Technical Review of Site C Water Licence

December 31, 2015 15-22 _

Treaty 8 Tribal Association 10233 100 Avenue Fort St. John, BC, V1J 1Y8

(Via email) Attention: Jason Lee Re:

Technical Review of the Application for Water Permit of Site C Clean Energy Project – BC Phase 1: Technical review of existing data and methodologies employed by BC Hydro

GW Solutions Inc. (GW Solutions) is pleased to present the following report summarizing the background information provided in the Site C Clean Energy Project (Site C) water permit application and the results of our technical review of existing data and methodologies employed by BC Hydro, specific to the characterisation of the groundwater regime.

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The amount and distribution of groundwater level and quality data - especially along the south bank and up the tributaries of the Peace River - is insufficient to adequately characterize the hydrogeology of the 83 km long study area and to evaluate the effects of the filling of the reservoir on the groundwater regime.

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The groundwater regime is not sufficiently described, especially near the dam site; maps describing the piezometric contours pre and post construction for each hydrogeological unit are needed, especially near the dam site.

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Post-construction downstream effects on groundwater near the dam has not been assessed, in particular the larger lateral groundwater flows and pressure expected to be generated by the high hydraulic gradients resulting from the build-up of the reservoir.

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The cumulative effect of Oil and Gas well fracking and reservoir filling on the long-term modification of the regional groundwater regime has not been assessed.

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The risks on dam stability resulting from fracking induced seismicity should be reassessed.

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A more thorough assessment on the impact on groundwater quality should be completed.

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GW Solutions Inc. 201 – 5180 Dublin Way, Nanaimo, BC, V9T 0H2 Tel. (250) 756-4538 gw@gwsolutions.ca

T8TA–Site C water permit review

December 31, 2015

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BC Hydro has recently started the site preparation for the construction of the Site C dam within the Treaty 8 Tribal Association (T8TA) territory. T8TA has concerns about the negative impacts on groundwater resulting from this project. GW Solutions has been requested in Phase 1 to provide a technical review of the hydrogeological aspects (data and methodology) of the water permit application.

Background Information and Site Characteristics BC Hydro Site C dam would be a third dam located on the Peace River in northeast BC, about 7 km southwest of the city of Fort St John.

It is located downstream of the WAC Bennett dam and Peace Canyon dam.

In August 2011, the environmental assessment process started. In July 2013 the Environmental Impact Statement (EIS) was completed and approved by the Canadian Environmental Assessment Agency (CEAA) and the BC Environmental Assessment Office (BCEAO) in August 2013. As part of the Environmental Assessment process, the EIS reported on the potential environmental, economic, social, health and heritage effects and proposed mitigation measures. Then, a Joint Review Panel completed a review of the EIS in May 2014.

In October 2014, the Site C received environmental approval from the federal and provincial governments, and the EAC (Environmental Assessment Certificate) was issued. The Site C project received approval from the provincial government to proceed to preliminary construction (site preparation) in December 2014.

At least 8 streams are flowing directly to the Peace River future reservoir area, which are from downstream to upstream: The Moberly River, Tea Creek, Wilder Creek, Cache Creek, Halfway River, Farrell Creek, Dry Creek, and Lynx Creek.

The artificial impoundment of water behind the dam will create a reservoir at an elevation ranging from 460.0 to 461.8 m, which is approximately 50 m higher than the current Peace River elevation. The dam would create a 83 km long reservoir extending to the Peace Canyon dam.

Scope As part of GW Solutions’ technical review, we have focused on the following tasks: 1. Task 1 – Review of BC Hydro Nov 18th, 2015 response 2. Task 2 – Brief review of technical requirements on hydrogeology for large complex earth dam structures in the world 3. Task 3 – Review of piezometric data and interpretations in the close proximity of Site C dam, in zones where uncontrolled groundwater flow could be induced, and where the highest groundwater pressure and hydraulic gradients could be created __________________________________________________________________________________________________________________________________________________________________________________________________

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4. Task 4 – Review of geotechnical data, stability cross-sections and their interpretation especially in the close proximity of the Site C dam (including downstream) in order to estimate whether the groundwater regime has been adequately integrated in the geotechnical analysis 5. Task 5 – Mapping of the lengths of sections that have undergone fracking (fracking footprint) and that may act as potential pathways for groundwater, around Site C, if any 6. Task 6 – Review of the groundwater quality assessment and monitoring program.

Information Sources During the review, GW Solutions has mainly relied on the following documents, available on the Site C website and the BC EAO website: • • • • • • • • • • • •

Volume 1 of the EIS - Executive Summary, Introduction, Project Planning and Description; Volume 2 of the EIS - Assessment Methodology and Environmental Effects Assessment- Section 10 and 11; Volume 2, Appendix F of the EIS - Groundwater Regime Technical Report, dated December 2012; Volume 2, Appendix B of the EIS - Geology, Terrain and Soil Reports, dated November 2012; Volume 3 of the EIS – Section 20: Agriculture; Volume 4 of the EIS – Section 30: Community Infrastructure and Services; Volume 5 of the EIS – Section 35: Summary of the Environmental Management Plans; Volume 5 of the EIS – Section 36: Compliance Report, dated June 5, 2015; Engineering report: Review of upstream axis, dated May 2006; CEAA decision statement, dated October 2014; Construction Environmental Management Plan, dated May 19, 2015; and Several Field Studies Summary and information sheets from BC Hydro website from 2009 to November 2015.

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Task 1 - Review of BC Hydro Nov 18th, 2015 response In this section, the response from BC Hydro’s consultant to GW Solutions preliminary comments on groundwater dated December 8, 2015 is presented in underlined text. GW Solutions response follows.

1. “BGC disagrees with the characterization that the model used in the EIS was not “high resolution” and says the EIS studies were sufficient to model groundwater flow.” And “In BGC’s view, a 3D model as recommended by GWS would result in lower resolution at the cross-section locations, and would not add to the analysis.”

GW Solutions agrees that 2D cross-sections is suitable for the upstream part of the study area that will be less affected by groundwater level rise, but still believes that a more detailed groundwater flow model is required near the dam site. Contours illustrating current and future piezometric conditions in the different hydrostratigraphic units should be drawn on figures including areas both several hundred meters upstream and downstream of the dam. GW Solutions believes these figures are critical for assessing the consequences of the creation of an important pressure difference between the upstream and downstream zones of the dam on slopes and dam stability.

2. Volume 2, Appendix F, pages 12-15, describe the predicted effects of reservoir formation on hydraulic gradients, groundwater flow directions, and the physical aspects of groundwater and surface water interaction.

In its Groundwater technical report, BC Hydro’s description of the effects of reservoir formation on hydraulic gradients and groundwater flow directions is very general and not detailed enough. Again, GW Solutions believes that BC Hydro’s study does not provide sufficient details on groundwater characterization close to the dam site. Figure 1 shows the cross-sections location close to the dam site (copied from the appendix of the Geology, Terrain and Soil Reports - Part 2). A 3D schematic (or at least a detailed 2D map) of the piezometric lines in the different hydrostratigraphic units, flow directions and hydraulic gradients under current and future conditions near the dam site should be presented in the main document of the groundwater report.

The lack of a piezometric contour map has already been mentioned in the Working Group and Public Comments Technical Memo (page 10; dated June 2013).

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Figure 1. Zoom on groundwater cross-sections location near the dam site 3. Volume 2 Appendix B, includes a detailed evaluation of the geology of the Project area, including interpreted geological crosssections along the north and south banks of the Peace River at approximately 1 km intervals and 3D models (geological fence diagrams) showing interpreted geology between the cross-sections (drawings 5 to 10). Volume 2 Appendix F, at pages 11-12 provides a summary of the geology and links the geology to the hydrogeology, including a description of the hydraulic connections between the different hydrogeological units The description of the hydraulic connections between the different hydrostratigraphic units is too general and needs to be refined near the dam site (see task 3).

4. The conditions in the EAC require BC Hydro to implement measures to address contaminated sites and to monitor potential effects on groundwater GW Solutions understands that BC Hydro has to implement a Groundwater Protection Plan and Contaminated Sites Management Plan.

Such plans should be produced (if not already available) and made available to the public.

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Task 2 - Brief review of technical requirements on hydrogeology for large complex earth dam structures in the world The following recommendations are listed in the “General Design and Construction Considerations for Earth and Rock-Fill Dams (2004)” of the US Army Corps of Engineers: “the Geological and subsurface investigations at the sites of structures should cover variations in piezometric levels in groundwater at different depths.” […]

“The magnitude of the foundation exploration program is governed principally by the complexity of the foundation problem and the size of the project.” “ The foundation is the valley floor and terraces on which the embankment and appurtenant structures rest. Comprehensive field investigations and/or laboratory testing are required for […] shales, clay seams [...].”

“Subsurface investigation for foundations should develop […] piezometric levels of groundwater in various strata and their variation with time including artesian pressures in rock or soil.”

“The safety of a dam is affected by hydrostatic pressures that develop in the embankment, foundation, and abutments. Periodic piezometer observations furnish data on pore water pressures within the embankment, foundation, and abutments, which indicate the characteristics of seepage conditions, effectiveness of seepage cutoff, and the performance of the drainage system. The installation should consist of several groups of piezometers placed in vertical planes perpendicular to the axis of the dam so that pore water pressures and/or seepage pressures may be accurately determined for several cross sections. At each cross section that piezometers are placed, some should extend into the foundation and abutments and be located at intervals between the upstream toe and the downstream toe, as well as being placed at selected depths in the embankment. In addition to the groups of piezometers at selected cross sections, occasional piezometers at intermediate stations will provide a check on the uniformity of conditions between sections.

Each piezometer should be placed with its tip in pervious material. If pervious material is not present in the natural deposit of foundation material, or if the tip is in an impervious zone of the embankment, a pocket of pervious material should be provided. Two of the more important items in piezometer installation are the provision of a proper seal above the screen tip and the water tightness of the joints and connections of the riser pipe or leads.”

A plot of groundwater levels measured in piezometer versus time and reservoir level during the filling should be done to verify if behavior is as predicted.

Seepage quantities should be monitored (e.g. relief well discharge) for underseepage and uplift pressure downstream the dam site.

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In Millenium Challenge Corporation (MCC) - USA:  

Demonstration that sufficient and reliable […] data and studies have been provided in preliminary or feasibility reports […] on ground water pattern and its interaction with surface water.

Review and assess all hydrogeological data and analysis and provide recommendations for complementary investigations, including geophysical surveys, drilling etc., needed to establish ground water patterns and/or ground water modeling and to identify potential leakage and seepage problems associated with the dam site.

In the BC Guidelines for Groundwater Modelling to Assess Impacts of Proposed Natural Resource Development Activities 1, it is written that the groundwater characterization and monitoring data should include: 1. Coverage of all areas of potential concern; 2. Coverage of all hydrogeological units of interest; 3. Good spatial distribution (not all clustered in one small area of the domain); 4. Coverage of the entire depth range of interest; 5. Transient aquifer hydrogeological unit properties (storage) and transient monitoring (if problem is transient).

Even if the guideline is mostly for mining and groundwater extraction projects, it also includes general guiding principles for groundwater modelling that would apply for large dams. In its groundwater study, BC Hydro does not address points 1 to 3, because it does not cover the area near the dam with a high enough resolution. The locations where data is available seem to be far upstream of the reservoir, water levels are not recorded for each hydrogeological units and are mostly on the north bank (see more in task 3).

The review of hydrogeological information related to the stability of the dam and its foundations is not part of GW Solutions scope of work. However, GW Solutions has noticed that the groundwater regime near the dam pre and post-construction seems to have been poorly described.

1

B.C. Ministry of Environment, 2012. Guidelines for Groundwater Modelling to Assess Impacts of Proposed Natural Resource Development Activities, April 2012.

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Task 3 - Review of piezometric data and interpretations in the close proximity of Site C dam, in zones where uncontrolled groundwater flow could be induced, and where the highest groundwater pressure and hydraulic gradients could be created; GW Solutions understands that: •

groundwater elevations from historical geotechnical data have been reviewed. However, it is not clear how many and where these data are (assumed the ones being on Figure 2) and how they were integrated in the groundwater characterization.

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According to Vol 2 Appendix F p6 – Groundwater Monitoring “Level loggers were installed in ten piezometers in the south bank drill holes in late October 2011. Level loggers were installed in the remaining reservoir slope drill holes on the north bank, including the drill holes completed as part of the Highway 29 re-alignment investigations, in March 2012. Groundwater levels were monitored in 39 groundwater monitoring wells for twelve months from June 2011 to May 2012”. This is actually less than one year because the time period between November and March is missing according to the groundwater level plots found in Volume 2 – Appendix B2 (it is the only “continuous” monitoring that GW Solutions could find in the documents for 24 wells/44 piezometers). The final total number and location of groundwater level data is not clear – the 24 wells level plots being the only place where GW Solutions could find groundwater level records as well as with the water quality results for wells that have been sampled (the same wells). GW Solutions understands that groundwater level from 12 drill holes (20 piezometers) are taken from the HWY 29 geotechnical study (Figure 3) but does not see records of these levels and related interpretation in the reports. Most of the piezometers installed along the south bank are dry (according to Volume 2 – Appendix B2) and therefore do not allow a proper characterization of the groundwater regime.

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In Volume 2 section11.2.2.4 there is a description of water levels measured at the dam site in the different bedding planes and on the south bank. However, there is no map or cross-section that clearly show the piezometers location, the water table in the different units and no explanation on how this affects the dam structure and what will be the consequences of the reservoir filling on the groundwater pressures. Indeed, there are historical examples where dams have failed because of the fractures being pressurized too fast (e.g., Malpasset dam, France). GW Solutions understands that BC Hydro will monitor the change in pore pressure in piezometers during reservoir filling. However, GW Solutions has not seen a figure illustrating where such monitoring locations are proposed.

GW Solutions has found that the actual data used for the study is not clearly described in the reports. It should be clearly summarized in tables and illustrated on maps especially near the dam site.

Looking at the map provided by BC Hydro showing confirmed groundwater level measurement locations (Figure 3), GW Solutions believes that this is not sufficient to accurately estimate the elevation of the water table and to define hydraulic gradients for 8 different __________________________________________________________________________________________________________________________________________________________________________________________________

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hydrostratigraphic units, especially in the close proximity of the dam site and on the south bank, because most of the water level measurements are taken far upstream from the dam site.

In addition, the time period to assess the seasonal variation of the water table is not adequate. GW Solutions recommends comparing the data obtained from year 2011-2012 to historical data, if available, in order to confirm the observed seasonal fluctuations over time.

Figure 2. Historical drill holes and test pits __________________________________________________________________________________________________________________________________________________________________________________________________

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Figure 3. BGC 2011 drill holes (EIS - Volume 2 - Appendix B) __________________________________________________________________________________________________________________________________________________________________________________________________

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Hydraulic conductivities Seven (7) packer tests were performed in 5 drill holes and 27 slug tests were performed in piezometers to estimate the hydraulic conductivity values for 6 of the 8 defined hydrostratigraphic units. These two methods typically give an estimate of the hydraulic conductivity at a small scale around the tested wells. Historical data from 71 tests were also used, although the type of test is not reported. The geometric mean hydraulic conductivity values were calculated for each of the 6 hydrostratigraphic units; these average values were used as input data in the numerical model. The 2 remaining hydrostratigraphic units (Tufa and valley rebound affected siltstone) do not have field calculated hydraulic conductivity values. The valley rebound affected siltstone unit was assigned with a hydraulic conductivity value during the calibration process of the numerical model.

GW Solutions agrees with the methodology of calculating the hydraulic conductivity values, but pumping test data that are generally more reliable and representative of larger volumes of aquifers would have been preferable. GW Solutions agrees with the use of the average hydraulic conductivity for each hydrostratigraphic unit as an input in the numerical model for a regional analysis. However, a better definition of the hydrogeological parameters should be used for the more critical area near the dam site.

It is not clear where the values of hydraulic conductivities have been collected (assumed to be shown on drawing 8 to 24 of Appendix F Vol2). If this is the case, the data is not well distributed and lacks definition near the dam. In Vol 2 Section 11, it is stated that permeability values have also been calculated near the dam site for the bedrock units, but GW Solutions could not find a map showing the precise locations where the tests had been completed.

The modelled conditions for the bedrock units assume a continuous and homogeneous media which is obviously unrealistic but acceptable for a regional groundwater study or in some cases where the bedrock is regularly and densely fractured. The structure of the bedrock creates preferential pathways for groundwater (defined by the fracture network). This limitation of the model can lead to erroneous prediction in the rise of groundwater levels. GW Solutions understands that BC Hydro will compensate well owners in case their well become unusable. However, this assumption should not be made near the dam site where fractures in the bedrock can create preferential pathways for groundwater. The fractures near the dam site that may act as drain for groundwater and may create underseepage and uplift pressure downstream the dam should be described in detail. BC Hydro stated in Volume 1 of the EIS: “Instrumentation would be installed to measure the performance relative to the expected performance based on the design analyses.

Instrumentation would include devices that measure water pressures in the foundation or body of the dam and buttress (piezometers) and devices that measure deformations. During and after reservoir filling, the readings from the instrumentation would be checked against expected values. If the readings indicated unsatisfactory performance, remedial work would be undertaken.�

GW Solutions is of the opinion that these piezometers should be installed prior the beginning of construction for baseline monitoring. GW Solutions is not aware if this has been done yet (this information does not appear in construction bulletins).

BC Hydro and its consultants did not provide any detail on the downstream effects the reservoir may have on groundwater such as the reduction of groundwater availability due to inadequate recharge and modification of the interaction with surface water. This was already __________________________________________________________________________________________________________________________________________________________________________________________________

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mentioned by the City of Fort St John who is relying for its water supply on aquifers downstream of the dam site. Surface water and groundwater interaction post construction should be better assessed downstream of the dam.

Task 4 - Review of geotechnical data, stability cross-sections and their interpretation especially in the close proximity of the Site C dam (including downstream) in order to estimate whether the groundwater regime has been adequately integrated in the geotechnical analysis; In Volume 2 Appendix B2 p45 “Groundwater seepage and slope stability analyses were undertaken to help verify that the predicted eroded and ultimate slope angles, as determined through the slope angle inventory, are typically associated with factors of safety greater than 1 and 1.5, respectively.”

GW Solutions understands that BC Hydro has used simulated groundwater levels for the stability analysis at 21 cross-sections which do not include the 3 cross-sections near the dam site (Figure 4).

Landslide study/inventory has been done downstream the dam site as well.

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Figure 4. Slope stability analysis cross-sections

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Task 5 - Mapping of the lengths of sections that have undergone fracking (fracking footprint) and that may act as potential pathways for groundwater, around Site C, if any; Figure 5 shows the fracked wells, the fracking footprints and the reported major faults in the area of Site C reservoir. There is a very high density of oil and gas fracked wells in the proximity of the Site C area as well as in the proximity of water wells. Fracking footprints, as mapped by the Oil and Gas Commission (OGC), do not seem directly in contact with major faults reported in the area. However, it is well known that the wells might loose their integrity with time, creating preferential pathways to shallower aquifers that may be used for groundwater supply. Regarding the proximity of water wells, it is critical to assess the cumulative effect of the filling of the reservoir and the rise of water table on groundwater resources.

The EIS only mentions Oil and Gas related to compensation for tenures that will be inundated and seismicity related to fracking. In the EIS Vol2 – Section 10 and 11 written in 2012, it is explained that the process of hydraulic fracturing a well does not pose a high risk for inducing seismic events and effects it may have on engineered structures. BC Hydro also specified that “earthquakes less than about magnitude M5 do not release enough energy to cause damage to engineered structures”.

However, in 2015, the BC OGC acknowledged that fracking has caused earthquakes of magnitude up to 4.6 2. Therefore the risk of seismicity induced by fracking and its potential effect on the dam structures should be re-assessed, even if BC Hydro proposes that hydraulic fracturing be suspended upon detection of an earthquake of magnitude M4 or more.

GW Solutions strongly recommends T8TA to conduct a review of the risks associated with induced seismicity resulting from fracking and disposal of liquid waste in disposal wells and how induced seismicity may jeopardize the stability of the proposed Site C dam.

2

http://thetyee.ca/News/2015/07/21/Fracking-Industry-Changed-Earthquake-Patterns/ and http://commonsensecanadian.ca/bcs-biggest-fracking-quake-yet-4-6felt-residents-north-fort-st-john/ and http://www.cbc.ca/news/canada/british-columbia/fracking-triggered-2014-earthquake-in-northeastern-b-c-1.3203944 __________________________________________________________________________________________________________________________________________________________________________________________________

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Figure 5. Drilled oil and gas wells and fracking footprint around Site C __________________________________________________________________________________________________________________________________________________________________________________________________

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Task 6 - Review of the groundwater quality assessment and monitoring program The groundwater quality baseline is based on samples from 5 private water wells (with only 3 well logs available) and 15 piezometers and associated nested piezometers (21 samples). The sampling campaign was completed in June 2011 for the private wells (in order to establish a baseline of the water quality and identifying potential effects of the Site C drilling program on drinking water quality), and in August 2012 for the 21 piezometers/nested piezometers. These piezometers are completed in several geologic units including unconsolidated soil units (sands, silts, clays, gravel, sand and gravels), and bedrock units (sandstones, siltstones/shales).

The samples were tested for enhanced potability analysis.

BC Hydro has correctly followed the standard procedure for sampling (i.e., sample handling method, quality control), according to the described methodology.

Sample locations are distributed along the north bank and mostly toward the Peace Canyon dam; there is only one sample at the dam location and then no sample for 25 km. No samples were collected from the south bank. GW Solutions believes that the distribution of the data is not representative of the domain to be characterized. In particular, the majority of the locations tested are located far from the dam and where the changes in water levels and water chemistry will likely to be lowest.

In addition, the baseline is based on a single year campaign (2012). GW Solutions would recommend also using historical data available, to give more weight to background values obtained, all the more that the quality control (duplicates analysis) did not show very satisfactory results ( > 20% difference).

The seasonal variability of the groundwater quality has not been taken into account in this study as only one season was analyzed. GW Solutions recommends to complete another sampling campaign in another season (suitable period to be determined based on the seasonal variations of the water level) or to verify with historical data if a seasonal variability is observed.

The results show a large variability in the water quality even within the same hydrostratigraphic units. This demonstrates the heterogeneity of the different aquifer units present within the study area. Therefore, GW Solutions is of the opinion that a larger monitoring program is needed to adequately define the groundwater quality baseline.

The groundwater quality should be compared with the surface water quality from the Peace River and tributaries (which has been assessed in the Volume 2 Appendix E of the EIS - Water Quality Baseline Conditions in the Peace River). This has not been done.

However, this is necessary since the change in groundwater quality will be directly related to both the surface water quality of the Peace River and how surface water will interact with the soil formations that will become saturated due to the filling of the reservoir.

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Contaminated sites: The objective was to assess the risk of contaminated sites to be flooded during and after the filling of the reservoir. A list and characterisation of existing contaminated sites within the study area has been adequately described in Volume 2 Appendix B – Part 3 (Contaminated sites technical data report). However, the contaminated sites have not been localized on a map, according to the EIS guidelines (Section 1.3). Selected contaminated soils were considered as a risk for groundwater quality if the predicted water table elevation increased by greater than 1 m (within model accuracy) beneath the contaminated site. The results of BC Hydro’s work showed that 5 out of 40 of the identified potentially contaminated sites may experience water table rise that can potentially influence groundwater quality. The Contaminated Site Management Plan is likely to assess the level of contamination of these potential contaminated sites.

In the technical groundwater report it is stated that: “agricultural properties are located throughout the length of the reservoir and some of these will become partially or fully inundated during reservoir creation. Therefore, there is potential for the groundwater quality to be influenced if fertilizers or pesticides were used at these sites and remain present at concentrations of concern during the filling period”.

The presence and concentrations of fertilizers and pesticides in the agricultural land that will be flooded and how the fertilizers and pesticides may become mobilized in water has not been assessed and this needs to be done.

Groundwater Protection Plan and Contaminated Sites Management Plan In the different accessible documents related to the Groundwater Protection Plan (e.g. Volume 5 of the EIS, CEAA decision statement), BC Hydro committed to include: a) the results of groundwater and surface water quality modeling supported by pertinent geochemical data; b) identification of water quality parameters to be monitored and establishment of threshold values above which mitigation measures must be taken; c) identification of the geographic extent, frequency and duration of water quality monitoring; d) baseline sampling of parameters established in accordance with condition b; e) monitoring of parameters established in accordance with condition b; f) identification of potential preventative measures to limit acid generation and metal leaching; g) identification of potential mitigation measures if water quality threshold values specified in b are exceeded; and h) a process for implementing mitigation measures to address water quality impacts, if necessary. i) The Proponent shall submit to the Agency, Environment Canada and Natural Resources Canada a draft copy of the plan for review 90 days prior to initiating construction. j) The Proponent shall submit to the Agency the final plan a minimum of 30 days prior to initiating construction. When submitting the final plan, the Proponent shall provide to the Agency an analysis that demonstrates how it has appropriately considered the input, views or information received from Environment Canada and Natural Resources Canada.” __________________________________________________________________________________________________________________________________________________________________________________________________

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In a presentation by BC Hydro dated June 25, 2015, it is written that a draft plan of the Groundwater Protection Plan was provided for comments to regulatory agencies, Peace River Regional District, City of Fort St. John and District of Hudson’s Hope.

GW Solutions agrees with the general outline described above but does not have access to the completed document submitted and therefore cannot discuss the content of each above described points (e.g. location, distribution, frequency of monitoring, analyzed parameters).

The Contaminated Site Management Plan as summarized in the Volume 5 of the EIS dated July 2013 (35 Summary of the Environmental Management Plan) is likely to include the assessment of the level of contamination of the identified potential contaminated sites as well as procedures for determining site remediation methods. No other detail about this plan is available to date, as for the Groundwater Protection Plan. Such plans should be produced and made available to the public.

Conclusions GW Solutions draws the following conclusions based on the review of technical documents related to groundwater and hydrogeology in the area of the proposed Site C dam: •

The amount and distribution of groundwater level and quality data - especially along the south bank and up the tributaries of the Peace River - is insufficient to adequately characterize the hydrogeology of the 83 km long study area and to evaluate the effects of the filling of the reservoir on the groundwater regime.

•

The groundwater regime is not sufficiently described, especially near the dam site; maps describing the piezometric contours pre and post construction for each hydrogeological unit are needed, especially near the dam site.

•

Post-construction downstream effects on groundwater near the dam has not been assessed, in particular the larger lateral groundwater flows and pressure expected to be generated by the high hydraulic gradients resulting from the build-up of the reservoir.

•

The cumulative effect of Oil and Gas well fracking and reservoir filling on the long-term modification of the regional groundwater regime has not been assessed.

•

The risks on dam stability resulting from fracking induced seismicity should be reassessed.

•

A more thorough assessment on the impact on groundwater quality should be completed.

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Closure Conclusions and recommendations presented herein are based on available information at the time of the study. The work has been carried out in accordance with generally accepted engineering practice. No other warranty is made, either expressed or implied.

Engineering judgement has been applied in producing this letter-report.

This letter report was prepared by personnel with professional experience in the fields covered. Reference should be made to the General Conditions and Limitations attached in Appendix 1.

GW Solutions was pleased to produce this document. If you have any questions, please contact me.

Yours truly, GW Solutions Inc.

Gilles Wendling, Ph.D., P.Eng. (BC and Alberta) President

Appendix Appendix 1: GW Solutions Inc. General Conditions and Limitations

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APPENDIX 1 GW SOLUTIONS INC. GENERAL CONDITIONS AND LIMITATIONS

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This report incorporates and is subject to these “General Conditions and Limitations”.

1.0 USE OF REPORT This report pertains to a specific area, a specific site, a specific development, and a specific scope of work. It is not applicable to any other sites, nor should it be relied upon for types of development other than those to which it refers. Any variation from the site or proposed development would necessitate a supplementary investigation and assessment. This report and the assessments and recommendations contained in it are intended for the sole use of GW SOLUTIONS’s client. GW SOLUTIONS does not accept any responsibility for the accuracy of any of the data, the analysis or the recommendations contained or referenced in the report when the report is used or relied upon by any party other than GW SOLUTIONS’s client unless otherwise authorized in writing by GW SOLUTIONS. Any unauthorized use of the report is at the sole risk of the user. This report is subject to copyright and shall not be reproduced either wholly or in part without the prior, written permission of GW SOLUTIONS. Additional copies of the report, if required, may be obtained upon request.

2.0 LIMITATIONS OF REPORT This report is based solely on the conditions which existed within the study area or on site at the time of GW SOLUTIONS’s investigation. The client, and any other parties using this report with the express written consent of the client and GW SOLUTIONS, acknowledge that conditions affecting the environmental assessment of the site can vary with time and that the conclusions and recommendations set out in this report are time sensitive. The client, and any other party using this report with the express written consent of the client and GW SOLUTIONS, also acknowledge that the conclusions and recommendations set out in this report are based on limited observations and testing on the area or subject site and that conditions may vary across the site which, in turn, could affect the conclusions and recommendations made. The client acknowledges that GW SOLUTIONS is neither qualified to, nor is it making, any recommendations with respect to the purchase, sale, investment or development of the property, the decisions on which are the sole responsibility of the client.

2.1 INFORMATION PROVIDED TO GW SOLUTIONS BY OTHERS During the performance of the work and the preparation of this report, GW SOLUTIONS may have relied on information provided by persons other than the client. While GW SOLUTIONS endeavours to verify the accuracy of such information when instructed to do so by the client, GW SOLUTIONS accepts no responsibility for the accuracy or the reliability of such information which may affect the report.

3.0 LIMITATION OF LIABILITY The client recognizes that property containing contaminants and hazardous wastes creates a high risk of claims brought by third parties arising out of the presence of those materials. In consideration of these risks, and in consideration of GW SOLUTIONS providing the services requested, the client agrees that GW SOLUTIONS’s liability to the client, with respect to any issues relating to contaminants or other hazardous wastes located on the subject site shall be limited as follows: (1) With respect to any claims brought against GW SOLUTIONS by the client arising out of the provision or failure to provide services hereunder shall be limited to the amount of fees paid by the client to GW SOLUTIONS under this Agreement, whether the action is based on breach of contract or tort; (2) With respect to claims brought by third parties arising out of the presence of contaminants or hazardous wastes on the subject site, the client agrees to indemnify, defend and hold harmless GW SOLUTIONS from and against any and all claim or claims, action or actions, demands, damages, penalties, fines, losses, costs and expenses of every nature and kind whatsoever, including solicitor-client costs, arising or alleged to arise either in whole or part out of services provided by GW SOLUTIONS, whether the claim be brought against GW SOLUTIONS for breach of contract or tort.

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4.0 JOB SITE SAFETY GW SOLUTIONS is only responsible for the activities of its employees on the job site and is not responsible for the supervision of any other persons whatsoever. The presence of GW SOLUTIONS personnel on site shall not be construed in any way to relieve the client or any other persons on site from their responsibility for job site safety.

5.0 DISCLOSURE OF INFORMATION BY CLIENT The client agrees to fully cooperate with GW SOLUTIONS with respect to the provision of all available information on the past, present, and proposed conditions on the site, including historical information respecting the use of the site. The client acknowledges that in order for GW SOLUTIONS to properly provide the service, GW SOLUTIONS is relying upon the full disclosure and accuracy of any such information.

6.0 STANDARD OF CARE Services performed by GW SOLUTIONS for this report have been conducted in a manner consistent with the level of skill ordinarily exercised by members of the profession currently practicing under similar conditions in the jurisdiction in which the services are provided. Engineering judgement has been applied in developing the conclusions and/or recommendations provided in this report. No warranty or guarantee, express or implied, is made concerning the test results, comments, recommendations, or any other portion of this report.

7.0 EMERGENCY PROCEDURES The client undertakes to inform GW SOLUTIONS of all hazardous conditions, or possible hazardous conditions which are known to it. The client recognizes that the activities of GW SOLUTIONS may uncover previously unknown hazardous materials or conditions and that such discovery may result in the necessity to undertake emergency procedures to protect GW SOLUTIONS employees, other persons and the environment. These procedures may involve additional costs outside of any budgets previously agreed upon. The client agrees to pay GW SOLUTIONS for any expenses incurred as a result of such discoveries and to compensate GW SOLUTIONS through payment of additional fees and expenses for time spent by GW SOLUTIONS to deal with the consequences of such discoveries.

8.0 NOTIFICATION OF AUTHORITIES The client acknowledges that in certain instances the discovery of hazardous substances or conditions and materials may require that regulatory agencies and other persons be informed and the client agrees that notification to such bodies or persons as required may be done by GW SOLUTIONS in its reasonably exercised discretion.

9.0 OWNERSHIP OF INSTRUMENTS OF SERVICE The client acknowledges that all reports, plans, and data generated by GW SOLUTIONS during the performance of the work and other documents prepared by GW SOLUTIONS are considered its professional work product and shall remain the copyright property of GW SOLUTIONS. 10.0 ALTERNATE REPORT FORMAT Where GW SOLUTIONS submits both electronic file and hard copy versions of reports, drawings and other project-related documents and deliverables (collectively termed GW SOLUTIONS’s instruments of professional service), the Client agrees that only the signed and sealed hard copy versions shall be considered final and legally binding. The hard copy versions submitted by GW SOLUTIONS shall be the original documents for record and working purposes, and, in the event of a dispute or discrepancies, the hard copy versions shall govern over the electronic versions. Furthermore, the Client agrees and waives all future right of dispute that the original hard copy signed version archived by GW SOLUTIONS shall be deemed to be the overall original for the Project. The Client agrees that both electronic file and hard copy versions of GW SOLUTIONS’s instruments of professional service shall not, under any circumstances, no matter who owns or uses them, be altered by any party except GW SOLUTIONS. The Client warrants that GW SOLUTIONS’s instruments of professional service will be used only and exactly as submitted by GW SOLUTIONS. The Client recognizes and agrees __________________________________________________________________________________________________________________________________________________________________________________________________

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that electronic files submitted by GW SOLUTIONS have been prepared and submitted using specific software and hardware systems. GW SOLUTIONS makes no representation about the compatibility of these files with the Client’s current or future software and hardware systems.

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