Guidelines for Spill Contingency Planning

Guidelines for Spill Contingency Planning
Guidelines for Spill
Contingency Planning
Prepared by Water Resources Division Indian and Northern Affairs Canada Yellowknife, NT April 2007
Table of Contents
1.0
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2
2.0
Spill Contingency Plan Contents . . . . . . . . . . . . . . . . . . . .3
2.1
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3
2.2
Response Organization. . . . . . . . . . . . . . . . . . . . . . . . . . . .4
2.3
Action Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4
2.4
Resource Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5
2.5
Training Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5
3.0
Spill Contingency Planning and Risk Assessment . . . . . .6
4.0
General Contingency Planning . . . . . . . . . . . . . . . . . . . . .6
5.0
Related Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . .7
Guidelines for Spill
Contingency Planning
Prepared by Water Resources Division
Indian and Northern Affairs Canada
Yellowknife, NT
April 2007
APPENDIX A NT-NU SPILL REPORT . . . . . . . . . . . . . . . . . . . . . .8
APPENDIX B EXAMPLE SPILL CONTINGENCY PLAN . . . . . .10
APPENDIX B-1 Material Safety Data Sheets . . . . . . . . . . . . . .25
APPENDIX B-2 NT-NU SPILL REPORT . . . . . . . . . . . . . . . . . . .26
APPENDIX B-3 Immediately Reportable Spill Quantities . . . .28
Preface
Under such legislation as the Northwest Territories
Waters Act, the Territorial Lands Act, the Arctic
Waters Pollution Prevention Act, and the Mackenzie
Valley Resource Management Act, Indian and
Northern Affairs Canada (INAC) has responsibilities
with respect to the protection of land and water
in the Northwest Territories and Nunavut. Of
particular concern to INAC is the occurrence of
spills and subsequent response and follow-up. As
a result, INAC has been party to the Spills Working
Agreement since its inception in 1979.
These Guidelines update and expand on the
Northwest Territories Water Board’s 1987 Guidelines
for Contingency Planning and are intended
to complement other existing guidelines and
requirements for Spill Contingency Planning in the
North. It is recognized that site-specific activities
will vary and in certain instances may necessitate
deviations from these Guidelines. However, it is the
responsibility of the operator to ensure that they
meet all applicable regulatory requirements.
The political and legislative environment in the
North is in a period of unprecedented change. If
these Guidelines are to keep pace with the shifting
operational environment, and political and legislative
developments, they must be a living document or
they will lose their currency and effectiveness. To
this end, Indian and Northern Affairs Canada (INAC),
NWT Region, will update these Guidelines annually
by means of external and internal reviews. A new
updated version will be available in April of each
New Year.
1
1.0 Introduction
Spills of petroleum products and other hazardous
materials cannot be entirely prevented; however, the
impacts of spills can be minimized by establishing a
predetermined line of response and action plan. The
remote location of developments in the NWT and
the environmental sensitivity of the region underline
the necessity for good spill contingency planning.
Under the NWT Waters Act and Section 6 g (i) and
(ii) of the NWT Waters Regulations all operations
requesting licences for water use and waste disposal
must prepare comprehensive spill contingency
plans. These plans are required to establish a
state of readiness which will enable prompt and
effective response to possible spill events. The
plans submitted to Land and Water Boards must
demonstrate that the Licence Holder is capable of
responding and taking appropriate action in the
event of a spill.
The purpose of this document is to provide guidance
for the preparation of acceptable Spill Contingency
Plans. The recommended structure and content
of a spill contingency plan including response
organization, action plan, resource inventory, and
training is provided in Section 2.0. An example plan
illustrating these components is also provided in
Appendix A. The Land and Water Board issuing
licences for specific projects will review all submitted
plans and may require changes prior to final
approval.
Spill contingency planning and risk assessment for
larger projects involving more complex infrastructure
and activities are often required as a part of
licencing. Guidance on the approach for developing
such plans is provided in Section 3.0. In some cases,
general contingency plans are also required to
address all types of emergency situations. General
contingency plans follow the same basic format as
spill contingency plans, and are discussed in Section
4.0. Finally, related regulatory requirements are
discussed in Section 5.0.
2
Guidelines for Spill Contingency Planning
Wherever possible, these Guidelines were developed
to minimize inconsistencies with other regulators’
requirements. However, it is the developer’s
responsibility to comply with relevant regulators’
requirements.
2.0 Spill Contingency Plan Contents
A Spill Contingency Plan identifies lines of authority
and responsibility, establishes proper reporting and
communication procedures and describes an action
plan to be implemented in the event of a spill. All the
information necessary to effectively control and clean
up a spill should be included in the plan. A copy of
the plan should be kept on-site at all times and at the
company’s main office/headquarters.
The plan must reflect current state-of-the-art
containment and clean up procedures and methods.
The plan should be updated annually, at a minimum,
to reflect changes such as fuel storage locations, new
hazardous materials on site, new construction and
new personnel and contact information. As a result,
an easy-to-update format such as a binder where
pages may be easily removed is most appropriate.
Index tabs further increase the usability of the plan
by improving access to specific information. The
inclusion of an appendix identifying or summarizing
revisions or changes made in annual updates is
recommended to facilitate review and to aid in
conformity checks.
•
company environmental policy related
to regulatory compliance, environmental
protection, safety, spill response and clean-up
•
project description
•
site description, including the size, location,
topography, buildings and infrastructure
•
identification of potentially impacted
communities, traditional use areas (e.g. hunting
and trapping camps), other developments and
any environmentally sensitive areas (e.g. parks,
game preserves, resource harvesting areas,
fish spawning areas, waterfowl habitat, animal
migration routes, beaches, archaeological and
historic sites, public or private water supplies, etc.)
•
list of type and amount of hazardous materials
normally stored on-site, the storage capacity
and the type and number of storage containers.
The storage locations for each of these materials
should appear on the map of the site. Material
Safety Data Sheets (MSDS’s) for each hazardous
material should be included in an Appendix
•
existing preventive measures should be outlined,
such as secondary containment, fuel handling
procedures, etc.
•
relationship of the spill contingency plan to
territorial or local community contingency plans
•
details on how to obtain additional copies of
the plan
The plan should include:
•
an introduction
•
a response organization description
•
an action plan
•
a resource inventory
•
a description of training programs
Specific details on the contents of these sections are
described below.
2.1 Introduction and Project Details
The introduction should include the following
elements:
•
company name, site name, site location
•
effective date of plan, recently revised sections
and their revision dates
•
distribution list
•
purpose and scope of the plan
It is recommended that a process for response to
media and public enquiries should be discussed in
the plan, as guidance for their employees.
The plan should include a map (or maps) showing
the following:
•
buildings, roads, culverts, airstrips and other
infrastructure
•
all surface water bodies and direction of water
flow including catchment basins
•
storage locations of each hazardous material
3
•
probable spill locations and direction of flow on
land and in water
•
locations of all response equipment
a) protecting the safety of personnel at the
site and notification of all personnel of spill
occurrence
•
environmentally sensitive areas
b) shutting of ignition sources, if safe to do so
•
any approved disposal sites
c) activating the Spill Response Team
•
topography e.g. slope of land
•
any other important on or off-site features
d) identifying the spilled material
e) locating the likely source of the spill
The map should include any off-site areas that may
be affected by a spill, such as nearby communities,
wetlands, archaeological sites, protected areas, etc.
Two or more maps at different scales may be needed
to accommodate the on and off-site features.
f) stopping the spill at its source, if it is safe to
do so
g) take actions to contain and clean up the
spilled material
2.2 Response Organization
This section should identify response personnel (e.g.
On-scene Coordinator, Environmental/Safety Advisor,
Field Operations Supervisor, etc.), their duties, on
or off-site work locations and contact information,
including 24-hour telephone numbers for those
responsible for activating the plan. A flowchart
should be prepared to depict communication lines
and the response duties of each member of the
response team. For remote areas, a summary of
available communication equipment should be
provided. An example flowchart is presented in
Appendix B as part of the example Spill
Contingency Plan.
2.3 Action Plan
This section outlines the procedures that must
be taken in response to a spill. It should begin by
indicating the size of spill that could occur for each
material stored on-site, the potential source of the
spill and the potential impacts related to that spill.
A description of the worst probable case scenario
for the site should also be included, for example a
breach of the largest storage vessel and/or numerous
vessels at once.
The following procedures should be described in the
action plan:
1.
4
Procedures for initial action. These procedures
are for the first person arriving at the scene of a
spill and should cover:
Guidelines for Spill Contingency Planning
h) recording relevant information for reporting
purposes (e.g. approximate quantity, product
type, location, whether spill in still in progress,
odour, colour, weather)
2.
Spill reporting procedures. This part of the plan
describes the communication system put in
place by the plan holder to ensure an expedient
response to a spill. Reporting typically occurs to
parties inside and outside an organization. The
procedures should include:
a) telephone numbers of company officials,
off-site spill response contractors and
government officials who can provide
technical assistance (e.g. include in response
organization flowchart)
b) instructions for when and how to report
spills to the NWT 24-Hour Spill Report
Line (1-867-920-8130). This service is
used throughout the NWT to inform all
relevant government departments (federal,
territorial and/or Aboriginal) that a spill has
occurred. The information to be reported to
government is outlined on the Spill Report
Form in Appendix A. Depending on the site
location and industry, there may be specific
reporting regulations or protocols that apply.
To determine whether these apply to you,
contact the permitting agencies
c) if the public may be impacted by a spill,
include notification procedures to alert
the public
3.
Procedures for containing and cleaning up the
spill. This is one of the most important sections
of your spill contingency plan. The procedures
should identify the containment and clean
up strategies for various spill scenarios, with
detailed instructions for how to achieve the
strategies. Procedures will vary depending on
whether the spill is on land, water, snow, or on or
under ice. Procedures need to be proactive to
deal with the spill as quickly as possible. Provide
criteria and procedures for scenarios which might
require ignition and burning of oil or fuel spills.
4.
Procedures for transferring, storing, and
managing spill-related wastes. For example,
contaminated soil, vegetative matter, snow/
ice, spilled product, residual product (e.g.
after burning) and waste response materials
(e.g. sorbent materials). If materials are to be
disposed on or off-site, the plan should describe
the disposal method and approved location. Be
sure to identify any regulatory steps that must
be taken to acquire regulatory approval for the
waste management options outlined in the plan.
5.
Procedures for restoring affected areas,
providing Inspectors with status updates
and cleanup completion. Determining the
required level of final cleanup and restoration
is to be completed in consultation with, or to
the satisfaction of, the Indian and Northern
Affairs Canada (INAC) Inspector, Inuvialuit Land
Administration and/or National Energy Board
depending on location/operation. Site specific
studies may need to be performed to determine
the appropriate final clean up levels.
Where appropriate, the procedures outlined
above should discuss alternative actions to be
taken in the case of impeding environmental
conditions (e.g. poor visibility in blizzards, limited
daylight hours, extreme cold, difficult terrain,
etc.) For example, if spill response relies on
contractors accessing the site via a winter road,
response actions to be taken when roads are
closed should be included in the plan.
For smaller operations, it may be sufficient to
develop one set of procedures to address all
sizes of spills. At locations where spills may vary
from those with little or no impacts to very large
spills that could result in serious injury, fatalities
or cause significant damage to the environment,
it may be helpful to categorize spills by their
potential hazards. Spill response procedures can
then be developed for each category of spill. If a
spill occurs, the level of success of the response
effort should be examined and lessons learned
should be incorporated into an updated
spill plan.
2.4 Resource Inventory
This section should describe all resources available
for responding to spills. This includes personnel
and an inventory of and the location of clean up
materials, tools and equipment. The resources
should be described in two categories:
•
On-site Resources. These may include spill
kits, booms, sorbent materials, earth moving
equipment, etc. Be sure to include the location
and quantity of these resources on the map
provided in the Introduction and Project Details
section.
•
Off-site Resources. Detailed instructions
on how to obtain off-site resources must be
provided in the plan. This includes contact
numbers for deploying off-site resources and an
estimate of how long it takes to deploy them.
If spill response is primarily reliant on an offsite contractor, a written contract, mutual aid
agreement or memorandum of understanding
is strongly advised to ensure timely access to
cleanup equipment.
2.5 Training Program
Training employees to familiarize them with the
action plan and testing the plan’s elements through
mock spill exercises is critical to ensuring the success
of the plan. Training and training exercises can
prepare personnel, evaluate the plan holder’s ability
to respond to a spill and demonstrate to government
and to the public that there is adequate preparation
The action plan should address spills of all sizes
including the probable worst case scenario.
5
should a spill occur. Training should be performed
annually at a minimum, and under typical operating
conditions.
•
a training schedule, indicating when training has
occurred and future training dates
•
a commitment to notify INAC Inspectors and
other relevant regulators of planned upcoming
mock spill exercises so that regulators have the
option of observing the on-site exercise
•
a description of the record keeping procedures
that will document which employees have
received training and when
•
records of recent employee training
(e.g. personnel sign-off sheets)
This section should include:
•
an outline of the company’s training program,
including a description of training materials
and simulation exercises. The training program
should ensure that employees understand the
procedures in the action plan, the hazards of the
materials stored on-site, where to find response
equipment and how to operate it, and how to
obtain off-site resources. Copies of training
materials are not required in the plan but should
be referenced
3.0 Spill Contingency
Planning and Risk Assessment
Projects with a large and complex scope, usually
requiring a Type A licence, in some cases requiring
Type B licences, may warrant a risk-based method
of spill contingency planning. By initially developing
a pollution potential assessment, based on data
collected as part of the impact assessment phase,
areas of potential risk to spills are identified.
To consider the combination of the probability
and consequences of a spill incident, a technical
analysis of the data will need to be conducted.
This will facilitate risk-based decisions about
contingency planning. This involves a sensitivity
analysis to identify areas of the plan where a change
in assumptions renders a change in results. The
process of risk assessment will help reduce areas
of uncertainties in the spill contingency plan as
assumptions are tested.
The use of risk based spill contingency planning
should be discussed on a case-by-case basis with the
Land and/or Water Board issuing the licence for the
project.
4.0 General Contingency Planning
Land and Water Boards in the NWT issuing licences
occasionally require general contingency plans that
address all types of emergency situations, not just
spills. These may include fires, explosions, dam
breaches, equipment failures, wildlife encounters,
security threats and more. The basic approach
to preparing a general contingency plan is very
6
Guidelines for Spill Contingency Planning
similar to that used for spill contingency plans.
Specific instructions for spill contingency planning
provided above should be used to develop general
contingency plans, bearing in mind the additional
situations that must be addressed.
5.0 Related Requirements
•
Environment Canada’s Storage Tank Systems
for Petroleum Products and Allied Petroleum
Products Regulations
•
Environment Canada’s Guidelines for the
Preparation of Hazardous Material Spill
Contingency Plans, 1990
•
Environment Canada’s Environmental Emergency
(E2) requirements
National Energy Board Spill Reporting Protocol
for Upstream Oil and Gas Operations in the
Northwest Territories and Nunavut, 2003
•
Canadian Standards Association (CSA)
Emergency Preparedness and Response
document
Indian and Northern Affairs Canada Spill
Reporting Protocol for Upstream Oil and Gas
Operations, 2003
•
Indian and Northern Affairs Canada Reporting
of Minor Spills on Frozen Waterbodies Used as
Working Surfaces, 2005
•
Indian and Northern Affairs Canada Spill
Reporting Protocol for Mining Operations in the
Northwest Territories and Nunavut, 2004
There are several regulatory requirements,
regulations, guidelines that are directly or indirectly
linked to spill contingency planning in the NWT.
Following the above guidelines for spill contingency
planning does not absolve the licensee from
ensuring compliance with all applicable federal,
territorial and/or municipal legislation.
Related requirements are:
•
•
•
•
National Energy Board requirements such as
those in the Canada Oil and Gas Operations
Act and Regulations and the Onshore Pipeline
Regulations, 1999
Government of the Northwest Territories
Spill Contingency Planning and Reporting
Regulations
7
Appendix A: NT-NU Spill Report Form
8
Guidelines for Spill Contingency Planning
9
Appendix B
Example
Spill Contingency Plan
Table of Contents
1) Introduction and Project Details
i) Company name, site name, site location and
mailing address
ii) Effective date of spill contingency plans
iii) Last revisions to spill contingency plans
iv) Distribution list
v) Purpose and scope
vi) Company environmental policy
vii) Project description
viii) Site description
ix) List of hazardous materials on-site
– amount normally stored and storage capacity
– types and number of storage containers
– storage location
– MSDS’s for each material (in Appendices)
Spill Contingency Plan
Company Unknown
x) Existing preventative measures e.g. secondary
containment, fuel handling
Lake Invisible Location,
Northwest Territories
xi) Additional copies – how to obtain
Prepared by:
xii) Process for staff response to media and public
enquiries
John Fiction, EHS Specialist
2) Response Organization
Approved by:
Jane Leader, EHS Manager
10
Guidelines for Spill Contingency Planning
i) Flow chart of response organization
3) Action Plan
i) Potential spill sizes and sources for each
hazardous material on site
ii) Potential environmental impacts of spill
(include worst case scenario)
iii) Procedures (include alternative action in case
of impeding environmental conditions):
A. Procedures for initial actions
B. Spill reporting procedures
C. Procedures for containing and controlling
the spill e.g. on land, water, snow, ice, etc.
D. Procedures for transferring, storing, and
managing spill-related wastes
E. Procedures for restoring affected areas
4) Resource Inventory – describe all resources
available for responding to spills
Figures
Figure 1: Site location map (1:50,000 scale)
Figure 2: Sketch of site plan including buildings,
roads, water bodies, hazardous material locations,
spill kit locations and direction of flow
Figure 3: Flowchart of response organization
Tables
Table 1: List of hazardous materials stored on-site,
type and number of storage containers, the normal
and maximum storage quantities and storage
locations
Table 2: List of hazardous materials, potential
discharge events and volumes and direction of flow
Appendices
Appendix B-1: Material Safety Data Sheets (MSDS)
for hazardous materials stored on site
i) On-site resources e.g. spill kits, booms,
sorbent materials, earth moving equipment
Appendix B-2: NWT Spill Report Form (most recent
approved version)
ii) Off-site resources e.g. contact numbers for
deployment and time estimate
Appendix B-3: Immediately Reportable Spill
Quantities
5) Training Program
i) Outline of training program
ii) Training schedule and record keeping
11
1) Introduction and Project Details
Company Unknown has prepared this spill
contingency plan for drilling and exploration
activities being undertaken at their camp on the
west shore of Lake Invisible, Northwest Territories.
The plan demonstrates that Company Unknown has
appropriate response capabilities and measures in
place to effectively address potential spills at its Lake
Invisible site.
i)
Company name, location and
mailing address
Water Resources, Indian and Northern
Affairs Canada
A. Smith
Environmental Protection, Environment
Canada
I. Spell
Area Manager, Fisheries and Oceans
Canada
P. Brown
Environmental Protection Division,
Government of the NWT
J. Kraft
Chair, Land and Water Board
Company Unknown
v)
West shore of Lake Invisible, Northwest Territories
The purpose of this plan is to outline response
actions for potential spills of any size, including a
worst case scenario for the Company Unknown site
at Lake Invisible. The plan identifies key response
personnel and their roles and responsibilities in the
event of a spill, as well as the equipment and other
resources available to respond to a spill. It details
spill response procedures that will minimize potential
health and safety hazards, environmental damage,
and clean-up efforts. The plan has been prepared to
ensure quick access to all the information required in
responding to a spill.
Mailing address:
Box 1, Yellowknife, NT X1A 1A1
Phone: (867) 123-1111 Fax: (867) 123-2222
Email: [email protected]
Attention: A. Bonito, Environmental Health and
Safety Manager
ii) Effective date of spill contingency
plan: January 1, 2004
iii) Last revisions to spill contingency
plan: June 1, 2005 (Sections 2 and
3 were updated, and re-dated)
iv) Distribution list:
The plan and the most recent revisions have been
distributed to:
A. Bonito
12
S. Davie
Environmental Health and Safety
Manager, Company Unknown
Purpose and scope:
vi) Company environmental policy
Company Unknown is committed to the concept of
sustainable development and the protection of the
environment and human health. Company Unknown’s
environmental, health and safety policy is to:
•
protecting employees, the public and the
environment
•
fully comply with all applicable legislation,
regulations, and authorizations
•
work proactively with federal, territorial and
Aboriginal governments, other relevant
organizations, and the general public, on all
aspects of environmental protection
C. Donald
Project Engineer, Company Unknown
D. Edwards
Public Relations, Company Unknown
C. Cat
Camp Manager, Company Unknown
F. Grolsch
President, Company Unknown
H. Inez
Contractor – ABC CleanUP
Incorporated
•
anticipate future spill control requirements and
make provision for them
J. Doe
Inspector, Indian and Northern Affairs
Canada
•
keep employees, contractors, Inspectors, Land
and Water Boards, appropriate governments
Guidelines for Spill Contingency Planning
(Aboriginal, federal and territorial), and the
public informed of any changes at the site or
with project activities.
The plan is presented to all staff during their on-site
orientation sessions. All employees and contractors
are aware of the locations of the plan on the site at
Lake Invisible and in the head office in Yellowknife.
During the orientation meeting, training sessions
are scheduled to ensure employees have an
understanding of the steps to be undertaken in the
event of a spill. All employees and contractors are
shown where spill kits are stored, are aware of their
contents and are trained in using spill equipment
and responding to spills. The company is committed
to keeping personnel up to date on the latest
technologies and spill response methods.
vii) Project description:
The Lake Invisible location of Company Unknown is
used as a camp and staging area for local test drilling
as well as exploration activities in the surrounding
region. Permits and licences are in place for the
company’s drilling and exploration activities. The
camp operates year round, except freeze-up and
break-up, at varying levels of capacity.
viii) Site description:
The camp is located xx kilometres north of
Yellowknife on the west shore of Lake Invisible, at
xox’ N, xox’ W. It is a remote area, with no adjacent
communities or inhabitants. Thus the only people
immediately affected by a potential spill are
employees or contractors.
The site is located 50 kilometres north of a licenced
fishing lodge, 60 kilometres northwest of the XX
Protected Area and Yellowknife is the nearest
community. Figure 1 illustrates the Company
Unknown site on a 1:50,000 scale.
13
Figure 1: Site location map
A map of the site including the location of fuel
storage areas, offices, kitchen, sleeping shelters,
generators, helicopter landing pad, drilling site and
surrounding water bodies and direction of flow is
presented in Figure 2. All buildings and fuel storage
areas are at least 100 meters from the nearest water
body. All supplies arrive on-site via air (twin otter or
helicopter). The lake is used for landing float planes
in the summer and planes on skis in the winter on the
north shore of the camp.
14
Guidelines for Spill Contingency Planning
Figure 2: Sketch of site plan including
buildings, roads, water bodies,
hazardous material locations, spill kit
locations and direction of flow
15
ix) List of hazardous materials on-site
There are two fuel storage areas on site. The fuel
storage area near the helicopter pad is for storing
diesel, jet B, gasoline and propane. The second fuel
storage area near the drill site contains only diesel
and gasoline. Smaller amounts of other petroleum
products and oils/lubricants are stored on-site at
the Lake Invisible camp in a storage building. Table
1 presents a list of hazardous materials on-site, the
type of storage container, the average and maximum
quantities stored and their storage location.
Table 1: List of hazardous materials stored on-site, type of storage container,
the normal and maximum storage quantities, and storage locations
Material
Storage
Container
Normally
On-site
Maximum
On-site
Storage Location (see Figure 1)
and Uses
Diesel Fuel
200 L drums
3,000 L
(15 drums)
5,000 L
(25 drums)
Two fuel storage areas. Used to
heat communal buildings by oil
stoves and used for drill rig.
Jet B Fuel
200 L drums
2,000 L
(10 drums)
4,000 L
(20 drums)
Fuel storage area near helicopter
pad. Used to power helicopters
and twin otter aircraft.
Gasoline
200 L drums
1,000 L
(5 drums)
2,000 L
(10 drums)
Two fuel storage areas. Used for
ATVs and snow machines.
Propane
45kg cylinders
900 kg
(10cylinders)
1,800 kg
(20cylinders)
Fuel storage area near helicopter
pad. Used for kitchen stove and
fridge.
Waste oil is stored in empty 200 L drums in either of
the fuel storage areas, and shipped out by plane for
off-site disposal at an appropriate waste facility.
Other hazardous materials found on-site in very
small quantities are in a storage building and/or
the kitchen. These include lubricants/oil/grease for
maintenance of motorized equipment and general
cleaning products for kitchen/bathroom/office use.
16
Guidelines for Spill Contingency Planning
Motorized equipment on site includes two allterrain vehicles, a small loader, a drill rig, three snow
machines, a zodiac boat (for emergency response;
e.g. airplane accident) and three fuel transfer hoses
with pumps.
All buildings containing hazardous materials are over
100 m from any water body. Material Safety Data
Sheets for each hazardous material are included in
Appendix B-1.
x)
Existing preventative measures:
Planning for an emergency situation is imperative,
due to the nature of the materials stored on site as
well as the remoteness of the site. Along with the
preventative measures outlined below, adequate
training of staff and contractors is paramount.
All hazardous materials arrive by air as needed
throughout the year. They are unloaded by airplane
and helicopter pilots and Company Unknown staff
and carefully placed in the fuel storage areas.
Protective flame retardant clothing, steel toe
boots, hard hats and safety glasses are worn while
unloading the fuel drums.
The storage areas for diesel fuel, jet B fuel, gasoline
and propane are lined with impermeable liners and
bermed with 110% containment. Planking is used to
protect the liner from the fuel drums and cylinders.
In addition the fuel drums used for the oil stoves
heating common areas are in secondary containers
that are leak proof and are placed on a drip tray.
Spill kits are located wherever fuel is stored or used
(see Figure 2). See Section 4.i. for details on spill
kit contents. Portable drip trays and appropriately
sized fuel transfer hoses with pumps are used
when refuelling aircraft, ATVs, or other motorized
equipment, to avoid any leaks/drips onto the land.
The camp manager or designated fuel monitor
conducts daily visual inspections to check for leaks
or damage to the fuel storage containers, as well
as for stained or discoloured soils around the fuel
storage areas and adjacent motorized equipment.
For example, lids/caps are checked for tight seals.
A checklist is used to ensure no areas have been
missed and results of the inspections are recorded
in the company database. Regular maintenance
and oil checks of all motorized equipment are also
undertaken to avoid preventable leaks.
xi) Additional copies:
Several copies of the plan are kept on-site at all
times at the two fuel storage areas, in the office and
in the kitchen building. A copy is also held at the
company’s main office/headquarters in Yellowknife,
Northwest Territories and with the Land and Water
Board. Additional copies of the plan can be obtained
by contacting the company directly at the phone
number, fax or email presented in section 1i).
xii) Process for staff response to
media and public inquiries:
The company has established procedures for dealing
with media and public inquiries. All inquiries are
to be directed to the manager of public relations
at the headquarters office in Yellowknife. If the
manager is not available, there will be another
staff member available to act in this position. If a
reporter or member of the public arrives at the site
unexpectedly, the official in charge of responding
to their questions will be the camp manager or
acting camp manager. Prior to responding to their
questions, they should make every effort possible to
contact the head of public relations to discuss the
situation.
The camp manager should always keep the head
of public relations informed of any news or updates
of potential interest to the media or general public,
such that the company is prepared to deal with
inquiries any time.
If a spill has occurred and a NWT Spill Report needs
to be filled out (see Appendix B-2). This information
is available for the public to view upon request by
contacting the NWT Spill Line or by viewing the
GNWT Hazardous Materials Spills Database online at
http://www.e-engine.ca/eps_spillreport/.
Gray water is piped to a sump at least 100 m inland
of the kitchen, office and sleeping quarters. The
sump must maintain a 1 meter freeboard at all times.
The sump and pipe are inspected regularly for leaks
or overflow.
17
2) Response Organization
The flow chart depicted in Figure 3 identifies the
response organization and when applicable their
alternates, as well as the chain of command for
responding to a spill or release. The duties of
various response personnel are summarized, contact
information is provided including 24-hour phone
numbers for responsible people and the location of
communications equipment on site is discussed.
An immediately reportable spill is defined as a
release of a substance that is likely to be an imminent
environmental or human health hazard or meets or
exceeds the volumes outlined in Appendix
B-3. It must be reported to the NWT 24-Hour
Spill Report Line at 867-920-8130. Any spills less
than these quantities do not need to be reported
immediately to the spill reporting line. Rather,
these minor spills will be tracked and documented
by the company and submitted to the appropriate
authority either immediately upon request or at a
pre-determined reporting interval. If there is any
doubt that the quantity spilled exceeds reportable
levels, the spill will be reported to the NWT 24-Hour
Spill Report Line.
Emergency satellite phones are located in the office
and two fuel storage areas. In the event of a spill
involving danger to human life these phones will
be used to contact emergency response personnel
in Yellowknife. In addition, all employees and
contractors carry two-way radios for communication
with the camp manager and other staff on site.
Following reporting of the spill to the camp manager,
he/she will report spills to the NWT 24-Hour Spill
Line as necessary. The camp manager will also
inform the head office for tracking spills in company
databases and notify the head office in the event of
media inquiries. The 24-hour emergency head office
number is 867-123-3333.
18
Guidelines for Spill Contingency Planning
Figure 3: Flow chart of response
organization (details of each step
will be provided in the procedures
for initial actions under Section 3
Action Plan)
Spill or Release identified
by staff or contractors
Assess personal safety and safety of others
Identify product
Notify camp manager (via two way radio
which all employees carry)
Minor spill (under
guideline levels)
Major spill (over
guideline levels)
Stop the spill if
safely possible
Stop the spill if
safely possible
Ensure spill does not
enter water bodies
Ensure spill does not
enter water bodies
Keep track of small
spills in company
database and report
to the Inspector on
a set timeframe
Notify NWT 24-Hour
Spill Report Line at
867-920-8130
Notify head office
during regular
office hours
Notify head office
via 24-hour line at
867-123-3333
Keep track of
spills in company
database
Recover as
much fuel as
possible
3) Action Plan
i)
Potential spill sizes and sources for
each hazardous material on site
In Table 2, a list of potential discharge events,
with associated discharge volumes and directions
is presented for the primary hazardous materials
stored on site. The most likely discharge volume is
indicated and the spill clean up procedures will focus
on spills of this quantity. A worst case scenario is also
presented. Specific discharge rates are not indicated
for each fuel type as these would vary from a few
minutes to several hours, based on the source of leak
or puncture.
Table 2: List of hazardous materials, potential discharge events,
potential discharge volumes (worst case scenario in brackets) and
direction of potential discharge
Material
(sources)
Potential Discharge Event
Discharge
Volume
(worst case)
Diesel Fuel
(drill rig,
oil stoves)
1) Over pumping of fuel from drum into drill rig.
Likely under
200 L/1 drum
(max 11,000 L/
55 drums)
Toward stream from drill site or
fuel storage area near drill site.
Likely under
200 L/1 drum
(max 4,000 L/
20 drums)
In camp on flat ground, from
fuel storage area or helicopter
pad with potential underground
seepage to Lake Invisible and/
or stream.
2) Leaking from drill rig.
3) Minor leaking fuel drum in/outside fuel
storage area.
4) Large puncture, fast leaking drum in/outside
fuel storage area.
5) From drum connection to stoves in communal
buildings.
Direction of Potential
Discharge
In camp on flat ground, from
fuel storage area or communal
buildings with potential
underground seepage to Lake
Invisible and/or stream.
6) All drums punctured and leaking at once (very
unlikely).
Jet B Fuel
(twin otter,
helicopter)
1) Overfilling of aircraft.
2) Leak from drum or hose while filling aircraft.
3) Minor leaking fuel drum in/out side fuel
storage area.
4) Large puncture, fast leaking drum in/outside
fuel storage area.
In Lake Invisible while refuelling
twin otter.
5) All drums punctured and leaking at once (very
unlikely).
Gasoline
(ATVs, snow
machines)
1) Overfilling of ATVs or snow machines (small
spill).
2) Leak from drum or hose while filing ATVs or
snow machines.
3) Minor leaking fuel drum in/outside fuel
storage area.
3) Large puncture, fast leaking drum in/outside
fuel storage area.
Likely under
200 L/1 drum
(max 2,000 L/
10 drums)
In camp on flat ground, from
fuel storage area with potential
underground seepage to Lake
Invisible and /or stream.
Toward stream from fuel storage
area near drill site.
4) All drums punctured and leaking at once (very
unlikely)
19
Propane
1) Leak while connected to kitchen stove or
fridge.
(kitchen stove
and fridge)
2) Minor leaking cylinder in or outside fuel
storage area.
Likely under
45 kg/ 1 cylinder
(max 900 kg/
20 cylinders)
3) Large puncture, fast leaking drum in/outside
fuel storage area.
In camp on flat ground, from
fuel storage area or communal
buildings with potential
underground seepage to Lake
Invisible and/or stream.
4) All drums punctured and leaking at once
(very unlikely).
Waste oil stored in empty 200 L drums, could
potentially leak. The quantity of waste oil drums
would be quite limited as they would be shipped out
by plane as they are filled up. The risk of a spill from
a waste oil drum impacting the environment is very
low as waste oil is stored in a bermed site designated
for certain wastes.
ii)
Potential environmental impacts of
spill (include worst case scenario)
Overall for all hazardous materials discussed below,
impacts are lower during winter as snow is a natural
sorbent and ice forms a barrier limiting or eliminating
soil or water contamination, thus spills can be more
readily recovered when identified and reported.
Gasoline
Environmental impacts: Gasoline may be
harmful to wildlife and aquatic life. It is not
readily biodegradable and has the potential for
bioaccumulation in the environment. Gasoline is
quick to volatize. Runoff into water bodies must be
avoided.
Worst case scenario: All fuel drums were punctured
or open simultaneously and contents seeped into
surrounding soil and water bodies. This could cause
illness or death to aquatic life and indirectly affect
wildlife feeding from the land and water.
Diesel Fuel
Environmental impacts: Diesel may be harmful
to wildlife and aquatic life. It is not readily
biodegradable and has the potential for
20
Guidelines for Spill Contingency Planning
bioaccumulation in the environment. Diesel burns
slowly and thus risk to the environment is reduced
during recovery as burn can be more readily
contained compared with volatile fuels. Runoff into
water bodies must be avoided.
Worst case scenario: All fuel drums were punctured
or open simultaneously and contents seeped into
surrounding soil and water bodies. This could cause
illness or death to aquatic life and indirectly affect
wildlife feeding from the land and water.
Jet B Fuel
Environmental impacts: Jet B fuel may be
harmful to wildlife and aquatic life. It is not
readily biodegradable and has the potential for
bioaccumulation in the environment. Jet B fuel
volatizes relatively quickly. Runoff into water bodies
must be avoided.
Worst case scenario: All fuel drums were punctured
or open simultaneously and contents seeped into
surrounding soil and water bodies. This could cause
illness or death to aquatic life and indirectly affect
wildlife feeding from the land and water.
Propane
Environmental impacts: Propane may be harmful to
wildlife and the surrounding environment. It has the
potential to accumulate in the environment. Propane
is extremely volatile and is the most flammable
material stored on site, thus immediate impacts to
the surrounding environment are a concern.
Worst case scenario: All cylinders were punctured or
failed simultaneously and contents leaked into the
surrounding environment and ignited leading to an
explosion. This could cause serious environmental
impacts in the immediate surroundings. Safety
during emergency response to a propane spill is of
the utmost concern.
Waste Oil and Miscellaneous Oils/Grease
Environmental impacts: Waste oils may be
harmful to wildlife and aquatic life. It is not
readily biodegradable and has the potential for
bioaccumulation in the environment. Runoff into
water bodies must be avoided.
Worst case scenario: All storage drums were
punctured or open simultaneously and contents
seeped into surrounding soil and water bodies.
This could cause illness or death to aquatic life and
indirectly affect wildlife feeding from the land and
water.
iii) Procedures:
A. Procedures for initial actions
•
Ensure safety of all personnel.
•
Assess spill hazards and risks.
•
Remove all sources of ignition.
•
Stop the spill if safely possible e.g. shut of pump,
replace cap, tip drum upward, patch leaking
hole. Use the contents of the nearest spill kit to
aid in stopping the spill if it is safe to do so. Tyvek
suits and chemical master gloves are located in
the spill kit and should be worm immediately if
there is any risk of being in contact with fuel.
•
No matter what the volume is, notify camp
manager via two way radio (all employees carry
these, as well as on-site contractors if they are
not accompanied by an employee).
•
Contain the spill – use contents of spill kits to
place sorbent materials on the spill, or use shovel
to dig dike to contain spill. Methods will vary
depending on the nature of the spill. See Section
C for more details.
B. Spill reporting procedures
Report spill immediately to camp manager, who
will determine if spill is to be reported to the
NWT 24-Hour Spill Line at 867-920-8130.
Each spill kit, as well as the office and camp manager,
will have copies of the NWT Spill Report form to be
filled out (see Appendix B-2). Fill out and fax or email
the Spill Report to the staff of the NWT 24-Hour spill
line. Also fax or email the report to the head office.
NWT 24-Hour Spill Line
Phone: (867) 920-8130
NWT 24-Hour Spill Line
Fax: (867) 873-6924
NWT 24-Hour Spill Line
Email: [email protected]
Head office, Company Unknown
Phone: (867) 123-1111
Head office, Company Unknown
Fax: (867) 123-2222
Head office, 24 hr phone line
Phone: (867) 123-3333
C. Procedures for containing and controlling the
spill (e.g. on land, water, snow. etc.)
•
Initiate spill containment by first determining
what will be affected by the spill.
•
Assess speed and direction of spill and cause of
movement (water, wind and slope).
•
Determine best location for containing spill,
avoiding any water bodies.
•
Have a contingency plan ready in case spill
worsens beyond control or if the weather or
topography impedes containment.
21
Specific spill containment methods
for land, water, ice and snow are
outlined below.
1) Containment of Spills on Land
Spills on land include spills on rock, gravel, soil
and/or vegetation. It is important to note that soil
is a natural sorbent, thus spills on soil are generally
less serious then spills on water as contaminated
soil can be more easily recovered. Generally spills
on land occur during the late spring, summer or fall
when snow cover is at a minimum. It is important that
all measures be undertaken to avoid spills reaching
open water bodies.
Dykes
Dykes can be created using soil surrounding a
spill on land. These dykes are constructed around
the perimeter or down slope of the spilled fuel. A
dyke needs to be built up to a size that will ensure
containment of the maximum quantity of fuel that
may reach it. A plastic tarp can be placed on and at
the base of the dyke such that fuel can pool up and
subsequently be removed with sorbent materials or
by pump into barrels or bags. If the spill is migrating
very slowly a dyke may not be necessary and
sorbents can be used to soak up fuels before they
migrate away from the source of the spill.
Trenches
Trenches can be dug out to contain spills as long as
the top layer of soil is thawed. Shovels, pick axes or a
loader can be used depending on the size of trench
required. It is recommended that the trench be dug
to the bedrock or permafrost, which will then provide
containment layer for the spilled fuel. Fuel can then
be recovered using a pump or sorbent materials.
2) Containment of Spills on Water
Spills on water such as rivers, streams or lakes are the
most serious types of spills as they can negatively
impact water quality and aquatic life. All measures
need to be undertaken to contain spills on open
water.
Booms
Booms are commonly used to recover fuel floating
on the surface of lakes or slow moving streams. They
are released from the shore of a water body to create
22
Guidelines for Spill Contingency Planning
a circle around the spill. If the spill is away from the
shoreline a boat will need to be used to reach the
spill, then the boom can be set out. More then one
boom may be used at once. Booms may also be
used in streams and should be set out at an angle to
the current. Booms are designed to float and have
sorbent materials built into them to absorb fuels at
the edge of the boom. Fuel contained within the
circle of the boom will need to be recovered using
sorbent materials or pumps and placed into barrels
or bags for disposal.
Weirs
Weirs can be used to contain spills in streams and
to prevent further migration downstream. Plywood
or other materials found on site can be placed into
and across the width of the stream, such that water
can still flow under the weir. Spilled fuel will float on
the water surface and be contained at the foot of the
weir. It can then be removed using sorbents, booms
or pumps and placed into barrels or plastic bags.
Barriers
In some situations barriers made of netting or
fence material can be installed across a stream,
and sorbent materials placed at the base to absorb
spilled fuel. Sorbents will need to be replaced as
soon as they are saturated. Water will be allowed to
flow through. This is very similar to the weir option
discussed above.
Note that in some cases, it may be appropriate to
burn fuel or to let volatile fuels such as gasoline
evaporate after containment on the water surface.
This should only be undertaken in consultation with,
and after approval from the INAC or lead agency
Inspector.
3) Containment of Spills on Ice
Spills on ice are generally the easiest spills to contain
due to the predominantly impermeable nature of
the ice. For small spills, sorbent materials are used
to soak up spilled fuel. Remaining contaminated ice/
slush can be scraped and shovelled into a plastic
bag or barrel. However, all possible attempts should
be made to prevent spills from entering ice covered
waters as no easy method exists for containment and
recovery of spills if they seep under ice.
Dykes
Dykes can be used to contain fuel spills on ice. By
collecting surrounding snow, compacting it and
mounding it to form a dyke down slope of the spill,
a barrier is created thus helping to contain the spill.
If the quantity of spill is fairly large, a plastic tarp can
be placed over the dyke such that the spill pools at
the base of the dyke. The collected fuel can then
be pumped into barrels or collected with sorbent
materials.
Trenches
For significant spills on ice, trenches can be cut into
the ice surrounding and/or down slope of the spill
such that fuel is allowed to pool in the trench. It can
then be removed via pump into barrels, collected
with sorbent materials, or mixed with snow and
shovelled into barrels or bags.
Burning
Burning should only be considered if other
approaches are not feasible, and is only to be
undertaken with the permission of the INAC or lead
agency Inspector.
4) Containment of Spills on Snow
Snow is a natural sorbent, thus as with spills on soil,
spilled fuel can be more easily recovered. Generally,
small spills on snow can be easily cleaned up by
raking and shovelling the contaminated snow into
plastic bags or empty barrels, and storing these at an
approved location.
Dykes
Dykes can be used to contain fuel spills on snow.
By compacting snow down slope from the spill,
and mounding it to form a dyke, a barrier or berm
is created thus helping to contain the spill. If the
quantity of spill is fairly large, a plastic tarp can be
placed over the dyke such that the spill pools at the
base of the dyke. The collected fuel/snow mixture
can then be shovelled into barrels or bags, or
collected with sorbent materials.
5) Worst Case Scenarios
Another worst case scenario would be an excessive
spill on water may be difficult to contain with the
booms present at the site. In this case, an emergency
response mobile unit would have to be called in to
deal with the spill using appropriate equipment.
D. Procedures for transferring, storing, and
managing spill related wastes
In most cases, spill cleanups are initiated at the
far end of the spill and contained moving toward
the centre of the spill. Sorbent socks and pads are
generally used for small spill clean up. A pump with
attached fuel transfer hose can suction spills from
leaking containers or large accumulations on land
or ice, and direct these larger quantities into empty
drums. Hand tools such as cans, shovels, and rakes
are also very effective for small spills or hard to reach
areas. Heavy equipment can be used if deemed
necessary, and given space and time constraints.
Used sorbent materials are to be placed in plastic
bags for future disposal. All materials mentioned
in this section are available in the spill kits located
at Camp Unknown. Following clean up, any tools
or equipment used will be properly washed and
decontaminated, or replaced if this is not possible.
For most of the containment procedures outlined in
Section C, spilled petroleum products and materials
used for containment will be placed into empty
waste oil containers and sealed for proper disposal
at an approved disposal facility.
E. Procedures for restoring affected areas
Once a spill of reportable size has been contained,
Company Unknown will consult with the INAC
or lead agency Inspector assigned to the file to
determine the level of cleanup required. The
Inspector may require a site specific study to ensure
appropriate clean up levels are met. Criteria that may
be considered include natural biodegradation of oil,
replacement of soil and revegetation.
Dealing with spilled fuel which exceeds the
freeboard of a dyke or barrier would present a
possible worst case scenario for the Company
Unknown site. To contain the overflow, a trench or
collection pit would have to be created downstream
of the spill to contain the overflow.
23
4) Resource Inventory
i)
On-site resources
ii)
Off-site resources
Spill kits are located throughout the sites at the
locations indicated in Figure 2. The contents are
described below. In addition, earth moving and other
equipment located at Camp Unknown is also listed
below.
All the contacts listed below could reach the site
in 2 hours at a minimum. However, realistically
government officials would not be able to reach the
site until the next business day, depending on the
severity of the spill.
Contents of Spill Kits
Company Unknown, 24-hour emergency line
(867) 123-3333
4 tyvek splash suits
4 pairs of chemical master gloves
NWT 24-Hour spill line
(867) 920-8130
10 large bags with ties for temporary use
2 oil only booms (5” x 10’)
Indian and Northern Affairs Canada Inspector
(867) 669-2761
50 oil only mats (16” x 20”)
5 sorbent socks
Environment Canada (Emergency) Yellowknife
(867) 669-4725
10 sorbent pads
2 large tarps
GNWT Environmental Protection Division
(867) 873-7654
1 roll duct tape
1 utility knife
GNWT Environmental Health Office
(867) 669-8979
1 field notebook and pencil
1 rake
RCMP (Yellowknife)
(867) 669-1111
1 pick axe
3 aluminium scoop shovels
Medivac (Yellowknife)
(867) 669-4115
1 instruction binder
Earth moving and other equipment
1 small loader
2 all-terrain vehicles
3 snow machines
1 zodiac boat
1 chain saw
3 fuel transfer hoses with pumps
tool kit including hack saw, hammer,
screwdrivers, etc.
24
Guidelines for Spill Contingency Planning
Great Slave Helicopters (Yellowknife)
(867) 873-2081
Air Tindi (Yellowknife)
(867) 669-8218 or 669-8200
Arctic Sunwest (Yellowknife)
(867) 873-4464
As planning for an emergency situation is imperative
due to the materials stored on-site and the
remoteness of the site, an employee and contractor
training program has been prepared. It is outlined
below.
5) Training Program
i)
Outline of training program
The employee and contractor training program was
developed by the manager of environmental health
and safety, and has been disseminated by the camp
manager. The following are key steps in the program:
•
all individuals entering the site are required to
participate in an orientation session
•
during this session, all locations of the spill plan
and spill kits are provided on a map in hard copy
•
an overview of the plan is provided by the camp
manager leading the orientation session
•
specific training sessions, including mock spill
exercises, are scheduled for individuals directly
involved in handling hazardous materials to
ensure they know all steps to be undertaken in
handling these materials, as well as the steps
involved in the event of a spill, including the
proper use of spill kits
•
all employees and contractors are required
to have their basic first aid training, as well as
WHMIS training, before working on the site
•
supervisors are required to have advanced
level first aid training, as well as transport of
dangerous goods training
ii)
Training schedule and
recordkeeping
A spreadsheet is kept by the camp manager and
head office indicating the training undertaken, and
expire dates of specific training e.g. first aid. It is
regularly updated.
•
diesel
•
jet B
•
gasoline
•
propane
Appendix B-1:
Material Safety Data Sheets (MSDS) for hazardous materials stored on site
The formats of Material Safety Data Sheets vary
greatly. Examples can be found on the internet and
from Spill Contingency Plans in place for various
Water Licences in the NWT (see Land and/or Water
Board public registries).
25
Appendix B-2:
NT-NU Spill Report Form
26
Guidelines for Spill Contingency Planning
27
Appendix B-3:
Immediately Reportable Spill Quantities
TDG
Class
Substance
for NWT 24 Hour Spill Line
Immediately Reportable Quantities
1
2.3
2.4
6.2
7
None
Explosives
Compressed gas (toxic)
Compressed gas (corrosive)
Infectious substances
Radioactive
Unknown substance
Any amount
2.1
2.2
Compressed gas (flammable)
Compressed gas (non-corrosive,
non-flammable)
Any amount of gas from containers
with a capacity greater than 100 L
3.1
3.2
3.3
Flammable liquids
> 100 L
4.1
4.2
4.3
Flammable solids
Spontaneously combustible solids
Water reactant
> 25 kg
5.1
9.1
Oxidizing substances
Miscellaneous products or substances
excluding PCB mixtures
> 50 L or 50 kg
5.2
9.2
Organic peroxides
Environmentally hazardous
> 1 L or 1 kg
6.1
8
9.3
Poisonous substances
Corrosive substances
Dangerous wastes
> 5 L or 5 kg
9.1
PCB mixtures of 5 or more ppm
> 0.5 L or 0.5 kg
None
Other contaminants (e.g. crude oil,
drilling fluid, produced water, waste or
spent chemicals, used or waste oil,
vehicle fluids, waste water, etc.)
> 100 L or 100 kg
None
Sour natural gas (i.e. contains H2S)
Sweet natural gas
Uncontrolled release or sustained flow
of 10 minutes or more
In addition, all releases of harmful substances, regardless of quantity, are to be reported to the NWT
spill line if the release is near or into a water body, is near or into a designated sensitive environment or
sensitive wildlife habitat, poses imminent threat to human health or safety, poses imminent threat to a
listed species at risk or its critical habitat, or is uncontrollable.
28
Guidelines for Spill Contingency Planning
Contact Information:
Water Resources Division
Indian and Northern Affairs Canada
P.O. Box 1500
3rd Floor, 4914 - 50th Street
Yellowknife, NT
X1A 2R3
(867) 669-2654 (tel)
(867) 669-2716 (fax)
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