From: KALEN.KE@forces.gc.ca Sent: Friday, March 30, 2007 3:06 PM To: keima@inac-ainc.gc.ca Cc: Wade.Romanko@EC.GC.CA; REno@GOV.NU.CA; KusugakP@inac-ainc.gc.ca; McLeanC@inac-ainc.gc.ca; RobertsonKL.Region13.NU@inac-ainc.gc.ca; licensing@nunavutwaterboard.org; McCarthy.CGA@forces.gc.ca; RHEAUME.J@forces.gc.ca; BEATON.MAR@forces.gc.ca; CAMERON.AD@forces.gc.ca; scott.charland@nasittuq.com; Craig.Broome@EC.GC.CA; James.Noble@EC.GC.CA; reno@GOV.NU.CA Subject: Response to Inspector's Direction - BAF-3 Fuel Spill Response Importance: High Attachments: Final Report_2007-03-28.doc Good afternoon, Mr. Keim, Please find herein the comprehensive clarifications requested in your letter, 22 March, 2007, and submitted in compliance with the Inspector's Direction, 19 March, 2007. #1. Paragraph 3, item 2.0, page 2. - "Additionally, a water release of approximately 40,000 litres occurred after the fuel release". More detailed information item on this matter is required. In a typical year, as part of normal site operations, there is an annual summer transfer of water from the raw water source to one of the two raw water storage tanks on site, housed in a separate building. This water is used for both domestic use and for sprinkler system throughout selected portions of the site. In the summer of 2006, the pump used for this annual transfer became unserviceable, and the complete transfer did not take place. At that time, Nasittuq deemed that the water in the tank was sufficient to guarantee fire protection, and to accommodate known (minimal) operation and maintenance requirements at the site though to the summer of 2007. As previously reported, on 12 January, Nasittuq staff discovered the spill. One of the key considerations in supporting immediate and on-going clean-up effort was to ensure an adequate supply of water to support the crew, while always guaranteeing enough for the sprinkler system. As such, as soon as the road had been opened, Nasittuq began to haul water by truck. To keep track of usage, the water tank was continuously dipped to monitor the quantity. On 23 January, the dip showed a sudden unexpected drop, which could only be the result of a leak. In short order, a break was found in a 1½ inch line, approximately 6 inches above an elbow leading into the Technical Services Module (TSM). All material and labour was on site to effect the repair, and this was completed the same day. The reason for the break in the line is unclear. With the break in the fuel line and the water line only 9 days apart, it would seem that there is some connection, however, Nasittuq can find no obvious relations. Their civil engineer has reviewed the drawings for the building, and has confirmed that the pilings are sitting on native rock, each with a 3 metre rock anchor. It is felt that, although there may have been some settling of the building shortly after construction (completed in the mid-1980's), it is unlikely that the building has experienced any recent shifting. If some settling did occur in the past, the fuel line may have been under strain for this period of time, and finally failed. However, while the steel fuel line is original construction, and may have been stressed as noted above, the water lines were replaced in 2002, and would not have been subject to similar stresses. To cover all possibilities, Nasittuq has determined that there is some moderate geological activity in the Baffin Island area. However, the Natural Resources Canada web site shows no earth tremors in January 2007. With respect to the impact of this water on the fuel spill, it does appear that this release of water did cause the fuel to migrate further than it normally would have. However, it also appears to have encapsulated it, allowing for the collection scheduled to start 30 March. #2. Item # 5.3.1, page 4. - " A total of 21 test pits (TP-1 to TP-21) were excavated in the snow and ice by hand". Have any other test pits been dug. Additionally, as no results from any of the test pits were submitted, could the results from all tests pits be submitted as an addendum to this report? Finally, were test pits dug beyond Pits numbered 16 through 19? It is our understanding from the diagram submitted that these pits may have noted the presence of contamination. If so, were pits dug beyond these locations to determine if contamination extended beyond them ? See attachment, revised JW report, Section 5.3. #3. Item 7.0 Conclusions (3). - "Based on estimated volumes of impacted snow and ice, a preliminary estimation of impacted water that may require treatment is in the order of 2,950,758 litres". Given the test results of "BAF-3 Filter Water and 96 Hour Bioassay", please supply us with specific information on what "treatment" options are being considered for this contaminated water, and what schedule of testing and analysis will be implemented prior to any discharge of this water back into the environment. As you are aware, the bioassay conducted by Nasittuq failed. Nasittuq anticipates the installation of a simple robust treatment system, consisting of an oil/water separator with coalescing media, an aerator, and finally through a series of carbon filters. In the meantime, Nasittuq continues testing of the water. They feel it is essential to identify the root cause for the failure of the bioassay to ensure the filtration system removes this contamination. Further samples have been taken, and are expected to be at the lab the week of 02 April. This testing will ensure an appropriate design of the filtration system. In the meantime, water recovered during the clean-up will be stored in one of the site's 1M litre storage tanks. See attachment, revised JW report, Section 8.1.4. Additionally, and with respect to scheduling of bi-monthly inspections of the BAF-3 site, NWSO proposes the first visit will take place on Thursday, 11 April, 2007, in compliance with the Inspector's Direction. Please indicate your availability, for travel to the site, at this time. Respectfully, K.E. (Kim) Kalen Environmental Officer - North Warning System R&CS 3-4-3 (613) 998-8482 FAX: (613) 998-9261 -----Original Message----- From: Andrew Keim [mailto:keima@inac-ainc.gc.ca] Sent: Thursday, 22 March, 2007 11:07 To: Kalen KE@ADM(Mat) DAEPM(R&CS)@Ottawa-Hull; nippernips@sympatico.ca Cc: wade Romanko; REno@GOV.NU.CA; Peter Kusugak; Carl McLean; Kevin Robertson; Phyllis Beaulieu Subject: IQALUIT-#133635-v1-Response_to_Baf_3_Clean_up_plan_.DOC Mr. Kalen, Please find attached a letter acknowledging receipt of the required clean up plan. Thank you in advance for your attention in this matter. Andrew Keim Water Resources Officer INAC Nunavut Regional Office P.O. Box 2200 Iqaluit, Nunavut X0A 0H0 Email: KeimA@inac-ainc.gc.ca Phone: (867) 975-4289 Fax: (867) 979-6445