TERMPOL 3.1 INTRODUCTION

Transcription

1 TERMPOL 3.1 INTRODUCTION Trans Mountain Expansion Project Prepared for: Prepared by: 777 W. Broadway, Suite 301 Vancouver, BC, V5Z 4J7 November 29, 2013

2 TERMPOL 3.1 Introduction TRANS MOUNTAIN EXPANSION PROJECT November 29, 2013 M&N Project No Prepared by: MOFFATT & NICHOL Reviewed by: MOFFATT & NICHOL James Traber, EIT. Staff Engineer Ron Byres, P.Eng. Senior Project Manager Revision Purpose of Issue Date Author Reviewed Approved 0 For TRC Review November 29, 2013 JT RB

3 TABLE OF CONTENTS 1. INTRODUCTION CONTRIBUTIONS TERMPOL REVIEW PROCESS NATIONAL ENERGY BOARD APPLICATION PUBLIC ENGAGEMENT ABORIGINAL ENGAGEMENT SCOPE OVERVIEW GEOGRAPHIC SCOPE OF STUDIES DESIGN VESSEL AND FACILITIES TRAFFIC STUDY SECOND NARROWS TRANSIT WINDOWS MARINE RISK ASSESSMENT CHARACTERISTICS OF THE CARGO FATE AND BEHAVIOUR OF POSSIBLE OIL SPILLS IN THE STUDY AREA OIL SPILL RESPONSE SUMMARY OF RECOMMENDATIONS CONCLUSION APPENDIX A: ABSTRACT OF TERMPOL STUDIES APPENDIX B: LIST OF SUPPORTING DOCUMENTS AND REFERENCE MATERIALS APPENDIX C: DISCUSSION TOPICS (MARINE) AT INFORMATION SESSIONS APPENDIX D: LIST OF ABORIGINAL GROUPS APPENDIX E: LETTER TO CANADIAN COAST GUARD AND US COAST GUARD Termpol 3.1: Introduction 1

4 1. INTRODUCTION The Trans Mountain pipeline system was constructed almost 60 years ago and currently has a capacity of 47,690 m 3 /d (300,000 bbl/d). The pipeline transports a range of petroleum from western Canada to locations in central and southwestern British Columbia, Washington and to offshore markets via its Westridge Marine Terminal. The Westridge Marine Terminal (Westridge) is the only oil handling facility that is connected to a pipeline system on the West Coast of Canada. It is the only facility that provides access for Canadian oil production to markets in the Pacific Rim: California, Washington State and Asia. Trans Mountain Pipeline ULC (Trans Mountain) is a Canadian corporation with its head office located in Calgary, Alberta. Trans Mountain is a general partner of Trans Mountain Pipeline L.P., which is operated by Kinder Morgan Canada Inc. (KMC), and is fully owned by Kinder Morgan Energy Partners, L.P. Trans Mountain is the holder of the National Energy Board (NEB) certificates for the Trans Mountain pipeline system (TMPL system). In response to requests for service from Western Canadian oil producers and West Coast refiners for increased pipeline capacity Trans Mountain proposes to expand the existing TMPL system to 141,500 m 3 /d (890,000 bbl/d). The NEB decision RH reinforces market support for the proposed expansion and provides Trans Mountain the necessary economic conditions to proceed with design, consultation, and regulatory applications. The proposed Trans Mountain Expansion Project (referred to as TMEP or the Project ) will comprise the following: Pipeline segments that complete a twinning of the pipeline in Alberta and BC with about 987 km of new buried pipeline. New and modified facilities, including pump stations and tanks. Three new berths at the Westridge Marine Terminal in Burnaby, BC, each capable of handling Aframax class vessels. Currently, in a typical month, five vessels are loaded with heavy crude oil (including diluted bitumen) at the terminal. The expanded system will require 34 Aframax class vessels per month, with actual demand driven by market conditions. The maximum size of vessels (Aframax class) served at the terminal will not change as part of the Project. Similarly, the future cargo will continue to be crude oil, primarily diluted bitumen or synthetic crude oil. Of the 141,500 m 3 /d (890,000 bbl/d) capacity of the expanded system, up to 100,200 m 3 /d (630,000 bbl/d) may be delivered to the Westridge Marine Terminal for shipment. Termpol 3.1: Introduction 2

5 In addition to tanker traffic, the terminal typically loads two to three barges with oil per month and receives one or two barges of jet fuel per month for shipment on a separate pipeline system that serves Vancouver International Airport (YVR). Barge activity is not expected to change as a result of the expansion. The Project can be characterized as an expansion within the existing footprint for petroleum transportation. The pipeline will be twinned primarily within the existing corridor and the resulting increase of tanker traffic will transit via the same shipping lanes that are used today for tankers and other large vessels calling in Vancouver and Washington State. While Trans Mountain does not own or operate the vessels calling at the Westridge Marine Terminal, it is responsible for ensuring the safety of the terminal operations. In addition to Trans Mountain s own screening process and terminal procedures, all vessels calling at Westridge must operate according to rules established by the International Maritime Organization, Transport Canada, the Pacific Pilotage Authority, and Port Metro Vancouver. Although Trans Mountain is not responsible for vessel operations, it is an active member in the maritime community and works with BC maritime agencies to promote best practices and facilitate improvements to ensure the safety and efficiency of tanker traffic in the Salish Sea. Trans Mountain is a shareholder of Western Canada Marine Response Corporation (WCMRC) and maintains an arrangement with WCMRC for spill response services at the Westridge Marine Terminal, as legislated in the Canada Shipping Act, Trans Mountain has requested Transport Canada to conduct a Termpol review to assess the safety and risks associated with tanker movements to, from, and around the Westridge Marine Terminal that will result from the Project. This document provides an overview of the Termpol studies, supporting work, and a summary of the recommendations to the Termpol Review Committee. 1.1 CONTRIBUTIONS In addition to material provided by Trans Mountain Pipelines, a number of different individuals and organizations contributed material to this effort including (in alphabetical order): Ausenco Captain Bikramjit Kanjilal, Valiance Maritime Consultants Ltd. Captain John Swann, L.J. Swann & Associates Det Norke Veritias EBA, a division of Tetra Tech Moffatt & Nichol Termpol 3.1: Introduction 3

6 Stantec Tera Environmental Consultants Terrence Smyth, Seaport Consultants Western Canada Marine Response Corporation 1.2 TERMPOL REVIEW PROCESS The Termpol Review Process (TRP) is a voluntary process whereby Trans Mountain as the proponent conducts a prescribed set of studies, described in Termpol Review Process 2001 (TP743E), and submits these to a Termpol Review Committee that is chaired by Transport Canada and includes representatives of other federal agencies. The purpose of the review in this case is to assess the safety and risks associated with tanker movements to, from and around the Westridge Terminal resulting from the Project. The review includes consideration of: ship design and operation; navigational and physical characteristics of the approaches to the terminal; terminal design and infrastructure; risk and accident analysis along the transit route and at the terminal, and the related mitigating measures; pollution prevention program; and contingency plans The set of studies which address these issues follows the terms of reference set out in Section 3 of the TP743E document. For ease of reference, the studies comprising this Termpol submission use the same numbering sequence and titles as TP743E. Specifically these are: Termpol 3.1 Introduction Termpol Origin, Destination and Marine Traffic Volume Survey Termpol 3.3 Fishery Resources Survey Termpol Offshore Exercise/Exploration/Exploitation Activities Survey Termpol Route Analysis, Approach Characteristics and Navigability Survey Termpol Special Underkeel Clearance Survey Termpol Transit Time and Delay Survey Termpol Casualty Data Survey Termpol Ship Specifications Termpol Site Plans and Technical Data Termpol Cargo Transfer and Transshipment Systems Termpol Channel Manoeuvring and Anchorage Elements Termpol Berth Procedures and Provisions Termpol Single Point Mooring Provisions and Procedures Termpol 3.15 General Risk Analysis and Intended Methods of Reducing Risks Termpol 3.1: Introduction 4

7 Termpol Port Information Book Termpol Terminal Operations Manual Termpol Contingency Planning Termpol Oil Handling Facilities Requirements Termpol Hazardous and Noxious Liquid Substances Three studies (Termpol 3.4, 3.14, and 3.20) are not relevant to the TMEP project, and are not included in this submission. For convenience some of the other studies are combined due to overlapping areas of content in the terms of reference. A brief description of the scope and content of these studies as they pertain to the TMEP application is provided in Section 1.6 below and in Appendix A. The Termpol Review Committee reviews the proponent s submission and evaluates potential risks and mitigations as well as the adequacy of the existing marine infrastructure and regulation to accommodate the project. The results of the review are documented in a report issued by the Termpol Review Committee and made public along with the supporting studies. This report is not considered to be a regulatory instrument, nor a statement of government policy or government endorsement of the Project. While recommendations of the Termpol Review Committee are not binding they are expected to be helpful to Transport Canada and other agencies to help determine the need for regulatory improvements or special measures. The outcome of Termpol is not intended to prejudice the comprehensive review of the Project by the National Energy Board (NEB). The list of issues to be considered by the NEB has been defined to include the potential environmental and socio-economic effects of marine shipping activities that would result from TMEP, including the potential effects of accidents or malfunctions that may occur. Some Termpol studies submitted by Trans Mountain describe enhancements to the existing tanker safety regime that could mitigate the risk presented by TMEP traffic along with recommendations as to how these could be implemented. Trans Mountain recognizes that the implementation of these enhancements may fall within the regulatory purview of the Termpol Review Committee members and is committed to working closely with the members to implement enhancements that are accepted as appropriate and endorsed by the Termpol Review Committee. Ways and means of implementing any such measure will be discussed with the Termpol Review Committee and it is expected that the specific agencies with authority over the implementation will lead these efforts as required. 1.3 NATIONAL ENERGY BOARD APPLICATION Trans Mountain is making application pursuant to Section 52 of the National Energy Board Act for the Project. The NEB will undertake a detailed review and hold a Public Hearing to Termpol 3.1: Introduction 5

8 determine if it is in the public interest to recommend a Certificate of Public Convenience and Necessity (CPCN) for construction and operation of the Project. In its list of issues to be reviewed the NEB has included the potential environmental and socio-economic effects of marine shipping activities that would result from the Project, including the potential effects of accidents or malfunctions that may occur. Trans Mountain completed an environmental and socio-economic assessment (ESA) of the marine aspects of the Project separate from the Termpol Review Process. The ESA forms part of Trans Mountain s application to the NEB. Subject to the outcome of the NEB Hearing process, Trans Mountain plans to begin construction in 2016 and go into service in late PUBLIC ENGAGEMENT Trans Mountain has embarked on an open and extensive engagement process on all aspects of the proposed Project along the route between Strathcona County, AB (near Edmonton) and Burnaby, BC and the marine corridor, which is defined as the existing shipping route between Westridge Marine Terminal and the Pacific Ocean. The engagement program included a series of 44 public information sessions held between October 2012 and October 2013 in 31 communities along the pipeline corridor and marine corridor. In addition to the public information sessions, engagement efforts include ongoing meetings and topic specific workshops (including two marine) with various organizations, governments at all levels, community groups and stakeholders. The project also maintains a comprehensive website that includes an on-line engagement tool where people can ask and have answered their questions about the Project (see and on-line discussion forums, a general project address and phone number, and participates in the social media through YouTube and Twitter. Of all the feedback received, concern for risk and safety particularly pipeline safety and marine safety were the top concerns. In terms of tanker movements in the waters off the West Coast, public feedback gathered in the engagement process indicates the tanker safety regime in Canada is not well understood or appreciated. In particular, Trans Mountain found that people asked questions about the relative roles of Transport Canada, the Canadian Coast Guard (CCG), Port Metro Vancouver (PMV), Pacific Pilotage Authority (PPA), Environment Canada, the Government of British Columbia and industry. Appendix C contains a summary of some of the specific tanker and marine transportation comments and concerns Trans Mountain received from its public information sessions. Termpol 3.1: Introduction 6

9 1.5 ABORIGINAL ENGAGEMENT Trans Mountain has taken an open, extensive and thorough Aboriginal engagement approach and has engaged with, and continues to engage with Aboriginal communities that have traditional rights in coastal and marine areas. Through input from the federal and provincial governments Aboriginal communities were identified including those who share an interest in the protection of the Salish Sea. All communities have been given the opportunity to engage with the Project and Trans Mountain has commenced discussions with most of them to determine their interests and concerns related to the Project. A list of these communities is provided in Appendix D. Trans Mountain is committed to meaningful engagement with these communities and each community has been offered the opportunity to review and comment on the Termpol technical reports. Through correspondence in November, 2013 each community was asked to notify Trans Mountain of their interest in receiving the Termpol Reports when they are filed with the Termpol Review Committee. Those communities wishing to comment on the reports were asked to respond with feedback to Trans Mountain within 2-3 months. Trans Mountain will collect feedback and provide it to Transport Canada and the Termpol Review Committee for their consideration. Trans Mountain and Transport Canada are available to meet with First Nations in support of the Termpol process and Trans Mountain has offered capacity funding to support their engagement with the Project. 1.6 SCOPE The safety regime in place today for both the existing tanker traffic and the operation of the Westridge Marine Terminal has been developed and continually improved since the terminal entered service in The regime is based on regulatory requirements, local experience and international best practices. It is comprehensive, well established, and has proven to be effective. While the Project will result in increased tanker traffic it will be the same vessels carrying the same type of petroleum and transiting the same well established routes that are used today. TMEP is an expansion of existing operations. Therefore, during the initial meetings with Transport Canada 1 it was agreed that the Termpol Review Committee should focus on the new elements that will result from the Project rather than document the existing tanker safety 1 Following an initial introductory meeting held on May 9, 2012, Trans Mountain wrote to Transport Canada on September 14, 2012, requesting a Termpol Review Process, and provided a suggested outline and scope for the various Termpol studies. A meeting was held with Transport Canada and other agencies on March 12, 2013 to discuss the proposed scope. On July 2, 2013, Transport Canada wrote to Trans Mountain, generally accepting the proposed scope of work, and a subsequent meeting was held on July 24, 2013 to finalize the scope. Termpol 3.1: Introduction 7

10 regime, which is well understood and known to be adequate. With respect to the Termpol scope, Project-related changes include the reconfigured marine terminal and the increased frequency of tanker traffic. To refine the scope for Termpol, Trans Mountain prepared a gap analysis to assess where a focused process could bring most benefit. From this analysis an abstract of each study was prepared with a focus on the new elements that will result from TMEP. The gap analysis and abstracts were discussed with Transport Canada and agreement was reached on the scope of the studies undertaken. The abstracts can be found in Appendix A. Termpol 3.1: Introduction 8

11 2. OVERVIEW The following discussion describes the scope of the Termpol studies and the resulting recommendations. 2.1 GEOGRAPHIC SCOPE OF STUDIES The study area has been demarcated to include the entire tanker route between Westridge Marine Terminal and Buoy J, which is situated at the mouth of the Juan de Fuca Strait (See Figure 2-1). The entire route has been reviewed and reported in a combined Termpol 3.5/ Termpol 3.12 document. Figure 2-1: Termpol Study Area Termpol 3.1: Introduction 9

12 2.2 DESIGN VESSEL AND FACILITIES Today the Westridge terminal typically loads crude oil onto five tankers and two or three barges per month. With approval of TMEP the typical number of tanker loadings is expected to increase to 34 Aframax vessels per month. The majority of tankers are expected to be Aframax class (80,000 Deadweight Tonnes (DWT) to 120,000 DWT) although Panamax class tankers (60,000 DWT to 80,000 DWT) may be nominated as well. Barge traffic is not forecast to change. As no changes to either crude oil or jet fuel barge traffic are expected, the focus of the Termpol studies is the new elements introduced by increased tanker traffic. A description of the tanker vessels is included in Termpol 3.9. In order to accommodate the increase in traffic the Westridge Marine Terminal will be expanded. The existing single tanker berth will be replaced with three new berth faces. The new facilities are discussed in Termpol TRAFFIC STUDY Existing marine traffic for the study area was assessed based on Automated Information System (AIS) data and other vessel traffic information. Using a combination of economic forecasting, regional project announcements, and interviews, the amount of future traffic has been forecast for 2018, 2020, 2025, and These projected traffic volumes were used in Termpol Study 3.15 to estimate the probability of spills both with and without the proposed TMEP traffic for the years 2018 and The former is expected to be the first full year of service for TMEP, the later is used to assess the effect of additional traffic growth on risk after 10 years of operation. The forecast is used to assess the effect of TMEP traffic on other users of the waterways and vice versa. The traffic study is discussed in detail in Termpol 3.2. Information from the traffic study was used in Termpol 3.15 to calculate the contributions by vessel type to the annual distance sailed in the study area, since the total distance sailed by vessels is a better measure of navigational risk than simply the number of vessel sailings. The assessment shows that if the project proceeds, the additional sailed nautical miles for the new Trans Mountain tankers will increase approximately 70% from 2012 tanker mileage levels in the region. If all types of vessels (not just tankers) are included, the additional TMEP traffic represents an increase of just 3.2% in the total nautical miles sailed. 2.4 SECOND NARROWS TRANSIT WINDOWS The effect of increased tanker movements on other waterway users particularly at the Second Narrows has been assessed and is expected to be minimal. This is because movement restrictions at the Second Narrows are more stringent for tankers, especially Aframax vessels, Termpol 3.1: Introduction 10

13 than for non-tankers and vessels of lesser size. These other vessels have significantly more opportunities to transit the Second Narrows during each tidal cycle either before or after laden tankers have passed. Furthermore, non-tankers are allowed to transits the Second Narrows at night and avail of those tides as well. Unladen tankers will also have a large number of transit opportunities. The effect of increased tanker movements on anchorages was also assessed. It was concluded that the four existing anchorages are sufficient to meet the needs of the TMEP traffic as well as all other terminals east of Second Narrows for the foreseeable future. These assessments are described in Termpol 3.7 which also includes information that can be used by PMV and PPA to refine vessel traffic management plans including the management of Indian Arm anchorages if necessary. 2.5 MARINE RISK ASSESSMENT Trans Mountain engaged Det Norske Veritas (DNV) to conduct a quantitative marine risk assessment. DNV facilitated two separate Hazard Identification (HAZID) workshops with local experts and others and undertook significant research and modeling in order to develop their report. The risk assessment considers the possible occurrence of five types of accidents involving a project tanker in the study area: Collision, Structural failure Fire/Explosion Powered grounding Drift grounding And four types of possible terminal operations accidents: Cargo transfer leak Impact of the berth by a project tanker Striking of a project tanker at berth Striking of a project tanker at anchor DNV calculated a credible worst case oil spill volume of 16,500 m3, which is equivalent to about 15,500 tonnes of heavy crude oil. This volume corresponds to the entire loss of two cargo compartments of a partially laden Aframax vessel. The probability of accidents that could lead to an oil spill was also calculated. DNV found that with the adoption of additional mitigation measures the frequency of the credible worst case oil spill due to the Project will change from once every 3,093 years to once every 2,366 years. DNV has evaluated the risk controls that form part of the current safety regime and determined that these already meet high global standards, however there is benefit in adopting additional mitigation measures to Termpol 3.1: Introduction 11

14 further improve tanker and marine safety. Without adoption of the additional mitigation measures, the change of frequency of the credible worst case oil spill will change from once every 3,093 years to once every 456 years due to the Project. The probability of smaller oil spills including those from Westridge Marine Terminal are also assessed and detailed information is available in the report. The analysis concluded that after the Project is in service the frequency of a small spill (10 m 3 or less) is estimated to be once every 34 years, while the frequency of a spill up to 100 m 3 is estimated to be once every 234 years. The basic frequencies of a release during cargo transfer activities are derived from European terminal accident statistics and modified to account for site specific risk reducing measures that will be implemented at the new Westridge Marine Terminal. The preventative booms deployed around the berths are expected to have an oil containment capacity of more than 1,500 m 3 of oil. The quantitative risk assessment is presented in Termpol The results of the risk assessment were also used to develop recommendations for enhancement to the existing marine spill response planning standards that are administered by Transport Canada. 2.6 CHARACTERISTICS OF THE CARGO The expanded Westridge Marine Terminal, like the upstream pipeline, will continue to be capable of handling a wide range of petroleum types. However, as is the case today, the majority of crude oil loaded from the expanded terminal is expected to be heavy crude oil, primarily diluted bitumen. While the petroleum transported on the Trans Mountain pipeline is limited by tariff to a maximum specific gravity of 0.94 and viscosity of 350 cst and will float if released into water, a portion of spilled petroleum could submerge or sink if left to weather for an extended period. To inform the risk assessment (Termpol 3.15), Trans Mountain commissioned a program of testing of diluted bitumen (Polaris (2013)). The testing program included a ten day weathering test for two types of diluted bitumen as well as testing to assess the effectiveness of skimming equipment, dispersants, and in-situ burning. The tests were attended by a wide range of regulators and other agencies who were invited to attend. The diluted bitumen showed properties and weathering behavior similar to other heavy crude oils. During the course of the ten day test the diluted bitumen floated on the water and could be retrieved effectively using conventional skimming equipment. The report documenting the testing program (Witt O Brien s (2013) is listed in Appendix B and is available as a supplementary supporting reference document to the Termpol studies. Information from this report was used in the report, Modeling the Fate and Behaviour of Marine Oil Spills for the Termpol 3.1: Introduction 12

15 Trans Mountain Expansion Project (EBA 2013) and in the spill response assessment included in Termpol FATE AND BEHAVIOUR OF POSSIBLE OIL SPILLS IN THE STUDY AREA The fate and behaviour of representative cargo spills of diluted bitumen have been simulated stochastically at various locations along the tanker route using credible worst case and smaller volumes. Spills at the Westridge Marine Terminal were also modeled using similar assumptions. This work was conducted by EBA and a report of their investigation is available as part of the Termpol submission as noted above. This report highlights the benefits of prompt response in order to reduce the effect of spilled oil on the environment, shorelines and communities of this area. Information from the report was used in the assessment of spill response included in TEMRPOL OIL SPILL RESPONSE The adequacy of oil spill response in the area is a public concern and Canada s oil spill response regime is currently the subject of review by both the Federal and BC Provincial Governments. The regulation of marine oil spill response is primarily defined in the Canada Shipping Act, 2001 and administered by Transport Canada. The Act defines the requirement for oil spill Response Organizations to be certified by the Minister, the requirement for all large vessels and oil handling facilities to have an arrangement with a certified Response Organization as a condition of operating in Canadian waters, and establishes planning standards that define minimum levels of capacity to be maintained by the Response Organization. Western Canada Marine Response Corporation (WCMRC) is the Response Organization for the West Coast. Current planning standards require a minimum capacity to respond to oil spills of up to 10,000 tonnes in specified time frames which in some cases allow up to 72 hours plus travel time to deliver response equipment. WCMRC currently maintains capacity significantly in excess of the minimum planning standard requirements. Relative to the existing planning standards the credible worst case oil spill volume calculated by DNV (15,500 tonnes) suggests the need for increased spill response capacity and EBA s fate and behaviour study shows the benefit of reduced response times in the study area. Trans Mountain therefore engaged WCMRC to review this work and to describe enhancements to the existing planning standards that would better accommodate the Project. In addition to providing WCMRC with results of the risk assessment Trans Mountain proposed the following principles: Termpol 3.1: Introduction 13

16 Augment capacity within the existing regime. Where the need exists for additional response capacity, it should be met through an expansion of WCMRC s resources. Response capacity should reflect the risks. Response capacity should be established based on consideration of probability and consequence with particular consideration to predicted spill volumes, material fate and behavior, and geographic setting including sensitive areas. Investments should benefit affected communities. Where new investment in response capacity is required, Trans Mountain will seek to maximize the benefit to First Nations and other communities along the transit route. Benefits may consist of capacity building, capital investment, training and provision of ongoing services. The WCMRC study (WCMRC 2013) describes an enhanced response regime that will be capable of delivering 20,000 tonnes of capacity within 36 hours from dedicated resources staged within the study area. This represents a response capacity that is double and a delivery time that is half the existing planning standards. These enhancements will reduce times for initiating a response to two hours for the harbour and six hours for the remainder of the study area and parts of the West Coast of Vancouver Island. These reduced times will be achieved by creating new base locations along the tanker route. Meeting the response capacities within the designated times requires redundancy of equipment, as a result the overall capacity of dedicated response equipment available in the area will be in excess of 30,000 tonnes as shown in Table 2-1. The WCMRC report is available as a supplementary report supporting the Termpol submission and was used in the spill response discussion that forms part of Termpol Termpol 3.1: Introduction 14

17 Table 2-1 Proposed Response Base Capacity for Future Oil Spill Equipment Staging Areas Distribution of Proposed Equipment to Staging Areas m 3 Response Capacity tonnes Burrard Inlet (Burnaby) A 9,550 9,000 Delta Port area A 1,350 1,250 South Vancouver Island (Nanaimo Chemainus area) 2,800 2,650 North Saanich Peninsula (Sidney area) A 11,900 11,200 South Vancouver Island (Victoria Sooke area) 4,700 4,400 Southwest coast of Vancouver Island (Port Renfrew Ucluelet area) 1,600 1,500 Total Capacity at Bases 31,900 30,000 A These locations will require full-time staff, 24-hours/day, 7-days/week. In addition, Community response packages will be allocated (150 tonnes) ten locations 1,600 1,500 While the probability of the worst case scenario (total loss of containment for an Aframax tanker) has a probability that is so low that it is not, in DNV s assessment, a credible planning scenario, this event would be addressed by cascading equipment in from other areas. In addition to the enhanced resources based in the Salish Sea, WCMRC has, through its existing mutual aid assistance agreements, access to supplementary resources which will provide sufficient capacity to respond to a worst case spill. Mutual Aid is a formal agreement among responders to lend assistance across jurisdictional boundaries when required and several such agreements have been formed between WCMRC and three other organizations: Southeast Alaska Petroleum Response Organization (SEAPRO) Eastern Canada Response Corporation (ECRC) Marine Spill Response Corporation (MSRC) As a result of these agreements, organizations train and exercise together, ensure equipment is compatible, share communication frequencies as well as best management practices. In addition to WCMRC s agreements, there are Joint Marine Contingency plans that exist between Canada and the US, France and Denmark. The effectiveness of the enhanced response was exercised under simulated conditions by EBA with input from WCMRC for a credible worst case oil spill event. The results of these simulations are included in Trans Mountain Expansion Project Oil Spill Response Simulation Study, Arachne Reef & Westridge Marine Terminal (EBA, WCMRC, 2013). The WCMRC study serves as a practical example of how response capacity could be enhanced to accommodate the Project. Implementation of the plan would be subject to a Termpol 3.1: Introduction 15

18 number of factors and requires knowledge that will be gained through the outcome of the Federal and Provincial reviews of marine spill response, the NEB review of TMEP, and further consultation with Aboriginal groups and other marine communities. While recognizing that there are alternative means to achieve similar results, Trans Mountain is supportive of the enhanced capacity and the general means of implementation described by WCMRC. 2.9 SUMMARY OF RECOMMENDATIONS Mitigation of risks is an essential consideration in Trans Mountain s submissions, both in terms of avoiding accidents and reducing their consequences should they occur. The existing tanker safety regime is based on local experience and international best practices. It is comprehensive, well established, and has proven to be effective. A wide array of risk mitigation measures will be employed for the TMEP operations, the majority of which are already in place for the existing Westridge operations. These measures include: Tethered tugs and standby tugs to assist the tanker during berthing at the terminal. Oil booms deployed around the vessel during cargo transfer activities. Loading platform at the berths drained to sloop tanks and treated at shore. Emergency Release Couplers at the loading arms Emergency shutdown (ESD) valves at flow pipelines by the manifold at the loading platform and at landfall, all ESD can be activated from the control room. Overfilling detection at the tanker vessel. Leak detection at the pipeline Operational procedures to assure that all systems works adequately prior to cargo transfer. Operational procedure for safe cargo transfer activities both onboard the ship and at the terminal A Loading Master assigned to each loading tanker. Fire prevention and protection both onboard the vessel and at the marine terminal. Marine Terminal personnel who are trained for the purpose. Emergency Response Plans that are already developed and in place for current operations at Westridge terminal, which will be further adjusted for the increased future activities. However, to further mitigate the effects of the existing and proposed tanker traffic that will result from the Project Trans Mountain recommends the Termpol Review Committee consider the following measures: Potential improvements to the Aids to Navigation system (See Termpol 3.5 / 3.12) Termpol 3.1: Introduction 16

19 Potential extension of the zone of Pilotage (e.g. to a location west of Race Rocks) and traffic scheduling / management protocols in congested areas (Termpol 3.5/3.12) Additional untethered tug escort for laden tankers through Strait of Georgia and Juan de Fuca Strait (Termpol 3.15) The availability of suitable tugs for this purpose has been assessed in An Evaluation of Local Escort and Rescue Tug Capabilities in Juan de Fuca Strait (Robert Allan, 2013). Introduction of a laden tanker moving exclusion zone (Termpol 3.15). On October 8, 2013, Trans Mountain wrote to the Canadian Coast Guard and the United States Coast Guard, the managers of the Joint Cooperative Vessel Traffic System, requesting for such measures to be introduced for all laden tankers in the region as part of continuous improvement of waterways management practices (see Appendix E to this document). Consider applying similar rules and restrictions associated with meeting traffic at Turn Point to East Point and Discovery Island as well (Termpol 3.15) Facilitate the development of a shipping channel in the eastern section of PMV between Second Narrows and Port Moody (Termpol 3.5/3.12) Formalize the existing practice of using tethered tugs and passing at reduced speed for large commercial vessels passing the Westridge terminal (Termpol 3.5/3.12) Assign the area demarcated by the oil spill prevention booms surrounding the tankers loading at Westridge terminal as exclusion zones (Termpol 3.15) Encourage fitting and use of AIS equipment and radar reflectors by more vessels on a voluntary basis (Termpol 3.5/3.12). Today the International Convention for the Safety of Life at Sea (SOLAS) requires AIS to be fitted aboard all vessels of 300 GT or more. As AIS has been proven to be a key tool in accident avoidance a large number of smaller vessels have fitted AIS on a voluntary basis. Consider making the provision of AIS mandatory for all powered vessels exceeding 12 m length. Until such time as such mandatory regulations can be enacted, consider promoting the voluntary use of AIS on smaller vessels. Trans Mountain will assist an expedited rollout of AIS on smaller vessels by supporting fitting those small craft that enrol in WCMRC s Fishermen s Oil Spill Emergency Team (FOSET) program. Trans Mountain proposes adding a requirement to their vessel acceptance criteria that a vessel planning to depart Canada via the Juan de Fuca Straits shall agree that, upon exiting the Juan de Fuca Strait, it shall steer a course no more northerly than due West (270 ), till the vessel is outside Canadian EEZ (Exclusive Economic Zone) (200 NM from coast of Canada) (Termpol 3.5/3.12) That risk based planning standards for spill response be adopted for the Salish Sea. These planning standards should be established based on consideration of Termpol 3.1: Introduction 17

20 probability and consequence, with particular consideration to credible worst case spill volumes, material fate and behaviour, as well as the geographic setting and sensitivities. The regime should be modified to provide a means to identify and sanction risk based response planning standards for areas requiring enhanced response. Whether through the private response organizations such as WCMRC, or through the public efforts, where new investment in response capacity is required opportunities to maximize the benefit to Aboriginal and other communities affected by the possible risks with marine traffic should be sought. Termpol 3.15 and the supporting studies provide an example of how risk based planning standards could enhance the spill response capacity and response times for the study area. Trans Mountain is willing to actively support efforts in this regard CONCLUSION This suite of Termpol studies and the associated supplementary reference and background material comprise a thorough and comprehensive review of the navigational and operational safety aspects of the proposed TMEP facilities. The existing Westridge facility has operated safely for many decades, demonstrating the effectiveness of the existing safety protocols. Additional safety protocols have been recommended that, if implemented with TMEP, will reduce the risks and hazards even further, offsetting the effect of increased tanker traffic. It is Trans Mountain s opinion that the added risk posed by increased tanker traffic is both reasonable and manageable. With the implementation of additional risk mitigation measures as recommended in these reports, the total project risk will be reduced to a similar level of risk that already exists, and will allow the continued safe transport of oil in British Columbia waters for many decades to come. Termpol 3.1: Introduction 18

21 APPENDIX A: ABSTRACT OF TERMPOL STUDIES Termpol 3.1: Introduction

22 ABSTRACT OF TERMPOL STUDIES 1. Introduction (Termpol Study 3.1) - This introductory section provides a brief overview of the TMEP project and a summary of the Termpol scope as agreed upon with the TRC. It can be viewed as an executive summary of the entire Termpol process undertaken by Trans Mountain. 2. Origin, Destination and Marine Traffic Volume Survey (Termpol Study 3.2) -The objectives of this survey are to quantify and describe all marine traffic movement that collectively forms the regional marine traffic network. The purpose is to assess the impact of the proposed shipping traffic on existing and potential future shipping traffic in the region. The traffic data is used as input into the risk analysis elements (Termpol 3.8 and 3.15). 3. Fishery Resources Survey (Termpol Study The objectives of this survey are to identify locations of fish, fish habitat, fishing operations and the customary routes to major fishing grounds. It serves to update the existing database on regional fisheries resources. 4. Offshore Exercise, Exploration and Exploitation Activities Survey (Termpol Study 3.4) - This identifies the geographical locations and frequency of use of military exercise areas involving ships and aircrafts; and the routes used by offshore supply vessels engaged in the offshore exploration and exploitation of oil and gas fields. This study was not required because the movement of military vessels is covered in Termpol 3.2 and there are no offshore oil and gas fields within the project s study area. 5. Route Analysis, Approach Characteristics and Navigability Survey (Termpol Study 3.5) - This study is to assess ship and route safety, the adverse effects of ship accidents and, when applicable, public safely matters associated with tanker traffic. This study is at the heart of the navigation assessment and involves a detailed assessment and description of the route. 6. Special Underkeel Clearance Survey (Termpol Study 3.6) - All relevant factors which may affect underkeel clearance in order to ensure navigation safety is covered as part of this study. 7. Transit Time and Delay Survey (Termpol Study 3.7) - The objective of the transit time component of this survey is to determine the safest coastal zone and/or inland waterway speed profile for ships proceeding to and from the proposed marine terminal. The objective of the delay component of this survey is to determine the probable causes, locations, durations and the frequencies of delays in the movements of marine traffic through a ship channel or ship channels connecting the coastal approaches and the proposed marine terminal. Termpol 3.1: Introduction

23 8. Casualty Data Survey (Termpol Study 3.8) - This study researches historical casualty information and is an important component of the risk analysis. 9. Ship Specifications (Termpol Study 3.9) - The objective of this is to document the range of tankers expected to demonstrate that the navigability assessment and terminal design are appropriate for the intended vessels, and that all vessels will be compliance with statutory requirements under the IMO and Canada Shipping Act. 10. Site Plans and Technical Data (Termpol Study 3.10) - This is a technical discussion of the engineering design information relating to the proposed marine terminal together with relevant background data, design criteria, environmental and other site studies. 11. Cargo Transfer and Transshipment Systems (Termpol Study 3.11) - The survey outlines the plans and descriptions of the design ship s cargo containment and transfer systems. It briefly outlines the key features of the marine terminal s cargo handling and transfer system, which will incorporate equipment and instrumentation and procedures that will be to industry best practices. Transshipment of cargo is not considered part of this project and is not covered in this study. 12. Channel, Manoeuvring and Anchorage Elements (Termpol Study 3.12) - Here the suitability of existing channels for the design ship(s) is assessed and it identifies any areas of concern where navigation requires particular attention. 13. Berth Procedures and Provisions (Termpol Study 3.13) - Although specific detailed procedures will only developed later after the terminal design has advanced, the study documents normal or expected berthing and unberthing procedures based on fast time simulation of the design vessel in relation with the design terminal and accepted best practices in the industry. 14. Single Point Mooring Provisions and Procedures (Termpol Study 3.14) - This section is not applicable for the TMEP project. 15. General Risk Analysis and Intended Methods of Reducing Risks (Termpol Study 3.15) - The risk of uncontrolled releases of cargo either en route or at the terminal are assessed together with the fate and behaviour of any oil spilled to the marine environment. Risk mitigation is discussed and detailed in this study. 16. Port Information Book (Termpol Study 3.16) - The Port Information Book is to provide ship s personnel with a comprehensive set of details relevant to the needs of the port of Vancouver. It is based on the Port Metro Vancouver Harbour Operations Manual and would be prepared prior to the facility commencing operations in order to ensure it is up to date. Termpol 3.1: Introduction

24 17. Terminal Operations Manual (Termpol Study 3.17) - A Terminal Site Operations Manual is meant to inform and to guide the crews of ships calling at the marine terminal on specific terminal related items that the vessel would require to know in order to conduct itself safely and responsibly. As an existing facility Westridge Marine Terminal already has operating procedures. It is intended to combine items 16 and 17 in one document, which will include updated procedures to address the expansion of the terminal and increased activities there. It shall be available prior to six months before the commencement of operations of the expanded facility. 18. Contingency Planning (Termpol Study 3.18) - A preliminary outline of the future expanded marine facilities intended contingency plan is prepared. The actual plans will be based upon detailed design work of the marine terminal, which will be available later and shall be developed in consultation with the Western Canada Marine Response Corporation (WCMRC) and other experts in the field of marine emergencies. It will be submitted at a later date. 19. Oil Handling Facilities Requirements (Termpol Study 3.19) - This section documents that the terminal design and operation will be implemented in a manner consistent with the requirements of an Oil Handling Facility as defined in the Canada Shipping Act. While the proposed TMEP facilities have not yet been fully designed, Trans Mountain can confirm that the future facilities and operations will meet or exceed all applicable regulations. 20. Hazardous and Noxious Liquid Substances (Termpol Study 3.20) - This study is not applicable to TMEP. Termpol 3.1: Introduction

25 APPENDIX B: LIST OF SUPPORTING DOCUMENTS AND REFERENCE MATERIALS Termpol 3.1: Introduction

26 Table B-1. List of Termpol Studies and Appendices Doc. No. Termpol Study Document Title Author Pages Introduction Moffatt & Nichol (2013) Origin, Destination and Marine Traffic Volume Survey Moffatt & Nichol (2013) Appendix B Projections of Vessel Movements Seaport Consultants Canada Inc. (2013) incl Fishery Resources Survey TERA Environmental Consultants (2013) 39 5 N/A Offshore Exercise, Exploration and Exploitation Activities Survey Not required Route Analysis, Approach Characteristics and Navigability Survey Moffatt & Nichol (2013) Appendix D Summary Report of Manoeuvring Assessment Westridge Terminals LANTEC Marine Inc. (2013) Vancouver Expansion. incl Special Underkeel Clearance Survey Moffatt & Nichol (2013) Transit Time and Delay Survey Moffatt & Nichol (2013) Casualty Data Survey Det Norske Veritas (2013) Ship Specifications Moffatt & Nichol (2013) Site Plans and Technical Data Moffatt & Nichol (2013) Cargo Transfer and Transhipment Systems Moffatt & Nichol (2013) Channel, Manoeuvring and Anchorage Elements Moffatt & Nichol (2013) Combined with 3.5 incl Berth Procedures and Provisions Moffatt & Nichol (2013) N/A Single Point Mooring Provisions and Procedures Not required General Risk Analysis and Intended Methods of Reducing Risks Det Norske Veritas (2013) Appendix 1 MARCS Methodology Det Norske Veritas (2013) incl Appendix 2 Navigational HAZID Report Det Norske Veritas (2013) incl Appendix 3 Terminal HAZID report Det Norske Veritas (2013) incl Appendix 4 Effect of Risk Reduction Options Det Norske Veritas (2013) incl Port Information Book Moffatt & Nichol (2013) Terminal Operations Manual Moffatt & Nichol (2013) Combined with 3.16 incl Contingency Planning Moffatt & Nichol (2013) Oil Handling Facilities Requirements Moffatt & Nichol (2013) 4 26 N/A Hazardous Noxious Liquid Substances Not required - Subtotal 1006 Termpol 3.1: Introduction

27 Table B-2. List of related background/supporting studies completed for the TMEP Project Doc. No. Termpol Study Document Title Author Pages S1 Supports 3.2 Marine Traffic (2012) relevant to Trans Mountain Expansion Det Norske Veritas (2013) Project 8 S2 Supports 3.5/3.12 Meteorological and Oceanographic Data Relevant to the Proposed EBA. (2013). Trans Mountain Expansion Project 220 S3 Supports 3.5/3.12 An Evaluation of Local Escort and Rescue Tug Capabilities in Juan Robert Allan Ltd (2013) and 3.15 de Fuca Strait 67 S4 Supports 3.7 Analysis of Second Narrows Transits Ausenco (2013) 7 S5 Supports 3.10 Westridge Marine Terminal 2013 Interim Meteorological Report, EBA. (2013). 56 S6 Supports 3.10 Oceanographic Observations at Trans Mountain's Westridge EBA. (2013). Marine Terminal 43 S7 Supports 3.15 A Study of Fate and Behaviour of Diluted Bitumen Oils on Marine Witt O'Brien's, Polaris Applied Water Dilbit experiments, Gainford, Alberta Sciences, and Western Canada Marine Response Corporation (2013) 163 S8 Supports 3.15 A Comparison of the Properties of Diluted Bitumen Crudes with Polaris Applied Sciences, Inc. other Oils (2013) 26 S9 Supports 3.15 Modeling the Fate and Behaviour of Marine Oil Spills for the Trans EBA (2013) Mountain Expansion Project 759 S10 Supports 3.15 Modeling the Fate and Behaviour of Marine Oil Spills for the Trans EBA (2013) Mountain Expansion Project (Summary Report) 97 S11 Supports 3.15 Methods of Estimating Shoreline Oil Retention Coastal & Ocean Resources (2013) 20 S12 Supports 3.15 Future Oil Spill Response Approach Plan, Trans Mountain WCMRC (2013) Expansion Project 81 S13 Supports 3.15 Trans Mountain Expansion Project Oil Spill Response Simulation EBA, WCMRC (2013) Study, Arachne Reef & Westridge Marine Terminal 84 S14 Supports 3.15 Technical Note - Aframax Characteristics Det Norske Veritas (2013) 4 S15 Supports 3.18 Central Burrard Inlet - Westridge Terminal Pre-Spill SCAT Project Brief Oct, 2013 E3 Environmental (2013) 2 Subtotal 1637 Note: The list of studies in Table B-2 above includes those that were completed as part of the TMEP project as a whole and not specifically for the Termpol process. Citations and references from other public domain sources are not included in the tables above. Termpol 3.1: Introduction