jones Quality Manager Approved By: Original Signed By Date: 15 January 2008 David Wilson Project Director, Earth Tech




Revision Summary Revision Date of Issue Purpose

A 18 October 2006 Initial draft for review B 08 December 2006 Discipline code revised, E-mail filing procedure revised and

document delivery formats added. C 10 January 2007 Table II extended. Specification format & identification. Document control file.

D 1 March 2007 Table II extended, e-mail filing revised. E 15 January 2008 General update, all sections.

Notes:

1. This Procedure is an uncontrolled document and it is the reader’s responsibility to confirm

that this copy is the latest revision.

2. Revision letters will be used (e.g., A, B, C, etc.) until a quality document is issued for tender.

Upon issue for tender, this document will become Revision 0 and subsequent revisions will

be indicated with numbers.

Design & Construction Oversight Services Documentation Control Procedure

i

i


Table of Contents

1.0 PURPOSE ......................................................................................................................................................1

2.0 SCOPE ...........................................................................................................................................................1 2.1 PROJECT COMMUNICATIONS .......................................................................................................................1 2.2 DESIGN DOCUMENTATION ..........................................................................................................................1

3.0 PROJECT E-MAILS ....................................................................................................................................2 E-MAILS CAN BE CONSIDERED EITHER “NON-ESSENTIAL” OR “PROJECT RELATED”....................................................2 3.1 E-MAIL IDENTIFICATION..............................................................................................................................2 3.2 INTERNAL E-MAIL FILING...........................................................................................................................2 3.3 EXTERNAL E-MAIL FILING..........................................................................................................................3 3.4 RECORDS.....................................................................................................................................................3

4.0 DOCUMENTATION ....................................................................................................................................3 4.1 COMMUNICATIONS DOCUMENT IDENTIFICATION ........................................................................................3 4.2 DESIGN DOCUMENT IDENTIFICATION..........................................................................................................4 4.3 DOCUMENT MANAGEMENT.........................................................................................................................8 4.4 DESIGN DOCUMENT FORMATTING ..............................................................................................................9 4.5 DESIGN DOCUMENT CHECKS AND APPROVALS...........................................................................................9 4.6 DESIGN VERIFICATION ..............................................................................................................................10 4.7 DESIGN DOCUMENT DISTRIBUTION...........................................................................................................10 4.8 DOCUMENT DELIVERY FORMATS..............................................................................................................10 4.9 DESIGN CHANGES .....................................................................................................................................12 4.10 DESIGN DOCUMENT REVISIONS AND OBSOLETENESS ...............................................................................13 4.11 DESIGN DOCUMENT CONTROL CENTRE ....................................................................................................13 4.12 DOCUMENT RETENTION ............................................................................................................................14

5.0 RESPONSIBILITIES .................................................................................................................................14

List of Tables

TABLE I: PROJECT ELEMENT CODES..............................................................................................................................6 TABLE II: DOCUMENT TYPE CODES...............................................................................................................................7 TABLE III: DISCIPLINE CODES .......................................................................................................................................8



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1.0 PURPOSE

The purpose of this procedure is to provide clear guidance regarding the control and tracking of

project communications documents and design documentation relating to the Remediation of the

Tar Ponds and Coke Ovens Sites. Design documents are to be appropriately documented,

distributed and retained in a controlled manner and project tem members trained on the procedure

to ensure understanding and compliance.

2.0 SCOPE

2.1 Project Communications

Project communications documents include, but are not limited to the following:

• Emails • Memos • Letters • Facsimiles • Transmittals • Meeting Minutes • Documentation of Verbal Conversations

2.2 Design Documentation

This procedure is applicable to the suite of design documentation to be created, so the design can

be related to the design requirements; and, the construction oversight and commissioning phases

can be effectively implemented by the responsible organizations.

Applicable documents include, but are not limited to, the following:

• Project Implementation Plan • Quality Management Plan • Risk Management Plan • Health & Safety Plan • Environmental Protection Plan • Communications Plan • Design Requirements • Design Drawings and Sketches • Design Reports



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• Design Analyses and Calculations • Technical Specifications • Submissions for Licensing Purposes • Purchasing Requirements • Project Element Level Requirements • Commissioning Requirements • Operating and Maintenance Requirements

3.0 PROJECT E-MAILS

E-mails can be considered either “non-essential” or “project related”.

Non-essential e-mails are those for which the content is not considered necessary for future

reference or long term record purposes.

Project related e-mails are those that may have contractual implications, such as design memo’s,

scope, cost, approvals or meeting minutes. These must be adequately titled to facilitate correct

filing and retrieval.

3.1 E-mail Identification

Date (year xxxx month xx day xx)–(project number)–(element number)–(subject)

Example: 2008 01 27 97918 CO8 Scope of work

3.2 Internal E-Mail Filing

All project related e-mails that have contractual implications are to be filed on the network.

E-mails are to be filed under file folder:

97918 \ 04a \4a.1 Emails \ (element #) the e-mails will be filed by date order.

The e-mails can be filed either by copying to (cc):

[email protected]

Or, alternatively, you can file directly using the following path:

97918 \ 04a General-Correspondence \ 4a.1 Email \ (element #)



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The email can be saved by:

1. upon opening your email, do a “SAVE AS”

2. locate the path (shown above)

3. Ensure that the “SAVE AS TYPE” is selected to “Outlook Message Format” - your

email will automatically have the extension “.msg”.

If the e-mail has attachments, it should be indicated if these are intended for filing or not by including a

note addressed to Central Filing.

3.3 External E-Mail Filing

Copy any relevant e-mails using the above format to:

[email protected]

3.4 Records

A hard copy of all project related e-mails that have contractual implications should be sent to

the Central Filing System. The hard copy should have the Project Number with its file directory

extension at the top right corner in order to assist the Central Filer in placing the document in the

appropriate file.

Attachments to e-mails that are intended for filing at the Sydney Office should be indicated as

such in an instruction to the filer.

4.0 DOCUMENTATION

4.1 Communications Document Identification

Each communications document, with the exception of email messages, should be identified with

the Project Number, File Number, name of owner/originator, revision level (if applicable) and the

date.



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4


4.2 Design Document Identification

Design documentation excluding drawings and technical specifications is to be uniquely

identified in the following manner:

[ET Project number] - [Project element] - [document type] - [discipline code] – [sequential

number] – [revision]

Example: 97918-TP1-REP-C-001-RA

Revisions are to be identified with a two letter revision code: RA, RB, RC, etc.

Documents to be issued for tender are to be identified alpha-numerically as R0 upon issue for

tender and subsequent revisions are to be numbered sequentially: R1, R2, R3, etc.

Dates of document production, issue and revision are to be clearly identified on each document.

4.2.1 Drawings identification:

[ET PN] - [project element*] – DWG - [discipline*] - [three digit sequential # as defined by the

project CAD Coordinator] – [revision]

Refer to the “Remediation of the Tar Ponds and Coke Ovens Sites CAD Standard Manual”.

Revisions are to be identified with a two letter revision code: RA, RB, RC, etc.

Drawings are to be identified alpha-numerically as RO upon issue for tender and subsequent

revisions are to be numbered sequentially: R1, R2, R3, etc.

4.2.2 Technical Specification Format and Editing:

The technical specification sections will be based on National Master Specifications (NMS);

amended to suit Project requirements.

The Sydney Design Centre will be responsible for specification editing using the NMS Edit Pro

word processing software.



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5


The NMS specification sections can be obtained from the Sydney Design Centre or by email

[email protected] c.c. [email protected]. The Design Centre will send the requested

specification sections electronically or by fax. The sections can be sent in PDF, NMS Edit Pro or

MSWord files and can be marked up by pen and faxed in or by using Track Changes in MSWord.

If the specification sections are changed in NMS Edit Pro they must be sent by the section only

and not in a created project, sections would have to be extracted as the main Project (SPP) file

will be held at the Sydney Design Centre.

Specification Identification:

[Project number] - [project element] - [document type]-[Six digit Section #] - [revision]

Example: 97918-TP7-TS-03 41 00-RA

Revisions are to be identified with a two letter revision code: RA, RB, RC, etc. Specifications are

to be identified alpha-numerically as R0 upon issue for tender and subsequent revisions are to be

numbered sequentially: R1, R2, R3, etc.



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The codes for the project elements are listed in the following table:

Table I: Project Element Codes

Project Element

Element Description TP1 Coke Ovens Wash Brook Channels

TP2 Material Processing Facility

TP6 Solidification/Stabilization

TP1/TP6 Alternative Pump Around Design

TP7 Tar Ponds Surface Cap

CO1 Coke Oven Brook Connector Sediment Removal & Disposal

CO2 Tar Cell Solidification/Stabilization

CO5 Vertical Cut-off Walls

CO6 Coke Ovens Surface Cap

CO7 Coke Oven Brook Sediment Removal & Groundwater Collection System

CO8 Coke Oven Water Treatment Plant

CO9 On-Site Engineered Landfill

TC1 Temporary Construction Water Treatment

TC2 Operations Contract No 1

GEN General (Common Services, etc.)

CP Cooling Pond

CPT Cooling Pond Treatment



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The codes for the document types are listed in the following table:

Table II: Document Type Codes

Code Document Type Code Document Type AHASP Assignment Health & Safety Plan HG Hydro Geology AUD Audit Document LIST Listing AQ Air Quality MHSP Master Health & Safety Plan BOM Bill of Materials MTM Maintenance Manual CAD Cad Manual NCR Nonconformance Report CAL Calculations OPM Operations Manual CSP Client Satisfaction Plan PIP Project Implementation Plan COD Contract Document PLR Plain Language Report CN Change Notice PROT Protocol CO Change Order QAP Quality Assurance Procedure CP Commissioning Plan QAF Quality Assurance Form CPT Cooling Pond Treatment QMP Quality Management Plan CMP Construction Management Plan QAQC Quality Assurance/Quality Control COMM Communications Plan REP Report DD Design Description RFI Request for Information DM Design Manual RFQ Request for Quotation DR Design Report SCH Schedule DRC Document Review & Comment SKT Sketch DRQ Design Requirements TS Technical Specification DRD Design Review Document WBS Work Breakdown Structure DWG Drawing WP Work Plan EMP Environmental Management Plan GWIP Groundwater Investigation Programs EPP Environmental Protection Plan FDP Field Demonstration Plan FORMS Forms Directory



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The codes for the disciplines are listed in the following table:

Table III: Discipline Codes

Code Discipline A Architectural B Geotechnical C Civil E Electrical F Fire Protection G General H Hazardous Material I Instrumentation (I&C) L Landscape M Mechanical (Includes Plumbing & HVAC) N Environmental P Process Q Quality S Structural T Telecommunications V Survey/Mapping

4.3 Document Management

The forms listed in the Forms Directory (97918-GEN-QAF-Q-000) define the format and

presentation of certain documents referenced in this procedure.

Before any formal documents are submitted externally to the Agency or others, they should be

proof read, reviewed for content and approved.

Meeting minutes or notes are to be prepared and distributed to all project team members within

five days. This is required in order to allow for the prompt response to action items. Meeting

action items will be logged and tracked in a Meeting Action Item Log in the Project File Folder.

Key elements from important verbal communications, including telephone conversations, should

be logged by recording them in an email or a memo.



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4.4 Design Document Formatting

Each design document is to be prepared and managed in accordance with Earth Tech’s practices

or the Agency’s specified requirements.

Design drawings are to be stored electronically in AutoCAD (2000) format and printed in

accordance with the “Remediation of the Tar Ponds and Coke Ovens Sites CAD Standard

Manual”.

Reports and Manuals are to have a Revision Record page (Summary) Page within the document.

Manual calculations are to be documented on standard calculation sheets, with a cover sheet

containing dates and signatures of the original designer, reviewer and approver.

Calculations or other design analysis documents are to be identified by subject, originator,

reviewer and date for ease of access; and, are to include:

• objective of the calculation or design analysis

• identification of design inputs on which it is based

• identification of data or information from other sources used in calculation

• identification of assumptions and indication of those that must be verified as design

proceeds

• identification of computer software programs used in the calculation

• documentation of review and approval

4.5 Design Document Checks and Approvals

Design documents are to be subject to on-going quality checks by the design team members for

adequacy, completeness and correctness prior to approval by the appropriate manager and issue.



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The signatures or initials of design document reviewers and approvers with dates are to be

documented at the beginning of the document for reports and in the title block for drawings. An

Engineer’s Seal is to be applied to the master drawing copy.

4.6 Design Verification

Verification of design work through a formal Design Review process is to be carried out in

accordance with procedure 97918-GEN-Q-QAP-002, prior to submission of key deliverables at

75% and 95% milestones.

4.7 Design Document Distribution

The issue and distribution of design documents to the Agency and other external organizations, is

to be carried out in accordance with a distribution list.

Design documents issued to external organizations are to have a Transmittal Form attached with a

description of the contents or changes made since the previous issue. A copy of each Transmittal

Form should be filed in the Project File Folder 05 Transmittals.

4.8 Document Delivery Formats

Draft and final reports are to be delivered in both hard and electronic copies.



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Hard Copies

Deliverable Number of Copies

Consultant’s Assignment Health & Safety Plan 20

Project Implementation Plan 20

Project Master Health and Safety Plan 20

75% Design Report 20



Bid Documents in addition to copies provided with Design Reports 30

Construction Contract Documents 5

Draft Plain Language Report 20

Final Plain Language Report 100

Draft Post Construction and Long Term Monitoring Reports and Bid Documents 20

Final Post Construction and Long Term Monitoring Reports and Bid Documents 30

Electronic Copies

All electronic reports shall be submitted to the Agency on properly labeled compact discs. Two copies of

the CD’s shall be submitted. Electronic files over 10MB in size must be submitted in two versions. The

first version as one file of the entire report while the second report version contains the entire report but is

broken into component files limited in size between 5 and 10 MB. All electronic files submitted to the

Agency shall be according to the file labeling directives, which shall be available on request.

Electronic copies of reports shall be provided according to the following specifications:

1) Reports to be in Adobe Portable Document Format (PDF).

2) All reports, drawings, spreadsheets, etc., can be developed separately in their native

programs such as MS Word, MS Excel, GINT, AutoCAD, etc., provided the software is

compatible with Adobe (see specific requirements for figures and drawings).



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3) Images, drawings, etc., shall be ‘printed’ as PDF where possible and inserted into the

final PDF report document.

4) No security, password, encryption, etc., is to be enabled.

5) The PDF file created must be a ‘smart’ document supporting searching, bookmarks and

hyperlinks to aid in document navigation.

6) Hyper linking of the original Table of Contents (TOC) within the Word document to its

subsections is allowed and desired, but not required.

7) All Table of Contents, Table of Figures, section headers, etc., within MS Word (or other

word processing software) are to be formatted using TOC, TOC1, or Header, Headings 1,

etc., so that they are bookmarked automatically by Adobe during conversion.

8) Appendices titles are to be formatted as TOC or Header, Heading 1, etc., so that they are

book marked automatically by Adobe during conversion.

9) Default PDF conversion settings are to be used from within MS Word etc., with the

exception that Bookmarks are to be enabled for TOC, TOC1, etc., where used.

10) All fonts must be embedded in the PDF document.

Documents needed for inclusion in reports that are only available in hardcopy are to be scanned

and converted to PDF for insertion into the final report document, taking careful attention to

minimize the size of the scanned PDF while ensuring its legibility.

Double-sided printing is preferred, as is not less than 11-point Seriffed font and 1.5 line spacing.

4.9 Design Changes

Design changes required by project scope changes and design changes following the issue of

design documents, are to be carried out in accordance with the Design Review procedure (97918-

GEN-QAP-Q-002).



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4.10 Design Document Revisions and Obsoleteness

Revisions to documents which do not alter the intent, objective or quality requirements expressed

by the document, are to be considered minor and not subject to the requirements of this

procedure. Minor changes which can be made or authorized by the preparer of the document

include: typographical errors, punctuation, editorial corrections and inconsistencies.

Revisions to documents, other than those defined above as minor, are to be controlled by the

same or equivalent measures used to control the original document, including the same

authorization level as the original document.

A Revision Record (Summary) Page indicating the revision level, date and changes since the last

revision, should be attached to all revised reports and manuals.

Revision letters will be used (e.g., A, B, C, etc.) until a document is considered “Final” or is

issued for tender. Upon finalization or issue for tender, the document will become Revision 0 and

subsequent revisions will be indicated with numbers

No liquid white outs, correction tape or mark-ups to hard copies are to be used to revise design

documents, revisions are to be made to soft copies only.

Obsolete documents should be marked as “Obsolete”, or “Superseded” to preclude inadvertent

use and adverse effects on quality.

4.11 Design Document Control Centre

The design document control center is to be located at Earth Tech’s Sydney Design Centre, where

current copies of the documents can be made available to the project team on request. Project

team leaders are to obtain their most recent document for editing purposes from the ET Sydney

Design Center, ensuring document control is adhered to at all times.

Hard copies of current design documents are to be maintained in the Project Master File by the

Document Controller(s).

Electronic copies of design documents are to be maintained in folders in the Project File.



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4.12 Document Retention

Refer to Canada East Office Operating Procedure SOP-01 Control of Records for project storage

and retention.

5.0 RESPONSIBILITIES

The Project Lead, supported by the Deputy Project Manager, the Design Manager and the Design

Coordinators, has both the responsibility and authority for ensuring the documentation control

system is implemented and maintained in accordance with the requirements of this procedure.

The Document Controllers are responsible for document tracking and management by means of

logs of transmitted and received project communications documents and by maintaining the

Design Document Control Centre.

The Quality Manager is responsible for establishing the quality requirements, developing

procedures for the documentation control system and for monitoring the program to ensure it is

functioning to its intended extent. The Quality Manager will be the point of contact for inquiries

and matters regarding quality measures as they relate to documentation control.

All members of the project team have the responsibility for ensuring that project communications

documents and design documentation are prepared, identified, reviewed, approved, filed,

distributed, revised and retained in accordance with the requirements of this procedure.

of 2

Form No. QAF – 003 Project Name: Remediation of the Tar Ponds & Coke Ovens Sites

Records Retention Schedule

Storage Categories: Category: A Central Records, Departments, Libraries & Regional Centers Category: B Central On site Storage and/or Off Site Storage Note: (Expressed in years and P = Permanent storage)

Record Type

Listing Code

Record Type/Description Cat. A Storage

Cat. BStorage

Present Total

Retention

Total RetentionRequiredBy Law

Comments

A. Accounts

2 7 9 varies to P

*Requires a more detailed breakdown of this Record Type. Note as part of Corporate Records, some records are kept permanently

B. Field Books

1 29 30 P

C. Computer Printout

1 9 10

D. Drawings (P&R)

5 P P P

E. Contract Documents • Signed • Blank Records Copy

5 5

P -

P 5

P

F. Correspondence: • Files • Files (Microfilmed) • Microfilm Copies

1 1 1

29 4

29

30 5

30

30

Depending on the Correspondence if they relate to a contractual agreement they may be deemed necessary for Permanent storage as are contracts and other agreements

G. Misc. Administration

1 29 30

H. Design Calculations

1 29 30 30

I. Cost Estimates

1 29 30 30

J. Soil Reports

1 P P P

K. Shop Drawings

1 29 30

L. Library

1 29 30

of 2

Record Type

Listing Code

Record Type Description

Cat. A Storage

Cat. B Storage

Present Total

Retention

Total Retention Required

By Law

Comments

M. Survey Data

1 29 30

N. S Drawings

1 29 30

O. Engineering Agreement

1 P P P

P. Personnel Records

1 P varies to P

Some records such as accident reports should be Permanent

Q. Quantities

1 29 30

R. Reports (including Sub-consultants reports)

5 P P

S. Site Administration

1 29 30

T. Proposals (P&R)

5 10 15

U. Curriculum Vitae

- - -

V. Photographs

1 P P

W. Work Files

1 29 30

X. Y. Corporate Records

1 P P P

Z. Spare Copies of Publications

Computer Records:

• Tape (Mainframe & Network)

• Diskettes -CADD • Diskettes - REPORTS

1

10 10

9 - -

10

10 10




97918-GEN-EMP-N-001-R2 14 June 2010

Appendix F

Environmental Inspection Log

L:\work\97000\97918\19-Pplans\19-Project Plans\GEN\Quality\Forms Page 1 of 2

Form No: 97918-QAF-070 R3

Remediation of the Tar Ponds and Coke Ovens Sites


Remediation of the Sydney Tar Ponds and Coke Ovens Sites

Environmental Inspection Log (EIL)

Design Element:

Date: (D/M/Y):

Time (24 hrs):

Weather Conditions:

Daily Construction Activities:

EIL Completed by (printed name and signature): EM Name EM Signature

EIL Reviewed by (DE name, signature, date, time): DE Name DE Signature DD/MM/YYYY, 24:00

DAILY CHECKLIST ITEM: DESCRIPTION ACCEPTABLE NOT

ACCEPTABLE1

NOT

APPLICABLE

Comment #

(See P.2)

1. Sediment Control Structures:

Hay

Silt Fences

Dissipation Measures

Silt Curtains

Oil Absorbent Boom

Other:

2. Stabilization Areas

3. Noise Control Measures

4. Dust Control Measures

5. Air Emission Control Measures

6. Materials, Product & Equip. Storage

7. Fueling and Maintenance Area

8. Waste Disposal/Debris

9. Access Roads

10. Dewatering

Hoses

Connections

11. Decontamination Areas (ONCE DAILY)

Workers

Equipment/Vehicles

12. Barriers for Disposal, Storage &

Work Areas (ONCE DAILY)

13. Other Specific EM Activities:

Type:

Type:

Type:

14. Field Sampling:

Type:

1 Criteria for Acceptable and Not Acceptable for each checklist item is given on Pages 3 to 6.

Where a checklist item is not acceptable, comments must be provided below detailing: the nature of the concern; the extent of any environmental impacts;

the remediation measures undertaken; the requirement for any further remediation measures; if notification of a regulatory body was required, and if so, the

response; any recommendations for improvements/follow-up; and any other relevant information.

L:\work\97000\97918\19-Pplans\19-Project Plans\GEN\Quality\Forms Page 2 of 2

Form No: 97918-QAF-070 R3

Remediation of the Tar Ponds and Coke Ovens Sites


Remediation of the Sydney Tar Ponds and Coke Ovens Sites Environmental Inspection Log (EIL)

Design Element:

Date: (D/M/Y):

Time (24 hrs):

WEEKLY CHECKLIST ITEM: DESCRIPTION ACCEPTABLE NOT

ACCEPTABLE1

NOT

APPLICABLE Comment #

1. Above Ground Storage Tanks:

Tank

Pipe

Valve

Pump

Other Tank Equipment

2. Compressive Gas Storage

Data

Comments/Observations

(Comment #, Comment, Date, Time, Initials) If additional space is required, please attach a separate page.

Time: Surface Water Monitoring Results (NTU)

Location Notes/Observations

Time: Sound Monitoring Results (dBA)

Location Average Notes/Observations

____________________________________________________________________________________________________

________________________________________________________________________________________________________

________________________________________________________________________________________________________

________________________________________________________________________________________________________

________________________________________________________________________________________________________

________________________________________________________________________________________________________

________________________________________________________________________________________________________

________________________________________________________________________________________________________

________________________________________________________________________________________________________

________________________________________________________________________________________________________

________________________________________________________________________________________________________

________________________________________________________________________________________________________

________________________________________________________________________________________________________

________________________________________________________________________________________________________

________________________________________________________________________________________________________

___________________________




97918-GEN-EMP-N-001-R2 14 June 2010

Criteria to Determine if Mitigation Effectiveness is Acceptable or Non-acceptable

1. Sediment Control Structures:

a. Acceptable: If instantaneous Turbidity readings are within 8 Nephelometric Turbidity

Units (NTUs) above background (upstream sample location), if background

concentrations are less than 80NTU. If background is greater than 80NTU and samples

are within 10% of background levels on downstream side of the structure, the structure is

deemed to be functioning as intended. During visual inspection, if the sediment control

structures are intact with no gaps, tears, slumping or weathering of the materials and no

noticeable impacts in the receiving water “downstream” of the sediment control

structures.

b. Not Acceptable: If instantaneous Turbidity readings are greater than 8NTU if background

is less than 80NTU, or if readings are greater than 10% of background levels on

downstream side of the structure, the structure is deemed to be not functioning as

intended. During visual inspection, if the sediment control structures are not intact with

gaps, tears, slumping or weathering of the materials and noticeable impacts in the

receiving water “downstream” of the sediment control structures.

2. Stabilization Areas:

a. Acceptable: During visual inspection, if there is no apparent sloughing banks or erosional

processes occurring in an area of disturbance created by the Project.

b. Not Acceptable: During visual inspection, if there is sloughing banks or erosional

processes occurring in an area of disturbance created by the Project.

3. Noise Control Measures:

a. Acceptable: If noise measurements (based on two hour averages) are within the following

limits:

Leq < 65dBA between 0700 to 1900hrs

Leq < 60dBA between 1900 to 2300hrs




97918-GEN-EMP-N-001-R2 14 June 2010

b. Not Acceptable: If noise measurements (based on two hour averages) are not within the

above limits.

4. Dust, VOCs and Odour Control Measures:

a. Acceptable: During visual inspection, dust, VOCs and odours are controlled during

grading, excavation and construction activities. The exposed surfaces, stock piles or

stored materials are covered with water, foam or tarps, as required. The vehicles used for

excavation or transportation of materials are completely enclosed or with retractable load

covers, the haul unit seals are in good working order, hoses and connections on

equipment are free of leaks or drips.

b. Not Acceptable: During visual inspection, dust, VOCs and odours are not controlled

during grading, excavation and construction activities. The exposed surfaces, stock piles

or stored materials are not covered with water, foam or tarps. The vehicles used for

excavation or transportation of materials are not completely enclosed or with retractable

load covers, the haul unit seals are not in good working order, hoses and connections on

equipment have leaks or drips.

5. Particulate Control Measures:

a. Acceptable: If measurement by Air Monitoring Consultant at fenceline at downwind

averaged over 15 minutes does not exceed 100 g/m3

or if measurement at fenceline at

downwind averaged over 10 hours does not exceed 990 g/m3.

b. Not Acceptable: If measurement by Air Monitoring Consultant at fenceline at downwind

averaged over 15 minutes exceeds 100 g/m3 or

if measurement at fenceline at downwind

averaged over 10 hours exceeds 990 g/m3.

6. Air Emission Control Measures:

a. Acceptable: If measurement by Air Monitoring Consultant halfway between fence line

and source(s) is less than or equal to: 2ppm averaged over 15 minutes; or, with the

exception of benzene and naphthalene, five exceedances to the 15 minute averaging

period over the workday averaged over 10 hours; or 2.5ppm for benzene and naphthalene

(as confirmed by Draeger –Tubes or olfactory means) averaged over one hour.




97918-GEN-EMP-N-001-R2 14 June 2010

b. Not Acceptable: If measurement by Air Monitoring Consultant at halfway between fence

line and source(s) is greater than: 2ppm averaged over 15 minutes; or with the exception

of benzene and naphthalene, five exceedances to the 15 minute averaging period over the

workday averaged over 10 hours; or 2.5ppm for benzene and naphthalene (as confirmed

by Draeger –Tubes or olfactory means) averaged over one hour.

7. Product Storage:

a. Acceptable: All potentially hazardous products are stored in a pre-designated, safe and

secure product storage area at the worksite, in accordance with provincial legislation; all

products shall be properly labelled according to WHMIS; any spilled products are

contained and the area cleaned.

b. Not Acceptable: Any potentially hazardous products are not stored in a pre-designated,

safe and secure product storage area at the worksite, in accordance with provincial

legislation; or any products are not properly labelled according to WHMIS; or any spilled

products are not contained; or the area has not been cleaned after a spill.

8. Fuelling and Maintenance Area:

a. Acceptable: Area is clean, well organized. All potentially hazardous products are stored

in a pre-designated, safe and secure product storage area within the construction area, in

accordance with provincial legislation. All products are properly labelled according to

Workplace Hazardous Materials Information System (WHMIS). Material Safety Data

Sheets (MSDS) are on site with the relevant product.

b. Not Acceptable: Area is not clean, unorganized and any of the above noted safeguards

are missing.

9. Waste Disposal/Debris:

a. Acceptable: Project site is free from any waste/debris whether it be benign solid waste or

hazardous waste other than wastes stored in designated bins/areas.

b. Non Acceptable: Project site contains waste/debris whether it is benign solid waste or

hazardous waste, is not destined for immediate disposal and requires appropriate

disposal.




97918-GEN-EMP-N-001-R2 14 June 2010

10. Dewatering:

a. Acceptable: Fish have been removed prior to dewatering; fish screens are installed in

pumps; and the dewatered cells are maintained during construction.

b. Not Acceptable: Fish have not been removed prior to dewatering; fish screens are not

installed; or the dewatered cells are not maintained during construction.

11. Environmental Monitoring Activities:

Air Quality (Responsibility of the Air Monitoring Consultant)

a. Acceptable: Monitoring instruments are regularly calibrated. Data is collected and

recorded hourly. During times periodically when there is a potential for increased

emissions, real time monitoring shows compliance with previously established limits as

identified above in items 5 and 6.

b. Not Acceptable: Monitoring instruments are not regularly calibrated. Data is not collected

or not recorded hourly. During times periodically when there is a potential for increased

emissions, real time monitoring shows exceedances of limits as shown in numbers 5 and

6 above.

Surface water

a. Acceptable: Monitoring instruments are regularly calibrated. Data is collected and

recorded hourly. Periodically, during times when there is a potential for increased

sediment loading (e.g. excavation), real time monitoring shows no exceedances of limits

as described in Item 1.

b. Non Acceptable: Monitoring instruments are not regularly calibrated or data is not

collected and recorded hourly. Periodically, during times when there is a potential for

increased sediment loading (e.g. excavation), real time monitoring shows exceedances of

limits as described in Item 1.

Groundwater

a. Acceptable: If a contaminant of concern in groundwater does not have an upward trend

after the fourth sample for three consecutive samples using the Mann-Kendall trend




97918-GEN-EMP-N-001-R2 14 June 2010

analysis; this approach will use the entire available time series of data (within the

numerical constraints of the test).

b. Not Acceptable: When an upward trend after the fourth sample for three consecutive

samples using the Mann-Kendall trend analysis is identified; again, this approach will use

the entire available time series of data (within the numerical constraints of the test).

12. Access Roads

a. Acceptable: Upon visual inspection, the access roads are dust suppressed, free of debris

or unnecessary materials with no spills. If applicable, the silt fences appear to be working

and are being maintained along toe of slope (along banks) and drainage ditches appear to

be working to direct flow away from waterways.

b. Non Acceptable: Upon visual inspection, the access roads are not dust suppressed, have

debris or unnecessary materials with spills. If applicable, the silt fences appear not to be

working or to not be maintained along toe of slope (along banks) and drainage ditches

appear not to be working to direct flow away from waterways.

remediation of the tar ponds and coke ovens sites

Documents