Notice of Determination

Belledune, NB – September 5, 2025 – The Belledune Port Authority has determined that the proposed Upgrades to Port of Belledune Tank Farm project is not likely to cause significant adverse environmental effects.

This determination was based on a consideration of the following factors:

• impacts on rights of Indigenous peoples;
• Indigenous knowledge;
• community knowledge;
• comments received from the public; and
• technically and economically feasible mitigation measures.

Mitigation measures taken into account for this determination are:

1. Each truck loading and offloading areas will have a secondary containment system designed to capture small spills.
2. Stormwater from containment areas will initially be directed to  underground catch basins, where it will be fully contained, monitored daily, and removed as needed using a hydrovac truck. 
3. An oil/water separator (OWS) will be installed once available to replace the interim catch basin system. Discharge from the berm  to the OWS will be controlled by a normally closed valve.
4. The Operator will test the OWS outflow in accordance with regulations. If sample results exceed applicable guidelines, an assessment will be conducted and corrective measures implemented.
5. A preventive maintenance program, including inspection and cleaning, will be developed for the OWS.
6. Containment pans will be installed at the secondary truck loading area to ensure that any drips or spills are properly contained.
7. A thermal relief system will be incorporated into the secondary  truck loading area setup to relieve built-up pressure back to the storage tanks, preventing accidental leaks or ruptures.
8. Vent and drain ports will be included in the secondary truck loading area setup to facilitate safe draining of the pipes, minimizing the risk of residual product leaks.
9. Horizontal above-ground tanks located outside the existing berm will be double-walled with interstitial space fluid and alarm monitoring.
10. Daily reconciliation of tank volumes will be completed using newly installed tank gaging equipment and instrumentation against loaded Bills of Lading (BOLs) or ship's manifest and truck-loaded BOLs outbound. Any discrepancy >0.25% will be noted and investigated, including a physical inspection of all tanks, pipes, valves, and pumps. Tank volumes will be continuously displayed on monitors in the terminal control center.
11. The pipeline and all tank farm piping will undergo a pressure test prior to commissioning to confirm integrity, strength, and leak-tightness.
12. The pipeline from the marine dock to the tank farm will be monitored continuously during ship offloading by walking the line to identify any present or potential issues.
13. Visual inspections of the tank farm piping will be completed daily by site operators. In addition, daily inspections of operating equipment will be conducted to identify any present or potential issues.
14. The Operator will develop spill prevention and response plans and protocols, including clear reporting procedures and regulatory notification, and will maintain on-site emergency spill kits appropriate for the activities involved. Operator staff will be trained in spill response, use of spill containment equipment, and reporting.
15. A rigorous inspection will be carried out at least annually on all equipment located outside the berm to check for damage or leaks. 
16. All necessary precautionary measures will be taken to avoid spillage, displacement, or loss of products during handling or transfer.
17. All existing equipment and systems designed to protect the environment against petroleum product release will be inspected prior to commissioning to verify integrity, functionality, and compliance with applicable standards. A documented preventive maintenance program will be implemented to ensure continued reliability and to prevent malfunctions.
18. The compacted natural clay liner will be assessed to confirm its current condition. If repairs are recommended, they will be completed.
19. A temporary Vapour Combustion Unit (VCU) with a volatile organic compounds (VOC) destruction efficiency of at least 98% will be rented during the interim period while the Vapour Recovery Unit (VRU) is being designed, fabricated, delivered, and installed.
20. The VCU will be replaced by a VRU that ensures equal or improved performance in controlling emissions.
21. The temporary VCU will include an air-assisted anti-flashback burner tip and an air assist blower with a VFD to ensure proper air/vapour mixing for efficient and smokeless combustion.
22. Automated controls in the temporary VCU will adjust air and/or assist gas as needed to maintain a specific operating temperature to ensure greater than 98% destruction efficiency of any VOC's in the waste stream.
23. Automatic pilot ignition and monitoring panel in the temporary VCU will continuously monitor the pilot and attempt to relight if a pilot failure signal is received.
24. High-temperature shutdown systems and detonation arresters are included to prevent unsafe operating conditions and control emissions efficiently.
25. Regular inspection and maintenance of combustion components will be conducted to ensure optimal performance and prevent emission spikes due to equipment degradation.
26. The secondary truck loading area will include vapor return connections to the VCU to capture vapors from trucks during loading.
27. The Operator will apply for a provincial Approval to Operate, which will outline specific operational requirements.
28. The Operator will satisfy both federal and provincial air emission requirements.
29. Activities generating noise must be carried out during time acceptable to local authorities.
30. The Operator shall ensure that all equipment and vehicles should be kept in good working order, well maintained and properly muffled.
31. The use of engine breaks and excessive idling will be minimized.
32. Slamming doors will be avoided.
33. The Operator must follow the agreement made with the BPA to circulate through the port and not in the residential area. Curry Drive route only to be used as a backup in case there is a temporary issue with access through the port.
34. All activities should be conducted in accordance with the Canada and New Brunswick Migratory Birds Convention Act and Species at Risk Act.
35. If a migratory bird or species at risk, or their nest, shelter, or den is discovered, no attempt shall be made to willfully or knowingly destroy, disturb, or interfere with it.
36. In the event of unexpected contact with migratory birds or species at risk, no attempt will be made to kill, pursue, capture, harm, or harass the animal in any manner.
37. If an active bird nest is encountered, all disturbance work must temporarily stop and a buffer zone should be established around the nest. The nest must not be disturbed until the chicks have fledged. Bird nests must never be marked using flagging tape or similar materials, as this increases the risk of nest predation. Environment and Climate Change Canada's Canadian Wildlife Service shall be consulted or the Department of Natural Resources and Energy Development - Species At Risk Section should be consulted to determine the appropriate buffer size.
38. Any accidental death of a bird, or damage to an active nest or its eggs, must be reported to the Canadian Wildlife Service or DNRED's Species at Risk Section.
39. Any sick or dead wild birds discovered should be reported to DNRED at 1-833-301-0334.
40. Ensure compliance with all federal legislation and provincial, territorial, municipal and international laws codes, and standards, as applicable.
41. Ensure that all waste material will be disposed of in an environmentally responsible manner, and in accordance with provincial, territorial, municipal legislation.
42. Ensure that all trucks are road worthy, and that drivers observe all speed and weight limits on site.
43. Ensure care is taken to observe for evidence of archaeological deposits while work is being completed.  Stop work if evidence shows a potential archaeological artifact or deposit and notify a provincial representative before proceeding.

The Belledune Port Authority is satisfied that that the carrying out of the project is not likely to cause significant adverse environmental effects.

Therefore, the Belledune Port Authority may carry out the project, exercise any power, perform any duty or function, or provide financial assistance to enable the project to be carried out in whole or in part.