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*iYRE'PQR.TOFTHE 'D.o.E. TASK F6"RC'E ON:;;THE "/':' MACKENZIE VALLEY PIPELINE APPLICATION', Pa rt I. North of 60°

EnvironmentConade

EnvironnernentCanada

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Environ mentalrV!3nagemcnt

Cestionde l'environncrneut

C,:18d inn Forestrv ServiceNr,rtn:!:n Forest f~cs('arch Centre:>:.; 21) _. 12 2 StreetEd.r.1I.Jn ton, AlhertaT6ll 355

?-II'" J.J. EatockChaa.rmm ,rt~giO:1al Board,'West;~rn and Northern Regi.on ,1023 - 10025 Ja;~·er'Avenue

ED}lCNTffil, AlbertaT5J 2X9

.R~: Report of the D.C.E. Tas}: FO~Ge

Teieplll:me: (403) 435-7210

Aoril 1, 1975

Attached is a copy of the report of the DOE Tasl·: Force on t;"a

}1ackenzie Valley Pipeline Aoplication, nnrth of 60°. This report is the

result of a. re'!]'i'::no1 of t~e above App'Llcat.Lon , and reflects the expert

" . opinions of the Task Force 'members and the agencies they represento."

The first draft of )'Digest of En~iron:nental Concerns!' which

was r.~de··'aYa.ili1ble to Ocmmi..s ai.on CounceL on Narcn 9, 1975, is included

in the Appendix.. Inasmuch as the abstract of the report is already 'Dublic

information, the attached. r-epor..t may also have to be made. available to

o

Jus,tice Berger e

Distribution:

Dro JoS. TenerDr 0 A.R.. Hacph81"SCnt:~ro E.. Pat.ersonMembers, Task Far~e

5,,1';. Zolt:~i

Chaarman ,p.O.E. Task Forc~

e

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. REPORT OF TRE D.O.E. TASK FORCE ON THE

MACKENZIE VALLEY PIPELINE APPLICATION

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Part I. North of 60 0

TASK FORCE

S.C. Zoltai .(Chairman)

R.P. BaldHin

R. Edwards

A. Goodman

B. Janz

L. C. l-lunn

J.N. Stein

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TABLE OF CONTENTS" . "",,',

I~TRODUCTION, 1

'GENERAL TOPICS1. Total impact . •2. Assessment of final design3. Monitoring of activities •4. Pipeline generated demands

. . . . ..

on natural resources

22223

44

467

899

10

11

111213IS161618

10

19 .. . '. 20

2021

2122

,. .

.'. . .

Ice bulb development • • • . • . •Interference with drainage by generatedpermafrost • ~' • • • • • •Test facilities ~ • • • •Excessive width of right-of-wayIneffectiveness of artificial revegetation as ,insulation. . .. . ........•.• ". .Increased incidence of forest fires . • • •Tundra revegetation • • • • • • • • • • • •Appli~ation of arctic construction methods • • • •Estimates of stream discharge and flood stagelevels . . . . . . . . . . . . . . . . . . . .Routing of pipeline to avoid difficult stream

-. .crossdngs • • • .• • • • ._ • • .'. •.• • • •Stream'bed changes induced by constructionactivities • • • • • • • • • •Fuel and oil spillsPipe testing liquids • • • • •Wastewater treatmentSolid waste disposal., • • • • • • •Emissions from compressor stationsStream crossings • • • • • • • • • •Removal of borrow material from lake and riversystems • • • • • • • • • ..• • • • • •Waste and toxic material in water bodiesUtilization of fish resources by pipelinepersonnel ... • • • • • • • .•" .' •••Culvert stream crossings • • • .0 . . . .Pipeline construction, routing and timing inrelation to fish resources . • • • • •Effects of water use and disposal

21.22.

19.20.

23.

12.13.14.l5~

16.17.18.

SPECIFIC TOPICS1.2.

3.4.5.

6.7.8.9.

10;

11.

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24. Effects of disturbance on wildlife 0 0 ~

25 ~ Effects of erosion and sedimentation 0 .0

26. Effect of the Dempster Highway 0 • 0 0 0 • 0 •

27. tack cif ~oncern for recreation sites •• 0 0 0

28. Alignment Changes •• 0 ••••

222627

. 2728

APPENDIX 1. Membership of Task Force and area of .responsibility' ,'. • • • 0 0 • 0 29

J.

APPENDIX II. Digest of environmental concerns 30

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o , .INTRODUCTION

The' obj ective of the Task Force ~JaS to r evi.ew the application.of Canadian Arctic Gas Study Limited to build a pipeline from Alaskato the U.S. border along the 49th parallel. The Task Force was to identify

,any detrimental environmental conseque~ces of the pipeline proposal ·thatwere not considered, or ,vere inadequately or incompletely handled by theApplicant. The Task Force was to examine all aspects of environmentalimpact for whIch the Task Fo rce and its parent agencies 'can claim expertise.not being restricted to areas where DOE has legislative responsibilities.

In evaluating the possible environmental impact of pipelineconstruction, operation and abandonment, the Task Force assumed thatthe intentions of the Applicant are outlined in his Application to theDepartment of Indian Affairs and Northern Development, Application to theNational Energy Board, and in Sections 8, 9, l3a & b, l4c, e, f & d andin the Alignment Sheets of the supportive material.

The r evLew of the Task Force 1 "as iramensely aided by the reportof the Pipeline Application Assessment Group, consisting of personnel ofthe Department of Energy, Mines and Resources, Department of the Environment,and Department of Indian and Northern. Affairs. This group published avery thorough assessment of the application. In the review process theyidentified some deficiencies, which were transmitted to the Applicant whoreplied in January, 1975. The replies contained in this "Responses toPipeline Application Asse3sment Group Requests for Supplementary' Information"deal effectively with some poten~ially difficult situations by, in effect,modifying the original proposal. The original 'application, however. wasnot amended to accomodate these modifications, hence the intentions ofthe Applicant are not clear.

Department of Environment personnel .were wholly responsible forsections of the Pipeline Application Assessment Group review in the fieldsof fisheries, wildlife 'and hydrology, and reade significant contributions inother fields. It is to be expected, therefore, that· concerns expressedby the Pipeline Application Assessment Group and this Task Force would.in many cases, be identical. Because of the co~prehensive nature of theAssessment Group~s review, there would be little merit in attempting 'tomake the present r evf.ew a complete s t atement on the anticipated effectof the Applicant's proposal on the natural environment. The intentionwas , therefore,

TO AUGNENT THE tolORK OFTRE ASSESS~lENT GROUP BYCm-::HENTING ON CONCERNS THEY DID NOT RAISE,AMPLIFynrG S021E OF THE CONCER?iS THEY DID RAISEp~ SUPPORTING THE ·GREAT BULK OF TREIRREVIEWBY NOT CO~'fHENTING ON IT.

Membership of Task Force and area of responsibility is given inAppendix 1.

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The, Task Force found that .their r ev Lew was frustrated by theincompleteness of the info~ntiQn on many important details. Numerousr eferences we r e made by the Applicant to studies still in progress andto the importance of local aata to be collecte.d later, all of which will­influence the location or engineering design. The present review is,therefore, not,site specific, but is concerned Hith principles applicableto the general proposal. '

This r evLew consists of two par t s , In the first part some overalltopics relating to Government-Applicant interactions are identified. Inthe second part some environmental concerns are highlighted, includingsuggestions for the mitigation, avoidance or minimization of the detrimentaleffects.

GENERAL TOPICS

1. Total impact

The impact of the proposal on the environment is believed tobe' \vithin tolerable limits, although both short-term and long-term dis­ruptions and detrimental effects can be expected. 110st detri~ental

consequences and disruptions can be mitigated and kept to a minimum ifcertain design modifications, route relocations or careful timing ofactivities. are observed. Many. of the mitigating measures are aimed atprotecting the integrity of the pipeline and hence the environment, andmany are intended to protect a particular resource.'

2. Assessment of firial design

The Applicant makes it clear that the submitted oaterial is notthe final design of the pipeline and further modifications and changes\vill follow in engineering design and location. Subsequent regional andsite specific studies will influence the final design, as w~ll as compliancewith any conditions that may be imposed upon the Applicant. It is there­fore vital that

the final design be examined in detiai.l: by agoverr~ent agency or agencies~ and constructionnot be permitted to proceed without the approvaiof such an agency or agencies.

3. Monitoring of activities

It is essential tr~t all activities and facilityperformances dVJ'inq the constructicn~ operationand abandonment phases be monitored and super­vised by a qouernment: agency to ensure thatregulations~ terms'and conditions are met' accordingto tihei» original intent; to minimize the effectsof' accidental events; and to ovel'come any longterm influences of pipeline development on theenirivonment: and natural. resources.

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4. Pip~line generated, demands, on natural resources (Concern #18 in,"Digest')! .

,\UthO the cons truction of .a pipeline or any development ofa similar scale, considerable numbers of people, either connected withtile development itself or ~dth various ancillary business, Hill be movingnorth. At the completion of the project, some may elect to remain inthe north. As a result, there will be new demancs for Hater or forstream gravels as sources of construction materials. resulting in areduction in the availability of suitable habitat for the aquatic resource.Increased volumes of sewage and waste -.'ill have to be disposed of.Increased handling, storage and use of oils. fuels and other chemicalsa~d toxicants will result in a higher incidence of spills and pollution.There will also be a new demand for the fish, ~.]ildlife and timber r esource ,Sport usage will increase tremendously. especially with new roads andrigh~of-wayt providing improved accessibility. Although such developmentscould be initiated by the construction of the proposed pipeline and itssupport systems, the responsibility for preparing a comprehensive assessmentof these long term impacts may be a joint proponent-government effort.

1.

2. Comprehensive resource management programs should beexpanded toaccomodate the anticipated accelerateddemand.' Such programs, aimed at controlled harvestingat sustainable levels, must be based on accurate infor­mation of present and potential productive capacity ofthe terrestrial and aquatic ecosystems.

3. Biological monitoring programs should be established with \all major development projects, once government approval (Ihas been granted. Such programs should determine theeffectiveness of environmental protection measures incor­porated:by the developer or recommended by government.

Clearly, the responsibility for expanding or initiating theabove activities rests with the government. The proponent has however,both a direct and indirect interest in maintaining the equilibrium inthe en~ironment. In some areas he,has direct control and responsibili~ies

(personnel,' environmental accidents~ access, etc.) hence he has an activerole in mitigating the long range impact of the pipeline on the environment.

Digest of Environmental Concerns, Appendix II.

4o

Geoth~rmalstudies indic~ted ~hat a considerable po~tion ofthe groundwater remains unfrozen in perennially frozen ground. Thesestudies also shot.. that if a temperature gradient exists, moisture willmove from the warmer to the colder area Hhere much of it Hill freeze.Thus, excess moisture will accu~ulate in icy layers near the chilledpipeline whLch is colder than the surrounding permafrost. As themoisture content, permeability and therr.lal gradient is variable in theterrain, the resulting ice buildup and stresses will be variable. Thisconcern was expressed by the Assessnent Group (Section 8.1).

The Applicant recognizes the potential for differential frostheave due to ice build-up around the chilled line. He lists a number ofmeasures (8.b.l.4.2) that can be taken·to prevent frost heave, but noneis proposed. The application further states that a test program isbeing undertaken and that the engineering design will incorporate theresults of these studies.

In view of the cont~cversial and incompleteexperimental: data aoai.Labl-e on 'the performanceof chilled pipeZin6 0ith respect to ice bui~-

up, the Applicant should make all pertinentdata cQllected at ~is test facilities avaiZablefor a· tihovouqh stv..-J'j by a national or inter­nat-ional: panel of expert:s uhc iaoul.d judge theeffectiveness of pneoent-ice measures. Constructionpractices should conform to the expert: opiniongiven.

2. Interference with drainage by generated permafrost (Concern #1 in"Digest") •.

2a. The proposed chilled, buried pipeline will cross unfrozen ground.In the far north (in the Continuous Permafrost Zone) the only.unfrozenareas are under lakes and large rivers. Under smaller rivers the activelayer may be thick, with permafrost at greater depth. In the northernpart of the Discontinuous Permafrost Zone additional unfrozen areas occurunder the very wet organic deposits (fens), most of which serve asdrainage channels. South of about ~Hllo"Tlake Rive the proportion ofunfrozen mineral soil terrain increases) mainly in better drained areas.However) very large tracts of unfrozen, very ~~et peaty soils will also becrossed', most of whi.ch are in s Lowl.y draining fens.

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In the Discontinuous Permafrost. ZOne natural processes ~ause

the permafrost to melt anu builc up in different parts of deep peat .deposits. The buil~-up of permafrost can occur in very wet fens, butnever in such a manner as to block the natural drainage.

The chilled pipeline will induce permafrost formation by freezingthe Het peat arid the underlying mineral soil, creating a strip of. imper-'maable material through the fen. This frozen strip 'viII probably project'.ell above the surface of the fen due to ice accumulation in the underlyingmfnera L soil. This frozen s t r Lp., if cutting across the fen, will act .asa dam, causing ponding upstrea!:l and desiccation dotvnstream. Continuingseepage during the winter may cause icing conditions.

The Applicant states that their design will eliminate drainageproblems (8b.l.3.8.4.l). The proposed designs,however are for betterdrained mineral soils and are for t~et, peaty areas. The method proposedfor perennially frozen peaty areas is not applicable, as the unfrozenpeat does not offer adequate support for the placement of granular materialsin the ditch. Further suggestions in the "Responses" (p. 20-4) of restrict­ing the availability of water do<no t seem feasible, nor would they avoidthe creation of a dam. The remed:'al measure of increasing the load atthe frost frong may reduce frost heaving, but would create an even higherdam~ Insulating the pipe will delay the process, but not prevent it •

. "Z-.' 'In order to mitigate the effect of damming offens .. the Applicant shoul.d ccneider alternatemodes of pipeZir.e construction.. 'Such aselevating the pipg on supports.

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ii. In the southern part of the Mackenzie VaZZeywhere most permafrost occurs as patches of .perennially frozen peatlands, the thalJing ofsuch patches would caU3~ Less disru.ption than .the freezing of unfrozen areas. In this area~

e.g. south of Fort Si~pson, the gas need not ,be ohi.l.led,

2b. Hinter water conditions in the smaller northern streams are ~'incompletely known , Flow levels are minimal in the t'Tinter, in many cases 15("the streams will freeze to the bottom. In many instances, however, somemovement of trater continues in the gravel under the bed of the river. .Other streams-that show no Hater movement one winter may have a substantialflot~ the following year due to particular weather conditions.

A chilled-, buried pipeline, crossing such streams, will freezethe stream bed adjacent to it, and impede toe f Low through the gravel.The water f Low , vital for fish overwi.nterLng in local pools and for eggsincubating in gravel, will be diminished or cut off. Furthermore, theimpeded flow may incuce the formation of icings, e.g. the development ofthick ice sheets on the bed of the stream.

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S"trear.ls which havesubtetrranean 'flo'..Js tnuei: not 'be blocked byinduced pexmafrcet., The conetvuct-ion of 'a,b~idge or elevated supports to carry thep-ipel-ine across sucli .etireams should beconsidered. In SOffoe streams additionalinsulation may be a suitable soLution.

2c.' In areas underlain by permafrost the infiltration of' precipitationinto the ground is inhibited by the pernafrost layer. The excess moistureis drained by do~~hill seepage in the active layer, over the permafrost.The' chilling effect 'of the buried pipeline ~",ill reduce the thickness ofthe active layer over the pipe. This will affect the drainage, as identified'by the Assessment Group (Sections 8.1 and 8.10). Sub-surface drainag~

normally passi~lg through this layer cou~d be impeded to a point where itwoul.d exit from the ground near the pipeline, or at some point up slopefrom the pipe, thus altering the sub-surface drainage pattern and maycreate icings in the early \virtter months which could alter surface drainagethe folloWing spring.

The Applicant's drainage control works' are designed to controlsurface drainage arising from sources identified at or prior to construction.However, the operation of a chilled line may later the drainage character-'.istics to 'a point' 't-7here the system is'locally overtaxed. Such overtaxingcould lead to concentration of drainage, ponding or uncontrolled drainage,resulting in erosion, terrain instability and siltation.~~,

The interference 'with sub-surface drainage is par t LcuLarLyimportant in areas of groundwater discharge identified by springs, mineralsprings or'spring fed lakes. Impeding ,or interfering with the drainage,of such areas could very easily lead to serious icing conditions in thev1inter.

Areas of high groundwater activity should beavoided by a bus-ied, chi Zled pipe line. Thedesign of surface drainage works over thepipeline must include careful considerationof both'existing and potential drainage flow.

3.' Test facilities

The Applicant has constructed test facilities at Prudhoe Bay,Sans Sault Rapids (Mountain River), Norman 'i\lells and Calgary. The con­stTuction and' operations of these facilities were fully recorded andmonitored with sophisticated instruments. The northern test sites wereallegedly located on terrain that is difficult and is representative ofthe Mac.kenzie· Valley. The results 'obtained from these test facilitieswere used to design the pipeline.

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The results obtained from the test facilities are containedin consultants' reports and were not made public, ncr ~lere they discussedin any de'tati L in the submi.s's t.on , This makes it impossible to evaluatethe claim that'the rest.:lts were utilized in the construction and engir.eeringdesign of the pipeline. Results pertaining to elevated pipeline are s1miarlynot available, hence the reasons for the dis~issal of this construction modeby the Applicant is not kno~m. ~

The Sans Sault Rapids test facilities is located on a fluvial' ' , 'terrace, composed of ,silt and sand (Geol. Surv. Canada, Surficial Geology' ..and Geomorphology Hap 106 11). A study of other surficial geology maps

valleys. .The claim that the terrian is representative of the MackenzieValley appears to be exaggerated. .The terrain featur-es at the Calgary..facility are not known , but a general know.Ledge of the facility area .indicates that the water table is below the test pipe. If this is true,this condition would certainly not be representative of conditions in theNackenzie Valley.

All the northern facilities are on permafrost terrain, therefore t'.:\Jthe effects of cold pipeline on unfrozen soil, ar.d especially on unfrozenpeat soils could not be tested. Another wea~,ess in the siting of the .test facilities is the lack of variations in subsurface drainage, especially"ith the pipeline going across the slope. Having missed these vari~tions

in the terrain, the Applicant is' in poor posd t Lon to design for these very ;. cowman problematic conditions.

The Applicant should be requi~ed to produceevidence of having utilized the data obtainedfrom the test facilities. In the absence of 'experimental data he is· requested to reconsider,the construction modes for areas to whichresults from his test facilities do not apply~

4. Excessive width of righ-of-way (Concern #2 in "Digest")

, The applicant proposed to utilize a right-of-~ay 120 feet in,;idth ",,,ith variations dependant on local requirements" (Application toD. LA.N.D., p. 9). This ,·ddth wouLd allow room for the temporary place­ment of spoil on one side of the pipeline ditch, and room for a workinglane and a two-lane access road on the other side. The entire right-of­way 'lould be cleared of trees and shrubs Hith machines over frozen ground.or by hand on unfrozen ground. The machines would be equipped withprotective shoes for operating under arctic construction conditions. '

In. the subarctic forests the re~oval of trees and high shrubs issufficient to thicken the active layer. Hany insulating mosses (feathermosstype) cannot survive the. re~oval of shade, er.d will be replaced by herbsand grasses ,lhich have far less insulating value. It is important therefore.that the tree cover be left intact over as much area as possible, especiallyon sensitive permafrost areas.

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. Nowhe.re doas the Applicant justify the need for a 120-:foot ,.,ider Lgh t-eofi-way , Dt:.2. to r.estrictive legislation, sections of the A1aksaPipeline are being constructed on -55-foot r tght-of-ways , This imposesrestrictions on the mov~rnent of vehicles and materials (e.g. the workinglane is also a travel lane; excavated material is stored on disposal groundsand returned to fill the ditch, etc.), but it also illustrates thatconstruction is possible on much less than a l20-foot right-of-way;

A crude estimate (access road: 30 ft; working lane: 30 ft; ditch:7 ft; spoil: 23 ft.) suggests that the right-of-way could be reducedsubstantially. There may be circumstances under ~hich a wider right-of-waymay be required; these should be identif ied by the Applicant. 'The width"of the r rght.-o t-way f or ancillary roads was no t .indicated by the Applicant.

The pipeline right-of-way shouZd be reduced by25-33% to a standard 90-80 feet in width in the

. sensitive per.mafrost areas. The width of right­of-way for access roads should be restricted tothe width of the road. The Applicant should berequested to justify the need for a wider thanthe standard right-of-wp:y c.rd obta.in permissionin each case before proceeding. . '

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5. Ineffectiveness of artificial revegetation ·as insulation (Concern ·03in "Digest).

The Expanded Guidelines require the Applicant to develop "plansto carry out assisted revegetation or alternative methods of providing aninsulating cover on vrhLch natural revegetation ~~ occur". This guidelineclearly emphasizes the value of revegetation \07ith respect to its insulatingqualities. This concern was raised by the AssessQent Group in Section 8.14.

The Applicant proposes to seed grasses on the disturbed right­of-way. He states .that these grasses are ef f LcLent ' insulators of t heground and \-7i11 prevent hydraulic erosion. Heat flux measurements bythe Applicant (Arctic Gas, Biological Report Series, Vol. 2, p. 30-33;and Progress Report on CAGSL Revegetation. studies north of 60°, by ~o~thern

Engineering Services Co. ·Ltd.· p . 19-2.4) show that under a full cover ofmeadm" foxtail the heat flux is almost as ION as under an undisturbed naturalsite. This, however , did not prevent the thickening of the active layerunder areas from which trees and shrubs have been removed and \.;hich weresubsequently seeded to grass. Diagrams in "Progress r.epo r t on' CAGSLrevegetation s.tudies north of 60°" show that after two growing seasons theactivalayer is 15-35% thicker under the well drained treated areas thanunder undisturbed areas, and 60-85% thicker under poorly drained threatedareas. The general ineffectiveness of grasses as insulators has beensho~vn by numerous studies in a number of locations .

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Effective~ long term insulation of the di$turbed"surface must be achieved. Experimentation willbe neCeBSD.1~Y utiliz1:ng natural and ai'tificialmeWlS. Insulation directly above the frozen pipeby vegetation is not a concern.

6. Increased incidence of forest fires (Concern #4 in "Digest").

Fires", occuring chiefly in the ·forested areas, are a constantmenace. Direct terrain damage can be caused by the destruction of the organicmat"over sensitive·permafrost terrain." Further damage may result fromattempted control measures "such as bulldozed fire breaks. The Applicantwill have fire fighting equipment available at all "times and contingencyplans will be developed in collaboration with appropriate government agencies.The Applicant does not anticipate an increase in fires during the constructionphase, as most construction will take place during the winter. The AssessmentGroup "identified this concern "in Section 8.15 of their report~

The construction scheduling proposed by the Applicant shows ·thatconsiderable activity (surVeying, stockpiling, construction of supportfacilities, etc.) will occur in the summer. This m~ans an influx of people,hence an increase in the possibility of accidental fires. Even in the "winter fires may smoulder under the snow cover to erupt later. If ill ""prepared for the increased probability of fires, such activities as equipmentdeploycent in summer over thawed surfaces, fireguard construction, delay ineffective control, etc. will cause additional damage.

The Applicant should be »eqwi.red to initiate acontingency plan, including stQckpiling ofmaterial and equipment.. and tl~aining ofpersonnel during both the preconstruction andconstruction phases~ in order to cope with theincreased probability" of forest fires.

7. Tundra revegetation

The revegetation of distur~ed tundra poses a difficult problem. "The plants" in the tundra~re "exposed to a very harsh environment. and the"growing season is short. This limits the number of species that cansurvive under such conditions. The disturbed terrain itself is altered bythe construction: a mound will be created over the centre line which willpresent a much different habitat than the original surface.

In the original exhibit the Applicant proposed to scrape offthe organic mat in the ,dnter, store it, and spread it over the disturbedsurface. Although a few plants may survive this drastic treatment. itis certain to produce unsa t Lsf'ac t or'y results. Recognizing "this, theApplicant revised this method and now proposed to rely on seeding (see"Responses.", p , 33-1). The Low insulating value of the seeded grassesis not expected to pose a problem in the cold tundra environ~ent.

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The· species of grasses to be used in the northern section ofthe p f pe.Li.ne ar e given in the "Responses" (Tab Le 32-1). The recommended.seed mixture contains grasses whLch proved to be Hinter hardy, the Arc taredCreeping Red Fescue, the Nugget Kentucky Bluegrass and Meadm.. Foxtail.However, it also contains grasses which proved to be unsuitable at SansSault Rapids and at Caribou Hills (Progress report on CAGSL revegetationstudies north of 60°, Table 2-1, and p. 31-37). The wisdom of usingspecies that were shown to be unsuitable by the Applicant's o~vn studies isquestionable.

The "Applicant is requested to adhere to thetiundra reveqetatrion method outlined in" their"Responses /I and to j1!-stify the use of unsui.tabl.especies in their seeding program.

8. Application of arctic construction methods. "

The Applicant proposed to apply special arctic construction·techniques for northern areas. These techniques, if applied as intended,will greatly reduce the environmental i~pact of construction and associatedactivies dn the terrain. In the original exhibit, the Applicant proposedto use conventional ~.;inter construction methods "generally south of" 65°".Had this guide been followed, a great deal of disturbance would have been

. caused to sensLtLve permafrost" areas. In the "Responses", however, theApplicant appears to favour a more flexible appro'ach , based 'on surface andsubsurface da t a . . The criteria now proposed to deterr.tine wher e cut gradingand/or vegetation removal wculd be'reco~~ended are satisfactory in lessening.the Lmpact; on the terrain.

The Appl.icani: is requeetied to determine the a.1'easwhere conventional winter const~~otion methodsa.1'e to be used on the basis of driZt hole dataand on site inspection.

9. Estimates of stream discharge and flood stage levels (Concern #10in "Digest").

Es t Imates of 'discharge and. stage for extreme flood event's onstreams crossed by the pip~line are required for the design of certainfeatures such as location of sag bends or extent of slope armouring.Recorded data on which to base these estimates are. minimal for the Nackenz1eSystem north of 60°1'1, particularly for the tributary streams. There isindi~ation that the Applicant may have underesti~ated these discharges andstages.

The. estimates of stream discharges and stagesshould be re-assessed afl.d utilized with extrasafety margins in construction design.'

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10. Routing of pipeline to avoid difficult stream crossing (Concern #9in "Digest"),.

: ~.: ..:.: :' .; . .,. ', ~". ,.;. ' .. ; : \ , -. :.".'., '.. '. :..; ~ : ~: ..:..::;~.~ :- .•..~ :..~.~.:. ~.:'. ~~" :.~ ..', It' is' apparent that a domiriimt factor' in the se1e~tion of the

pipeline route was the desire to mininize the construction cost of thepipeline. In many instances the Applicant has chosen to apply engineeringsolutions to environmental problems encountered, rather than avoid theseproblems by re-routing the line. There is a concern that this method ofroute selection may overlook the potential for local shifts in alignmentthat wouLd avoid the creation of environmental problems , particularly inthe vicinity of stream crossings. Humerous concerns were identified bythe Assessment Group (Section 8.7).

Re-alignment should be considered, for example, when encounteringa portion of a river showing signs of a history of ice jamming, or atstream crossings uhere bank instability is sl1;spected. In the case whereunstable sheam-banks_e:anno.Lhe_aY..o.ided;_t1:'...e line sho.u1d_b_e_$J).;i...fted to apoint within the unstable area \07here tJlJ~ p'roducts of slJJ.I!lp'ing or erosionwould be contained on the shore of the .stream, rather than flO\ving immediately'into th~. Stream crossing should also be' avoided at points where, ,the river shows vidence of frequent channel changes and where banks cont/ainsensitive, ice~r ch materials. The benefits of a philosophy of avoidanceof problems we~ recognized by the Applicant when a change was made in thealignment to ross the rlackenzie River above its confluence with the Liard

River.'· 1.IlL~R- .N~:::::J' .~. iV ~vu' . ,,-- { ,The Appl-icant: should be prepared to adjust theal.iqnmeni: of the pipe line to avoid enirivoruneniial:problems at river crossings. Such problem areasshouZd be identified end considered beforec~~pleting the 'final design of the pipeline.

11. Stream bed changes induced by construction activities (Concern #11iIi. "Digest").

The Applicant has based his consideration of'scour depths,channelization, and lateral migration at stream crossings on exfscdng orhistorical conditions~ In his design he apparently did not consider thepossible changes induced by the pipeline or its construction.

Construction and operation of a chilled, buried pipeline has apotential for changing the streambed conditions. Ground disturb~nce ,associated \vith construction, or unexpected bank slumping can change thechannel of the stream. Berm. placed in the channel for construction ·purpo~e~

~ay change scour depth, and may cause a shift in the channel. Icing inducedby the pipeline may 'deflect the spring f Low and, cause a shift in the channel. ..On floodplains, a cleared right-of~way not.at right angles to the river,valley could induce channeling of flood flows and lead to stream channel. .

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changes as wel.L as erosion of the pipe cover and a consequent t hrea t 'topipe integrity. Thus natural stream processes after the construction of'the pipeline may not relate to' pre-econs t ruc t Lon -cond Lt f orrs ; . '. "

, . ,

The Applicant should re-cssess the design for'streccn cY'ossings3 taking into cccount theeffects of possible changes caused by theconstruction and operation of the pipeline.A consid€ration shouZd be given to elevctepipeline crossings3 as well as conservativelydeep burial, in strea~ channels and on streambanks.

12. Fuel and oil spills (Concern /'!12 in "Digest").

The Pipeline Application Assessment Gro~p has addressed itselfto the potential hazard to the environment which \,ill exist from the largequantities of fuel and oil required for construction of the pipeline. Ofparticular concern in t ha s regard is the everpreserit danager of a .fueLor oil spill which may cause considerable damage to ter~s.trial-and

~pecially aquatic ecosystems. Although these dangers have been recognizedby the Applicant, it must '6'eemphasized that every precaution should betaken to guard against the occurrence of spills and to reduce the environmentaldamage, \.]hich may be caused by them. ,To this end it is essential that .'adequate contingency plans be prepared for fuel storage'and staging ~reas" 'and sufficient equipment be readHy available at all fuel stockpile andtransfer areas to contain and clean-up spills under any conditions, together

,with competent personnel trained to operate such equipment and implement 'such plans. This equipment should be maintained in working order andperiodically 'tested.

The Assessment Group's Request for Supplementary Information hadidentified information related to quantities of fuel, ~odes of storage offuel, method of handling and transfer of fuel, etc. which should be' provided.In addition to this information, the availability of containment and clean-upequipment at all stockpile sites and major transfer areas should be provided.

It is r-ecommended that the Appl icant: pr-ovideinformation on tihe-coniainment: and clean-upequipment which will be immediately avaiZableat all fuel stockpiling areas wid at areas where,majo~ transfer of fuel or oil takes place frembarges to land based stor-age facilities . . Inaddition3 contingency plans to, contain andclean up spilZs of water/metranol which,may

,occur dUY'irog pipeline testing3 should beprovided.

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13. Pipe tes~ing liquids (Concern ltD in "Digest").

The Applicant ha s indicated ,that he Lnt'end s 'to' test 10 milesections of completed pipeline, using warm Hater or a "Tater/methanol mixtureas a test medlum. For non-permafrost areas '.arm water will be used whichwill be cooled to 34-38°F before dischar,ge. For permafrost areas, theApplicant has indicated that testing will be done in winter using eitherwarm water or a water/methanol mixture. After final use the water test

.medaum will be discharged to natural water courses whi.Le the water /rnethano1mixture \11'111 be either diluted \vith water to less than 1% methanol anddischarged to water courses, or concentrated by distillation and then burnedor used for other purposes whi Le the aqueous residue from distillation. willbe sprayed on to land or onto snow surfaces. Several concerns associated....:ith 'pipe testing war e identified by the Assessment Group (Se c t Lon 8.16).

l3a. The quantity of water used during pipe testing may pres'ent problemswith its disposal. Since a 10 mile section 'of pipeline will, contain closeto 4 million gallons of water, the discharge of this quantity of water toa small stream under winter conditions of lo~v flow, when'the stream is,cornpletelyfrozen over, could pose a significant environmental. hazard.Possible adverse impact could be realized through a variety of actionsincluding initial melting of the stream ice at the-point of discharge"melting of snow cover over the ice, melting of sno\, cover over stream banksandteroufon of bank material, and finally .af t er f r eez Lng, an increasedthickness of stream ice ~ay be formed which may delay spring breakup.

, , '

In order to mi.t.iqatevthe problem associatedwith 'the di.eposal: of test uaiier, it isrecommended that the same iaaiier be re-usedfor subsequent tests in adjacent sections'of the pipe l.ine,

l3b. Contaminants ickedup from within the pipeline may be toxicto aquatic organisms at' varioustr hic leveiS>, and appropriate merhods fortreating test \vater to remove conta inants should be developed.

In view of the lack of information on the effect of impuritiesthat may be present in the test water, it is recommended that

before final disposal of test water, ananalysis be performed and if necessary,the ~ater be treated to render' it non-toxic.

13c. The proposed disposal of water/methanol mixtures by dilution isnot an acceptable method of disposal. Since the Applicant intends to,re-use the water/methanol test liquid for subsequent sections of the pipeline,it is probably that this'mixture,'containing the organic solvent methanol~

'vill become increasingly contaminated 'by p i peLfne i r esLdues through- continueduse. Again, the question of toxicity to aquatic organisms is raised both

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with respect to contaminants and with respect to the methanol itself, which'may be tqxic to some aquatic organisms under the .particular conditions atthe time of disposal. The oxygen demand ~...hich bio-oxidation of a 1% water!methanol solution will ex~rt on a receiving stream, appears to be overlooked.A.1% methanol solu t fon has a 5-day Biochemical Oxygen Demand (B0Ds) of 4.8gmOxygen/litre, and a BOD20 of 8.8 gm Oxygen/litre. The theoretical BODof Ii. methanol is 12 gm Oxygen/litre. Four million gallons of 25%'methanol~.;ill contain 3,500 long tons of methanol which will require over 5, 000 longtori~s of oxygen for complete oxidation. Clearly, it is impossible for areceiving water body to provide this much oxygen from the limited oxygensupply dissolved'within the water, and therefore this method of disposalis completely unacceptable. As a point of information, Federal guidelinesindicate a maximum BODs of 20 mgm/litre in wastewater discharged to theenvironment.

The pr?ferred test medium is a methap~Z/water

mixture. flhere a water/meihano 1, mi.xtiure isused as a ~est liquid~ the disposal of thetest Liquid by diZutionconstitutes an 'unacceptable practice.

l3d. Another concern exists in connection with the proposed disposalof water/methanol test liquid bY'disd.l1ation. No objections are raisedregarding the'~isposal of the distillate fraction by .burning; 'however, the

',proposed disposal of. the residue liQ1.1id by' spraying on to land or snowsurfaces does cause concern on three accounts: a) the composition of thissubstance is not know:nand therefore i~s disposal on land can not safely herecommended; b) if the residue liquid is sprayed on to snow surfaces towardsthe end of the winter construction period, the liquid will in all likelihoodbe absorbed by the top few inches of snow where it would freeze. Tha~ing.

in the spring takes place at the upper surface'of the snow layer firstand consequently much of this applied liquid would not reach the soil butwould be carried away in runoff over 'the frozen ground and may therefore enter·'water courses in an un t r ea ted condition; c) spray discharge of the residueliquid to vegetation surfaces will be difficult to accomplish withoutadditional terrain disturbance by the spray discharge equipment.

Thewater/methaP~l, test liquid should bedisposed of by distillation and burning of'the distillate and effective treatment ofthe residue liquid before discharge.

l3e. Another point of concern with respect to this subject relates ·tothe facilities required to store the almost 4 million gallons' of testliquid needed to test a 10 miie section of pipeline. The Applicant' hasgiven no indication of how this is to be stored, whether it wil'l be storedwi.thd.n a completed section of the pipeline or whether it w~)l be stored intank o~'bladder facilities. It is interesting to note tha1i 4 million

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imperial gal19ns is equivalent to 114,000 barrels which will require 76bladders of 1,500 barrel capac~ty' or 23 steel tanks of 5,000 barrel cap~city

for storage. Contamination of the test liquid by oil could occur if thetest liquid is' stored in tanks which have previously been used for oilstorage.

The Applicant should indicate the methodof storage of test liquidS.

14. Wastew"ater treatment (Concern {,!14 in "Digest").

The Applicant has indicated that "wastewater will generallyreceive'sedondary treatment prior to discharge to the environment" (Sect.8b.l.4.6), and that this will be achiaved by the use of either 'sewagelagoons or package treatment units. No information is provided regardingthe possible environnental effects which might result from the use'oflagoons.

14a. A lagoon of sufficient capacity to store the wastewater producedby an 800 man camp over a 6 month period would be 5.5 acres in extent whenfilled to a depth of 4 feet, and wouLd contain approximately 6 million 'gallons.,The construction of a lagoon this size would require considerable quantitiesof impervious material for the,berm. If it were sited in a permafrost area,,'a thaw bulb could be expected to develop under the 'lagoon 'and surroundingberm., Since, high-ice content permafrost'soils are quite common along the~lackenzie Valley, this may lead to severe settlement and possibly instabilityof the berm, and potential failure of the berm under operating conditions.

As a part of good engineering design, detailed geotechnicalinformation is necessary at proposed lagdon sites prior to construction, andthermal calculations should be performed in order to evaluate the possibilityof thaw-instability and to estimate potential settlement rates.

The Applicant should give more considerationto the potential problems which,~ay beencountered in building lagoons in permafrostareas 3 particuLarly with respect to thestability of the, lagoon berms.

l4b. The Applicant has given no indication of an intent to maintainthe proposed lagoons after the camp has moved away, since it may benecessary to periodically repair the lagoon berms to maintain .theirintegrity and prevent leakage. No plans for rehabilitation of the lagoonand surrounding area are provided by the Applicant and the ultimate fate~' _ ..of the proposed lagoons is therefore unknown.

Plans must be developed for rehabilitatingthe lagoons a~~ surrounding areas priorto abandonment:

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l4c. \·[here package treatment plants are used, the continuous dischargeof effluent durin~ the winter to nuskeg, ~ay prove problematic. For example,a BOO-man c~2p.would have a 4aily discharge of approxima~ely 34,000 gallons,\.hich, after 5 months, would cover an area of about 22 acres to a depth' ofI foot. Under winter conditions much of this discharge effluent may floodover the ice and ~ecome frozen, thereby considerably increasing the iceformation over the muskeg.

The discharge of sewage effluent at a discharge rate'of 34,000 'gallons per day, to a small stream would obviously severely effect the biotaof the stream. Discharge of \vaste\.;raterat this rate wouLd therefore requirea receiving water with a substantial flow if possible injury to the streamis to be avoided.

fihere discr~rge of treated wastewater to astream is plan~ed~ consideration'must be

" .qiven to the fZow of the stream in relation- to the amount of wasteuater to be discharged

into it.

15. Solid waste disposal (Concern filS in "Digest").

The problems aS$ociated with solid waste disposal in perma~rost ,areas have not been addressed by the Applicant. In the application, the

'Applicant states "In permafrost areas, solid waste will be'stockpiled foreventual salvage or bur'LaL at appr oved locations".

, Although the practice of dumping selid waste is prevalent at many- communities in the north, the Applicant should not be permitted to follow

the same procedures. Stockpiles of solid waste, if continued to any length.of time, will become attractive to wildlife, a haven for disease organismsand an aesthetic blight on the landscape. Solid waste should therefo~e notaccumulate in an unprocessed state. lJhere possible, the combustiblematerial should be incin~rated, and the residue buried. Stockpiling of .

. sucb inert waste as broken equipment, etc; is acceptable. An aOO-mancamp will produce in excess of 3 tons of solid waste per day. The collection, .processing and disposal of this quantity of material on a daily basis will •require the development of an effective waste di~posal program.

Incineration of solid uaste should bepracticed in permafrost areas ar~ theincombustible residue buried in approvedlocations.

16. - Emissions from compressor stations (Concern i123 in "Digest").

16a. Turbines fired with natu~a1 gas will be used' as prime movers forpipeline and refrigeration compressors. The only 'significant ~{haust

pollutant will be NO. Water vapour will also be emitted at such quantitiesx

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that ice fog ~o1ill form on occasion as identified by AES.220 ppm or less in the stack and the submission indicatesthat this emission will not be detrimental to air qualitydamage vegetation. However:

NO will be atinxvarious placesand ~"ill not

- method of dispersion calculation .is not given,meteorological conditions for calculations werenot specifiedonly one reference is given for effects of NO 'on

xvegetation and it is 19 years oldstack heights are not given.

Using the information given plus other sources we estimate thatcompressor station M-03 will exhaust 300 lbs/hour NO which will cause theNational Air Quality Objective of 400 ugm/m3 for N02

Xto be exceeded underlimited mixing conditions and for unlimited mixing conditions if a stackheight is less than 10 mat ers, ' ,

The concern here' is that methods of reducing the emission rateof NO from turbines are available and the proponent does not appear tohave ~onsidered them. Design changes such as:

steam or water addition in combustion chamberexhaust gas recyclegas nozzle designcoobustion chamber design to reduce residence time,

can ,be made which will significantly reduce NO emissions. It is our "philosophy that best practicable technology bexapplied in new inst~llationsfor minimizing emissions to the atmosphere and in this case we feel thatthe proponent has overlooked certain design changes available to him.

Methods of reduci~4 the emission rate ofoxides of nitrogen are available. TheApplicant rrrust be made auare of suchdesigns and should be required toinstitute changes to reduce emissions to

, safe Leuel.e under al.l: atmosphericcondi: trione,

1Gb. The Applicant intends to use natural gas to fuel the turbines 'and concludes that the gaseous emissions will have no detrimental effecton the terrestrial environment or on air quality (8.b.I.4.3.).

The Applicant recognizes that lichens are very sensitive to 502but states that on'the basis of calculations, ground level concentrationsshould not exceed .0002 ppm, which the Applicant considers well below toxiclevels. Similarly the Applicant's'calculations show that concentrations ofoxides of nitrogen will be below"levels toxic to plants.

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The pipeline corriqor is subject to high pollution poteritialin ~vinter due to the pr evaLence of' strong ground based inversions and light~.;inds. The s t andard approach using' Pasquill-Gifford (or equivalent) tocalculate dispersions and ground level concentrations is inappropriate underthese conditions. The Applicant has not shown what approach was used tocalculate ground level concentrations of either S02 or.the oxides of nitrogen.

The Applicant is requested~ with reference tostack emission a~fl stack design and taking intoaccount very low ventilation coefficients (i.e.under condi:tions of etironq surface basedtempera-ture inversions and light ioindeI , to ,demonstrate that:

'2-. the predicted ground level concentrationsof ~02,wil~ be below levels consideredtOX'2-C ~o l'2-chens;

ii. the predicted ground level concentrationsof other pollutants such as oxides ofnit~ogen will not harm the terrestria~

envuronment; J;Jf:A'17. Str eam crossfngs (Concern ;/~6' in "Digest")., ~

. One of the ~ost potentially seri~us to the pro~uct~vity,

of the aquatic resources, posed. by the cons t ction of pipeline stream': 'crossings, ~ increa'sed levels of suspend~d sed'iment." Impact severity 'wil~

be dependent on 'several factors including the time of year,' composition of' A',~.'".'

river bed and bank materials, stream discharge rates, composition and tv.!)sensitivity of fish and benthic invertebrate populations and 'the amount andproximity of critical habitats. A detailed discussion of sedimentation and

s e i~~lica.tions is pres~nted in the Assessment Group's report~Section ~~~~? " ,

In his discussion of stream crossings, the Applicant has definedminor crossings as those having little, or no significant flow during ~-linter

conditions, when construction would occur. However even relativ~ly smallflows may be highly significant for the survival through the winter of theaquatic resource. Stream gravels may contain the eggs of fall spawningspecies including the whdtef Lsh , ciscoes, Lnconnu and Arctic char. Over­wintering freshwater fish populations are restricted to open water areas,deep pools or lakes and are therefore more vulnerable to disruption.

The problem during winter construction will be to identify criticalhabitats such as egg incubation or fish overwintering areas prior toconstruction. Compounding the problem is the paucity of data concerningstream conditions under ice including the existence of sub-~ravel w~ter flows,and .d Lff Lcul.t Les in interpreting t he data that .does exist. For example,the Applicant had reported a certain stream as freezing to the bottom duringwinter; yet during a 1974 government survey open water, high oxygen levels andArctic grayling wer~ observed. '

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In view of the great variability of stream f Low conditions fromyear to year and difficulties in determining under ice conditions down­stream from the crossing sites, it is recommended that

the Applicant develop ~o crossing techniquesfor minor stream systems: one utilizingstandard trenching technioues for streamsfrozen to the bottom arfl where sub-graveZflows do not exist; ar4 the other for

~ running water incorporating sedimento ~ontroZs. The choice between one or the

,other crossing techniques ~ouZd,then bemade on site.

The preconstruction drilling program and on site, inspections bygovernment appoi ted inspectors should assist in determinin which'methodshould Since even sma 1 increases in suspended sediment in smallclear rivers cause an increase in zoobenthic drift, and probably no crossingcan be made without such a 'small increase, every attempt should be made tominimize this increase, 'but especially the length of time over which it 'occurs. Erosion control measureft should be 9,emonstraLed_to be effective inthiSregard.~:\.vkJ.~.~l.tL . ,/-;J , .~18. Removal ~r~rial from lake and river systems (Concern #24 '

in, "Df.gesc"},

The removal of borrow material or' gravel from'river to lake systemscan have serious environmental consequences including the destruction of ~~nJ

fish spawning grounds, the introduction of debris, tDcreased suspended Y'~~sediment levels and the disruption of spring and .ground water flows, diversionof stream flows or disruption of fish I:1igrations.A detailed and sitespecific discussion of environmental concerns arising from the Applicant'spropo sed borrow operations is presented in the Assessment Group's report(Section 8.13).

Borrow removal operations should be Zimitedto areas above the design flood high waterstage ~ad no cZoser than 500 ft (or 100 m)from any active river channeZ.

If the Applicant wishes to remove gravel from below design floodhigh water stage or 300fe~t of an active river channel, Fisheries and

,_.,.,}farine Service must be consulted. If and when Fisheries and Marine Serviceis satisfied that a stream does not support or has the potential to supportsignificant fish populations, then permission may be given for excavationand removal of riverbed mater ale S~ch permission will' be dependent uponremoval, operations being co ucted','in~ c~t,~Rl~~r~d subj ect tothe appjrovaL of a Fisheries Officer. Wf-4.\~1 "'. ?

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19. \~aste and toxic materials in water bodies (Concern (,125 in "Digest").

The potential for various wastes and toxic materials to enterwater bodies during ~he construction or operation of the pipeline issubstantial, and yet their possible, impacts have not been discussed in anydetail by the Applicant. A p~peline rupture under a water body could occur,however remote the possiblity. The fact that 95% of natural gas is methanewhi.ch is non-toxic to adult fish seens irrelevant if its effects on immaturefish and organisms in the food chain are not knOWTIE In ignorance of ' ,solubilities under natural conditions) relative tox'cities, redUCing,potentia~.,~,'(especially under winter iceh caution should be ex cised, and studies ~ J

undertaken to evaluate potential impacts. ,',. ,~\~-r- ~~JV'-- at: »:Gas condensates constitute a 'more tangible threat to~;c'

ecosystems as they are known to be toxic even in small amounts. It is assumedthat these compounds Hill· be stripped from the gas before it enters 'the 'pipeline, but the Applicant does not state this.

The soLubiLity of naturaL gas components inwater ana their effects on aquatic ecosystemsshould be investigated by the AppZicant. TheAppZicant shouZd stipuLate that aLL gascondensates and other toxic components wiZlbe stripped from the gas before it enters the,pipeLine.

20. Utilization of fish resources by pipeline personnel (Concern f!17in "Digest").

Northarn fish populations are characterisitcally s Low growing. Thisslow rate of growth, coupled ,-lith increased age at maturity, can result inlong recovery periods for populations if their numbers are severely reduced.

, ,

Although pressure is increasing on the fishery resource for bothsport and commercial purposes, the greatest utilization is still'throughthe domestic fishery. Even now, the domestic utilization, of Arctic charin the Big Fish River is threatening population stability. Increased fishingpressure in this river) be it for domestic or sport purposes, ,vould not onlyfurther reduce stock size, but could jeopardize an important food source fornative peoples.

The Applicant has stated that fishing by pipeline personnel willnot be permit ted as a matter of corporate policy .l:IO\'lever~) such s policyis only as good as its enforcement. Government can not deny the sale offishing licenses to anyone meeting,the,criteria of the Fisheries Act.Policy enforcement is the critical factor •

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The App,licant z.s requested to ineZude fisheries,resource topics i,n his personnel educationprogram~ and reinforce critieal points by postersdistributgd in field camp3. Hg should bringTerritorial Fisheries ReguZations to the attentionof his employegs~ and note that ~oeal fish stocksare not used for feeding construction personneZ.~

and that the sale or trade of fish is illegalunless caught under a commercial license.

21. Culvert stream crossings (Concern If20 in "Digest").

In response to the deficiency statement issued by the PipelineAppl~cation Assessment Group, the Applicant has stated that "Only fivestreams are planned to be crossed by permanent roads constructed by theApplicant". All of these systems occur in the Northwest Territories andthree of the five are indicated as having, or probably' having, significantfish activity. The streams are to be re-examined, and where fish passageis a requirement, culverts will be designed, presumabl~under the criteriaused by the Department of Public Works. - I

vfuen Applicant prepared his material, he was presumably not a~are

of highway construction'guidelines being drafted by the Fisheries and 11arineService for highway construction in the Northwest Territories. These' guide­lines .reccrcmend in part that' "a 7-d?y impassable period (for cuLver t s). shouLdnot be ex~eeded more than once in the design period of 50 years. A 3-dayfmpas sab Le period should not be exceeded during the average annual flood, . 'defined as a flood having a recurrence interval of 2.33 years", and that" ... the average cross-sectional velocity through any' culvert section shallnot exceed 0.9 mls (3 fps) during fish migration periods, unless it can besatisfactorily demonstrated that the· culvert design includes a selectedregion wherein velocities are low enough to permit fish passage."

The Applicant ehould be aware of these publishedguidelines when preparing culvert fi'YI.al designspecifications for approval by Fisheries andMarine Service.

22. Pipeline construction, routing and timing in relation to fish resources(Concern 1121 in "Digest").

, Based on materials submitted to date by 'the Applicant, severalexamples.can be cited where pipeline routing or the locations of ancillaryfacilities, .such as compressor' stations or borrow pits, appear to impingeon kno,m or suspected sensitive areas, either for the fishery resource orits utilization. However, Applicant has frequently stated that 'specificlocations can not and will not be identified until such time as generalapprov~l has been received from government, further topographical, geomor~

phological, hydrological, biological and subsurface information has been

be selectedmuekrat ,

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co Ll'ec t ed , and corrsuLtac Lons ~.,rith pertinent groups have been held. Despitethe lack of site specific information, environmental disruption should berelatively minor, assuming that suitable protective measur~s are implemented.

The impact of the exact location of streamcrossings or pipeline facilities on fishresov~ces must be determined afte~ the sub­mission of the final design for bhe entirepipeline and prior to construction.

23. Effects of wat er use and disposal (Concern fJ19 in "Digest").

The Applicant will draw considerable volume of wat er from nearbylakes and' streams, for pipeline testing, 'construction of snow roa-ds andcamp use. This could'cause significant changes in water bodies and systems.In his response to a deficiency statement of the Pipeline Assessment Group, ,he has stated that this water will be drawn from shallow fishless. lakes untilthese are frozen to the bottom, after which deep lakes or large river ~ystems ~

~ill be utilized. The Applicant also attempted to designate some ~f these 'An L.:.]systems in his response. W1\~-~~~~r~,~/~~

The greatest effect of such practice would be on the muskrat andbeaver population. Lowering water levels could cause ponds to freeze to .the bottom and thus ~linter kill the .muskrat and' beaver population. Fur t hermor'e ,"a small lake may be fishless at some time of the year, but it may be utilizedby the fish'resource at other times. Interference with natural drainagepatterns could significantly alter flow patterns in watersheds which couldinfluence waterfowl reproduction.

The source and release locations mustvery carefully to minimize effects onbeaver~ fish and waterfd~l resources.following information is required:

i. A thorough bioLogical ar~ hydrological . ~l~~

investigation of each system identified W·~,.v-·dfJ~as a source~ especially under winterr -~~~coni!.itions • . - On Ju., ~-, •

ii. A prediction of the biological and .r "hydrological impl.ioatrione of water· JAnextraction from each system~ especially ~ L~.~~

deep lakes, in all seasons. . ~(~~-:~---~.

24. Effects of disturbance of wildlife - ~~~.~ .

Disturbance of wildlife by man's activity places addit[onal str/ss .on populations, \o1hich,if occurring during critical time'periods can disruptreproduction,alter use of traditional areas, (some which are criticalbecause of limited amount of alternative areas) and contribute to poor'physical condition of individuals in advance of migration or ovenlinteringstresses. This can be the result of (a) aircraft movements. (b) construction

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activity and maintenace during construction, (c) operation activity andemergency maf.nt.enance activity, and (d) alteration of the structure of thelandscape.

24a. Effects of aircraft movements (Concern li9 in "Digest").

The reaction of ~Yildlife to aircraft overflights various from .species to species, in degree, with the season, and with the type of aircraft •.Potentially the effect is greatest during the reproductive phase of the specieslife cycle.

Caribou's variable reaction to aircraft overflights has led to arange of recommended flight al t Ltudes., mostly conservative.

Establishment of aircraft corridors offshorewith careful control of approach and departuredirections and altitude would help minimizeeffects 'of disturbance along the north slope.Monitoring herd movements would allow pre­cautions to be applied which would minimize ..contact uith the Porcupine caribou herd duringsensitive periods.

Application of these .principles·would also reduce disturbance ofmoo~e, a species not as significantly affected as caribou by aircraft.

. ,.

Dall's sheep have consistently demonstrated adverse s tampede'.reactions to aircraft, especially helicopters. Overflights may have to ~e

prohibited or done at high altitudes to avoid dis~urbance especially duringthe sensitive late winter and lambing periods. However, there have been nostudies to determine the.safe altitude 'limits for aircraft flights. Part ofthe proposed route is within one mile of the sheep. wintering range and theApplicant has indicated sheep displacement by helicopter activity greater thanone mile away, Until the ability of sheep to adjust to aircraft disturbancehas been demonstrated conservative measures should be implemented.

Such measures should include flock mon{toring~and careful adherence to a construction. scheduleand specific air corridors which lJould minimizeaircraft contact during the sensitive period.

Waterfowl, along the Mackenzie River, are especially vulnerable todisturbance during spring migration and during the nesting period. Dis­turbance of fall staging Snow geese can also have important effects onenergy reserves for migration. Since most construction' activities will takeplace in ~.]inter, the overall effects on wat er f cwL should be minimal.

..

~". ~~t.~

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24

The definition of flight paths an~ schedules,to avoid concent~ation areas will reduce theeffects of disturbance. Spring and eummeractivities will have to be carefully controlledto minimize disturbance. These measures willrequire continuous monitoring of the birdpopulation to locate important concentrationareas.

Raptors are extremely susceptible to distrubance during the earlypart of the nesting period. Their reaction to aircraft varies unpredictablyduring ,this time, thus conservative measures must be taken.,

-Known' rap tor nesting sites ~Ast be avoided during'the nesting period. There is no knoum safedistance, but the suggested 2.5 miles and 1,000-

, foot minimum altitude seem adequate to avoiddisruption of nesting. '

24b. '. Effects of construction and maintenance during construction 'phases,(Concern /17 and 8 in "Digest").

Interruption or de f Lec tLon of 'caribou migration because of con­struction activities must be avoided for Scc fo-eeconomf,c reasons and addd t Lonak

. animal stress load problems.

Herd monitoring, and implementation of contingencypl~~s if unpredicted movements occv~, and winterconstruction will minimize the extent ofdisturbance. ' '

Dall's sheep wintering and lambing range is within one mile'of theproposed route. Construction activity along that portion of the route duringlate winter and spring will likely have significant influence on Dall's sheepsince they react violently to helicopters. The Applicant's im?lication that ,activities are expected to keep wildlife away from the right-of-way recognizes,that disturbances will be significant, especially for sheep which have alimited amount of wintering and lambing areas. The additional stress on anoverhunted population means that population declines can be expected.

Through careful timing of construction activitiesnear t~~ zone of sensitive sheep range mostadverse reactions could be avoided. This wouldrequire monitoring 9f flock movement or,,'alternativeLy, relocation of the route farthera"

,away from such critical areas.

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25

Han~ t r Lbutary valleys of the Hackenz Le River, especially alongthe east side, are moose ~.;rinte:r range and migration routes to winter rangeon large river islands. Significant disturbance of moose in these areas hasbeen recognized by the Applicant. Construction activities may not affectpopulation numbers; ho~vever, population numbers are not well documented.

Construction shouZd be scheduLed throughthe i",?ortant valleys at times when theseare not being extensively used by moose.

There is considerable variation in which sites are used as fallstaging areas by Snow geese. Through the identification of critical waterfowlareas, maintenance of natural drainage patterns, and scheduling of ac.tivities·to avoid periods of sensitivity there should be minimal disturbance to water­fowl. The Kendall Island Bird Sanctuary is a very critical area for Snowgeese and the effects on· nesting and nesting habitat have not been addressedextensively.

The avoidance of disturbance of ~aterfowl wi~l

require careful monitoring of populations and a .review of effects of construction on drainagepatterns.

Arctic raptors vary in 'their nesting activity.from yearand therefore annual monitoring of nesting habitat is necessary.by noise, humans, vehicles and blasting during the nesting periodvery significant effects on raptors, especially peregrine falconsof one nest production can reduce the known population by as muchcritical period is Hay to August. Blasting could have additionalthrough destruction of eyries, by shockwaves accelerating natural

Relocation of routes and quarries to distanceswhere shockwaves from blasting ~ouZd.be weakat eyrie sites, and where noise levels wouZdbe Zow, would minimize potential conflicts.

to year'Disturbanc~

can havewhere lossas 1%. Theef f ect.s "forces.

'i. ",,,,,i'V

Other species such as wolves, faxes, bears, marten, other furbearers, shorebirds and passerines would not be greatly af'f ect.ed ,

On site inspections for den sites and concen~

tration areas with subsequent scheduling ofact~vities to minimize contact should berequired.

The Applicant's intentions on solid waste disposal are not.clear •.If the intended disposal method is simply stockpiling, this cou14 ~e ,attractiv~ to wildlife, particularly bears. Careful adherence to garbag~

control and disposal is essential 'to minimize conflicts with bears.

. ~ .

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26

o

Garbage and solid waste must not be allowedto accumuZate. Summer camps should not belocated near streams frequented by bears.Because of the bear 1s unprediotiab Le tempera­ment, a~oidance of bear areas (i.e. den sites,feeding areas) and actions to avoid attractionof them to work or camp areas will helpminimize problems.

24c. Effects of operations and maintenance during operation

Location of compressor stations and conduction of surveillanceflights should be carefully controlled to minimize disturbance of populations'

. at critical times of the year. For.example, activities over caribou calvingareas or compressors near lambing areas.

The greatest threat is the activities associated with emergencyrepair. The possibility of disturbance for some species is very h~gh andeffects can be most critical to popula~ion stability. These are site specificproblems.

Pipeline location should be selected tom~nun~zepotentialcontact.with specieswhile they occupy critical areas 'or dur~ng

ct-i: trica l: periods.' Contingency p laneshOWing approach routes to sensitive areasshould be firmly established and adhered to~

24d. Effects of changes to the structure of landscape

There is some concern that because marten will avoid open areas.they may not· cross the 120-foot wide right-of-way, and thus their movementwill be restricted. The right-of-way structure could cause "deflections. ofmigrating caribou, altering'seasonal paths and produce social problems. Theeffect of right-of-way an~ berm on carib~u is not known.

Right-of-way revegetation, completely or partiallyso that only narrow open areas remain, should makethis a short term concern. A review of cariboubehavior' is neceeearq to define the potential ofdeleterious effects and the means of offsettingthem.

25. Effects of erosion and sedimentation " .

Excessive short-term and gradual lo~g-term erosion into waterbodies can reduce aquatic vegetation growth and cause a shallowing of lakes;The. extent of these effects can be 'critical to survival of muskrat and beaverpOpulation~. The Applicant has indicated that the stabilization of the surfaceterrain will be accomplished by revegetation. However, on steep slopes andpond margins, surface stablization would be difficult ,.ithout some degree oferosion.

..'

'..~...'.,..i1

',-

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o

A plan should be developed to insure slopestability in the event of abnormally highrunoff from snoumel.t: or rains during »e­vegetation, particularZy in critical areaswhere there are steep sZopes and/or readilyerodible soil.

26. Effects of the Dempster Highway (Concern t.!6 in "Digest").

The traffic on and hunting from the Dempster Highway, when it iscomplete, could have a profound effect on the Porcupine Caribou herd. Therecould be a drastic reduction in herd size through hunting and road kilis.Also the time and path of migration,could be altered. The Applicant hasnot indicated ,how much use is, to be made of the Dempster. Use of the highwayas a pipeline supply route would' increase the interaction between caribou andthe potentially damaging forces of the highway.

Control of traffic during specific: periods andestablishment of no hunting iones along ,thehighway may help minimize the problem.

27. Lack of concern for recreation sites (Concern 1/22 in "Digest").

It is clear from,the information and impact assessments offered by'the Applicant that' a major deficiency exists with respect' to the 'inventor.y .,'and assessment of outdoor recreational sites and/or opportunities ,along andadj acent; to the pipeline corridor. The Applicant has limited his comment's'

.on r ecreat.Lon to (a) ,brief summaries of known National Or Provincial Parks"along or adj acent to the corridor, and (b) passing comments on certainrecreational activities. Nowhere in the documents is there a clear'indication that the Applicant carried out a detailed inventory and assessmentof recreational sites and/or opportunities, or, that the "route selected hasin any way been modified as a result of known recreational ,opportunities.Likewise, there is no indication that potential campsites, compressor sites,wharf sites, etc. were evaluated for their recreational value.

Further, on different occasions the Applicant has suggested thatthe impact from the pipeline will be largely of a temporary natu~e, primarilyduring the construction stage. Noise; exhaust, dust, smoke, etc., ,,,ereacknowledged as short term problems that. would affect people. More specifically,where existing or potential parks or outdoor recreation sites are or mightbe involved, the presence of an operating pipeline complete with clearedright-of-way, service road 'and possibly pumping stations would be foundobjectionable by many recreationists, particularly if the park or outdoor ,:recreation (a) was 'set in a wilderness-type backdrop ,and/or (b) was set,aside as a result of certain unique, unusual or outstanding natural r~source

features or combination of features. t~ithout detailed inventories andassessments in this regard, it seems unwise for 'the Applicant to'dismisspotent:!.al long term problems as "i~significant".

" ':J:.....

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28

The Applicant should show an awareness andapprecip.tion oj' the, outdoor recreation valuesoj' the area and plan the location of thefacilities accordingly~ otherwise the environ­mental assessment studies of the Applicant TmA.stbe considered incomplete.

28. Major alignment changes

In the "Response" to ques.t Lons posed by the Assessment' Group, the'Applicant stated that he is considering changing the alignm~nt in order tocross the Hackenzie River upstream from Fort Simpson (Response 15). ?:hereare allegations that the route '''ill be re-aligned in the north to cross the}~ckenzie Delta north of Aklavik. These route changes, while alleviatingsome problems, may encounter new ones and should be carefully examined.

, ,

The changeccontemplated by the ~pplicantin the Fort Simpson areawould be initiated at about River Between Two Houn t a Lns and "follow a direct

, ,

line to a Hackenzie River crossing about'six miles upstream of Fort Simpson".If taken as a' straight line (as shown in large scale maps by the Applicant),.this alignment would go up and over the Ebu t t. 'Hills, a local highlands some2000 feet above the Hackenzie Valley. The slopes having northerly andeasterly aspect s : (including the northwest and southeast slopes where thepipeline wouLd ascend the Hills) are quite icy near the surface. This ,incombination with moderately steep slopes, ,.ould make this area the potentialiymost sensitive terrain,of the pipeline route south of Wrigley. The terrainon top of the Ebutt Hills is also high in ice, with large tracts of perenniallyfrozen peatlands, and is the site of a proposed International BiologicalProgramme areav

A rough estimate shows that the realignment. around the south of theEbutt Hi~ls would add only about 2 miles to the length of the pipeline, but'it would cross a far more stable terra~n.. This points out the desirabilityof consultation between engineering and environmental staff at an early stage,·before decisions are made on the realignment.

It is highly desirable that terrain andenviron~ental expertise be utilizeq inmaking major realigr~ents. Thechangedroute mUst be assessed by government expertsin a manner similar to the assessment of theprimary 'proposal. '

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APPENDIX

Appendix 1. Membership of Task Force and area of responsibility

Name Agency and expertise Contribution, Specif~c Topics

S.c. Zoltai, Chairman

R.P. Baldwin

R. Edwards

A. Goodman

Canadian Forestry Service Nos. 1, 2a, 3, 4, 5, 6, . .7 ~(Terrain, vegetation) 8, 28.

Inland '-1aters Ddrec-tora t e Nos. 2b, 2c, 9, 10, 11-(Hydrology)

Environmental Protection Nos. 12, 13, l4~ 15, l6a.Service(Environmental engineering)

.CanadLan Wildlife Service Nos. 23, 24, 25, 26~

Oolild1ife)

)

B. Janz

L.C. Huon

J.N. Stein

Atmospheric EnvironmentService(Climate)

Lands Directorate(Land use'planning)

Fisheries and MarineService(Fish, aquatic ecosystems)

No. 16b.·

No. 27.

Nos. 17, 18, 19, 20, 21,'22, 23.

)

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30

Appendix II. Dd.ges.t of Environmental Concerns

(In meeting between Dr. J.S. Tener, ADM, Environment Canada, andHr. 1. Scot t , Chief Counsel, Hackeriz Le Pipeline Inquiry, it was decided tomake a draft copy of a summary of'environmental concerns available to theInquiry. This summary, although now, obsolete, is reproduced below.)

1. Interference with drainage by' generated permafrost~

Buried, chilled pipeline will freeze the material surrounding itin previously unfrozen terrain. This can interfere with the below and abovesurface drainage in different ways:

a. Most unfrozen wet organ~c deposits in'the DiscontinuousPe~mafrost Zone are fens, which act as seepage channels,

.Freezing a strip in this material will form a dam 'of ' '.frozen peat and ice, extending, into the underlyaing

. mineral soil 'and above the orginal fen surface becauseof expansion of wat er changing t.o ice. This will causeponding upstream, icing conditions across the'dam' ~n'

winter, and desiccation downstream.

J ',:.' if......:..

, '0

b. Burial of chilled pipe under streams of low but f~nit~

f Low , or with winter f-Low occurring as seepage, willinterfere with the stream. Tn winter icings will begenerated' and water vital for oyen-lintering of fishwill be cut off •

c. Burial of chilled pipeline along the contour (across ·theslope) in high groundwater activity area will interfere'with the natural drainage. Drainage over permafrost maybe. concentrated into subterranean indentations intothe permafrost 'table whLch may not be reflected on thesurface.' In other areas such subsurface channels are,not developed, but seepage takes place on a broad front.Blocking this drainage with a frozen ridge will cause .ponding and possible thermokarst development uphill,and desiccation downhill. Locally icing conditions willdevelop.

RECOMMEtIDATIONS: Pipe line should be placed on elevated supports wheneverencountering any of these conditions: 1. unfrozen seepage ~hannel

fens; 2. stre~ms with low volume or subterrane~n wint~r flow; ,3. when crossing area of high groundwater activitY

L. .

, , ,. . .' .' fP11{5,-: I

~SJ-M~···

~,

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0,

2. Excessive 'tddth 0 f right-cf-\~ay.

In the subarctic forest the removal of trees and high shrubs issufficient to thicken the active layer and increase the possib'ility of severethermal erosion. Many insulating mosses (feathermoss type) cannot survivethe removal of shade and will be replaced by herba and grasses having farless insulating value.', It is important therefore that the tree cover beleft intact over as much area as possible, especially on sensitive permafrostareas.

The Applicant proposed to clear a '120-foot wide right-of-,,,ay, butnowhere is the necessity for this Hid,th justified. Due to restrictive',legislation, sections of the Al~ska Pipeline are constructed on 55-footright-of-way. Although this width imposes special construction methods(e.g. storing of excavated material in designated areas), construction ispossible with much less than 120-foot right-of-way.

The width of right-of-way for access roads has not been determinedby the Applicant. Again much less than 120 feet should be sufficient. The,Applicant states that the width of the right-of-way ,,,ill have "variationsdepe~dent on local requirements", but failed to identify the loc~l requirementswhich may demand greater than 120 feet of right-of~way.

RECO~lliENDATIONS: The pipeline right-of-way should be'reduced by 25% to90 feet on sensitive 'permafrost areas. T~~ right-of-way for, 'access, road's should be restricted to the v'id'th of the road. TheApplicant should be requested to justify the need for wider than'standard right-of-'t"ay'and obtain permission in each case before,proceeding.

3. Ineffectiveness of artificial revegetation ~s insulation.

The Expanded Guidelines require the Applicant to develop "plansto carry out assisted revegetation or alternative methods of providing ainsulating cover on which natural revegetation can occur." '

The Applicant proposes to seed grasses on the disturbed right-of­way, stating the grasses are efficient insulators of the ground and wi11'prevent hydraulic erosion. However, data obtained at the Sans Sault Rapidstest facility. (Progress Report on CAGSL Revegetation Studies North of 60°,by W. Younkin and W. Friesen, Northern Engineering Services Co. Ltd.,Sept. 1971) show that after two growing seasons the active layer is 15-35%thicker under the well drained treated areas than under undisturbed areas,and 60-85% thicker under poorly drained treated areas. In addition, pools

,of water existed in subsidence hollows in the poorly drained treated areas.Apparently, grasses do not form effective insulating layers as claimed bythe Applicant.

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<::IGCONMENDATIONS: Effective, long term insulation must be achieved. This

,-,ill require experimentation. One such method may be the spreadingof artificial insulator (s t r aw, peat, e.tc , ) on the dLstjrrbed surfaceand covering it H,ith soil. Either natural or ar.tificial vegetationcan be established on such surface. Insulation directly above thefrozen pipe is not a concern.

4. Increased incidence of forest fires.

The Applicant prepared contingency plans and fire fighting equipmentunder the assumption that there will be no increase in the incidence of fires,as most construction will iake place in the winter.

The construction scheduling proposed by the Applicant shows that.considerable activity (surveying, stockpiling, construction of supportfacilities, etc.) will occur in the summer. This means an influx of people,hence an increase in the possibility of accidential fires. Fires will causedirect damage to the terrain by destroying the insulating organic mat, butadditional damage may occur when transporting supplies and equipment over .thawed ground. Further damage may occur due to ill advised control measures,caused by unpreparedness for the emergency.

F~CCMMENDATIONS: The Applicant must be prepared to cope with an increasedprobability of accidental forest fires.

The ranges and sensitive time periods ar~ known for each species.Restrictions of fly routes and altitudes will alleviate most .of the aboveconcerns.

Animals shov different degrees of sensitivity toward excessivenoise by aircraft. Da1l's sheep is very susceptible to distu~bance in latewinter and lambing periods. Haterfowl is susceptible during the springmigration, fall staging and during the 'nesting period. Birds of prey areextremely sensitive during the early part of their nesting period.

j" .

t~",

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5~ Harassment of animals and birds by aircraft.

RECOMMENDATIONS: Flyways must be established to minimize disturbance towildlife, these flyways should be approved by the CanadianWildlife Service. Additional restrictions may 'be placed oncertain areas at specific times of the year as advised by theCanadian Wildlife Service.

o 33

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6. Interference l"rith caribou migration by traffic on the Dempster Highway'-'

'~en the Dempster Highway is complete, the traffic on it andhunting from it, could have a profound effect on the Porcupine Caribou Herd.The size of the herd could be reduced drastically and the, time and path ofmigration could be altered. Although the Applicant has not indicated muchuse being made of the highway, he may be forced to use it as an alternatesupply line.

RECOMMENDATIONS: The use of controls over traffic on the highway duringspecific periods ,and the establishment of a no-hunting zone alongthe highway may alleviate the problem.

7. Disturbance of Dall's sheep by winter construction.

Data show that sheep wintering and lambing range is within one mileof the proposed pipeline route in the Mount Goodenough area. There areindications that the sheep may periodically use the route area itself. Yetthe Applicant stated that blasting disturbances will have no, impact on thesheep, and followed by a statement that general construction activities willkeep wildlife away from the r Lgbt-eof-way.jmyway , t her efor e blasting will'cause no disturbance.

Disturbance of the sheep 'population is indeed possible, and could'have considerable impact if it takes place in. the sensitive late winter toearly summer period. These 'sheep are already being hunted at or' over theirreproductive potential and more stresses could easily cause an increaseddecline.

FECOMMENDATIONS: Proper timing and extreme care during construction of thepipeline section within one-to two-miles of the sensitive sheeprange may reduce or avoid adverse reactions. An adequate monitoringprogram is essential.

8. Grizzly bear - campsite interactions.

The Applicant indicated that he will have adequate garbage disposal,'and will, if necessary. fence facilities with bear-proof fencing. Hu~ting

will be prohibited.

The intentions of the Applicant on solid waste disposal arecontradictory. as he declares his intention of "stockpiling" it (see Concern1115). Additional precautions must be taken: all garbage and waste must beburned, preferable daily; bear-proof or electric fencing should surround allcamp areas and permanent facilities. particularly if abandoned; camps shouldbe located away from stream valleys frequented by bears.

RECOMMEitDATIONS: Bears must be kept away from camps to protect personneland the bears.

0°,

::' ,0. '

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9. Routing of pipeline to avoid groundvater discharge a r aas and difficult·strea~ crossings.

The Applicant s2lected the pipeline route to minimize the constructioncost and has chosen to apply engineering solutions to environmental problemsencountered, rather than avoid the problems by re-routing the line. °

This method of route selection may overlook the potential benefitsof small shifts in alignment that \,ould avoid the creation of environmentalproblems. Such minorrealignrnents could result in avoiding problems in thevicinity of stream crossings, or areas of ground \later discharge.

RECONMENDATIONS: The Applicant should be prepared to re-route the pipelineto avoid environment~l problems. Such problem areas should beidentified at the final design stage of planning.

10. Estimates of stream discharge and flood stage levels.

Records of stream flow characteristics and extreme flood levelsare minimal for the }~ckenzie system, particularly for the tributary streams~

Such data are required for the design of certain pipeline design features,as location of sag bends, extent of slope armouring, etc. There is indicationthat the Applicant may have underestimated these discharges and stages.

RECOMMENDATIONS: Estimates of stream discharges and stages sould be re-assessedand conservative estimates be used for the determination of con­struction design.

11. Stream bed changes induced by construction acti~ities.

The Applicant has ?ased his consideration of scour depths, channel­ization, and lateral migration at stream crossings on existing and historicalconditions.

Construction and operation °of a chilled, buried pipeline has apotential to change the streambed conditions. Ground disturbance associatedwith construction, or unexpected bank slumping can change the channel of thestream. Berm placed in the -channel for cons t ruct Lon purposes may change °scour depth, and may cause' a' shLf t in the; channel. Icing induced by the °pipeline may deflect the spring flow and cause a shift in the channel. Thusnatural stream processes after the construction of the pipeline ~y notrelate to pre-construction conditions.

RECOMMENDATIONS: Applicant should re-assess the design for stream crossing"taking into account the effects of possible changes caused by theconstruction and operation of the pipeline. The Applicant shouldconsider the construction of elevated pipeline crossings.

o 35

.12. Fuel and oil spills.

The Applicant has recognized the dangers inherent to large concen­trations of fu~l and oil stored for construction operations. Information'on quantities stored, modes of storage, method of handling and transfer offuel should be provided to a controlling agent. Containment and clean-upequipment and materials should be provided.

RECO}~ffiNDATIONS: The Applicant must provide information on the containmentand clean-up equipment irnnediately available at 'all fuel stock­piling areas and,at major,fuel transfer points.

13. Disposal of pipe testing liquids.

The Applicant will use liquids to test lO-mile segments of completedpipeline. In non-permafrost areas warm water 'viII be'used, chilled to 38°Fbefore discharge. In permafrost areas the testing liquid Hill be warm water,or a Hater/methanol mixture. After testing the wat e r Zmet.hanoI mixture willbe diluted and discharged to water courses, or concentrated and burned, whilethe aqueous residue from distillation will be sprayed onto land or snowsurfaces.

A lO-mile section of pipe will contain close to 4 million gallons'of water. The discharge of this quantity of water into a small stream under,..inter conditions could pose a significant environmental hazard. The initialmelting of snow' and later freezing of the water will lead to increased 'thickness of ice, which may delay spring breakup. In addition, toxic con­taminants picked up within the pipeline may be harmful to aquatic organisms.

The disposal of water/methanol mixtures, as proposed, are not ,acceptable. The oxygen demand for the bio-degradation of 1% methanol solutionis great, estimated at over 5,000 long tons of oxygen; this amount if requiredto degrade the methanol from one 10-mile section of pipeline.

The disposal of water/methanol test liquid residue after distil­lation. Although the methanol would be disposed by this process, thedistillate remfnant has to be disposed. The composition of this liquidis not known; ~t may well contain substances toxic to vegetation. If theresidue is sprayed on snow, it will remain concentrated near the top ofthe snow and will run off in the spring, rather than seeping into the ground.This will concentrate the residue in ,..ater courses where it will have unknown,

,but not beneficial effects on aquatic organisms.

RECOMMENDATIONS: 1. Hhere testing of the pipeline is done with water, thesame water, be re-used for subsequent tests in adjacent sections ofthe pipeline; 2. Before final disposal of test water , an analysisof water be performed and if necessary, treatment be given to thewater to render it non-rt'oxf.c ; 3. \oJhere a water/methanol mixture.is used as a test medium, it should be disposed of by distillationand burning of the distillate, and effective treatment of the residueliquid before discharge; 4. ~~ere possible, the preferred test.medium be a water/methanol mi~ture.

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llf. t-lastewater treatment.

The AppLi.can t indicated t ha t "was t ewa t.e r lolill generally receivesecondary" t r eat.men t prior to discharge to t h e environment" and that thiswill be achieved ""by the use of lagoons or package treatment units.

A lagoon of sufficient capacity to store the wastewater produced byan BOO-man camp over a 6-month period would be 5.5 acres in size. The lagoo~

would require a large amount of impervious material for the berm. If sitedin a permafrost area, thermokarst rlevelopment is "to be expected under thelagoon and the berm, leading to possible failure of the berm.

The Applicant did not indicate any plans or" intent to maintain thelagoon after the camp has moved away. The berm would have to be inspectedand repaired to prevent the release of nutrient-rich water into the streamseven after the campsite is abandoned.

t·fuere package treatment plants are used, the. continuous dischargeof effluent during the winter to the environment may prove probleoatic. AnBOO-man camp would generate enough effluent over 6 months to cover an areaof about 22 acres to a depth of one foot. Under winter conditions. theeffluent will accumulate over the surface as ice. If discharged into astream, the biota of the stream will be affected.

RECOMMENDATIONS: 1. The stability of lagoon bern in permafrost must beconsidered; 2. Plans must be developed for rehabilitating thelagoons and surrounding areas prior to abandonmen t; 3.· ttneredischarge 9£ treated was t ewater to a stream is planned. consideration~ust be given to the flow of the stream in relation to the amount..9f discharged wastewater.

15. Disposal of solid waste.

The problem associated with solid waste disposal in permafrost areashave not been addressed by the applicant. He states "In permafrost areas.solid wastes will be stockpiled for eventual salvage or burial at approvedlocations".

Stockpiled solid waste is attractive to,olildlife, it is a haven "fordisease organisms and an aesthetic blight on the landscape. Grizzly bearsand polar bears may be attracted by the garbage and become a danger tohumans.

Where possible. the combustible material should be burned, preferablydaily. and the residue buried. Stockpiling of such inert waste as broken equip­ment. etc. is acceptable.

RECOMMENDATIONS: Incineration of solid waste be practices in permafrost areasand the incombustible residue buried at approved locations.

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16: Crossing of 'minor' streams.

Minor strean crossings ",ere defined by the Applicant as those havinglittle or no significant flo," during winter conditions. In the biologicalsense, however, even relatively small flows may be highly significant for theoverwintering and survival of the fish resou~~~eamgravel may con~ain

the- eggs of fall spa,vning species. ~/U~~-r~~~

The, problem during winter construction is to identify critical areas.Compounding the problem is the' pauciy of data concerning stream conditionsunder ice, including sub-gravel water flows. Yearly variations in waterconditions further complicate the identification of critical areas.

The above conditions combine to make the selection of stream crossingtechniques dependant on site conditions. A preconstruction drilling programand' on site inspection by government appointed inspectors should assist whichmethod should be used. The choice would be between standard trenchingtechniques utilized in streams that are frozen to the bottom and no:sub-gravelflow exists. The other technique to be utilized where there is renning water,necessitating sedtment control. Standard levels of sediment introductionshould be established based on bioassay research; the sediment tolerance lev~ls

Jlor aquatic orga ·sms· and the synergistic effect of oxygen depletion with~ncreased ,Se.d.i.ment le:ve'.fL. ~ wNvr9 --~ ~' - ~ f.RECOHMENDATIONS: The Applicant is requested to devel06 IHo cre ssing techniques

for minor screams: 1. Utilizing standard techniques for streamsfrozen to the bottom and where sub-gravel flows do not exist;2. Utilizing a technique with sediment controls for streams whererunning water, whether above or below the gravel, exists. Thechoice of crossing techniques oust be made on site.

17. Utilization of fish resources by,pipeline personnel.

The Applicant stated that fishing by pipeline personnel will not bepermitted, as a matter of corporate policy. The government, however, cannotdeny the sale of fishing licenses to anyone meeting the criteria of theFisheries Act. It is therefore necessary that the Applicant address himselfto resource protection in personnel education programs prior to entering thefield. - He should make it known that local fish stocks are not to be usedfor feeding construction personnel, and that the sale or trade of fish 1s

, illegal unless caught under special license.

RECOMMENDATIONS: The Applicant is requested to include fisheries resourcetopics in his person~el education program.

.,

v.'·'.. '-. ~';'

38

e

18. Utili~ation of fish as a result of increased accessibility •.

Hith the construction of the pipeline) considerable numbers ofpeople will be~oving no~th. At the completion 'of the project) some mayelect to remain in the north. As a result there will be new demands for wateror for stream gravels as sources of construction materials. Increased volumesof sewage and wastes will have to be disposed of. Increased handling and useof oils) fuels and other chemicals and toxicants 'Yill result in greaterincidence of spills and pollution. There will be a greater demand for thefish resource itself) both as sport and as a commercial p!oduct.

Although the pLpeLf.ne may have provided the impetus for initiatingthe increased use and the deteriorating aquatic environment) the responsibilityfor preparing a comprehensive assessment of these long term impacts may be ajoint Applicant/Government effort.

RECO~~~~ATIONS: The Applicant) in co-opeation with Government agencies shouldactively develop a program of aquatic resource conservation.

19. Use of water •

. The Applicant will use considerable volumes of water for pipelinetesting) construction of snow reads and camp use. Although· he has statedthat the water ,;ill be drawn from fishless lakes until frozen to the bottom,much additional information is required before such procedure can be permitted.

This information is: .

1. Identification of specific water resources if previouslynot indicated.

2. A thorough biological and hydrological investigati~n ofeach system, especially under winter conditions.

3. Documented proof that the lakes indicated as fishless bythe Applicant are indeed not utilized by the fish resourceat any time of the year. .

4. A prediction of the biologic~l and hydrological implica­tions of water extraction from each system) .especiallydeep lakes.

RECOMMENDATIONS: The Applicant should furnish specific documented informationon the biological and hydrological conditions and impact on waterbodies to be utilized.

.----39

o

20. Culvert stream cross tngs.,

The Applicant has stated that "Only five s t r eams are planned to becrossed by permanenz r oad s constructed by the Appl tcant", Three of the fivestreams are believed to have significant fish activity. The streams shouldbe re-examined and where fish passage is a requirement, culverts should bedesigned to allow the passage of fish. The Fisheries and Marine Service hasprepared guidelines for such culvert construction.

RECOMMENDATIONS: The Applicant should utilize the guidelines developed bythe Fisheries and Marine Service when preparing the final culvertdesigns.

21. Pipeline construction, routing and timing in relation to fish resources.

Based on the materials submitted by the Applicant, several examplescould be cited where pipeline routing, timing of activities or location ofancillary facilities' appear to impinge on known or suspected sensitive areas,either for the resource itself or its utilization. However, the Applicantstated repeatedly that specific locations cannot and will not be identified .until general approval has been received and compr ehens Ive data has beencollected and analysed. It is therefore imperative that at the time of f1na1·submission the final design be scrutinized in the light of the new knowledge.

RECOMME~~ATIONS: The impact of the exact location on fish resources must bedetermined after the submission of the final design for the entire.pipeline.

22. Lack of concern for recreation sites.

The Applicant has limited his comments on recreation to (1) briefsummaries of known National or Provincial Parks along or adjacent to theroute; and (2) passing comments on certain recreational activities. Therewas no assessment of compressor sites being located at or near choicerecreational sites, no consideration of the visual impact of a pipeline,'borrow pits and ancillary facilities in a potentially desirable wildernesspark. The noise, dust, exhaust, smoke, etc. are considered by the Applicantas short term problems. He viewed long term operational problems of pipe~1ne

as insignificant, and in so stating, illustrated an element of naiveness withregard to the views, wants and needs of recreationists.

REC01'~NDATIONS: The Applicant must show an awareness and appreciation ofthe outdoor recreation values of the area and plan the location ofcampsites and compressor stations accordingly.

2 " '.J •

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.---- -

40

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Effects of S02 emission

The Applicant actdresses the question of S02 effects on lichens 'bymaking a computer calculation of g~ound level concentration. He did not,however, give the details on the equations used or on assumed concentrations.Gaseous dispersions under intense Arctic inversions have not been adequatelyresearched, nor is the effect of 502 concentration on sno\~ and runoff knownin relation to damage to the vegetaEion. o. • ,0'

RECONMENDATION5: The Applicant is requested to provide information of possible502 concentration under inversion conditions. and evaluate the effectof 502 on the vegetation.

Prepared by Task Force on Mackenzie Valley Pipelice ApplicationDepartment of the EnvironmentS.C. Zoltai, Chairman

Concern #24. Removal of.borrow material from lake and river. systems., ~~~'

Removal of material from river or lake systems may destroy'fish ~"spawning grounds, introduces debris and seciment, and disrupts stream flow.'A detailed and site specific discussion of environmental concerns arisingfrom the Applicant's proposed borrow operations was presented in the AssessmentGroup's report (Section 8.13).

RECOMMENDATIONS: Bor r ow removal.' operations irius t be limited to areas abovethe design flood high water stage. and no closer than 300 ft. fromany active river channel.

Concern #25. Waste and toxic materials in water bodies.

Pipeline rupture can occur under wate~ bodies. The solubilityof natural gas under natural conditions, relative toxicites, reducingpotential in summer and winter conditions are not kno,~. Gas condensatesare known to be toxic to aquatic ecosystems even in small amounts.

RECOMMENDATIONS: The solubility of natural gas in water and its effects onaquatic ecosystems should be investigated by the Applicant. TheApplicant should stipulate that all gas condensates will bestripped from the gas.

.----41

Corice rn IJ26. Emissions from compressor stations.

Natural gas will be ~he power source for pipeline compressors and·refrigeration units. The only s;i.gnificant exhaust pollutant will be oxidesof nitrogen. The methods for calculating the emission levels were not given,nor was the stack height given. Calculations using the limit~d data showthat safe levels of NO will be exceeded under limited mixing conditions, andunder unlimited mixingXconditions if the stack height is less than 10 meters.

RECOM}lliEDATIONS: Methods of reducing the emission rate of NO are available.The Applicant must be made awar e of such designs an~ institutechanges to reduce emissions to safe levels under all atmosphericconditions.

Addendum: Harch 7, 1975.

Governmentof Canada

;

Gouvemementdu Canada

AlmONREOUEST

FICHE·DESERVICE

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FIL.ENO, - DOSSIER NO

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O WANTS TO SEE YOUDESIRE VOIJS VOIR

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MESSAGE R£(,IJ PAR l>

I TEL. NO. - NO DE TEL.II

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NOTE II RETURNNOTER E ETOIJRNERNO FORWARD

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--------------------- -----------~I'ClIlMUl.IlIOllWAI.Io(ll 124 D& L'OllClI.....

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•..• --<I...... Environment Cenada

MEMORANDUM NOTE DE S[RVICE'

FROM:DE:

Deputy Minister . ~VI'(/rJ D~/vrl ;'!L-'.-'- _. --"-- '.-

TO: tA: r

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I SAor~sAm1sRegional Board Chairmen

SUBJECT: bOE Assistance to Berger InquirySU]ET:

In a letter to Mr. Justice T.R. Berger dated March 6,1975 our ~1injster, the Honourable Jeanne Sauve, affirmed herintenti on to cooperate fu11y \'1; th the Royal Conmi ss i on Inqui ryinto the "terms and conditions that shou1d be imposed in respectof any ri ght-of-i'Jay that m; ght be granted acros s Crown 1ands II

in the Yukon and Northwest Territories. A COpy of the Minister's1etter is att acned..

To implement the Minister's purposes the following hassince been agreed wi th Conmf ss i on Counsel:

1. To provide the Inqul ry (at its Yel l owkn i fe office)with a copy of each of the unpublished reports in the possessionof the Department that have been identified as relevant and listed\'/ith the Inquiry. The only exceptions to this undertaking relateto the five unpublished reports) ~·:hich have been 'listed as "Confident i al "and for \'Ihich the j·jinister may wish to claim privilege .. The quest i onof how to deal \"ith these five unpubl i sher: rt:~P0~'-::'S wi l l be resolvecin due course in consultation idth Ccnmi ss ion Counsel.

2.· To 'provide the Inqui ry (at its Ye l l owkn i fe office)with a furtheT jist of oubl i sbed recorts or: env i ronrsente l matters,doting frc:'f1 january 1970. These report's \-,i11, of courses be addit~onclto those g-; '.':::n in the 1i sts aIre ady provi ded the: Inqui ry. The repor-tsso far lis~2d with the Inq~iry W2re selected b2:~~se they were identifiedas rel e\l-"~'''' "1"(' T'(1° Inqu: r" ""V the deca t-,.,.,·"''"'··... ~ 1 '-!' -sonnel \"'no Dr...... ~ ,~':'-l.... , a £, I.... ... \J \00 '- 1 J AJ OJ I C _ tJ II ~ II \.0a t-' '- • ' ''' 1 ill.. ~" I 4.:. ~

the iists. It appears that there are some oJ~h~:'i- repor-ts relatingto envircnmental ~atters which others consider 01' m~9ht consider relevant.The purpose , therefor-e , of t!18 add i t ions l list :Ltirrg fr-om January "l970is to enSL;i2) to tr,e extent poss ib l e and i'r;Ul;n n-;i.l"son) that no publishedreport \·:iyici, :\~ay be of relevance to the I:1q~jil'.Y ':c; o:nitt:ed. It i santicip.::u:d "tiE:t tr,·: preperat ion of this adcii·~~;;·::.::1 I i s t \·:;11 take \\bOL;~

cne ;'i10ntf).

3. "To second Dr. NOt":I1i:'lI: Sii;!:'f:'J:~~ of" the c.~::Jdi.:ln \.!i! Jl ire:Service to serve as an adv i ser to CO:;:;:1;:::;";0:1 Cljt~ll:;~l on (\ ful1-til:l~

basis'.

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2

1975 and thereafter to serve on a part-t tne basis until the endof the year.

5. To second certain other employees of the Department.. to serve as part-time advisers to Commission Counsel as they may

reasonably be required, from time to time, during the course ofthe Inquiry~ It is onticipated that these persons will be p~imarily

required to attend the he~rin9s of the Inquiry in order to assistCommission Counsel to cross-examine most effectively \~itnesses calledby other participants.

6. To provide Commission Counsel) for the use of allpartici pants oj n the Inqu i ry, ~':i th the notes prepared by the Hesternand Northern Region iask Force. These notes identify the concernsof those who served on the Task Force and contain the names of personswho, it is sUGgested, might be interviewed respecting these concerns.This step has already been taken. It has also been agreed to provideCommission Counse l , fOI~ the use of all participants in the Inquiry,with further statements of the concerns as they arise.

7. All participants shall be entitled to consult with anyemployee of th~ Oepa.tment on matters relating to such employee'sprofessional competence or expertise.

Cor.un ojss i{I'O Counsel \',i11 request all participants to indicateas far in advance as possible the names of those departmental employeesthey wish to meet with , so that the necessary ari-angements can be made.Mr.· J.J. Eatock, Regional Board Chairman s Western and Northern Region)10025 Jasper Avenue, Edmonton, will be responsible for making arrange­ments respecting persons stationed in inaccessible places; forexample. arrangements to bring someone stationed in Resolute Bayto Edmonton or Ottawa at a convenient time.

Every effort shall be made to accommodate all reasonable.. : requests for consul'tations.

A departmental emp loyee \'/lla is approached d i rect ly by aparticipant Oi by lesal counsel to a participcnt for consultationpurposes shall 'inform hi s superi or, who in turn :.rld 11 ensure thatth~ ~ppropriatG Assistant Deputy Minister is notified.

Oepa'('tm2ntol emp l oyees who are inter\fic';~:d should confine.what th2Y have to s~y to professional matters ~rJ refrain from

... cOlD!i1enL,i:ng on, h.a~te:~s of po.li cy unress spcc i fi cal Iy. autnori sec to, do....,.. ' ". SOl '".: .'. . , , '" ' -, ,:" 00.,..'".. .' ': . , "... :';",' '. ~;.',.'. ".,': " ° '. • .:: <, " ~ ,.'

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8. A number of depa r tment.e l cmp l oyce s wi l l undoubtedlybe required to testify at the Inquiry hearings as vri tnes se s forone or more of the participants. It has been agreed that any suchperson \·,ill t.e made available to do so at the' expense of the departmentand wi thout the necessity of a subpoena, provided the reques t isreasonable. Generally speaking, a minimum of two weeks· notice shouldbe required.

9. Every depar-tmental employee cal1ed upon to give evidenceat an Inquiry r.earing shoul d be give11 3. copy .of and be 'guided bythe attached document entitled "Eu i de l ines for Public Servants CalledUPo.n to Give Evidence Before the Courts or Before. Quasi-Judicial orAdministrative 800ies." These Guidelines should be treated as ageneral basis governing the conduct of departmental witnesses. Clearly,parts of the Guidelines are not applicable in the context of the Berge~

Jnqui ry <lnd \·.'hat has been stated in this memorandum. If there is anydoubt or need for clarification of any aspect of the Guidelines, thelegal advisers to the Department should be consulted. Noreover,if any departr,~2:ltal witness has any misgiving about answer-inc a particularquestion he could properly ask Mr. Justice Berger that before answering

~ he be given an opportunity to consul t vri th the legal advisers to theDepartment to determine if any question of Crown privilege was invol ved .

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J.B. Seaborn

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Ott a':'a) 0ntar i 0 ,Klf,OH3.

Narch 6, 1975.

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H0 n0 U r a b1e [·1 r. J u5 tic e T. R. 8erg e r ,c/o Mackenzie Valley Pipeline Inquiry)Resources Building,51st Street)P.O. Box 2817)

,Yellowknife, Northwest Territories.

Dear Mr. Justice Berger,

~e: N~ckenzie Valley Pipeline In~~iry

I am concerned that an impression is being createdt hat I don 0 tin ten d to cGOp era t e full Y '\'j i thy 0 urI nq1I oj ';'y

into "the terms and conditions that shoL:ld be imposed inrespect of any right-of-way that might be granted acrossCr-oWn 1and s ." .A n1- S II chi mpre s s ion i s \'} h0 11y fa 1S e -. ,

"It is my intention to"eniure th~t'a~y pa~ticipantin the Inquiry has, access to ~ll relevant documents andreports in the possession of my Department that the~articipant may require, subject only to any privilege Imay be obliged to claim. It is also ~y intention to enSui~

that no obstacle is pl~ced by officials of ~y Departmentin the way of any participant who wishes to consult with

'-~~~ny 'employee of myOerart~en~ Whose kno~le~ge of environ~en­

'. ·:···tal 'ma t t e r s .. the p a rt i c i pa n t t ma y 'wis h to a dc uce as e v i de nc eby callina such employee ~s a wit~ess.

I pro p0 set \~ n~ (~ k~ :' ub1 i c the t ~ x t 0 f t h-: s 1e t t e ;~

after you have receiv~d it.

Yo ur S 5 i :1eel'e l y ,

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a s p a r t of Jlis dut y Jo{'.~ not involve the: C'r o wn .

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f 01'" t ]1"'~ C ~~.:J;;""i t ·~~c ':11: ,

6. Fi:n.2.11y t h e folJ.o,;ing s h o u l d b c k c p t in mi n d ,

a) A P ..... :)):ic s c r v a n t \·:}:o as a private citizen~ishb5 to appear a~d nakc representations be­f orc auy }H101ic body f c d er o l , p r ov i n c ia I or'rm1.l:ic.ip::.J rna y do so but shall not d i v u r gc orPl"oOOUC::: any il)fOi.'l:,r.tioli 01" d o c urne n t s in hisp-oS.$ C S s i CJ~) he call s e 0 f his P 0 5 i t ion a 5 a p u h 1 i cSeTYL:l'.t u n l e s s it Ls of t h c sort. that is 0,1'

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t::i:;:.'Sc}f 2.11d is not 3dv,~ncinB the position or'P [) J j ~~ \' .0 f t h ~ d C' l"~ ~ 0:- -:-..mc n t ... . " . '

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