Boat Harbour Remediation Project

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Attachment Other Options Not Considered that could improve overall sludge amounts, dewatering and timelines

  • Boat Harbour Remediation Project
  • Author: Buckman Laboratories of Canada Ltd
  • Reference number: 68
  • Submitted: 2024-11-28 - 1:28 PM
  • Bio-remediation was not mentioned in the report as a synergistic option to reduce the amount of sludge, leachate, and most importantly timelines which would reduce costs and overall disposal of waste.  While the dredging and GEO-Sacs are necessary to fully remediate the site, it makes sense from both a total waste generating point of view as well as a shortened timeline using a Bio-remediation/Bio-Dredging option to lessen the overall costs and ie the effectiveness of the overall program.  This is using natural processes, which are described as "natural attenuation" in the document but with Bio-Remediation, the areas are seeded with micro nutrients and bacteria to jump start the process.  It is a kin to the use of Pre and Pro-Biotics in people to aid their overall health and digestion by imporving the natural balance of the micro flora which will then use the contaminated sludge as a food source and reduce it dramatically and positively impacting the overall operation. Please see attached files for Bio-Dredging options that would provide for significant improvements in the following areas: Less sludge to physically dredge Less polymer to treat that sludge Improved effluent quality being released (COD/BOD/TSS) Lower carbon (CO2 and Methane) emissions   For more information, please conatct me at kjmacdonald@buckman.com.    
  • Attachment included
  • Pulp and Paper Biological Water Quality and Dredge Program Offered by Buckman and MDG 1 Overview • Biological dredging • Benefits of biological dredging • Development of Biological dredging program • Real science, Trusted process, Proven Success • How the program works for you • Data review • Path Forward Goal: Introduce biological dredging program & discuss path forward for implementation 4 Bioaugmentation The process of adding scientifically selected organisms to a microbial community in order to enhance that community 7 Biotifx® enhanced bacterial activity in a P&P sample 0 0.05 0.1 0.15 0.2 0.25 0.3 0.35 0: 00 :0 4 2: 15 :0 4 4: 30 :0 4 6: 45 :0 5 9: 00 :0 5 11 :1 5: 04 13 :3 0: 04 15 :4 5: 04 18 :0 0: 04 20 :1 5: 04 22 :3 0: 04 24 :4 5: 04 27 :0 0: 04 29 :1 5: 04 31 :3 0: 04 33 :4 5: 04 36 :0 0: 05 38 :1 5: 04 40 :3 0: 03 42 :4 5: 04 45 :0 0: 04 47 :1 5: 04 49 :3 0: 04 51 :4 5: 03 54 :0 0: 04 56 :1 5: 04 58 :3 0: 03 60 :4 5: 03 63 :0 0: 04 65 :1 5: 03 67 :3 0: 03 69 :4 5: 03 72 :0 0: 04 Ba ct er ia l A ct iv ity Time (hours) Control Treated Sludge/ Bio-solids Living Cells Non-living • Dead cell material • Biopolymers • Bacteria • Protozoa • Metazoan • Fungi & yeast Biomass Particulates Organic Inorganic Microbial food sources Components of Sludge 9 Bacillus Carbs, Proteins, Lipids Native Community Simple sugars, fatty acids, amino acids H2O CO2H2O CO2 10 Bacillus Carbs, Proteins, Lipids Native Community Simple sugars, fatty acids, amino acids H2O CO2H2O CO2CO2 CO2 Reduction of Sludge Volume ...
  • Attachment included
  • REAL SCIENCE. TRUSTED PROCESS. PROVEN RESULTS. What was done • Dose bioaugmentation at 25lbs/day • Surveyed monthly • Sonar boat ~4,000-6,000 datapoints) • Sludge sampled at 10 locations • Reported results 2 Preliminary 4 Month Summary July – November 3 • 7.6 Inches of sludge digested & removed • 1.5 million gallons restored • 711 dry tons of sludge digested to date • Trial goal for facility was 380 dry tons • Exceeded the removal cap by 111 tons Pond Loading 4 Polishing Pond Loading 5 Polishing pond Infl. TSS Tons/month Before (2yr) 208 During 257 Effl. TSS (tons/month) Before (2 yr) 110 Durring 93 Tons captured/month Before 90.6 During 124.7 38% 7/6/2022 11/7/2022 7/7/22 vs 11/7/22
  • Attachment included
  • Introduction More than 50% of industrial wastewater treatment facilities in the US employ lagoons in their treatment process (4). Sludge is an integral part of a lagoon system, but excess amounts can negatively impact performance. Accumulation of sludge alters the holding capacity of the lagoon and topography of the bottom (5). These changes can result in decreased hydraulic retention time and subsequently reduce treatment efficacy. Sludge management in wastewater typically amounts to 40-60% of total plant costs, but charges relating to sludge disposal, such as transportation and landfill costs, have been trending upward, and regulations for land application are becoming stricter (7). One solution to help mitigate these rising disposal costs is the implementation of a biological treatment. Organic sludge components can be effectively digested with a biological treatment, reducing the frequency and cost of mechanical removal events, and making bioaugmentation an attractive sludge management option. Bioaugmentation aims to increase sludge digestion by enhancing the biology that naturally exists in the environment through the addition of bacterial species and/or nutrients that support microbial growth. In wastewater, the goal of employing bioaugmentation in the form of a bacterial species, such as Bacillus, p1 A Bacillus-Based Bioaugmentation Product Effectively Reduces Sludge In An Analysis Of Eleven Wastewater Lagoons is to shift the native population towards organisms that more effectively digest sludge (2). Sludge composition varies greatly based on the influent sources, but studies have found that municipal sludge is mostly organic with carbohydrates, proteins, and ...
  • Attachment included
  • Lagoon Sludge Removal with BiotifxTM P&P ABSTRACT A large pulp and paper mill in the upper Midwest was experiencing accumulation of solids in a wastewater treatment lagoon following their aeration basin and secondary clarifier. Core sampling was used to measure changes in sludge before and after the lagoon was dosed with BiotifxTM P&P 40B. Results included reduced sludge volume and increased hydraulic space. BACKGROUND The buildup of sludge was leading to hydraulic short-circuiting and loss of treatment capacity in the lagoon. The cause of excessive solids loading in the lagoon was due to unsettled solids and high BOD in the secondary clarifier effluent, as well as poor facultative digestion within the lagoon. A survey conducted in 2013, by a third party indicated that the entirety of the lagoon is 238 million gallons at 8’8” deep and 43.5% filled with sludge. Surveying and samples taken by MDG on Oct 7th, 2015 illustrated that solids loading in SSE portions of the lagoon were the most dramatic. A recommendation in fall of 2015 was made to use bioaugmentation product, BiotifxTM P&P 40B, to enhance biological digestion of accumulated solids in the lagoon. In June of 2016, the SSE portion of the lagoon was treated with BiotifxTM P&P 40B in an effort to remove accumulated organic solids. The objective of treatment was to demonstrate with quantifiable results, the digestion of accumulated solids after addition of BiotifxTM P&P 40B in a portion of the lagoon. Success is measured by increased hydraulic space (depth to sludge blanket) and removal of solids in the portion of the lagoon treated and monitored after 90 days. METHODS Vertical core samples of the strata in the top 3’ of the lagoon (surface ...
Report

Attachment Indigenous Services Canada comments on the Draft Environmental Assessment Report and Draft Potential Conditions

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Indigenous Services Canada
  • Reference number: 70
  • Submitted: 2024-11-19 - 4:05 PM
  • Project phase: Planning
  • See the attached submission / Veuillez consulter la pièce ci-jointe   
  • Attachment included
  • 1 Invitation to Comment on the Draft Environmental Assessment Report and Draft Potential Conditions IAAC is seeking Indigenous Services Canada’s comments on whether IAAC has: 1. accurately and adequately characterized the potential environmental effects within federal jurisdiction (as relates to your department’s mandate) and identified key mitigation measures, monitoring, and follow-up programs; and 2. accurately and adequately summarized any comments and views from your department. Comment ID Document Reference Comment (Question 1) Comment (Question 2) Comment idenƟfier by organizaƟon and comment number SecƟon of the document (e.g. Ɵtle, secƟon, subheading, page number) Comment on accuracy and adequacy of characterizaƟon of potenƟal environmental effects within ISC’s mandate and idenƟfied key miƟgaƟon measures, monitoring, and follow- up programs Comment on accuracy and adequacy of ISC comments ISC-01 DraŌ Environmental Assessment Report 2.3.1 Waste Management and Containment Cell Page 3 The EA Report references one of Pictou Landing First NaƟon’s proposed alternaƟve to the containment cell as not being feasible as it didn’t meet minimum distance from waterbodies, groundwater, and residenƟal and commercial buildings (pg 15). However, the containment cell will be located between two reserve parcels and the feasibility of the proposed placement of the containment cell adjacent to PLFN reserve parcels does not address whether this placement of the containment cell would impact future development on those reserve lands by the PLFN. Recommend including an assessment of impacts of the proposed placement of the containment cell to the two ...
  • Attachment included
  • <Original signed by>

Report

Attachment Public Input

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Trudi Rhynold
  • Reference number: 67
  • Submitted: 2024-11-18
  • Project phase: Planning
  • Participation notice: Public Notice - Public Comments Invited on the Draft Report and Potential Conditions
  • I am writing to suggest alternative remediation treatments at Boat Harbour (and other) projects. I do not believe dredging and placing contaminants in a lined capped pit onsite is a long term solution to remediation. Please consider such alternate treatments as mentioned in the following studies. These alternate treatments would also be usefully applied at abandoned mines and other contaminated sites.   https://www.hindawi.com/journals/isrn/2011/402647/   https://pubmed.ncbi.nlm.nih.gov/23357508/   https://www.intechopen.com/books/emerging-pollutants-some-strategies-for-the-quality-preservation-of-our-environment/study-on-magnetic-materials-for-removal-of-water-pollutants   https://www.tandfonline.com/doi/abs/10.1080/15320383.2019.1696279   https://www.researchgate.net/publication/228091682_Heavy_Metal_Removal_from_Soils_Using_Magnetic_Separation_1_Laboratory_Experiments   Thank you for your consideration.   Trudi Rhynold

Report

Attachment Stop testing effluent on animals

  • Boat Harbour Remediation Project
  • Author: Nicole Corrado
  • Reference number: 61
  • Submitted: 2024-11-14 - 9:56 PM
  • Participation notice: Public Notice - Public Comments Invited on the Draft Report and Potential Conditions
  •    ? https://www.change.org/p/stop-testing-pollution-and-effluent-on-fish-and-other-animals   Please stop the “acute lethality tests” on rainbow trout, three lined stickleback, and other fish species.  These tests involve pumping effluents into fish tanks once a month, and if more than half the fish die, the experiments are repeated twice a month.  Sub lethal effect tests are also conducted.  Wild fish are killed and their livers analyzed.  Canada does not allow Non Animal Alternatives for testing effluent at mines or sewage treatment plants.  https://laws-lois.justice.gc.ca/eng/regulations/SOR-2002-222/FullText.html There are animal free ways to test for pollution.  The Physicians Committee for Responsible Medicine suggests using rainbow trout cell lines instead (obtained without harming fish).   https://www.pcrm.org/news/good-science-digest/world-aquatic-animal-day Any guardians of companion fish will test their tank using paper strips and test tubes.  They do not deliberately expose the fish to effluents to see what happens. Bacteria and pollutants in swimming pools are also tested without animals. Please also end the practice of sublethal toxicity testing of effluent on baby fathead minnows, rainbow trout, and other animals.  These animals are killed, dried, weighed, and preserved. Aquatic Life Referencing Values are created by testing pesticides on laboratory fish.  These lethal dose tests/acute lethality tests and chronic toxicity tests are cruel and should be replaced with Non Animal Methods.  No new ALRV fish tests should be conducted, and only existing data ...

Report

Attachment PLFN comments on the Draft Environmental Assessment Report and Draft Potential Conditions

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Pictou Landing First Nation
  • Reference number: 62
  • Submitted: 2024-11-14 - 3:41 PM
  • Project phase: Planning
  • Participation notice: Public Notice - Public Comments Invited on the Draft Report and Potential Conditions
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • ____________________________________________________________________________________________________________________________________________________________ Purdy’s Wharf, Tower One, 1959 Upper Water Street, Suite 502, Halifax, NS B3J 3N2 Tel: (902) 423-2050 Fax: (902) 423-6707 Toll Free: 1-877-423-2050 (Atlantic Canada) Website: www.mckigganhebert.com November 14, 2024 File No. 8463-034 VIA EMAIL: mike.atkinson@iaac-aeic.gc.ca Mike Atkinson Regional Director Atlantic Regional Office Impact Assessment Agency of Canada Dear Mr. Atkinson: Re: Draft EA Report - Boat Harbour Remediation Project Please accept the following as PLFN’s comments on the Draft Environmental Assessment Report and the Potential Conditions for the Boat Harbour Remediation Project. 1. On page 6 of the Draft Report, there is reference to 128 acres of land to be transferred to PLFN. It should be noted with respect to this land, that it was promised to PLFN in the 1990s once the then promised cleanup of Boat Harbour had taken place. As such, the transfer of those 128 acres of land is to fulfil a longstanding legal obligation of the Province, rather than reflecting any fresh accommodation measures. 2. On page 90 of the Draft Report, when discussing the assertion of Aboriginal title, please consider inserting a comment that an analysis of Aboriginal title claims was beyond the scope of the environmental assessment and no strength of claim analysis has been carried out. 3. Beginning at page 91, the Draft Report discusses three categories of Aboriginal rights: (a) fishing rights, (b) hunting and trapping rights; and (c) the right to cultural continuity. Missing is a discussion on the Aboriginal right to the use and enjoyment of reserve land and ...
Report

Attachment Proponent comments on the Draft Environmental Assessment Report and Draft Potential Conditions

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Build Nova Scotia
  • Reference number: 69
  • Submitted: 2024-11-14 - 3:11 PM
  • Project phase: Planning
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • BOAT HARBOUR REMEDIATION PROJECT PROPONENT RESPONSE TO IAAC DRAFT ENVIRONMENTAL ASSESSMENT REPORT NOVEMBER 2024 Contents 1.0 INTRODUCTION ................................................................................................... 1 2.0 BALANCING THE OUTCOMES OF THE IAAC APPROVAL DECISION ............. 1 2.1 Funding ................................................................................................................................. 2 2.2 Participation .......................................................................................................................... 3 2.3 Lands and Legacy ................................................................................................................... 3 2.4 Approval or Non-Approval ....................................................................................................... 4 3.0 ABORIGINAL AND TREATY RIGHTS .................................................................. 5 4.0 CULTURAL CONTINUITY .................................................................................... 5 5.0 CONSULTATION ................................................................................................... 8 6.0 TABLE – CLARIFICATION OF ASPECTS OF THE REPORT AND PROPOSED CONDITIONS ...................................................................................................... 10 ~ 1 ~ 1.0 INTRODUCTION This document is Build Nova Scotia’s (the Proponent) response to the Draft Environmental Assessment Report issued by the Impact Assessment Agency of Canada (IAAC) for public comment on October 15, 2024. The ...
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Attachment Transport Canada comments on the Draft Environmental Assessment Report and Draft Potential Conditions

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Transport Canada
  • Reference number: 66
  • Submitted: 2024-11-14 - 3:03 PM
  • Project phase: Planning
  • Participation notice: Public Notice - Public Comments Invited on the Draft Report and Potential Conditions
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • Transport Canada General Comments on the Draft Environmental Assessment Report (DEAR) and draft Potential EA Conditions Boat Harbour Remediation Project (CIAR 80164) Thank you for the opportunity to review the Draft Environmental Assessment Report (DEAR) and draft Potential EA Conditions. Overall DEAR comments: • Potential impacts to navigation should be considered in the DEAR. TC understands that in addition to effects under federal jurisdiction, as defined in the Canadian Environmental Assessment Act, 2012 (CEAA 2012), “a change, […] caused to the environment and that is directly linked or necessarily incidental to a federal authority’s exercise of a power or performance of a duty or function that would permit the carrying out, in whole or in part, of the physical activity, the designated project or the project”. Additionally, questions regarding navigation were raised during a Virtual Question & Answer Session with Pictou Landing First Nation (PLFN) on January 7, 2021, regarding navigation impacts related to Indigenous interest. • As previously noted throughout the environmental assessment review process for this project, approval(s) under the Canadian Navigable Waters Act (CNWA) are likely for removal of existing and newly proposed infrastructure (e.g. removal of dam, replacement bridge) associated with this project. • TC also notes that approval under the CNWA may be required if armouring the estuary is pursued as a mitigation measure (i.e. Page 33, first paragraph). • The DEAR correctly identifies the requirement for CNWA approval(s) in Section 7.3 Issues to be Addressed During the Regulatory Approval Phase (Page 96), and forms part of the considerations within the EA ...
Report

Attachment Health Canada comments on the Draft Environmental Assessment Report and Draft Potential Conditions

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Health Canada
  • Reference number: 64
  • Submitted: 2024-11-14 - 2:43 PM
  • Project phase: Planning
  • Participation notice: Public Notice - Public Comments Invited on the Draft Report and Potential Conditions
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • Unclassified / Non classifié Environmental Health Program, Atlantic Region Regulatory Operations and Enforcement Branch 1505 Barrington Street, Suite 1625 Halifax, NS B3J 3Y6 November 14, 2024 Karen Lalonde Impact Assessment Agency of Canada 200 - 1801 Hollis St. Halifax, NS B3J 3N4 Sent by e-mail to: Karen.Lalonde@iaac-aeic.gc.ca and boatharbour@iaac-aeic.gc.ca Subject: Health Canada’s Comments on the Draft Environmental Assessment Report and Draft Potential Conditions for the Boat Harbour Remediation Project Dear Karen Lalonde: Thank you for the Impact Assessment Agency of Canada’s (IAAC) October 15, 2024, invitation to comment on the Draft Environmental Assessment Report (draft EA report) and Draft Potential Federal Conditions (draft conditions) for the Boat Harbour Remediation Project. Health Canada (HC) is participating in the environmental assessment process as a Federal Authority under the Canadian Environmental Assessment Act, 2012 (CEAA 2012). For projects reviewed under CEAA 2012, HC’s review is limited to biophysical health. As requested, the Department reviewed the draft EA report and draft conditions. The findings in the draft EA report related to HC’s mandate were appropriately reflected in the draft conditions, and HC’s comments and views were appropriately reflected in the draft EA report, except for the following: • HC’s comments on daily exposure limits are insufficiently reflected in section 5.3.1 of the draft EA report and potential condition 5.3.4 in the draft conditions; and • Key mitigation measures in the draft EA report on dust suppression are not appropriately reflected in draft federal condition 5.1.1. HC has ...
Report

Attachment ECCC comments on the Draft Environmental Assessment Report and Draft Potential Conditions

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Environment and Climate Change Canada
  • Reference number: 65
  • Submitted: 2024-11-14 - 12:21 PM
  • Project phase: Planning
  • Participation notice: Public Notice - Public Comments Invited on the Draft Report and Potential Conditions
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • Boat Harbour Remediation Project - Draft Potential Conditions Environment and Climate Change Canada Comments November 14, 2024 - 1 - Department Condition # Suggested change to mitigation / follow-up requirement Context/rationale for change ECCC-01 4.X Migratory Birds ECCC recommends adding a condition to avoid impacts to ground and burrow nesting birds, as follows: The Proponent shall cover all stockpiles or patches of bare soil during the migratory bird nesting period (mid-April to late August) in a manner that discourages birds from nesting in work areas. As stated on page 22 of the draft EA report, ground-nesting and burrowing migratory bird species, including species at risk (e.g. Bank Swallow, Common Nighthawk) may be attracted to nesting in working areas. Page 22 also states that the proponent committed to covering any large piles or patches of bare soil to discourage nesting by these species. If left uncovered these areas should be inspected for evidence of nesting by a qualified individual (as per 4.2). Any nests discovered should be protected by a set back distance (as per Condition 4.3) to prevent damage, disturbance, and/or destruction of nests and offspring of Common Nighthawk and other ground-nesting migratory birds. ECCC-02 4.2 Migratory Birds ECCC recommends that the condition be revised and expanded (added text in bold, removed text in strikethrough) as follows: The Proponent shall determine the presence, or likely presence, of migratory bird nest(s) protected under the Migratory Birds Convention Act (MBCA) and its regulations and residences protected under the Species at Risk Act (SARA) that may be adversely affected by any Designated Project activity prior to ...
  • Attachment included
  • Boat Harbour Remediation Project Draft EA Report Environment and Climate Change Canada (ECCC) Comments November 14, 2024 1. Quote (Section 5.2.1, pg. 37): “Species at risk with the potential to occupy the SSA, LSA, or RSA can be found in Appendix C of this report.” ECCC notes that the incorrect Appendix is referenced above. Appendix D presents “Species at Risk and COSEWIC-listed species that may be found near the Boat Harbour Remediation Project, including the Site Study Area.” 2. Quote (Section 5.2.1, pg. 40): “To discourage barn swallows and other ground- nesting or burrow-nesting birds (e.g., common nighthawk, bank swallow) from nesting in work areas, the Proponent stated that any large piles or patches of bare soil would be covered during the nesting season. Environment and Climate Change Canada noted that birds and nests are protected until the young have naturally fledged and recommended that if demolition activities can’t be avoided during the migratory bird breeding season, surveys should be conducted to identify if there is evidence of nesting. If a nest is discovered, any activities that could cause the nest to be abandoned or destroyed should be avoided until any chicks have fledged and left the area.” This statement implies that the Barn Swallow nests on the ground/in stockpiles, but it does not. ECCC recommends adjusting the text as follows (added text in bold, removed text in strikethrough): “To discourage bank swallows barn swallows and other ground-nesting or burrow-nesting birds (e.g., common nighthawk, bank swallow) from nesting in work areas, the Proponent stated that any large piles or patches of bare soil would be covered during ...
Report

Attachment Sipekne'katik First Nation Consultation Department Comments on the EA Report for Boat Harbour Remediation

  • Boat Harbour Remediation Project
  • Author: Sipekne'katik First Nation Consultation Department
  • Reference number: 60
  • Submitted: 2024-11-14 - 10:27 AM
  • Participation notice: Public Notice - Public Comments Invited on the Draft Report and Potential Conditions
  • Comments on Build’s Nova Scotia’s Boat Harbour Remediaiton Project Draft Environmental Assessment Report (October 15, 2024), outlining the proposed remediation of Boat Harbour and nearby lands. See letter attached.
  • Attachment included
  • November 12, 2024 RE: Comments on Build’s Nova Scotia’s Boat Harbour Remediaiton Project Draft Environmental Assessment Report (October 15, 2024), outlining the proposed remediation of Boat Harbour and nearby lands. To whom it may concern at the Impact Assessment Agency Canada (IAAC); This letter responds to the Draft Environmental Assessment Report for the Boat Harbour Remediation Project in Nova Scotia, published on October 15, 2024, and open for a 30-day comment period. After a comprehensive review of the draft Environmental Assessment report and the draft potential conditions published by the IAAC, Sipekne’katik expresses its full support for the final position adopted by Pictou Landing First Nation (PLFN). Sipekne’katik First Nation also reaffirms its support for the resolution passed by the Assembly of Mi’kmaq Chiefs to authorize and empower PLFN to lead consultation for this project on behalf of the Mi’kmaq community. While we acknowledge that the proposed remediation project aims to improve the environmental conditions at Boat Harbour, which has suffered severe degradation due to the operation of the former pulp mill, we remain concerned about the proposed permanent storage of hazardous waste on-site. Significant risks are associated with the potential leakage or spills of hazardous materials, which could further damage the fragile wetland ecosystem. Furthermore, we want to highlight that despite the proposed remediation efforts, it is highly unlikely that PLFN and the broader Mi’kmaq community will resume traditional use of the land, water, and resources in the Boat Harbour area. Therefore, additional compensation is necessary to address the permanent loss ...
Report

Attachment DFO comments on the Draft Environmental Assessment Report and Draft Potential Conditions

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Fisheries and Oceans Canada (DFO)
  • Reference number: 63
  • Submitted: 2024-11-06 - 1:03 PM
  • Project phase: Planning
  • Participation notice: Public Notice - Public Comments Invited on the Draft Report and Potential Conditions
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • .../2 Fisheries and Oceans Canada Pêches et Océans Canada 1 Challenger Drive PO Box 1006, P500 Dartmouth, NS B2Y 4A2 November 6, 2024 Our file Notre référence 18-HMAR-00523 Karen Lalonde Project Manager, Atlantic Region Impact Assessment Agency of Canada 200-1801 Hollis Street Halifax, NS B3J 3N4 Subject: DFO comments on the Draft Environmental Assessment Report and Draft Potential Conditions – Boat Harbour Remediation Project Dear Karen Lalonde: The Fish and Fish Habitat Protection Program (the Program) of Fisheries and Oceans Canada (DFO) received your request to review the draft Environmental Assessment (EA) Report and draft potential conditions for the proposed Boat Harbour Remediation Project on October 15, 2024. We understand that the proponent is proposing the following: • The remediation of Boat Harbour and nearby lands, located next to Pictou Landing First Nation and east of Pictou, Nova Scotia. The Project will include waste management, expansion of the existing containment cell, remediation, and infrastructure decommissioning. • During remediation activities in the Site Study Area (SSA), hydraulically (and in some cases, mechanically excavated) dredged sludge will be pumped through a dredge line to the containment cell (with an expected storage capacity of 930,000 cubic metres) to be dewatered by Geotubes. Leachate from the Geotubes will be collected and piped back into Boat Harbour to undergo natural attenuation. Remediation activities will start upstream in the SSA to ensure any impacts will be captured downstream. • Freshwater wetlands and the estuary will be remediated by using ex-situ remediation ...
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Attachment Comment on: Boat Harbour Remediation Project Draft Environmental Assessment Report (the Report) - October 15, 2024

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of W. A. Mac Quarrie
  • Reference number: 59
  • Submitted: 2024-10-28 - 8:53 AM
  • Project phase: Planning
  • Participation notice: Public Notice - Public Comments Invited on the Draft Report and Potential Conditions
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • To: Impact Assessment Agency of Canada October 25, 2024 Ottawa (by E-Mail) From: W. A. Mac Quarrie Subject: Comment: Build Nova Scotia’s Boat Harbour Remediation Project Draft Environmental Assessment Report, (October 15, 2024), outlining the proposed remediation of Boat Harbour and nearby lands. According to The Impact Assessment Agency of Canada (IAAC), Boat Harbour Remediation Project Draft Environmental Assessment Report (the Report) dated October 15, 2024, as proposed by the Proponent presents the view that the Project is not likely to cause significant adverse effects on fish and fish habitat. It indicates the implementation of the mitigation, follow-up, and monitoring measures subsequent to the cleanup of the lagoon has taken into account all factors. After a review of the Report I am wondering if proximity of the PLFN sewage plant, the plant efficiency and the makeup and quality of discharge at the outfall have been examined in relationship to the future water quality in a post remediation Boat Harbour – or if such has been ignored or over-looked. Before construction of the pulp mill treatment facility I had personal knowledge of the water at the entrance to Boat Harbour. Sea water flowed into Boat Harbour during a rising tide in the offshore area. The quantity of inflowing water was considerable and a strong current ran into the harbour. At that time PLFN did not have a sewage plant, today, about one kilometre west of the entrance to Boat Harbour not far off the beach at the eastern end of P ictou Bar there is a PLFN owned sewage plant and outfall. The Report contains a analysis of an area of the entrance limited to within 500 metres of the harbour entrance; (Figure C-2). It must ...
Report

Attachment DFO's Technical Review of Round 1 Information Requirement Responses

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Fisheries and Oceans Canada
  • Reference number: 48
  • Submitted: 2024-05-08 - 12:47 PM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • Fisheries and Oceans Canada Pêches et Océans Canada Ecosystems Management 1 Challenger Drive PO Box 1006, P500 Dartmouth, NS B2Y 4A2 Your file Votre référence August 30, 2022 Our file Notre référence 18-HMAR-00523 Lachlan MacLean Project Manager, Boat Harbour Remediation Project Impact Assessment Agency of Canada Suite 201 - 1801 Hollis St. Halifax, NS B3J 3N4 Subject: Boat Harbour Remediation Project – Technical Review of Consolidated Round 1 IRs Dear Mr. MacLean: The Fish and Fish Habitat Protection Program (the Program) of Fisheries and Oceans Canada (DFO) has completed a technical review of the consolidated Round 1 IRs for the Boat Harbour Remediation Project (dated July 28, 2022) received on August 8, 2022. Please note that our review only focused on sections related to DFO’s mandate. Given the limited timeline for DFO to complete our review, and the complexities and challenges of cross-referencing an EIS that is not presented in a succinct manner as the reader must refer to multiple EIS sections as well as multiple Appendices, which are often not referred to in the EIS, to get a complete overview of the project assessment. Furthermore, DFO may have additional comments in the future related to the Boat Harbour Remediation Project (the Project) as there are important baseline data gaps for the Estuary as well as the Marine Environment labelled Pictou Road which must be filled prior an adequate effects assessment being conducted. Based on the Program’s review of the IRs as well as the EIS, DFO has concerns about the potential effects on fish and fish habitat from the Project. In order for DFO to provide ...
  • Attachment included
  • Annexes – Page 1/14 ANNEX 1: Advice to the Agency Table 1: Please use the table below to provide advice for the Agency’s consideration in its recommendation to the Minister of Environment and Climate Change and preparation of draft conditions Questions Responses/Comments  Has the proponent described all project components and activities in sufficient detail to understand all relevant project-environment interactions? If not, identify what additional information is needed. No Change from Original December 21, 2020 submission.  Were the study areas sufficient to predict potential effects from all relevant project- environment interactions, and to consider the effects within a local and regional context?  Is the baseline information sufficient to characterize the existing environment, predict potential effects and obtain monitoring objectives? If not, identify what additional information is needed. No Change from Original December 21, 2020 submission. Alternatives Assessment  Has the proponent adequately described the criteria it used to determine the technically and economically feasible alternative means?  Has the proponent listed the potential effects to valued components (VCs) within your mandate that could be affected by the technically and economically feasible alternative means?  Has the proponent adequately described why it chose each preferred alternative means?  Are there other alternative means that could have been presented? If so, please describe. The proponent explored various mitigation measures such as widening the mouth of Boat Harbour and armouring the channel prior to the removal of the dam to determine a potential for the reduction of ...
  • Attachment included
  • Fisheries and Oceans Canada Pêches et Océans Canada Ecosystems Management 1 Challenger Drive PO Box 1006, P500 Dartmouth, NS B2Y 4A2 Your file Votre référence August 30, 2022 Our file Notre référence 18-HMAR-00523 Lachlan MacLean Project Manager, Boat Harbour Remediation Project Impact Assessment Agency of Canada Suite 201 - 1801 Hollis St. Halifax, NS B3J 3N4 Subject: Attachment (2) - DFO comments and Request for Information in relation to IR IAAC-14 Dear Mr. MacLean: The Fish and Fish Habitat Protection Program (the Program) of Fisheries and Oceans Canada (DFO) has completed a technical review of the consolidated Round 1 IRs for the Boat Harbour Remediation Project (dated July 28, 2022) received on August 8, 2022. This attachment is a compilation of our comments and specific questions/request for information in response to IR IAAC-14. Context and Rationale The proponent was requested to: Provide more detailed information on the baseline conditions in the estuary and the Northumberland Strait shorelines immediately outside of the mouth of Boat Harbour. They were requested to use this information and the results of the WSP 2020 Coastal Hydraulic Modeling Report (Appendix Z) to update the effects assessment of surface water, marine environment, and fish and fish habitat. This was to include a discussion of the impacts from both water column increases in TSS and deposition of sediment on: • marine water quality; • marine plants, including all benthic and detached algae, marine flowering plants, brown algae, red algae, green algae, and phytoplankton; 18-HMAR-00523 - 2 - • marine ...
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Attachment NSECC's Technical Review of Round 2 IR Responses

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Nova Scotia Environment and Climate Change
  • Reference number: 51
  • Submitted: 2024-05-08 - 12:46 PM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • MEMORANDUM To: Lachlan Maclean From: Bridget Tutty, Environmental Assessment Branch, ECC Date: Sept 12, 2022 Subject: Boat Harbour – Environmental Assessment Provincial Review of Round 2, Part 1 Information Requests Provincial Comments: The following provincial technical review comments are provided to the Impact Assessment Agency regarding the Round 2 Part 1 information request responses from Nova Scotia Lands Inc. Boat Harbour Remediation Project – Federal Impact Assessment Provincial Technical Review August 2022 NS Environment and Climate Change Comment # Reviewer Department Information Request # EIS Section and Page (if applicable) Context and Rationale Specific Question/ Request for Information Species at Risk Biologist Natural Resources and Renewables 2.7.2 IAAC- 21 Page 32 “A 300 m buffer around Piping Plover nests was conservatively assumed based on professional opinion and previous commitments made for other projects in Eastern Canada.” Statement is not sufficient to assess the basis for establishing a 300 m buffer. No reference to previous literature or expert opinion has been provided. Was ECCC-CWS (Atlantic Region) consulted with respect to this buffer distance? Please provide the experts contacted and previous literature cited in determining that the 300m buffer was sufficient. Provide information on whether ECCC was consulted with respect to this buffer distance. Species at Risk Biologist Natural Resources and Renewables 2.7.2 IAAC- 21 Page 32 Pictou Bar Spit (Lighthouse) has been identified as Core Habitat within the 2021 provincial Recovery Plan for Piping plover (Charadrius melodus melodus) in Nova ...
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Attachment Health Canada's Technical Review of Round 2 IR Responses

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Environmental Health Program (EHP), Atlantic Region
  • Reference number: 44
  • Submitted: 2024-05-08 - 12:45 PM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • Environmental Health Program (EHP), Atlantic Region Regulatory Operations and Enforcement Branch (ROEB) 1505 Barrington Street, Suite 1625 Halifax, NS B3J 3Y6 Lachlan MacLean Impact Assessment Agency of Canada (IAAC) 200 - 1801 Hollis St. Halifax, NS B3J 3N4 Sept. 13, 2022 Sent by e-mail to: Lachlan.Maclean@iaac-aeic.gc.ca and boatharbour@iaac-aeic.gc.ca s Technical Review of the s to the Round Two (Part One) Information Requirements for the Boat Harbour Remediation Project Dear Lachlan MacLean: Thank you for your email dated August 3, 2022 technical review of s to the Round Two (Part One) Information Requirements (IRs) issued by the Impact Assessment Agency of Canada (IAAC) on April 5, 2022 for the Boat Harbour Remediation Project (BHRP). Health Canada is participating in the environmental assessment process as a Federal Authority under the Canadian Environmental Assessment Act, 2012. Health Canada has reviewed the s to IRs IAAC-33, 35, 36, 37, 40/41/49/50/52, 42/43, 50, 44, 45, 48, 53, 57, 54b/56/58, 60, 62/63/65, 64, and 1/61 and provided detailed technical comments for consideration in the attached table. In summary, Health Canada identified the following main Site Specific Target Level (SSTL) calculations do not include all operable exposure pathways for the site, resulting in SSTLs that may not be protective of human health; Insufficient information to justify the use of intermediate/sub-chronic Toxicological Reference Values (TRVs) or Minimal Risk Levels (MRLs) in the SSTL calculations, which may underestimate site exposure and result in SSTLs that may not be protective of human health; Insufficient rationale to support the ...
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Attachment Health Canada's Technical Review of Round 1 IR Responses (IAAC-33, 36, 37, 39 and 62c)

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Environmental Health Program (EHP), Atlantic Region
  • Reference number: 46
  • Submitted: 2024-05-08 - 12:44 PM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • Environmental Health Program (EHP), Atlantic Region Regulatory Operations and Enforcement Branch (ROEB) 1505 Barrington Street, Suite 1625, Halifax, NS B3J 3Y6 Lachlan MacLean Impact Assessment Agency of Canada (IAAC) 200 - 1801 Hollis St. Halifax, NS B3J 3N4 Dec. 15, 2021 Sent by e-mail to: Lachlan.Maclean@iaac-aeic.gc.ca and boatharbour@iaac-aeic.gc.ca Subject: Health Canada’s Technical Review of the Proponent’s Responses to the Round One (Part Two) Information Requirements for the Boat Harbour Remediation Project Dear Lachlan MacLean: Thank you for your email dated November 15, 2021 requesting Health Canada’s technical review of the proponent’s responses to the Round One (Part Two) Information Requirements (IRs) issued by the Impact Assessment Agency of Canada (IAAC) on October 19, 2021 for the Boat Harbour Remediation Project (BHRP). Health Canada is participating in the environmental assessment process as a Federal Authority under the Canadian Environmental Assessment Act, 2012. Health Canada has reviewed the proponent’s responses to IRs IAAC-33, 36, 37, 39, and 62c and provided detailed technical comments for IAAC’s consideration in the attached table. In summary, Health Canada identified the following major issues in the proponent’s responses:  Insufficient rationale to support the soil allocation factors used in the calculation of the site-specific target levels for vanadium and dioxins/furans;  Insufficient rationale to support the exclusion of human consumption of terrestrial game mammals as an operable exposure pathway;  Insufficient information on plant/berry tissue sampling, and lack of clarity regarding the ...
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Attachment Health Canada's Technical Review of Round 1 IR Responses (IAAC-32, 34, 35, 38, 40 to 61, 62a/b, 63, 64, 65)

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Environmental Health Program (EHP), Atlantic Region
  • Reference number: 47
  • Submitted: 2024-05-08 - 12:43 PM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • Environmental Health Program (EHP), Atlantic Region Regulatory Operations and Enforcement Branch (ROEB) 1505 Barrington Street, Suite 1625, Halifax, NS B3J 3Y6 Lachlan MacLean Impact Assessment Agency of Canada (IAAC) 200 - 1801 Hollis St. Halifax, NS B3J 3N4 Nov. 30, 2021 Sent by e-mail to: Lachlan.Maclean@iaac-aeic.gc.ca and iaac.boatharbour.aeic@iaac- aeic.gc.ca Subject: Health Canada’s Technical Review of the Proponent’s Responses to the Round One (Part Two) Information Requirements for the Boat Harbour Remediation Project Dear Lachlan MacLean: Thank you for your email dated October 25, 2021 requesting Health Canada’s technical review of the proponent’s responses to the Round One (Part Two) Information Requirements (IRs) issued by the Impact Assessment Agency of Canada (IAAC) on May 11, 2021 for the Boat Harbour Remediation Project (BHRP). Health Canada is participating in the environmental assessment process as a Federal Authority under the Canadian Environmental Assessment Act, 2012. Health Canada has reviewed the proponent’s responses to IRs IAAC-32, 34, 35, 38, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62a/b, 63, 64, 65 and provided detailed technical comments for IAAC’s consideration in the attached table. In summary, Health Canada identified the following major issues in the proponent’s responses:  Insufficient evaluation of potential health impacts associated with the sediment release into the Northumberland Strait and sediment resuspension in the Boat Harbor Effluent Treatment Facility areas during the post-remediation period;  Insufficient information/rationale on ...
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Attachment Pictou Landing First Nation's Technical review of EIS

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Pictou Landing First Nation
  • Reference number: 49
  • Submitted: 2024-05-08 - 12:43 PM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • EXP Services Inc. Boat Harbour Remediation Project Environmental Impacts Statement Review January 29, 2021 Page A1 of A15 Comment Number Reference to EIS Context and Rationale Comment Number 1. Summary of Environmental Impact Statement (SEIS) Page 1 The closure of the BHETF operations and remediation of BHETF will result in a significant reduction in emissions, discharges, and wastes. Can you please clarify what emissions, discharges and wastes will continue into the BHETF? 2. SEIS Page 5 Prior to modifications of the existing containment cell, the current waste in the containment cell would be temporarily relocated either by pumping or hauling to existing Site infrastructure (i.e., settling basins, ASB) or constructed staging areas. Where are these staging areas? Not shown on any plans nor discussed. Seems like there are options but ASB is the focus. 3. SEIS Page 6 Leachate Management Dewatering effluent from Geotubes® or equivalent technology would be collected and conveyed to Boat Harbour, where it would undergo natural attenuation processes before being discharged to the estuary. The effluent discharge criteria are currently being developed using a risk based approach. Final discharge criteria would be adopted through the Provincial IA process required for the remediation. Dewatering Effluent = Leachate What is the natural attenuation process planned? Is this going through an engineered wetland and/or settling ponds? What if it fails and/or has constituents that cannot naturally attenuate quickly? Off site collection and disposal is proposed for long term leachate issues, why not here? Also flagged as an issue by the Provincial reviewers. ...
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Attachment NSECC's Technical Review of Round 1 IR Responses

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Bridget Tutty, NS Environment and Climate Change
  • Reference number: 50
  • Submitted: 2024-05-07 - 10:39 AM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • I:\Policy\EnvAsses\Templates\2021\ECC Memo Template.doc MEMORANDUM TO: Lachlan Maclean, Impact Assessment Agency of Canada FROM: Bridget Tutty, NS Environment and Climate Change DATE: December 10, 2021 SUBJECT: Boat Harbour Technical Review of Round 1 IR Good Afternoon Lauchie, Please find below provincial comments on the provided Round 1 Information Requirement responses. Boat Harbour Remediation Project – Federal Impact Assessment Provincial Technical Review December 2021 NS Environment and Climate Change Comment # Reviewer Department Information Request # EIS Section and Page (if applicable) Context and Rationale Specific Question/ Request for Information NSECC 1 SAS Hydrogeologist NSECC IAAC-53 p. 115 IR on - Drinking water for PLFN States the possibility for potable water exclusion zone around ASB. They have not defined background concentrations, just stating that Manganese is naturally elevated and not further evaluated. They state that potable exposure pathways are inoperable. My question still is in regard to assumptions that lead to the possibility that choosing risk management of groundwater, rather than more stringent criteria- based management, could leave it impacted in perpetuity. - Figure showing GW sampling results requested does not seem to have been provided ? NSECC 2 SAS Hydrogeologist NSECC IAAC-66 p. 93 IR on - HELP Model Point for clarification. The response states the “average porosity of 0.73, which is higher than the 0.67 default MSW porosity” - both of these seem extremely high for porosity of soil type materials. Are these correct? Why does the text go on to say – “the default MSW value of ...
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Attachment Final Position of Pictou Landing First Nation on Proposed Boat Harbour Remediation Project

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Pictou Landing First Nation
  • Reference number: 52
  • Submitted: 2024-04-23
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • Boat Harbour Remediation Project FINAL POSITION OF PICTOU LANDING FIRST NATION ON PROPOSED BOAT HARBOUR REMEDIATION PROJECT APRIL 23, 2024 Pictou Landing Fist Nation i Table of Contents 1 Executive Summary.................................................................................................................3 1.1 Introduction..................................................................................................................... 3 1.2 Aboriginal Title................................................................................................................4 1.3 Existing Landfill Infringes Aboriginal Rights..................................................................4 1.4 Lack of Remediation Agreement a Breach of s. 35 Rights.............................................. 4 1.5 Consultation Inadequate to Date.....................................................................................5 1.6 Proposed Accommodation/Compensation Inadequate....................................................5 1.7 Other Lands Available.....................................................................................................6 1.8 Boat Harbour Landfill Worst Option Based on Environmental Criteria........................ 6 1.9 Conclusion....................................................................................................................... 6 2 Introduction..............................................................................................................................8 3 Aboriginal Title..................................................................................................................... 11 3.1 ...
  • Attachment included
  • Boat Harbour Remediation Project Re IAAC Information Requirement Number 82 PLFN Response to NS Technical and Economic Feasibility Assessment of Alternative Containment Cell Location Site DOCUMENT BRIEF August 1, 2023 Pictou Landing Fist Nation 1 Table of Contents 1.1 PLFN Traditional Territory.............................................................................................................7 1.2 Discrimination and Deceit.............................................................................................................7 1.3 The Agreement............................................................................................................................. 8 1.4 Order-in-Council 1966-1669......................................................................................................... 8 1.5 Legal Obligations Ignored............................................................................................................. 9 1.6 Adverse Health Effects from Odors.............................................................................................. 9 1.7 Flooding Reserve Land.................................................................................................................. 9 1.8 1970 Wastewater Agreement.................................................................................................... 10 1.9 Lawsuit Against Canada.............................................................................................................. 10 1.10 Canada Approaches the Province............................................................................................... 10 1.11 Fish ...
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Attachment Comment posted in error / Commentaire publié par erreur

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Administrator on behalf of Impact Assessment Agency of Canada / Agence d'évaluation d'impact du Canada
  • Reference number: 41
  • Submitted: 2024-03-01 - 8:06 AM
  • Updated: 2024-03-05 - 3:29 PM
  • Rationale: Comment updated for administrative purposes
  • La version française suit Administrator Note: This comment was posted as an error on this assessment page (reference number 80164). Note de l'administrateur : ce commentaire a été publié par erreur sur cette page d'évaluation (numéo de référence 80164). Submitted by Administrator on behalf of the IAAC / AEIC

Attachment Comment posted in error / Commentaire publié par erreur

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Administrator on behalf of Impact Assessment Agency of Canada / Agence d'évaluation d'impact du Canada
  • Reference number: 42
  • Submitted: 2024-02-29 - 3:07 PM
  • Updated: 2024-03-05 - 3:21 PM
  • Rationale: Comment updated for administrative purposes
  • La version française suit Administrator Note: This comment was posted as an error on this assessment page (reference number 80164). Note de l'administrateur : ce commentaire a été publié par erreur sur cette page d'évaluation (numéo de référence 80164). Submitted by Administrator on behalf of the IAAC / AEIC

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Attachment FW: Boat Harbour IR Response Conformity and Technical Review

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Environment and Climate Change Canada / Government of Canada
  • Reference number: 45
  • Submitted: 2021-11-22 - 1:18 PM
  • Hi Lauchie, ECCC has completed its review of the proponent’s responses to IRs IAAC-14, 66 and 50.  We have undertaken a Conformity Review of IAAC 14 and our determination applies only to our portion of that IR (ECCC-06).  We understand conformity issues may be identified by other departments and we do not feel our comments should influence the overall determination however we are prepared to discuss if necessary.   IAAC-66 has been satisfactorily addressed in the response and Technical Review comments for IAAC-50 are provided below     IAAC-14 (ECCC-06) – The response conforms to ECCC-06 with the provision of the October 22, 2021 Memorandum from GHD to NS Lands (Response to IR IAAC-14 and IAAC-40).  As IAAC-14 also included information requests from other federal and provincial departments, ECCC understands the overall determination on conformity requires input from those other departments.  We are prepared to discuss any concerns identified by others with the Response.    IAAC-66 (ECCC-02) - ECCC provided general comments regarding the use of the HELP model and monitoring the actual performance of the disposal cell.  These have been satisfactorily addressed with the proponent’s response.   IAAC-50 (ECCC-14) - ECCC accepts the use of the 95 percent UCLM in calculating the Exposure Point Concentrations as part of the ecological risk assessment process in order to describe site conditions. While a reference to HC guidance is provided to support this statistical approach, ECCC also includes this option in the ...

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Attachment Boat Harbour Provincial Comments

  • Boat Harbour Remediation Project
  • Author: Administrator on behalf of Nova Scotia Environment
  • Reference number: 25
  • Submitted: 2021-02-10
  • Please find attached the provincial comments on the Boat Harbour EIS.  Personal information has been redacted in the comments.
  • Attachment included
  • Environment Comment Index Boat Harbour Remediation Project: December 2020 NS Government Number Source 1 Nova Scotia Environment (NSE) Environmental Health 2 NS Office of Aboriginal Affairs 3 NS Department of Business 4 NSE Water Resources Engineer - Sustainability and Applied Science Division 5 NSE Hydrogeologist - Sustainability and Applied Science Division 6 NSE Climate Change Unit 7 NSE Wetland Specialist 8 NSE Surface Water Quality Specialist - Sustainability and Applied Science Division 9 NS Department of Community Culture and Heritage 10 NSE Resource Management Unit 11 NS Department of Fisheries and Aquaculture 12 NS Department of Agriculture 13 NS Department of Municipal Affairs and Housing 14 NS Department of Lands and Forestry 15 NSE Inspection Compliance and Enforcement Division 16 NSE Air Quality Unit Memo To: Bridget Tutty, EA Officer, NSE Fr: Environmental Health, NSE Date: December 16, 2020 RE: Boat Harbour EIS Comments _____________________________________________________________________________ Bridget, The following comments are provided by Environmental Health, NSE, on the Boat Harbour EIS documents. General Comments • Information provided in the EIS is presented in a manner that challenges readers to navigate among a number of different documents to develop an understanding of the report’s findings. This creates a time-consuming and cumbersome review process for readers. The information contained in the EIS is primarily comprised of general statements, with no supporting evidence, data, or rationale. The data and the detail are primarily contained within supporting documentation. Providing greater overlap of information among the ...
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