JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 Sirs September 2011

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs September 2011

PART 3 – RESPONSES TO ROUND 2 SIRS

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Table of Contents September 2011

Table of Contents

ENERGY RESOURCES CONSERVATION BOARD ...... 1 Question 1: Stakeholder Notification and Consultation ...... 1 Question 2: Statement of Concern - Withdrawn ...... 4 Question 3: Standard Land Company Inc. P&NG Rights ...... 6 Question 4: Oil Sands and P&NG Leaseholders...... 7 Question 5: Waivers and Variances ...... 7 Question 6: SAGD Well Pairs Under Highway 63 ...... 8 Question 7: Venting From Pad Equipment ...... 23 Question 8: Reservoir Heterogeneity ...... 23 Question 9: Solution Gas in Reservoir Simulation ...... 24 Question 10: Initial Reservoir Temperature in Reservoir Simulation ...... 24 Question 11: Temperatures Above McMurray Formation ...... 27

ALBERTA ENVIRONMENT ...... 1

1. Acronyms used in this Supplemental Information Request ...... 1

2. General ...... 2 2.1. Public Engagement and Aboriginal Consultation ...... 2 Question 1: Mitigating Concerns in the Aboriginal Review Group Process ...... 2 Question 2: Ongoing Reporting and Documentation ...... 3 Question 3: ...... 3 Question 4: JACOS Response to MSES Review ...... 4 2.2. Waste Management ...... 5 Question 5: Site Suitability for Septic Field ...... 5 Question 6: Site Suitability for Landfill ...... 6

3. Air ...... 6 3.1. Dispersion Modeling ...... 6 Question 7: Primary and Secondary PM2.5 Emissions ...... 6 Question 8: Odour Issues Management ...... 9 Question 9: Residual Air Quality Effects ...... 10 Question 10: Air Quality Interactions Ranking ...... 11 Question 11: Icing and Fogging ...... 15

4. Water ...... 18 4.1. Hydrogeology...... 18 Question 12: Groundwater–Surface Water Interaction ...... 18 Question 13: Groundwater Triggers and Trigger Values ...... 19 Question 14: Groundwater – Vertical Gradients and Flow ...... 20 Question 15: ...... 22 Question 16: Long Term Sustainable Yield of Water Well ...... 23 Question 17: River Boundary Condition and Water Levels ...... 24 Question 18: Groundwater Levels and Drawdown ...... 25

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Table of Contents September 2011

4.2. Hydrology ...... 26 Question 19: Stormwater Pond Capacity ...... 26 Question 20: Winter Runoff ...... 27 Question 21: LSA – Surface and Sub-Surface Flows ...... 28

5. Terrestrial ...... 29 5.1. Conservation and Reclamation ...... 29 Question 22: Gravel Pits ...... 29 Question 23: Salvaged Fill and Reclamation ...... 29 Question 24: Merchantable Timber Volumes ...... 31 Question 25: Salvage at Source Water Well Pad...... 31 Question 26: ...... 32 Question 27: Location of Drilling Sumps ...... 33 5.2. Terrain and Soils ...... 34 Question 28: Disturbed Areas in the Soils LSA ...... 34 Question 29: Ground Heave ...... 35 Question 30: Timing of Vegetation Clearing ...... 36 5.3. Wildlife ...... 37 Question 31: Bird and Wildlife Deterrents ...... 37 Question 32: Light Mitigation ...... 37 Question 33: At Risk Species Mitigation Measures...... 38 Question 34: Winter Aerial Survey ...... 40

6. Health ...... 55 Question 35: Atmospheric Deposition to Surface Water ...... 55 Question 36: Modeled Theoretical Maxima Locations ...... 57 Question 37: Background Exposure in Water Consumption ...... 58 Question 38: Additive Risks for Mixtures ...... 58 Question 39: Receptor Locations for COPC Maxima ...... 59 Question 40: SUM15 Assessment of Fine Particulate Matter ...... 63

7. Approvals ...... 73 7.1 Environmental Protection and Enhancement Act ...... 73 Question 41: Septic Field ...... 73 Question 42: Drainage at CPF ...... 73 Question 43: Evaporator ...... 74 Question 44: NOX and SO2 Emissions ...... 75 Question 45: Erosion Control on Stockpiled Soils ...... 84 Question 46: Discharge of Runoff Water ...... 84 Question 47: Topsoil Salvage...... 85 Question 48: Disturbance by Footprint Component ...... 85 Question 49: Erosion Control and Vegetation Establishment ...... 86 Question 50: Wellpads in Deep Organics ...... 87 Question 51: Material Removal ...... 87 7.2. Alberta Sustainable Resource Development ...... 88 Question 52: Development in Proximity to Waterbodies ...... 88

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Table of Contents September 2011

List of Tables

ENERGY RESOURCES CONSERVATION BOARD Table 6-1 Further Requests from Alberta Transportation ...... 9 Table 6-2 Expansion Project Pipelines Crossing Highway 63 ...... 22 ALBERTA ENVIRONMENT Table 10-1 Comments relating to the Justification for a Project Activity Ranking of 1...... 12 Table 14-1 Magnitude and Direction of Vertical Hydraulic Gradients ...... 21 Table 33-1 Mitigation Measures to reduce Project Effects on Wildlife Including At Risk and May Be At Risk Wildlife Species ...... 39 Table 39-1 Locations of Maximum Regulatory Benchmark Exceedances (Baseline Case) ...... 60 Table 39-2 Locations of COPC Regulatory Benchmark Exceedances (Project-Alone Case) ...... 61 Table 39-3 Locations of COPC Regulatory Benchmark Exceedances (Application Case) ...... 61 Table 39-4 Locations of COPC Regulatory Benchmark Exceedances (Planned Development Case) ...... 62 Table 40-1 Receptor Location Populations and SUM15 Values for the Baseline, Project Alone, Application and Planned Development Cases ...... 64 Table 40-2 Equations to Estimated Health Endpoints from PM2.5 Exposure ...... 67 Table 40-3 Estimates of Mortality due to PM2.5 Exposure Based on Current Population Estimates ...... 67 Table 40-4 Estimates of Hospitalization due to Respiratory Illness from PM2.5 Exposure based on Current Population Estimates ...... 69 Table 40-5 Estimates of Hospitalization due to Cardiac Illness from PM2.5 Exposure based on Current Population Estimates ...... 71 Table 44-1 SO2 and NO2 Values at the WBEA Anzac Air Quality Monitoring Station ...... 76 Table 44-2 Maximum Predicted SO2 and NO2 Concentrations Associated with Expansion Project and Demonstration Project Scenario – with and without Background ...... 77

List of Figures

ENERGY RESOURCES CONSERVATION BOARD Figure 4-1 Oil Sands Leaseholders ...... map pocket Figure 4-2 PNG Leaseholders ...... map pocket Figure 6-1 BE-North Depletion Area Alternate Well Layout A ...... 18 Figure 6-2 BE-North Depletion Area Alternate Well Layout B ...... 19 Figure 6-3 Temperature and Pressure Monitoring Locations ...... 20 Figure 6-4 Temperature and Pressure Observation Instrumentation...... 21 Figure 10-1 Simulated Daily Production Rates ...... 26 Figure 11-1 Observation Well Temperature OBA4 (A Pair) ...... 30 Figure 11-2 Observation Well Temperature OBC4 (C Pair) ...... 31 Figure 11-3 Observation Well Temperature OBE2 (E Pair) ...... 32 Figure 11-4 Observation Well Temperature OBE3 (E Pair) ...... 33 Figure 11-5 Observation Well Temperature OBO1 (O Pair) ...... 34 Figure 11-6 Observation Well Temperature OBP3 (P Pair) ...... 35 Figure 11-7 Observation Well Temperature OBQ4 (Q Pair) ...... 36 Figure 11-8 100/10-13-84-11 Stratigraphic Column ...... 37 Figure 11-9 1AA/05-13-84-11 Stratigraphic Column ...... 38

iii

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Table of Contents September 2011

Figure 11-10 1AA/09-15-84-11 Stratigraphic Column ...... 39 Figure 11-11 1AA/15-16-84-11 Stratigraphic Column ...... 40 ALBERTA ENVIRONMENT Figure 11-1 Frequency of Fog over a 5-Year Period along Highway 63 due to the Demonstration Project and Expansion Project Scenario Water Vapour Emissions ...... 17 Figure 34-1 2010 Ungulate Aerial Survey Coverage...... 43 Figure 34-2 Location of Ungulate Species Observed in the Local Study Area and Regional Study Area ...... 45 Figure 34-3 Distribution of 2011 Winter Tracking Survey Triangle ...... 49 Figure 34-4 Observation of Species at Risk and Indicator Species in the Local Study Area ...... 51

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Abbreviations September 2011

Abbreviations

AENV ...... Alberta Environment EIA ...... Environmental Impact Assessment ERCB ...... Energy Resources Conservation Board

H2S ...... hydrogen sulphide P&NG ...... Petroleum and Natural Gas SAGD ...... steam-assisted gravity drainage SIR ...... Supplementary Information Request SOC ...... Statement of Concern VRU ...... vapour recovery unit WBMC ...... Wood Buffalo Metis Corporation

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Energy Resources Conservation Board September 2011

ENERGY RESOURCES CONSERVATION BOARD

Question 1: Stakeholder Notification and Consultation

Provide an update on the status of JACOS’ stakeholder (public and industry) notification and consultation respecting the proposed pilot project. This update should discuss any outstanding concerns or objections (including any statements of concern sent to Alberta Environment) and efforts to resolve them.

Response 1

Please note that the Application No. 168748, is for a “commercial scale” SAGD project, not for a “pilot” project as stated in the above question.

JACOS has continued consultation with stakeholders and has provided AENV with bi-monthly Aboriginal Consultation reports.

The Alberta Environment Individual and Group Consultation Reports for January – June, 2011 is provided in Appendix A.

STATEMENTS OF CONCERN

Three accepted statements of concern (SOC’s) were forwarded to JACOS by AENV. JACOS prepared written responses to these SOC’s in December, 2010. Further actions to resolve these SOC’s are as follows:

1. Regional Municipality of Wood Buffalo (RMWB)

February 4th, 2011

A preliminary meeting was held with Mr. Mike Kahn – Industrial Relations Officer of the RMWB and JACOS personnel to discuss the RMWB’s SOC and JACOS response. The RMWB indicated that they were interested in having a memorandum of understanding (MOU) between themselves and JACOS as a way of satisfying the RMWB’s Council resolution to file objections on every oil sands project. Mr. Kahn committed to preparing a draft MOU for further discussion. Mr. Kahn provided this draft MOU to JACOS on April 11th, 2011.

April 14th, 2011

JACOS personnel met with Mr. Kahn and provided feedback regarding the draft MOU. JACOS also suggested that a collective MOU with all of the oil sands developers who are members of the Oil Sands Developers Group (OSDG) might be a more workable approach than individual MOU’s with developers. JACOS indicated that they would be prepared to

negotiate an individual MOU if the concept of a collective MOU was not of interest to either the RMWB or the OSDG members.

April 15th, 2011

The RMWB presented their Municipal Development Plan outline to the OSDG Municipal Affairs Committee. At this meeting there was further discussion between the OSDG members and the RMWB Planning Department.

May 17th, 2011

Representatives of the OSDG Municipal Affairs Committee including Mr. Bill Rennie – JACOS Director of Stakeholder Relations, met with RMWB Councilor Ms. Jane Stroud. One of the discussion items was a collective MOU.

May 30th, 2011

JACOS sent an email to Mr. Kahn enquiring the status of a collective MOU.

July 7th, 2011

JACOS met with Mr. Mike Kahn and Mr. Michael Evans – Executive Director Stakeholder Relations. The RMWB expressed interest in a collective MOU with the OSDG, however the time to conclude one will likely make it necessary to have a JACOS/RMWB MOU first. Mr. Kahn to send an updated draft for further consideration.

2. Chipewyan Prairie Dene First Nation (CPDFN)

April 5th, 2011

JACOS followed up with the CPDFN (Industry Relations Corporation) (IRC) Environmental Coordinator – Ms. Lisa Donovan to enquire as to the status of their review of JACOS’ response. Ms. Donovan advised that she had not seen it so JACOS emailed it to her. She committed to reviewing it with the IRC Director. JACOS also mentioned that certain aspects of the current IRC agreement between JACOS and the CPDFN should be updated following the termination of the Athabasca Tribal Council All Party Core Agreement.

May 17th, 2011

JACOS met with Mr. Kyle Gladue of the CPDFN IRC and provided 2 draft versions of IRC agreements for their consideration.

June 1st, 2011

Upon request from JACOS as to the status of review of JACOS’ response to their SOC, Ms. Donovan provided an email indicating that “I would like to have it on record that CPIRC and Jacos are in the process of working out issues that CPDFN has had with Jacos. We will keep Jacos informed on our progress of this as it proceeds.”

June 28th, 2011

Mr. Kyle Gladue advised that CPDFN IRC are awaiting the review of their legal council.

3. The Huppie Family – Registered Trapline # 2277

April 14th, 2011

In a telephone conversation with Mr. Don Huppie, Mr. Huppie indicated that his family wished to have some form of agreement between JACOS and them before considering withdrawal of their SOC. JACOS agreed to prepare a draft agreement for their review.

June, 2011

The draft agreement will be sent for the Huppie’s review, followed by a meeting to finalize.

July 6th, 2011

Draft agreement sent to Mr. Don Huppie.

OTHER CONSULTATION ISSUES

FORT MCMURRAY FIRST NATION (FMFN) #468

When JACOS commenced consultation for the Hangingstone Expansion Project, the initial meetings with potentially affected First Nations, Métis Locals, and Aboriginal Trappers included discussions on “how the stakeholder wished to be consulted”. As described in Volume 2, Section 18.1 – Traditional Ecological Knowledge and Land Use, (Supplemental Filing December, 2010), and in Volume 1, Section 19.7 – Aboriginal Consultation (EIA Filing April, 2010), it was out of the initial meetings in early 2009, and primarily at the suggestion of the Aboriginal representatives, that the concept of the Aboriginal Review Group (ARG) originated. At the time, the FMFN #468 IRC Director expressed considerable dissatisfaction with the ‘status quo’ and was a leading proponent of the ARG approach. FMFN #468 actively participated in the ARG process throughout 2009 and 2010 and continued to be represented at ARG meetings until October 2010. On May 26, 2011, as noted in the Consultation Log, a meeting took place between JACOS and the Fort McMurray First Nation IRC. At this meeting the IRC Director, Mr. Robert Cree, indicated that Fort McMurray First Nation would no longer be participating in the ARG process. Mr. Cree was appointed in late 2010 and holds different views regarding how he would like consultation with his First Nation to occur, than the previous IRC Director. Mr. Cree committed to providing a confidential letter to be forwarded to the AENV and the ERCB, stating that they have officially withdrawn from the ARG process and outlining how they would like to be consulted going forward. JACOS committed to conducting separate consultation if that was the desire of the FMFN #468.

July 5th, 2011 JACOS provided a presentation for five FMFN #468 Elders, and IRC Director and IRC Regulatory Affairs Coordinator on the Pre-disturbance Assessment work that had recently commenced, and provided a project update.

Question 2: Statement of Concern - Withdrawn

SIR Response, ERCB Question No. 1.

JACOS states, “Chard Metis Local #214’s SOC (which is identical to Willow Lake Metis Local #780’s SOC) was withdrawn.” Provide Chard Metis Local #214’s objection withdrawal letter.

Response 2

JACOS received an email from Ms. Winnie Chan, AENV Industrial Approval Engineer, as shown below. The letter from the Chard Métis Local President to Alberta Environment (AENV), dated October 14 follows. It should be noted that although the Statement of Concern (SOC) was withdrawn, JACOS prepared a response to the issues raised in the SOC and forwarded it to the Chard Metis Local in December, 2010, as noted in the consultation log.

From: Winnie Chan [mailto:[email protected]] Sent: Tuesday, November 30, 2010 2:16 PM To: [email protected] Cc: Donna Hovsepian Subject: RE: Letters re SOCs

Hi Enzo,

The Huppie Family's SOC was sent out a little later. There are no response to Chard Métis local because another letter came in from them stating that they withdraw any SOC letters issued after August 20, 2010 by Mr. Tony Punko.

Thanks, Winnie

From: Enzo Pennacchioli [mailto:[email protected]] Sent: Tuesday, November 30, 2010 11:57 AM To: Winnie Chan Subject: Letters re SOCs

Hello Winnie,

We have received copies of the attached letters in a package from Patrick Marriot today. Thank you. We received SOC submissions from the Huppie family and the Chard Metis local as well but noticed there were no letters in the package addressed to them. I’m wondering if you know the status of those.

Regards,

Enzo Pennacchioli, P.Eng. Manager, Regulatory Affairs Japan Canada Oil Sands Limited

Question 3: Standard Land Company Inc. P&NG Rights

Standard Land Company Inc. owns the P&NG rights within Section 30-84-10W4M within the proposed project area. Provide confirmation that Standard Land Company Inc. has been notified of the subject application.

Response 3

Please see the letter below, dated June 14, 2011, whereby Standard Land Company Inc. was couriered a CD copy of the Expansion Project Application and EIA as well as a CD copy of the update and SIR responses.

JAPAN CANADA OIL SANDS LIMITED 2300 Standard Life Building, 639 - 5th Avenue S.W Calgary, Alberta, Canada T2P 0M9

June 14, 2011 via courier

Standard Land Company Inc. Suite 1300, 734–7th Avenue SW Calgary, Alberta T2P 3P8

Attention: Regulatory Affairs Department

Re: Japan Canada Oil Sands Limited (JACOS) Hangingstone Expansion Project ERCB Application No. 1648748 EPEA Application No. 001-153105

Japan Canada Oil Sands Limited (“JACOS”) has filed an application to construct a Commercial SAGD Expansion project in the Hangingstone Area, Alberta. The new facilities will provide additional production capacity of up to 35,000 barrels per day over a projected life of 25 to 30 years.

JACOS holds a 75% interest as the operator of the expansion project area, with the remaining 25% interest held by Nexen Inc.

JACOS’ Hangingstone Expansion Project is located 52km south-southwest of Fort McMurray, Alberta, and will utilize steam-assisted gravity drainage (SAGD), as the extraction process. JACOS has been producing bitumen at its demonstration operation via the SAGD process since 1999.

The regulatory approval and Front End Engineering and Design process is expected to take 18 months. Upon approval, construction of the Central Production Facility is expected to begin in Q1 of 2012 with initial site clearing and rough grading. Production startup is anticipated by the end of 2014.

Please find attached a CD of the application and Environmental Impact Assessment as well as a CD copy of the update and the SIR responses. They are also available on our web page, at: www.jacos.com

If you have any questions please contact the undersigned at 403-213-6760 or alternatively you may contact Mr. Bill Rennie – Director of Stakeholder Relations at 403-668-5223, [email protected].

Yours truly, Japan Canada Oil Sands Limited

Jill Dettling Land Administrator

Attach:

Question 4: Oil Sands and P&NG Leaseholders

Provide separate maps showing the oil sands and P&NG leaseholders in and adjoining the application area.

Response 4

See map pockets at the back of this report for maps showing the oil sands (Figure 4-1) and P&NG leaseholders (Figure 4-2) in and adjoining the application area respectively.

Question 5: Waivers and Variances

SIR Response, ERCB Question No. 4.

JACOS identified wavers and variances requested for the proposed project. Confirm that JACOS will apply for the proposed waivers and variances through separate applications.

Response 5

JACOS will apply for the proposed waivers and variances requested for the Expansion Project under separate applications.

Question 6: SAGD Well Pairs Under Highway 63

SIR Response, Figure 14-1, Location of Observation Wells, and Project Update, Figure 15-4, Distribution of Components within the Project Footprint.

Figure 14-1 shows that some of the proposed SAGD well pairs will be placed underneath the Highway 63 right-of-way. Figure 15-4 indicates a proposed pipeline corridor underneath Highway 63 for the transportation of steam and produced fluids. a) Provide confirmation that all potentially directly and adversely affected stakeholders, including Alberta Transportation, clearly understand the proposed plans and potential impacts associated with the placement of SAGD well pairs under Highway 63 and the construction and operation of a pipeline corridor under Highway 63 for the transportation of steam and produced fluids. b) Provide an update on any discussions held with Alberta Transportation and plans to address any concerns raised by Alberta Transportation. c) Provide a discussion on the potential impacts and risks associated with the proposed placement of SAGD well pairs (e.g. surface heave, steam and produced fluid release to the surface, etc.) on Highway 63 and its associated users and JACOS’ strategy to mitigate the potential impacts and risks, including supporting information and data (e.g. heave analysis, etc.). d) Provide a discussion on the alternatives considered to avoid placing wells beneath the Highway 63 right-of-way, including maps showing potential alternative wellbore orientations and locations considered and the impact on bitumen recovery. e) Considering the location of the proposed SAGD wellheads are approximately 200 m from Highway 63, provide a discussion on the potential impact operational issues, such as wellhead blow outs, may have on Highway 63 and its associated users and plans to mitigate these operational issues. f) Provide the details on the planned construction and operation of the proposed pipeline corridor from the proposed CPF site to the proposed surface pad locations on the east side of Highway 63, including the planned pipeline specifications, the type of fluids planned to transported, how the pipelines will be installed and operated, and the potential impacts the pipeline construction and operation will have on the Highway 63 structure and its associated users. g) Provide a discussion of alternatives to a pipeline crossing Highway 63 that JACOS has considered, including the viability of constructing a stand-alone CPF on the east side of Highway 63 for the recovery of bitumen reserves.

Response 6

PREAMBLE

Subsequent to the issuance of the Supplemental Information Requests (SIRs), JACOS has received clarification as to Alberta Transportation’s concerns surrounding development of steam chambers under Highway 63. The response to this SIR is intended to address Alberta Transportation’s concerns as identified in Table 6-1.

Additionally, JACOS is in the process of arranging a meeting with representatives from the Planning Branch and the ERCB to address the concerns in Table 6-1 in more detail and subsequently provide a supplemental document summarizing the information and outcome of the meeting.

Table 6-1 Further Requests from Alberta Transportation

Comment from Alberta Transportation JACOS Response Provide discussions on variety of loads (i.e., over The heave occurs slowly over a period of years, and the dimensional loads and associated weight) and speed at increase in elevation of the road surface and the slope which these loads will cross the heave area and potential itself will be imperceptible to all traffic on Highway 63. As disruption if drivers are unaware of the heave. the SAGD related heave is an effect that originates approx. 300m below the surface, there is no material change to the near surface characteristics of the road bed or road surface, and therefore no impact on the performance characteristics of the road. As identified in part b., JACOS intends to meet with Alberta Transportation and the ERCB to discuss outstanding issues surrounding development in proximity to Highway 63. Safety of transporting across heave area: will it be signed As per the response above, there will be no effect on the and will maximum weight limits need to be observed / performance characteristics of the road, and the heave enforced? area will be undetectable to drivers. As discussed in part f., detailed design information for the proposed crossing will be developed prior to development of the highway crossing. JACOS will discuss this further with Alberta Transportation and the ERCB. Will JACOS have monitoring program of the heave to the Per part c. of this response, JACOS has extensive pavement surface? experience with existing operations developed in areas subject to steam chamber heaving. JACOS anticipates that the potential for damage to the highway is minimal. JACOS will monitor the heave in the area using heave monuments similar to those employed in its current operation. Will JACOS commit to repair any damage to the highway See part c. JACOS will assume responsibility for damage structure as a result of their operation at their own costs? to the highway that is directly attributable to JACOS’s operations.

Table 6-1 Further Comments from Alberta Transportation (cont’d)

Comment from Alberta Transportation JACOS Response Highway 63 is the main transportation corridor with high As identified in part c., in the unlikely event of a blowout traffic volume, so closing the highway is completely requiring the closure of Highway 63, Secondary Highway unacceptable. If worst case safety scenario of a blow out 881 can be used as a bypass route. were to occur (example is the TOTAL Joslyn SAGD Additionally, JACOS notes that there are key differences explosion) what are the options for enabling traffic to between their proposed operations and the continue through? Should JACOS construct a “safety circumstances which led to the TOTAL Joslyn blowout bypass” route for this scenario? that would make such a situation at the Expansion Project much less likely, as detailed in part c. Will the JACOS SAGD operation (e.g., drilling and No impact is expected on the pipelines crossing the heaving of the ground) affect the existing pipeline development area. JACOS has notified the pipeline corridor on the west side of Highway 63? owners, and will consult with pipeline users in the corridor west of Highway 63 as identified in part c. Address concerns about potential damage to the Per part c., JACOS will assume responsibility for damage highway pavement structure due to the heat from the to the highway that is directly attributable to JACOS’s steam pipeline and the differential heaving during the operations. winter month. JACOS would be responsible for any damage to the highway pavement structure due to its steam pipeline crossing. A monitoring program may be needed. The heat from the steam pipeline could attract animals to Potential effects on vegetation and wildlife associated highway creating a safety hazard. Also the heat could with heat from the steam pipeline have been judged by change the vegetation in the area. JACOS to be negligible, as identified in part e. Considering the close proximity of the steam generator to Please see the response to AENV SIR 11. the highway, would it cause fog and precipitation over the highway? What is the optimum depth at which the lines should be Per part f, the depth of burial will meet Alberta buried to meet AT requirements? Transportation requirements. JACOS intends to meet with Alberta Transportation to discuss this and other outstanding issues. How will these crossings be visually seen from the JACOS believes that the visual impact of the crossings highway and will they be distracting / potentially will not be dissimilar to other installations. The crossing dangerous to drivers during adverse weather conditions? structure will comply with all AT design standards, and The crossing structure should not create a safety hazard will not create a hazard. As identified in part b., JACOS to vehicles that run off road. intends to meet with Alberta Transportation to discuss outstanding issues surrounding development in proximity to Highway 63. Will there be any noise heard /anything viewed from pipe No distracting noises are expected from the crossing. As expansion / contractions that could be heard / seen by identified in part b., JACOS intends to meet with Alberta drivers and potentially contribute as a driving distraction? Transportation to discuss outstanding issues surrounding development in proximity to Highway 63. Before getting to the design stage, JACOS must present Per part f, JACOS feels that detailed design information its concept and design criteria of the proposed crossing at this stage of project development would be premature, structure to Alberta Transportation for review and and per part b., JACOS intends to meet with Alberta approval. Transportation to discuss outstanding issues before getting to the design stage.

RESPONSE

a. JACOS can confirm that all identified stakeholders including Alberta Transportation and parties with interests in the pipeline corridor adjacent to Highway 63 have had the proposed plan conveyed to them. JACOS has taken reasonable efforts to ensure these stakeholders understand the potential effects associated with the placement of SAGD well pairs under Highway 63 and the construction and operation of a pipeline corridor under Highway 63 for the transportation of steam and produced fluids.

JACOS considers Alberta Transportation the key stakeholder with respect to developments that may affect Highway 63 and has made ongoing efforts to keep them advised of project developments and to facilitate an understanding of the effects that the Expansion Project will have both during construction and during normal operations. These meetings have been used to communicate and share new developments on the project and to provide a forum for Alberta Transportation to express any concerns with the project.

An initial meeting with North Central Region Alberta Transportation engineers was held in 2006 to have a high level discussion regarding the future development plans for the Expansion Project in the area. Topics addressed included the following:

• Traffic pattern changes that can be expected as a result of the Expansion Project • The timing of the construction of the commercial expansion and the Highway 63 four-lane upgrade • Development under Highway 63 • Surface heave expectations of approximately 20 cm over 500 m

A subsequent meeting was held with North Central Region Alberta Transportation representatives in March 2009. Conceptual engineering for the Expansion was kicked off in December of 2008 and sufficient development was made to review the conceptual plans and to revisit the impacts on Highway 63 from the Expansion Project. Topics addressed included the following:

• The four-lane construction drawings were reviewed in detail in the region of the Expansion • Highway access and construction timing was reviewed • Coordination of construction resources for roadway construction in the area of the Expansion was discussed • The process for approval for the installation of high pressure steam lines under the highway • Design considerations for the highway crossing including crossing span and crossing methodology

• Engineering mitigations for upsets within the region of the highway including the use of heavy wall pipe through the crossing and the implementation of relief and drain facilities to remove condensate from the lines • Agreement was reached on the strategy of ongoing design reviews of the crossing design at various stages of development during detailed engineering • The main Alberta Transportation point of contact for JACOS was identified as the North Central Regional Office in Fort McMurray.

Another meeting was held with Alberta Transportation in October of 2009 to review a brief presentation discussing the experience and history of JACOS operations in the area, expected impacts to the area during construction and during normal operations. Items addressed included the following:

• JACOS’ operational history • The technology behind SAGD • Construction traffic and manpower forecasts for the Expansion • Facility operations • Sub-surface operations • Surface heave theoretical projections • Actual heave experienced at existing JACOS operations over the past 10 years b. In addition to the discussions outlined in response a. JACOS is in the process of making arrangements to meet again with Alberta Transportation representatives from the North Central Region office to review a recently completed traffic impact assessment that was conducted for the Expansion Project and the associated Highway 63 access designs being proposed for the intersection upgrade. This meeting will provide the opportunity for any further discussions over Alberta Transportation concerns regarding development of the Expansion Project. The ERCB will also be requested to attend this meeting to ensure a full discussion on all aspects of the potential concerns. Plans to address the concerns raised by AT are discussed in response c., e. and f. and in Table 6-1. c. During normal sub-surface operations, the development of the steam chambers from well pairs aligned under the highway will lead to surface heave effects on the roadway. The heave effect develops gradually over time with sustained sub-surface operations. The heave effect at the surface is relatively uniform over the steam chamber, typically highest at the center of the steam chamber, gradually becoming more diffuse moving away from the center. Heave magnitudes were determined in the Caprock Integrity Study conducted by JACOS for the Expansion Project operations. The study indicated that the maximum expected heave will be 28 cm with a maximum expected slope of 7.0x10-4 about 100 m away from the well center of a well pair. This is a relatively conservative projection but is in line with JACOS Demonstration

Project data. JACOS has collected heave data annually, and over the past 10 years of operations. JACOS has observed cumulative heave of 26 cm and a maximum slope of 5.3x104 at the Demonstration Project, which has operated at higher pressure and temperature than that planned for the Expansion Project. During that time, though many of JACOS’ existing central processing facilities, interconnecting pipelines, and roads are built over top of steam chambers, there have been no incidents of equipment damage caused as a result of surface heave. The heave occurs slowly over a period of years, and the increase in elevation of the road surface and the slope itself will be imperceptible to any traffic on Highway 63. As the SAGD related heave is an effect that originates approximately 300 m below the surface, there is no material change to the near surface characteristics of the road bed or road surface, and hence no impact on the performance characteristics of the road.

JACOS has considered the risk introduced by the placement of well pairs in the vicinity of the highway is the possibility of a steam or fluid release to the surface. In accordance with ERCB requirements, as mentioned above JACOS commissioned a Caprock Integrity Study for the Expansion Project. Please refer to the Caprock Integrity Study Supplemental Report respecting ERCB Application No. 1648748 and EPEA Application No. 001-153105, dated October 29, 2010. In summary, the study concluded that the planned operating pressures for the Expansion Project are well within safe operating limits, with a safety margin of 20%.

JACOS has reviewed reports from prior incidents, such as the TOTAL/Deer Creek Joslyn steam release incident and there are a number of reasons which would make such a situation at the Expansion Project much less likely:

1. The McMurray formation top in the relevant area within the Expansion Project is approximately 300 m below ground, whereas the top of the McMurray formation at Joslyn is ≤ 50m from surface. 2. The most likely steam release scenario as identified by TOTAL in their report to the ERCB was that TOTAL exceeded the fracture pressure of the overlying stratum. JACOS completed an extensive Caprock Integrity Study which concluded that our planned operating pressures will be well within safe operating limits. 3. JACOS has identified all previously drilled and abandoned wells in the Expansion Project Area and will take appropriate steps, including re-entering and cementing abandoned wells where necessary prior to startup of the Expansion Project. Please refer to the response to SIR 11 for additional discussion. 4. JACOS will equip monitoring wells in the vicinity of the highway with pressure monitoring equipment and subsequent alarms in a suitable zone above the McMurray as an early warning. See Part (e), below. 5. JACOS has more than 10 years of operations experience with 22 SAGD well pairs targeting the same formation in the immediate vicinity.

Highway 63 has in the past been closed due to accidents, forest fires, etc. In the unlikely event that operation of the Expansion Project causes the closure of Highway 63, the secondary Highway 881 provides a “safety bypass” route. Given JACOS’ management processes as outlined above and JACOS’ emergency response plans, this is viewed to be highly unlikely.

As is standard practice with all road crossing or road use agreements, JACOS will assume responsibility for any damages to the highway that is directly attributed to JACOS’ operations.

JACOS does not anticipate that any aspect of development or operation of the Expansion Project has the potential to affect the pipelines in the existing corridor located on the western side of Highway 63. JACOS has notified the pipeline owners and will ensure that crossing agreements are secured prior to construction of this portion of the Expansion Project.

d. Figure 6-1 and Figure 6-2 show two alternate depletion pattern orientations for the BE-North Depletion Area laid out to ensure the steam chamber does not develop under the Highway 63 right-of-way. Well pairs have been placed no closer than 50 m to the Highway 63 right-of-way; however, while JACOS assumes a lateral steam chamber growth of 50 m, the steam chamber will likely grow laterally in an irregular fashion which could result in the 50 m buffer being exceeded. In this instance, the effects will not be material.

Well layout A, shown in Figure 6-1, will require a well pad to be placed on the east side of Highway 63 while the well layout in Figure 6-2 requires the well pads to be placed on the west side of Highway 63. In this case, the two northern horizontal wells will require increased spacing to increase their respective drainage areas, compensating for the reduced well lengths.

The grey areas shown on both figures represent the area of resource under the Highway 63 right-of-way assessed as being greater than 15 m in net pay. For both well layouts the stranded original bitumen in place (OBIP) within the grey area is estimated to be 3.2 million barrels, decreasing the expected recovery by 1.7 million barrels. By increasing the offset by an additional 50 m, the resulting stranded OBIP is 4.4 million barrels and the expected recovery is decreased by 2.3 million barrels.

e. Well pad facilities are designed with a number of operational safety measures that mitigate the possibility of an overpressure or other material failure situation that could potentially lead to a well head blow out. Such measures include wellhead Emergency Shut Down valves, pressure & temperature monitoring systems, alarms, automated control valves, pressure relieving devices, and Safety Instrumented Systems.

The primary source of sub-surface pressure for a SAGD well operation is the high pressure steam that is injected into the reservoir. All control valves, pressure relief valves, and operational alarms and shutdown controls at the well pads are configured to ensure that

steam pressure does not exceed safe operational limits, well below the fracture pressure of the reservoir as detailed in the Caprock Integrity Study (October 2010).

In addition to these basic measures, the following additional measures will be implemented as applicable:

• Steam and produced fluid pressure will be continuously monitored in real time from a central control room at the CPF that is staffed 24 hours per day, 7 days per week. If a significant and sudden pressure drop and or steam rate increase is detected, alarms will be triggered and injection to the well pair will be shut down. • Mechanical pressure relief valves will ensure that the pressure limitations of the piping and wells are not exceeded should there be a control valve malfunction. • Additional pressure transmitters and control valves immediately prior to the injection wellhead will provide further control of the steam injection pressure and will serve to ensure safe injection pressures. • Preventive maintenance programs will be in place to perform regular inspection of wellhead and piping facilities and provide early detection of corrosion or erosion patterns. • The well pads located in proximity to Highway 63 will also be equipped with video surveillance to provide continuous monitoring and detection of any operating anomalies. • JACOS is planning to install thermocouple temperature measurement points and pressure monitoring in and or above caprock intervals in three planned observation wells that are scheduled to be drilled in the winter of 2011/ 2012.

Figure 6-3 shows the locations of the three future evaluation wells to be completed for temperature and pressure observation. Well W07OB07 will be drilled and instrumented in the upcoming 2012 winter drilling season and wells W08OB06 and W10OB07 will most likely be drilled and instrumented in the 2014 winter drilling season.

Figure 6-4 shows the approximate depths of thermocouples and pressure sensors for well W07OB07. At each of the monitoring locations, ten thermocouples will be placed within the McMurray Formation interval to monitor steam chamber growth with the deepest thermocouple placed below the horizontal producer elevation and the shallowest thermocouple placed above the reservoir interval. Two additional thermocouples will be placed further up-hole; one within the Clearwater Sand interval and the second within the upper aquifer of the Grand Rapids C interval. These two intervals will also be instrumented with pressure sensors.

Above-ground steam lines also present potential sources of hazards. JACOS recognizes the potential effect that a steam line failure can have within close proximity to a major highway and has taken measures to adopt many of industry’s best design practices where reasonably practicable to the current designs for the Expansion Project. Where appropriate the

recommendations from the ERCB Investigation Report of the MEG Energy Steam Pipeline Failure of May 2007 have been incorporated into the JACOS design.

Furthermore, lessons from these past incidents will be incorporated into the Emergency Response Plan that would be activated in the unlikely event of a blowout. The plan would require notification and involvement of the necessary authorities and community groups to ensure the safety of its employees and of the general public.

f. JACOS is currently planning on installing the pipeline crossing of Highway 63 in 2017 with the intent of starting operations in 2018 as part of sustaining capital work to maintain production rates. The time frame of the crossing may be subject to change depending on the productive life of the initially drilled wells that will be part of the 2014 start-up. Based on this time frame, the detailed engineering for the construction drawings will be kicked off in 2016. Because of ongoing developments in the area and the uncertain timing of the construction for the twinning of Highway 63, JACOS feels that detailed design development earlier would be premature.

The pipelines proposed to cross Highway 63 are identified in Table 6-2.

For the crossing methodology JACOS plans on using large diameter casing pipe as a carrier for each of the commodity pipelines – in essence a pipe within a pipe for the full diameter of the crossing. The casing would be equipped with specially designed supports to maintain the central position of the inner pipeline and to allow for axial movement to accommodate thermal expansion of the high temperature lines. Heavy walled steel pipe will be selected for the casing pipe. The lines will be installed without pockets, gently sloping downwards towards the east to facilitate the sweeping of condensed steam through the crossing into the well pads. Insulation for the piping installation will be used to prevent excessive heat from the pipes from radiating into the road bed.

The casings would be installed using a combination of trenchless boring and jacking and open cut installation. The final installation methodology will be determined by the status of the four lane highway construction project with the intent of minimizing disturbance to highway traffic. With the four lane highway in place, the bore and jack approach could be utilized for crossing the entire highway right-of-way with minimal disruptions to traffic and without damaging pavements and road surfaces. With only the two-lane highway in place, the portion of the right of way occupied by the road surface would be crossed by bore and jack with the remainder of the crossing installed by open cut trenching. Regardless of crossing methodology the depth of burial will meet Alberta Transportation requirements.

With the casings in place the inner pipelines would then be pulled into place by winch or pushed into place by a boring and jacking machine.

Note: JACOS executed a conceptual study for crossing Highway 63 including a number of different crossing options. It is available for submission to AT and the ERCB upon requested.

JACOS does not expect any change in vegetation, nor does JACOS expect the insulated pipeline to attract animals, based on experience at existing operations in the area.

g. The only option to develop reserves on both side of the highway without the proposed pipeline crossing of Highway 63 would be to build separate plants to exploit the resource on each side of the highway. Note that in all cases product and diluent lines under the highway will be required. The reserves are split approximately 60/40 West/East of Highway 63. To exploit these reserves two plants of 10-15,000 barrels per day (bpd) capacity each would be required. Significantly more equipment will be required as portions of the plant that are now twinned for reliability and operability will need to be twinned at each plant. The overall project footprint will also increase, as two plants will have a bigger footprint than one. SAGD development is very sensitive to economies of scale. Plant capital per flowing barrel increases as plant size decreases from 30,000 bpd to 10,000 bpd. Fixed costs (for example higher staffing levels are required) are also higher on a per barrel basis for smaller plants. While the exact situation of two plants, one on each side of the highway has not been modeled, economic sensitivities conducted by JACOS indicate that for a given netback, the rate of return on a 10,000 bpd plant is as much as 5% lower than the return on a 30,000 bpd plant. There is also a corresponding reduction in net present value and an increase in payout and a resultant reduction in royalties and taxes. This increases the risk of the project not producing an economic return, and not proceeding to development. As long as the crossing of the highway can be designed, constructed, and operated in a safe manner, one larger plant reduces the economic risk of the development, reduces the impact in terms of footprint and staffing, and improves the operability of the development. JACOS will work with Alberta Transportation and the ERCB as outlined above to ensure that a safe and acceptable crossing is achieved.

Rge 11 W4M Rge 10 W4M

23 24 19 14 13 18 W07

Twp 84

W06

W10

R12 R11W4 R10

T84

Figure Area

Project Area W09 W08

Legend: N Scale (m) 1:15 000 Drawn By: Project Area Figure 6-1 LAS Depletion Area >15m Net Pay BE-North Depletion Area Date: 0100100 200 300 400 500 Japan Canada Oil Sands Limited 2011-07-22 Area >15m Net Pay Not Depleted by Well Pattern Layout Alternate Well Layout A Rge 11 W4M Rge 10 W4M

23 24 19 14 13 18 W07

Twp 84

W06

W10

R12 R11W4 R10

T84

Figure Area

Project Area W09 W08

Legend: N Scale (m) 1:15 000 Drawn By: Project Area Figure 6-2 LAS Depletion Area >15m Net Pay BE-North Depletion Area Date: 0100100 200 300 400 500 Japan Canada Oil Sands Limited 2011-07-22 Area >15m Net Pay Not Depleted by Well Pattern Layout Alternate Well Layout B Rge 11 W4M Rge 10 W4M

W07OB07

23 24 19 14 13 18 W07

Twp 84 W10OB07

W06 W08OB06

W10

R12 R11W4 R10

T84

Figure Area

Project Area W09 W08

Legend: N Scale (m) 1:15 000 Drawn By: Project Area Figure 6-3 LAS Temperature and Pressure Monitoring 0100100 200 300 400 500 Japan Canada Oil Sands Limited Temperature and Pressure Date: Location 2011-07-25 Monitoring Locations Observation Well W07 OB07 2-24-84-11 Depth (mKB) est KB = 605 masl

0 m

50 m surface casing

BEDROCK

BASE FISH SCALES

100 m

VIKING FM

JOLI FOU FM

GRAND RAPIDS FM 150 m Grand Rapids ‘A’

Grand Rapids ‘B’

200 m Grand Rapids ‘C’ TC P

CLEARWATER FM Clearwater Sand TC P 250 m Clearwater Shale

Wabiskaw Member

300 m Wabiskaw Sand MCMURRAY FM

TC 350 m WATERWAYS FM

Legend: Drawn By: Figure 6-4 TC Temperature Monitoring LAS Temperature and Pressure Date: Japan Canada Oil Sands Limited Pressure Monitoring 2011-07-25 P Observation Instrumentation JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Energy Resources Conservation Board September 2011

Table 6-2 Expansion Project Pipelines Crossing Highway 63

Normal Normal Operating Operating Design Design Nominal Wall Design Pipeline Constituents Pressure Temperature Pressure Temperature Pipe Size Thickness Insulated? Standard (kPa) (ºC) (kPa) (ºC) (inches) (mm) Steam Distribution Steam 8500 300 11 266 -29 to 321 20 12.7 Yes CSA Z245.1, Pipeline Gr. 550, Cat II Liquid Produced Oil Well 2380 180 4266 -29 to 230 16 11.1 Yes CSA Z245,1 Emulsion Effluent Gr. 359, Sour Service Produced Vapors Sour Natural 900 182 4266 -29 to 230 8 7.9 Yes CSA Z245,1 Gas Gr. 359, Sour Service Fuel Gas Fuel Gas 7200 20 9930 -46 to 38 3 4.4 No CSA Z245.1, Gr. 359, Cat I Quench Water Salt Water 1800 10 4660 -29 to 100 4 5.2 No CSA Z245.1, Gr. 359, Cat I

Question 7: Venting From Pad Equipment

Application, Volume 1, Section 9.9, Project Description.

JACOS states, “Process equipment and storage tanks that may vent vapors containing H2S and Hydrocarbons will be equipped with a sweet gas blanket system and VRU. " Clarify whether or not the aforementioned statement is intended to apply to field facilities. a) If yes, provide detailed information JACOS’ plans to mitigate venting from pad equipment such as group separators and pop tanks. b) If no, discuss the potential for H2S emissions and off-lease odors as a result of venting from pad facility equipment. Note that Section 8 of Directive 060 requires that venting not result in off-lease odors regardless of whether they are a result of routine or non-routine operations.

Response 7

a. The description of a sweet gas blanket system and VRU only applies to the CPF.

b. The potential for H2S emissions or off-lease odours associated with venting from wellpad facility equipment is minimal. For each wellpad, all vents will be routed to a Pop Tank

equipped with a vent scrubber that will remove H2S contained in vented gas.

Question 8: Reservoir Heterogeneity

The reservoir simulation model JACOS submitted did not consider any vertical and horizontal variation in reservoir properties. Discuss the effect that reservoir heterogeneity would have on SAGD performance in the field compared to the performance predicted by the simulation model.

Response 8

The reservoir simulation submitted was used for sensitivity analysis only, not for the forecasting of individual well production rates. As such, geological heterogeneity is not a critical component of the simulation model.

Based on experience at the Demonstration Project, SAGD performance is dominated by geological heterogeneity, both in terms of the reservoir structure and the continuity of reservoir facies. As part of JACOS’ ongoing simulation studies, the results of the computer simulations are corroborated with actual field performance and the geological model is revised as appropriate. This history matching is a key component in the development of predictive tools for SAGD performance which can be applied to the Expansion Project. JACOS continues to refine 3D heterogeneous geological models for history matching purposes, but at this point in time the analogue-based performance predictions used in the Application are considered by JACOS to be an appropriate tool for Expansion Project predictions.

Question 9: Solution Gas in Reservoir Simulation

The reservoir simulation input data files JACOS submitted did not include any solution gas in the ‘Oil’ component. Comment on the effects that using live bitumen would have on SAGD performance compared to the performance predicted by the model, which did not include solution gas.

Response 9

Bitumen has been treated as dead oil for all of the simulation studies conducted by JACOS. While a small amount of gas is produced at the Demonstration Project, there has been no indication that it plays a role in the actual production rates of the wells. In the simulator one of the biggest impacts of solution gas occurs when gas is allowed to build up in the steam chamber, creating an insulating layer which reduces heat transfer to the cold bitumen and hence reduces expected production rates. There has been no such build-up of solution gas observed at the Demonstration Project. None of the thermocouple data analyzed in the past 10 years show any temperature suppression at the edge of the steam chamber (temperature suppression in the steam chamber would result from the partial pressure effects associated with a buildup of solution gas). This temperature suppression has been observed when non-condensable gas was injected into the steam chamber during a test documented in JACOS’ 2008 Annual Performance Review to the ERCB. As soon as the injection of non-condensable gas stopped, the temperature suppression effects disappeared, reinforcing the conclusion that any impact of solution gas alone is not material at the Hangingstone site. Adding live oil to the simulations greatly increases the complexity of the simulation, requires additional assumptions (for example the rate at which solution gas moves out from the chamber into virgin reservoir), and is not warranted based on actual performance data from the Demonstration Project.

The effect of free gas from the live oil is important in the cyclic steam stimulation process in that the solution gas is one of the main driving forces when the oil flows from out in the reservoir to the well bore. However, since gravity is the main driving force in the SAGD process, the dead oil model is sufficient for the SAGD simulation.

Question 10: Initial Reservoir Temperature in Reservoir Simulation

An initial reservoir temperature was not assigned to the reservoir simulation model JACOS submitted thus a default reference surface temperature of 25°C was automatically assigned by the simulator.

a) Comment on the impact of using a measured initial reservoir pressure, instead of a default surface temperature of 25°C, would have on the simulated SAGD performance. b) The geomechanical model JACOS submitted used an initial reservoir temperature of 11°C. Explain the discrepancy and confirm what the initial reservoir temperature is.

Response 10

a) and b) The initial reservoir temperature as measured from exploratory well logs averages about 11°C.

The simulation model submitted by JACOS was primarily used to determine the effect of different operating pressures (3,000 and 5,000 kPa). While the production rates vary slightly with initial reservoir temperature, there is no material impact of the initial temperature when used to quantify the difference between the pressures.

Figure 10-1 compares the rates from the simulation using 11ºC (labeled “5000kpa 11C”, and “3000kpa 11C”) and 25ºC (labeled “5000kPa” and “3000kPa”) as the initial temperatures.

The peak rate is approximately 6 – 7 % lower when the initial reservoir temperature is reduced from 25°C to 11°C with the same injection pressure.

However, when comparing the change in rate as a function of injection pressure, the drop in rate is approximately 20% in both the 25°C and 11°C cases. The simulation was used in this manner in Section 7.5.1 of the Project Description (April 2010).

123510469-177 Drawn By: Figure 10-1 MD FIGURE HZOP 2D Homogenous Base Date: 20m-1m-50m (5000kPa) 2011-08-18 JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Energy Resources Conservation Board September 2011

Question 11: Temperatures Above McMurray Formation

SIR Response, Question No. 15 b).

JACOS states, “The cement above the McMurray formation will not be exposed to high temperatures directly from the formation face, as it would be in a steam chamber.”

a) To support the above statement, use the existing observation well data of a mature steam chamber to plot temperature as a function of depth starting from the base of the caprock to 50 m above or to the base of the immediate overlying formation, whichever comes first. b) Based on empirical data, discuss the highest temperature that non thermal cement can be exposed to without losing its strength. c) Provide a discussion on hydraulic isolation of cased wells penetrating the Wabiskaw-McMurray deposit with non-thermal cement in light of the findings from the above a) and b).

Response 11

a. While JACOS does not have thermocouples in the observation wells installed in the interval of the cap rock, JACOS has numerous wells with thermocouples above the steam chamber which show the relationship between distance above the steam chamber and temperature at the Demonstration Project.

Figures 11-1 to 11-7 are depth vs. temperature plots for several observation wells associated with the Demonstration Project. They show that in this area the McMurray formation has an interval of non-reservoir facies near the top of the formation. This interval varies in thickness but in most cases the formation temperature is less than 110ºC at the top of the McMurray formation. The plots also demonstrate that the formation temperatures fall rapidly in the non- reservoir quality facies above the steam chamber. In all cases the temperatures have fallen to less than 110ºC in less than 20 m True Vertical Depth (TVD) of non-reservoir facies.

The non-reservoir facies at the top of the McMurray are not present in all areas of the development area but these plots illustrate that even if the steam chamber does reach the cap rock, the high temperature effects would be limited to less than 20 meters into the bottom of the cap rock interval.

b. Based on empirical data, non-thermal cements start to lose their compressive strength at temperatures above 110ºC. This is based upon the following information from the Schlumberger Well Cementing Manual (Second Edition):

Portland cement is essentially a calcium silicate material, the most abundant components being tricalcium silicate (C3S) and dicalcium silicate (C2S). Upon addition of water, both hydrate to form a gelatinous calcium silicate hydrate called “C-S-H phase,” which is responsible for the strength and dimensional stability of the set cement at ordinary temperatures. The reaction also liberates a substantial amount of calcium hydroxide (CH).

C-S-H phase is the early hydration product even at elevated temperatures and pressures, and it is an excellent binding material at well temperatures less than 230°F [110°C]. At higher temperatures, C-S-H phase is subject to metamorphism, which usually results in decreased compressive strength and increased permeability of the set cement. In the petroleum literature, Swayze (1954) described this phenomenon as “strength retrogression.”

At temperatures above 230°F [110°C], C-S-H phase often converts to a phase called alpha dicalcium silicate hydrate (α-C2SH). αC2SH is highly crystalline and much more dense than C-S-H phase. As a result, matrix shrinkage occurs that can be deleterious to the set-cement integrity. This effect is illustrated in Fig. 10-1, which depicts the compressive-strength and water-permeability behavior of conventional Portland cement systems cured at 446°F [230°C]. Significant loss of compressive strength occurred within 1 month; nevertheless, the levels to which the compressive strength fell are sufficient to support casing in a well (Suman and Ellis, 1977). The real problem lies in the severe permeability increases. To prevent interzonal communication, the permeability of well cements to water should be no more than 0.1 mD. Within 1 month, the water permeabilities of the normal-density Class G systems portrayed in Fig. 10-1 (Curves 1 and 2) were 10 to 100 times higher than the recommended limit. The permeability of the high density Class H system (Curve 3) was barely acceptable. The deterioration of the lower-density extended cement (Curve 4) was much more severe.

c. In the area of the initial development, three wells, 10-13-84-11, 5-13-84-11 and 9-15-84-11, that are not cemented with thermal cement are located within the horizontal SAGD well patterns and will likely be exposed to thermal conditions. In addition, there is one additional well of this type, 15-16-84-11 located several hundred meters from the closest planned SAGD well.

All of the wells noted above have approximately 50 m of caprock overlaying the McMurray formation as shown in the stratigraphic columns of Figures 11-8 to 11-11, below. Based on the temperature profile data for non-reservoir facies, JACOS believes that, in the worst case, the temperature of the caprock facies will be below 110 ºC at a distance of less than 20 mTVD above the top of the McMurray formation. While the non-thermal cement around

the outside of the production casing may suffer some strength retrogression in this interval, in each case there will be a minimum of 30 m of cement that will not be exposed to temperatures above 110 ºC and which will be capable of forming a hydraulic seal between the McMurray formation and the formations above the caprock.

Based on this data, JACOS believes that no remedial action is required on these specific wells where the production casing is cemented with non-thermal cement. JACOS will ensure that the wells are abandoned on the inside of the production casing with thermal cement in accordance with Directive 20.

REFERENCE:

Drawn By: Figure 11-1 TLI Observation Well Temperature Date: 2011-08-18 OBA4 (A Pair) Drawn By: Figure 11-2 TLI Observation Well Temperature Date: 2011-08-18 OBC4 (C Pair) Drawn By: Figure 11-3 TLI Observation Well Temperature Date: 2011-08-18 OBE2 (E Pair) Drawn By: Figure 11-4 TLI Observation Well Temperature Date: 2011-08-18 OBE3 (E Pair) Drawn By: Figure 11-5 TLI Observation Well Temperature Date: 2011-08-18 OBO1 (O Pair) Drawn By: Figure 11-6 TLI Observation Well Temperature Date: 2011-08-18 OBP3 (P Pair) Drawn By: Figure 11-7 TLI Observation Well Temperature Date: 2011-08-18 OBQ4 (Q Pair)

N Drawn By: Scale (km) 1:60,000 Figure 4-1 TLI Oil Sands Leaseholders Date: 0.5 0 1 2 3 2011-08-17 N Drawn By: Scale (km) 1:60,000 Figure 4-2 TLI PNG Leaseholders Date: 0.5 0 1 2 3 2011-08-17 JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

ALBERTA ENVIRONMENT

1. Acronyms used in this Supplemental Information Request

The following acronyms are used in this Supplemental Information Request.

AAAQO ...... Alberta Ambient Air Quality Objectives ARG ...... Aboriginal Review Group AENV ...... Alberta Environment COPCs ...... Chemicals of Potential Concern CPF ...... Central Processing Facility CR ...... Concentration Ratio EIA ...... Environmental Impact Assessment ERCB ...... Energy Resources Conservation Board HHRA ...... Human Health Risk Assessment JACOS ...... Japan Canada Oil Sands Limited km ...... kilometer LSA ...... Local Study Area m ...... metre MPOI ...... Maximum Point of Impingement MSES ...... Management and Solutions in Environmental Science NOx ...... Nitrous Oxides PM ...... Particulate Matter PM2.5 ...... Fine Particulate Matter ROW ...... Right of Way SAGD ...... Steam Assisted Gravity Drainage SO2 ...... Sulphur Dioxide SRU ...... Sulphur Recovery Unit TEK/TLU...... Traditional Ecological Knowledge/Traditional Land Use TOR ...... Terms of Reference VRU ...... Vapour Recovery Unit

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

2. General

2.1. Public Engagement and Aboriginal Consultation

Question 1: Mitigating Concerns in the Aboriginal Review Group Process

TEK/TLU Study, Volume 2, Section 18.3.2, Page 18-9

JACOS states The specific approach to the conduct TEK/TLU study program for the Expansion Project evolved based on: JACOS’ interest in respectful and collaborative planning processes and a search for common ground and meaningful dialogue with the affected Nations, Métis Locals, Aboriginal trappers from the outset of the Demonstration Project, throughout the life of the Expansion Project, and during decommissioning and reclamation. a. Describe the process and timing for mitigating concerns throughout the life of the Expansion Project (including decommissioning and reclamation) with affected Aboriginal groups identified and involved in the Aboriginal Review Group (ARG) process.

Response 1

The Aboriginal Review Group (ARG) has been established as a consultative forum that provides the opportunity for Aboriginal voices and perspectives to be heard with respect to the JACOS Hangingstone Expansion Project. The ARG allows potentially affected First Nations, Métis Locals, and Aboriginal trappers to share concerns and knowledge with JACOS as well as for JACOS to provide project information to Aboriginal representatives in a timely and efficient manner. It has all along been the express intention of JACOS and the Aboriginal participants that the ARG would continue to operate and meet on an on-going basis throughout the life of the Project in order to solicit Aboriginal input on project planning, operations, reclamation and decommissioning. To this end, a meeting of the ARG was held in March 2011, in part to discuss next steps for the ARG. At this meeting, future meetings of the ARG were tentatively planned (June and September 2011) with monitoring, communications, and reclamation identified as topics for discussion. The ToR for the ARG describe the process to address concerns during the life of the Expansion Project. These Terms of Reference are provided in Volume 1, Section 19.7 of the Application.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Question 2: Ongoing Reporting and Documentation

TEK/TLU Study, Volume 2, Section 18.4, Page 18-13

JACOS states The methods to be employed to meet the specified objectives of this TEK/TLU include: the preparation of a TEK Report describing the ARG process to date; the information contained in the TEK Report will be supplemented through the ongoing reporting and documentation of the ARG process.

a. Provide additional details clarifying what supplemental information is expected to be part of the ongoing reporting and documentation. b. Identify who will be included in the distribution of JACOS’ ongoing reporting and documentation.

Response 2

a. Ongoing reporting and documentation refers to the bimonthly Aboriginal Consultation report, and other items such as meeting summaries, and JACOS responses to the MSES and ARG questions. The bimonthly Aboriginal Consultation report details meetings, emails, letters and phone calls between JACOS and JACOS’ consultants and ARG members. As noted in the ARG ToR “Notes will be taken at each meeting and a meeting summary will be provided to participants within two weeks of the meeting date.” JACOS maintains a copy of all notes and meeting minutes as stated in the ARG ToR – “It is expected that each community will keep their own file of ARG records. JACOS will also maintain ARG records.” b. The bimonthly Aboriginal Consultation report is sent to the designated AENV Aboriginal Affairs Advisor, (as of May 5, 2011 Drea Wonnacott).

Question 3:

TEK/TLU Study, Volume 2, Section 18.4.2.1, Page 18-17

JACOS states that Aboriginal representatives maintained that oil sands projects EIAs often had the following shortcomings: TEK/TLU is not static--it is an evolving process. a. Explain what this statement means and provide an example. b. Discuss plans to mitigate concerns in the long-term in response to a dynamic TEK/TLU process.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Response 3

a. This statement was made at an ARG meeting by one of the Aboriginal members, not JACOS, however JACOS understands the comment to mean that, as a lived experience that includes knowledge of past and present generations, TEK/TLU is qualitative, intuitive, holistic, and oral; therefore TEK/TLU continues to be compiled, change and evolve in response to changing cultural and environmental circumstances. b. Changes to TEK/TLU will be accommodated by the continuation of the ARG for the duration of the Expansion Project and adjusting the ARG ToR as appropriate.

“Going Forward: It is the desire of JACOS and the Aboriginal communities that the ARG continue on past the EIA, should the project be approved. To this end, an ARG meeting shall be held no later than 6 months following the submission of the EIA to clarify the structure and operation of the ARG through the presumed operations and decommissioning phases of the Hangingstone Project. At this time the ToR will be reviewed and adjusted as necessary to account for long-term needs of the ARG.”

It has been mentioned at ARG meetings that as opposed to conventional TEK/TLU studies that capture a snapshot of TK at a specific point in time, this collaborative dialogue initiated by the ARG allows for Aboriginal concerns, interests, issues, and recommendations to be brought forward throughout the life of the Expansion Project. JACOS is committed to working with potentially affected First Nations, Métis Locals and Aboriginal trappers through the ARG to reasonably and practically address Aboriginal issues and concerns.

Question 4: JACOS Response to MSES Review

TEK/TLU Study, Volume 2, Section 18, Appendix 18-D, Table 18D-1, Pages 18D-1 - 18D-8

JACOS has inserted an ARG Identified Impacts Table, identifying numerous impacts with two blank columns titled 1) Recommendations and 2) Measuring Success. a. Clarify what this table represents and what the relationship is between the Tables’ listed impacts to those recommendations listed in the MSES Review, Section 3.0, Page 120, Appendix 18A. b. Describe how JACOS plans to respond to MSES recommendations for follow up and ensure that ongoing reporting occurs. c. What are JACOS’ plans and timelines for responding to the long-term needs of ARG in measuring success and for determining and creating community based monitoring plans.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Response 4

a. Essentially this table represents a list of concerns and interests that were identified in the TEK Report. It was developed by MSES and was included in the TEK/TLU report at the request of the ARG. JACOS saw it for the first time in December, 2010. Prior to this JACOS had prepared responses to all of the questions raised by MSES in their review and by ARG members. This table was discussed at the March 2011 ARG meeting in a preliminary fashion. It is anticipated that items in this table will be the subject of ongoing discussions between JACOS and the ARG. b. Many of the issues raised in this table have been addressed in the responses JACOS provided to the ARG and MSES (December 2010). These responses have been provided to ARG members, reviewed by MSES, the technical consultant to the ARG, and discussed at the March 2011 ARG meeting. Further, JACOS will review the effects identified in this table and compare them to the responses. Should there be any unanswered issues, JACOS will prepare a response. These responses along with new questions will be responded to through the ARG process and AENV will be advised within the bimonthly Aboriginal Consultation Report prepared for Aboriginal Affairs. c. As mentioned in the response to ERCB SIR 1, part a, (February 2011) next steps for the ARG have already been discussed at the last meeting of the ARG, held in March 2011. At that time, the next two meetings of the ARG were tentatively planned to be held in June and September 2011, with monitoring, communications, and reclamation identified as topics for discussion. As per the ARG ToR, meetings will be held at a minimum of twice per year at which JACOS will respond to issues and questions raised. The June meeting was deferred and plans are underway for a meeting in either September or October.

Discussions for ‘measuring success’ have been held with the ARG, but the specifics are under review and dependent upon further elaboration of the monitoring plans. Monitoring has been identified as a topic for future ARG meetings. JACOS has agreed to review with the ARG how monitoring and reclamation have been addressed in similar project approvals by AENV to understand what standards might be applied to JACOS and provide a starting point for further discussion.

2.2. Waste Management

Question 5: Site Suitability for Septic Field

SIR Response 6, Part 3 – AENV, Page 106 Volume 1, Section 9.14, Page 9-18

JACOS indicates that the sites for the septic field have not been determined and that they expect to find a suitable site, or will modify the system.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

a. Provide detailed site suitability information or provide documentation of an alternative process to handle the sewage waste that demonstrates no environmental impacts would occur.

Response 5

Detailed site suitability information and system overall design will be completed in the detailed engineering phase, and in accordance with the Domestic Wastewater Management Guidelines for Industrial Operations (Updated 1997) and the Environmental Protection and Enhancement Act. The septic field will be located within the footprint of the CPF, once appropriate siting conditions are met.

Question 6: Site Suitability for Landfill

SIR Response 7, Part 3 – AENV, Page 107 Volume 1, Section 9.19, Page 9-19

JACOS indicates that the 2010 winter geotechnical investigation program was underway. JACOS also indicates the site suitability report of site conditions as well as hydrogeological evaluation for the proposed landfill site(s) would be provided at a later date.

TOR 2.3.2 [H] requires a discussion of the waste disposal options. The TOR specifically states in (c) site suitability from a groundwater protection perspective (provide geo-technical information to support the siting of disposal facilities).

a) Provide the geological and hydrogeological site evaluation for the landfill location(s).

Response 6

JACOS has decided not to include a landfill in the Expansion Project and will therefore not be providing the geological and hydrogeological evaluations for the formerly proposed landfill site.

3. Air

3.1. Dispersion Modeling

Question 7: Primary and Secondary PM2.5 Emissions

SIR Response 31, Part 3 – AENV, Page 144 Volume 2, Part A, Appendix 5D, Section 5D.5, Table 5D-21, 5D-23 and 5D-25, Pages 5D-46, 5D 49 and, 5D-52

JACOS has provided a response regarding dry deposition and primary and secondary PM2.5. From the review of the responses to the information in the original EIA, there is confusion in regards to the actual emission rates of primary and secondary PM2.5, and by extension, the impacts of dry deposition. Table 5A-6 and Tables 5A-9 thru 5A-16 (pages 5A-8 thru 5A-35) detail

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

the PM2.5 emission rates per emission source. It is assumed that these are primary emission rates. The summation of the emissions from these sources is confirmed in the footnotes to the results in Tables 5E-9 and 5E-10 (Pages 5E-25 and 5E-26). However in Section 5D.3.10 (Page 5D-15), JACOS states the PM2.5 predictions from the CALPUFF model therefore include the primary PM2.5 contribution plus the secondary sulphate and nitrate contributions. This is confirmed in the CALPUFF input file in Table 5D-23 (Page 5D-49). As a result, it is unclear what actually was modelled and what is being presented. a. Quantify the primary and secondary PM2.5 emissions by providing a table which lists: i. the emission source

ii. the primary PM2.5 emission rates

iii. the secondary PM2.5 emission rates iv. whether the emission source was considered for dry deposition

b. Clarify the primary and secondary PM2.5 emissions by discussing the claim that primary PM2.5 emissions are not a substantive source of PM2.5 emissions, and the reason(s) they were not considered for dry deposition.

Response 7

PREAMBLE:

PM2.5 plays two roles in the air quality assessment:

• ambient PM2.5 concentrations – PM2.5 is a respiratory irritant that is addressed by the AAAQG and AAAQO, and in the human health assessment

• PAI and N deposition – PM2.5 can contain nitrogen and sulphur compounds and, therefore, can contribute to potential acid input (PAI) and nitrogen deposition

Furthermore, PM2.5 in the atmosphere results from the contribution of primary and secondary

PM2.5, defined as follows:

• primary PM2.5 is emitted from a combustion stack or exhaust, and emissions are estimated by

using emissions factors. The PM2.5 emission rates shown in Tables 5A-9 to 5A-16 refer to

primary PM2.5 emissions. Furthermore, all PM2.5 emission rates shown in tables explicitly refer

to primary PM2.5 emissions rates.

• secondary PM2.5 is not emitted; therefore, secondary PM2.5 emission rates are all equal to

zero. Secondary PM2.5 is formed in the atmosphere from precursor SO2 and NOX emissions;

the SO2 and NOX emission rates are provided in the emission tables.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

AMBIENT PM2.5 CONCENTRATION APPROACH

The ambient PM2.5 concentration is calculated as:

PM2.5 = [primary PM2.5] + [secondary (NH4)2SO4] + [secondary NH4NO3]

Where:

• primary PM2.5 refers to the PM2.5 emission rates in the tables. PM2.5 was not dry deposited and so the ambient concentrations will be overstated as they are not subject to a depletion term.

-2 • secondary (NH4)2SO4 formation is based on the CALPUFF predicted SO4 concentration. The -2 -2 predicted SO4 concentration assumes that some SO4 has been removed from the -2 atmosphere by dry and wet deposition processes. The remaining ambient SO4 in the

atmosphere is assumed to be converted completely into (NH4)2SO4 through reactions with atmospheric ammonia.

- • secondary NH4NO3 formation is based on the CALPUFF predicted NO3 concentration. The - - predicted NO3 concentration assumes that some NO3 has been removed from the - atmosphere by dry and wet deposition processes. The remaining ambient NO3 in the

atmosphere is assumed to be converted into NH4NO3 through reactions with atmospheric ammonia.

We believe this to be a conservative approach to calculate ambient PM2.5 concentrations.

PAI AND N DEPOSITION APPROACH

All sulphur and nitrogen compound emissions were assumed to be SO2 and NOX. The primary

PM2.5 emissions, therefore, do not contribute to PAI or N deposition. The total sulphur deposition component of PAI is calculated as:

-2 -2 Total S = [wet deposition of SO2 + SO4 ] + [dry deposition of SO2 + SO4 ] + [background total S deposition from RELAD]

The total nitrogen deposition component of PAI and N deposition is calculated as:

- Total N = [wet deposition of NO + NO2 + HNO3 + NH3 ] + [dry deposition of NO + NO2 + HNO3 + - NH3 ] + [background total N deposition from RELAD]

By definition, PAI and nitrogen deposition includes dry and wet deposition calculations.

RESPONSE

a. i. The Expansion Project PM2.5 emission sources are identified in the tables provided in the

updated Air Quality assessment (Part 2B, Section 5), and the PM2.5 emission sources for the other developments are identified in tables provided in Appendix 5A (Volume 2 EIA).

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

ii. The Expansion Project PM2.5 emission rates are given in the tables provided in the

updated Air Quality assessment (Part 2B, Section 5), and the PM2.5 emission rates for the other developments are given in tables provided in Appendix 5A (Volume 2 EIA).

iii. By definition, there are no secondary PM2.5 emissions. The Expansion Project PM2.5

precursor SO2 and NOX emission rates are given in the tables provided in the updated Air

Quality assessment (Part 2B, Section 5), and the PM2.5 precursor SO2 and NOX emission rates for the other developments are given in tables provided in Appendix 5A (Volume 2 EIA).

iv. As per the preamble, the secondary PM2.5 dry deposition contribution from all SO2 and

NOX emitting sources was considered for PAI and nitrogen deposition predictions. Primary

and secondary PM2.5 was not considered for ambient PM2.5 concentration predictions; which results in conservative concentration predictions. b. JACOS would like to clarify the response to SIR 31, where it was stated, “The Expansion

Project is not a substantive source of primary PM2.5 emissions.” which differs from “primary

PM2.5 emissions are not a substantive source of PM2.5 emissions” as stated in AENV SIR 7.b. As outlined in the preamble to this response, in understanding the relationship between “ambient concentrations” and “deposition” it is important to recognize that the assessment approach has considered wet and dry deposition, and where dry deposition has not been

included, the predicted PM2.5 concentrations are conservative.

Question 8: Odour Issues Management

SIR Response 35, Part 3 – AENV, Page 146 (Volume 1, Section 14.3, Page 14-2) SIR Response 41, Part 3 – AENV, Page 185

JACOS focuses on the use and effective operation of a vapour recovery unit to prevent rather than control odours. While this is a preferred approach (prevention rather than control), the response to SIR 48 indicates that there could be odour issues due to the release of H2S, release of additional odours could exacerbate any issues.

a. Provide a discussion of additional measures or a contingency, should these measures not be successful and odour issues occur in actuality.

Response 8

As a further contingency to prevent odours, JACOS will develop a Fugitive Emissions Leak Detection and Correction Program, with the intent to identify any potential sources of odour and correct them before they lead to an off-site odour.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Each operational shift will include a person whose responsibility it is to respond to off-site odour complaints. In the event that an on off-site odour complaint is received, JACOS will provide a quick response to identify the source of the odour and take corrective action to control the odour and correct the source.

Question 9: Residual Air Quality Effects

SIR Response 36, Part 3 – AENV, Page 146 SIR Response 39, Part 3 – AENV, Page 149 SIR Response 41, Part 3 – AENV, Tables 41-4 and 41-5, Page 159 and 160

JACOS states that appropriate mitigation measures are built into the Expansion Project design to avoid or minimize residual air quality effects. However, residual effects are those that are predicted to occur after mitigation has been employed. SIR 41 (Tables 41-4 and 41-5) indicates

that H2S concentrations are predicted to increase substantially as a result of the Project, and result in exceedances of the one-hour and 24-hour AAAQO.

This would be considered to be a residual air quality effect which should be discussed in terms of the impact of this effect as well as potential additional mitigation strategies that may be required to reduce this effect. JACOS provides the requested information in terms of contributing sources and frequency of exceedances, but does not provide any detail on a potential mitigation strategy. Instead, the response focuses on preventing the emissions. a. Provide a discussion of the impact of the elevated H2S concentrations. b. Provide a discussion of the potential mitigation strategies to reduce H2S emissions in the event that the operational strategy outlined in the response is not sufficiently effective.

Response 9

a. The maximum predicted H2S concentrations at the CPF fenceline are 15.6 as a 1-hour average and 9.66 µg/m3 as a 24-hour average (SIR Response 41, Part 3 – AENV, Table 41-5, 3 page 160). The 1-hour AAAQO for H2S (14µg/m ) is based upon odour perception. Concentrations predicted that are greater than these values are assumed to result in the potential for odour. The impact of these predicted concentrations, if they occur, is an odour along the fenceline that may be detectible if a receptor is present at the time. b. JACOS discussed fugitive design and operation strategies in SIR Response 39 (Part 3 – AENV, Page 149) and in Volume 1 (Section 14.3.3 and 14.6). JACOS is confident that these actions are sufficiently inclusive that they can be applied to, or form the basis for enhanced strategies to manage fugitive emissions.

A significant source of odour associated with the Demonstration Project is as a result of truck loading. As all production from the Expansion Project will be pipelined JACOS is confident that the potential for odour associated with the Expansion Project will be substantially lower.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Question 10: Air Quality Interactions Ranking

SIR Response 40, Part 3 – AENV, Page 150

JACOS provides the requested rationale for only the individual elements given as examples in the SIR. However, the SIR requested the information for each of the elements in the tables.

a. Provide additional rationale for exclusion or provide examples to support the ranking of 1 for Table 5-2. b. Provide an explanation of the logic or rationale used to rank each of the individual elements in the tables. c. If any of the rankings are revised as a result of this explanation, revise the assessment accordingly.

Response 10

a. A ranking of 1 means that an interaction occurs but the interaction would not result in a significant environmental effect. A ranking of 1 is given if one or more of the following apply: • Project activity causing the effect has low associated emissions. • Project activity was demonstrated to result in a small effect (not significant) based on a similar project (i.e., professional judgment). • Project activity and associated effect is short-term. • Project activity and associated effect does not occur regularly. • Effect is site-specific or local in extent. • Effect with mitigation identified in the EIA is not significant. b. Additional justification for each activity ranked as 1 in Table 5-2 of the EIA is provided in Table 10-1. c. No upward ranking revisions are necessary. JACOS is confident that it has examined the appropriate sources and emissions associated with the Project.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Table 10-1 Comments relating to the Justification for a Project Activity Ranking of 1

Project Activities/Physical Works Justification for Ranking of 1 Comments Construction and Commissioning 1 Site clearing • Short-term, site-specific, sufficiently Emissions could result from fugitive dust due to surface mitigated disturbance and from site preparation vehicle exhausts. Given the small site, site clearing activities are short-term and site-specific. Fugitive emissions can be mitigated by watering if required. 2 Workers’ camp construction • N/A Ranking revised to 0. Per Project Description Update (Volume 1, Section 1.1), workers will be housed at a third- party commercial camp. 3 Access roads construction • Short-term, site-specific, sufficiently Same as 1. mitigated 4 Utility corridor construction (natural gas, • Short-term, site-specific, sufficiently Same as 1. electricity, etc.) mitigated 5 Construction of product shipping facilities • Short-term, site-specific, sufficiently Same as 1 plus potential for welding fumes, crane exhausts mitigated and solvents associated with painting. 6 Peat and topsoil removal • Short-term, site-specific, sufficiently Same as 1. mitigated 7 Main processing area construction • Short-term, site-specific, sufficiently Same as 5. mitigated 8 Wellpads and above ground pipe racks • Short-term, site-specific, sufficiently Same as 5. construction mitigated 9 Drilling of SAGD wells (on wellpads) • Short-term, site-specific, sufficiently Emissions could result from the drilling rig engine exhaust mitigated but these emissions are short-term and site-specific. 10 Workers’ camp operation during • N/A Ranking revised to 0. Per Project Description Update construction (Volume 1, Section 1.1), workers will be housed at a third- party commercial camp. 11 Vehicular traffic – transportation of • Short-term, sufficiently mitigated, JACOS vehicles small portion of Highway 63 traffic (~3500 construction workers to site professional judgment vehicles per day, Table 5A-86, page 5A-245, Appendix 5A, Volume 2 EIA).

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Table 10-1 Comments relating to the Justification for a Project Activity Ranking of 1 (cont’d)

Project Activities/Physical Works Justification for Ranking of 1 Comments Construction and Commissioning (cont’d) 12 Vehicular traffic – transportation of • Short-term, sufficiently mitigated, Same as 11. production modules and construction professional judgment equipment 13 Vehicular traffic – ongoing engineering, • Short-term, sufficiently mitigated, Same as 11. resources and environmental professional judgment assessments Operations 14 Maintenance and repairs • Occurs sporadically, low emissions Process pressure vessels, tanks and piping are purged with steam or an inert gas such as nitrogen prior to opening to atmosphere. 15 Vehicular traffic – transportation of • Low emissions, professional judgment Same as 11. workers to processing facilities 16 Waste management • Low emissions, professional judgment Would be better classified as a 0. Project activity has negligible air emissions and therefore no potential for effects to Air Quality. Effect has been discounted based on professional judgment. 17 Surface heave • Low emissions, professional judgment Same as 16. Closure 18 Reclamation and closure of central • Short-term, sufficiently mitigated, Same as 1. processing facilities professional judgment 19 Reclamation and closure of wellpads, • Short-term, sufficiently mitigated, Same as 1. pipe racks and associated facilities professional judgment 20 Deactivation of temporary access roads • Low emissions, professional judgment Same as 1.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Table 10-1 Comments relating to the Justification for a Project Activity Ranking of 1 (cont’d)

Project Activities/Physical Works Justification for Ranking of 1 Comments Accidents, Malfunctions and Unplanned Events 21 Pipe rack leak or explosion • Short-term, low probability to occur Leaks are addressed as fugitive emissions. The project does not maintain a large inventory of explosive gas. JACOS applies procedures to control ignition sources on site 22 Traffic accidents • Short-term, infrequent, professional judgment, low probability to occur 23 Petroleum product spills/chemical spills • Infrequent, low probability to occur Volatization from a petroleum product spill or a chemical spill is not the key environmental issue that needs addressing. Infrequent, low probability to occur. 24 Forest fires • Infrequent, professional judgment Wildfires are outside the scope of air quality management. JACOS will ensure the project activities are managed not to be a source of wildfires, and will take the necessary precautions should the site be endangered by a wildfire.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Question 11: Icing and Fogging

SIR Response 49, Part 3 – AENV, Page 186

JACOS indicates that there will be a significant increase in the frequency of visible plume lengths greater than 2000 m as a result of the combined effect of the Demonstration Project and Expansion Project emissions (i.e., an increase from 3.9% of the time (i.e., 1353 winter hours in 5 years) to 11% of the time (3536 winter hours in 5 years). a. Provide a discussion of the potential impacts, if any, of the increase in icing and fogging incidents of this increase.

Response 11

PREAMBLE

In responding to Question 11, it was noted that there were proofreading errors in SIR Response 49, Part 3-AENV, page 192. The corrected “Fog Predictions on Highway 63” is provided below:

Based on the previous results, a more refined receptor grid was adopted to examine the frequency of fogging along Highway 63 as ground-level fog along a highway can have an adverse effect on traffic safety. Therefore, the potential for fogging and icing conditions along a segment of Highway 63 near the project site was examined. The model predictions (see Figure 11-1) indicate that:

• For the Demonstration Project Only scenario, there were no predicted occurrences of fog along Highway 63. • For the combined Demonstration Project and Expansion Project scenario, CALPUFF predicted that: • fog could occur for one hour over the five-year period for one 2700 m section northeast of the Expansion Project CPF, • fog could occur for two hours over the five-year period for one 100 m section northeast of the Expansion Project CPF, and • fog could occur for one hour over the five-year period on one 80 m section east of the Expansion Project CPF • A further examination of the results indicated these fog events were predicted to occur in February and March and were associated with ambient temperatures less than 0°C.

While the model indicates a potential for fogging on nearby Highway 63, the predicted frequency of occurrence is very remote.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

The key numerical corrections are identified in italic font. Figure 11-1 is a reproduction of Figure 49-7 using larger fog symbols to provide additional clarity.

RESPONSE

Predicted elevated visible plume lengths were discussed in AENV SIR Response 49 a. An elevated plume does not result in surface icing and fogging unless it reaches the ground. Fog, defined as a ground-based visible plume, was discussed in AENV SIR Response 49 b. Surface icing and fogging are associated with ground-based visible plumes, or fog.

The frequency statistics that are provided in SIR question 11 refer to elevated plumes, not to fog. As discussed in SIR Response 49, for the combined Demonstration Project and Expansion Project scenario, fog was predicted to occur for a maximum of 145 hours for the five-year period (or an average of 29 hours per year) at the Expansion Project fenceline. This is the location where the liquid water content of the fog would be the highest and hence where the fog would be the most dense. However, the potential effect of fog near the plant is viewed as not significant as the local plant traffic would be slow moving (i.e. less than 60 km/h).

A more important concern with respect to the generation of fog would be on Highway 63 traffic which travels at a much greater speed. As further discussed in SIR Response 49, fog along Highway 63 was predicted to occur a maximum of two hours of the five year period (or an average of 0.4 hours per year). The fog would be less dense at this location given the greater distance from the emission sources. Because the predicted frequency of occurrence is so low, the effect of fogging along Highway 63 is considered not significant.

Notwithstanding the predictions, JACOS plans to monitor any fog occurrences from their operations to confirm and determine if fog originating from the plant water vapour emissions does reach Highway 63. In the event that fog does reach the highway, JACOS will discuss appropriate signage or other mitigation measures with Alberta Transportation.

457000 458000 459000 460000 461000 462000 463000 464000 465000 466000 6243000 6242000 6241000 6240000 6239000 6238000 6237000 6236000 6235000 6234000 6234000 6235000 6236000 6237000 6238000 6239000 6240000 6241000 6242000 6243000

457000 458000 459000 460000 461000 462000 463000 464000 465000 466000

Hours of Fog Predicted over a 5 Year Period

LEGEND Expansion Project Lease Boundary Watercourse

Highway Hangingstone Demonstration Central Processing Facility

ATS Grid Hangingstone Expansion Central Processing Facility File Name: Total Project Case Fog hrs on highway 63.srf

Drawn By: Figure 11.1 YS SCALE (m)

Date: 2010-12-23 0 1000 2000 JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

4. Water

4.1. Hydrogeology

Question 12: Groundwater–Surface Water Interaction

SIR Response 57 (a), Part 3 – AENV, Page 211

JACOS describes that the effect on shallow groundwater recharge, shallow groundwater quantity, quality, flow regime and groundwater / surface water interaction will be minimal because the disturbance footprint is small compared to the overall surface area where recharge of surface runoff is expected to occur. a. What is the overall surface area where recharge of surface runoff is expected to occur in relation the project footprint? b. How were the overall effects to shallow groundwater recharge, shallow groundwater quantity, quality and groundwater / surface water interaction quantified? c. What is the natural hydrological variability of the area and how was it quantified? d. What is the rationale for the statement that shallow groundwater quality effects are not anticipated from site grading or construction activities aside from possible occurrence of accidental spills and leaks of vehicle fluids?

Response 12

a. Surface runoff would recharge the subsurface through infiltration to the uppermost groundwater surface, or water table, in all locations where the ground surface is sufficiently permeable (i.e. not paved or heavily compacted - impermeable). The impervious portions of the footprint consist of roads, wellpads, and the CPF and cover an area of approximately 0.2% of the LSA. Therefore, the increase in impervious surfaces is not expected to measurably affect the recharge of shallow groundwater from surface water through the reduction in infiltration. Additionally, some of the runoff from the impervious surfaces (such as roads) will infiltrate into the ground in adjacent areas (ditches). b. The overall effects to shallow groundwater recharge, shallow groundwater quantity, quality and groundwater/surface water interaction were quantified by the increase in impermeable surface area due to the Expansion Project within the LSA, as described in Response 12 a.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

c. The natural hydrologic variability, in response to SIR 57, Part 3 AENV, Page 211, was referring to seasonal runoff of the Horse Creek watershed. The variability of seasonal runoff upstream of the confluence of the Horse River (boundary of the LSA) was characterized in Volume 2, Part A, Section 8A.4.5.2, Table 8A-15 and ranged from 21.7 mm to 273 mm with a mean of 101 mm. d. The rationale for the statement is that the disturbance area represented by site grading and construction activities will be very small and localized as indicated in Response 12 a). Accordingly, the risk of affecting shallow groundwater quality will be low. Site grading and related construction activities will also involve the use and alteration of natural site materials therefore the risk of introducing foreign constituents into the shallow groundwater will be equally low.

Additionally, the majority of the site is covered by low permeability till and clay deposits. This aspect, plus the fact that operational areas will be constructed in a way to contain any spills or leaks, will further protect the shallow groundwater quality from impact.

Question 13: Groundwater Triggers and Trigger Values

SIR Response 59 (c), Part 3 – AENV, Page 214

JACOS states that Ongoing monitoring of groundwater levels will be conducted by JACOS to verify the model projections. This monitoring, which is intended to be focused in the LSA, will allow for a rapid response to any changes in water levels that can be attributed to the Project activities. To support this monitoring effort, appropriate triggers will be developed for JACOS’ intended Groundwater Management Plan to ensure timely detection and response to such events. a. Discuss what triggers and trigger values are being considered in the Groundwater Management Plan? b. If the triggers are set, what is the proposed action plan(s) to be implemented to ensure a rapid response as stated?

Response 13

a. According to AENV’s draft Lower Athabasca Regional Plan Groundwater Management Framework (LARP GMF), trigger values will be set for the following primary groundwater quality indicators: temperature, total dissolved solids (TDS), chloride, silicon, arsenic, boron and phenols. Groundwater surface elevation measurements will be the primary groundwater quantity indicator.

JACOS will prepare and submit a Groundwater Management Plan (GMP) that includes site- specific triggers and limits that are consistent with the goals of the LARP GMF. Trigger values will be established using historical data and ranges from monitoring points throughout the

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

study area, and will be submitted to AENV in advance of monitoring activities to ensure compliance with EPEA requirements and the LARP GMF.

b. The type of action plan required if a trigger value is exceeded will depend on the circumstances and the level of risk posed by the event. JACOS will verify the trigger value exceeded, determine the spatial extent of the concern, and identify and ensure management actions are taken (if required) to meet site-specific and regional goals. In doing so, set limits for indicator parameters will not be exceeded.

Question 14: Groundwater – Vertical Gradients and Flow

SIR Response 60 (a) and 60 (b), Part 3 – AENV, Pages 215 and 217 SIR Response 60 (c) and 60 (d), Part 3 – AENV, Pages 215 and 216

JACOS provided a map showing the discharge and recharge areas (Page 217). In response to the request for vertical gradients in the recharge and discharge areas, JACOS indicated that, in recharge areas, gradients are downward and, in discharge areas, gradients are upward. JACOS also describes that the flux of groundwater movement will be highly dependent on vertical hydraulic conductivity.

JACOS notes that, since the Expansion Project will have a negligible effect on the surface water and groundwater hydrology, it is anticipated that there will be no measurable changes in the hydrologic regime of the springs. On Page 216, JACOS notes that effects to the lake and discharge areas are similarly considered to be minor, but are difficult to measure or quantify. a. Provide baseline information (showing the vertical gradient at each nested monitoring well location) to assess potential impacts to the groundwater flow regime in the future by showing the magnitude of the vertical upward and downward gradients on the map of the discharge and recharge areas. b. In the absence of measured baseline conditions prior to construction, discuss how JACOS determined and can validate the assumption that there will be no or minor effect on springs (and other discharge areas) and lakes after construction?

Response 14

a. Figure 7A-37 (Groundwater Surface Elevations and Inferred Vertical Gradients), provided in Appendix 7A depicts a summary of the inferred vertical gradient at each nested monitoring well location. Table 14-1 provides a summary of the magnitude of the vertical gradient for each nest. Of the 12 nested locations allowing vertical gradients to be calculated, 8 indicate recharging conditions.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Table 14-1 Magnitude and Direction of Vertical Hydraulic Gradients

Approximate Vertical Groundwater Middle of Well Hydraulic Well Pair ID Elevation Screen Depth Gradient Relative Flow Direction (masl) (mbgs) (Δh/Δl) Q09-01B 547.84 13.54 -0.78 Downwards Q09-01C1 542.15 20.84 Q09-01C1 542.15 20.84 0.05 Upwards Q09-01C2 542.31 23.90 Q09-03C1 573.29 21.05 0.45 Upwards Q09-03C2 574.40 23.54 Q09-03C2 574.40 23.54 -1.75 Downwards Q09-03D 549.86 37.59 Q09-04D 588.29 38.65 -0.94 Downwards Q09-04E 554.68 74.31 Q09-05A 579.39 7.18 -0.67 Downwards Q09-05D 562.74 32.18 Q09-05D 562.74 32.18 -0.08 Downwards Q09-05E 560.78 57.14 Q09-06E1 621.41 82.57 0.00 No Gradient Q09-06E2 621.41 98.23 Q09-06E2 621.41 98.23 -2.77 Downwards Q09-05F 500.28 142.05 Q09-07C 658.89 14.33 0.006 Upwards Q09-07D 659.03 36.38 Q09-07D 659.03 36.38 -0.21 Downwards Q09-07F1 638.30 134.90 Q09-07F1 638.30 134.90 -0.48 Downwards Q09-07F2 630.82 150.50

b. Measured baseline information is provided in Appendix 7A of the original Application (April 2010), as measured water levels were used for the model calibration. Additionally, historical pumping rates were also used to include existing well pumping effects on groundwater.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Question 15:

SIR Response 64 (a), Part 3 – AENV, Pages 221 and 222

JACOS identifies that the average of transmissivity values before the limiting boundary and after the limiting boundary were used to assess the long-term potential drawdown in the aquifer.

It is assumed that the higher transmissivity value is reflective of the aquifer property in the vicinity of the well before the drawdown cone has reached the boundary and the later time lower transmissivity value is reflective of well response after encountering the limiting boundary a. Provide a rationale regarding how an average transmissivity of these values will reflect long- term well response.

Response 15

As stated in the Waterline report (unpublished), selection of the transmissivity value at the inflection point (average of 2 lowest values) is supported in the literature by Driscoll (1986) and Freeze and Cherry (1979), and is expected to reasonably reflect hydraulic characteristics of the aquifer interval being tested. Based on analysis of the aquifer test data, the transmissivity of the Empress interval was determined to range from a high of 62.0 m2/day during early pumping (pre- boundary), to a low of 8.5 m2/day during later stages of the test (post-boundary).

It should be noted that the theoretical calculations for long-term yield required by AENV do not account for recharge (from surface or adjacent formation) and geologic complexity. However, the results of such calculations represent a conservative prediction of drawdown in an aquifer, given the safety factors incorporated. Nevertheless, long-term monitoring is typically required by AENV to confirm aquifer performance in relation to these theoretical calculations. If the observed drawdown in the aquifer exceeds established performance standards (in this case the Water Conservation and Allocation Policy) then steps are required to understand why, and to mitigate the situation if necessary.

JACOS intends to monitor the performance of the Empress aquifer to ensure its viability as a water supply source to the Expansion Project. The intent will be to ensure that established performance standards are maintained. Monitoring will be conducted as part of an agreed-upon plan supporting the terms and conditions outlined in the Water Act approval. This information will be assessed against theoretical calculations. If a significant departure is noted, that may threaten established drawdown targets in the Water Conservation and Allocation Policy, JACOS will investigate, and mitigate if necessary.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

REFERENCES

Driscoll, F.G. 1986. Groundwater and Wells (2nd edition). Johnson Filtration Systems Inc. ISBN 0- 9616456-0-1, 1089 pp.

Freeze, R.A. and J.A. Cherry. 1979. Groundwater. Prentice Hall Inc., Englewood Cliffs, New Jersey, ISBN 0-13-365312-9. 604 pp.

Waterline. 2009. Summary of Empress Formation Aquifer Test Program, Hangingstone West Expansion, South of Fort McMurray, Alberta. Unpublished report prepared for JACOS. October 2009.

Question 16: Long Term Sustainable Yield of Water Well

SIR Response 64 (c), Part 3 – AENV, Page 224

JACOS describes that the estimated long term sustainable yield for well DQ06-8, for the life of the Project (i.e., 25 years), is 806.37 m3/day.

Previously (in Volume 2, Section 7.6.1.2, Page 7-24), JACOS states that Based upon this test, the estimated deliverability potential for the Empress Formation aquifer indicated a potential long- term sustainable yield on the order of 780 m3/day. a. Explain how the well yield would increase from 780 m3/day (at 20 years) to 806.37 m3/day (at 25 years).

Response 16

Two different methods were used to calculate the predicted theoretical long-term safe yield, which would account for the two different well yield volumes.

3 The initial Q20 calculated for the Empress Formation (780 m /day) was based on Farvolden’s 20-year theoretical safe yield formula of:

Q20 = (0.68) (T) (H) (0.7) Equation 1

To calculate the theoretical safe yield for the life of the project (25 years), the following Cooper- Jacob (1946) equations were used:

r 2 ⋅ S u = Equation 2 4 ⋅T ⋅t s ⋅T ⋅ 4π Q = Equation 3 W (u)

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

The Farvolden Q20 calculation reflects a theoretical long term yield for the DQ06-08 well, while the

calculated Q25 value reflects the theoretical long term yield for the Empress aquifer in the vicinity

of well DQ06-08. As required by Alberta Environment, the Farvolden Q20 calculation provides an estimate of the long-term yield of the production well itself and is not a measure of the long term yield of the aquifer. The Farvolden equation incorporates a 30% safety factor to address well inefficiencies, such as frictional losses across the well screen which tend to increase drawdown in the well that may be caused by the production well design. As Farvolden did not develop a similar

equation to evaluate the 25 year sustainable yield of the well (Q25) JACOS applied the Cooper- Jacob form of the Theis equations to establish the long term theoretical yield of the aquifer.

The theoretical long-term yield calculated for a period of 25 years (807 m3/day) is based on the assumption that drawdown at a well located 150 m from the pumping well cannot be more than 50% of the available head, as per Alberta Environment’s Water Conservation and Allocation Policy for Oilfield Injection (AENV 2006).

Because the estimates of drawdown at a well 150 m from the pumping centre are theoretical and do not accommodate recharge from adjacent layers, they are considered conservative. As such, JACOS intends to monitor groundwater levels within the Empress Formation and shallower intervals to identify what the actual drawdown conditions will be during groundwater withdrawal to ensure that the goal of the above noted policy, as well as any terms and conditions of an associated Water Act approval are met.

Question 17: River Boundary Condition and Water Levels

Responses 67 (a) to 67 (c), Part 3 – AENV, Page 226

In SIR 67 (a), JACOS states River boundary conditions were used for rivers and creeks. In SIR 67(c), JACOS states the boundary condition placed on rivers and lakes was a constant head condition (no change). a. Explain the apparent contradiction in river boundary condition in Responses 67 (a) and 67 (c). b. What were the changes in water levels in Horse Creek and Horse Creek tributaries due to pumping, and what was the calculated hydraulic gradient between surface water and groundwater along Horse Creek and Horse Creek tributaries?

Response 17

a. In 67 (a), the river boundary condition in the MODFLOW code was selected to represent rivers and creeks within the model domain. This boundary condition represents a hydraulic head condition of the stream that does not change temporally, and an exchange term between the groundwater and surface water realms based on a streambed conductance term. In 67 (c), a constant head condition was mentioned to explain a major assumption of the river boundary

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

condition: that a temporally constant specified-head value in the rivers was used to represent the river stages. b. As described in Response 17 (a), the boundary condition applied in the groundwater flow model for the rivers and creeks was a constant specified-head with flux term, or river boundary condition. Because no temporal changes in river stage (river-water levels) are accommodated by this boundary condition, no water level changes would be simulated in Horse Creek or its associated tributaries during groundwater pumping simulations.

The predicted decrease in discharge of groundwater to surface water bodies (less than 5%) is considered to be negligible over the life of the Project and, therefore, water-level declines in Horse Creek and its associated tributaries are not expected to occur as a result of pumping from the Quaternary aquifers. The hydraulic gradient between the surface water and groundwater along Horse Creek and its tributaries was found to be quite variable, with values ranging from close to zero up to approximately one, depending on the location of the river reach. This variation of gradient is because of hydraulic head distribution and spatial distribution of hydraulic conductivity within, and between, the various formations between the pumping zone and surface.

Although the groundwater flow model indicates potential changes to hydraulic gradients in Horse Creek and its associated tributaries, JACOS plans to conduct groundwater-level monitoring to confirm actual effects from groundwater withdrawal in support of the Expansion Project. This groundwater-level monitoring is conceptually planned for intervals between the zones of groundwater withdrawal and the surface environment to detect such potential changes before being realized at the surface. Key receptors and locations will be identified for monitoring in the Groundwater Management Plan.

Question 18: Groundwater Levels and Drawdown

SIR Response 68 (a), Part 3 - AENV, Page 227

JACOS states that JACOS would consider the trigger to be a consistent downward trend in water levels within these aquifers as determined by successive monitoring results. a. How will JACOS differentiate between the consistent downward trend in water levels, which is expected in key aquifers during the course of water production from excessive drawdown? b. What will be the drawdown values at varying distances from the production well (e.g., at distances in the order of 100 m, 250 m, 500 m, etc.) that will trigger investigations for relocating wells and/or identifying alternative sources?

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Response 18

a. Upon Project approval, JACOS will develop a Groundwater Management Plan (GMP) specifying site-specific triggers for groundwater levels—as well as a suitable monitoring network—to ensure compliance with the requirements of EPEA approval and the Lower Athabasca Region Groundwater Management Framework.

To differentiate between excessive drawdown versus a downward trend in water levels, the GMP will:

• stipulate the frequency of manual and electronic (datalogger) water level measurements, as well as the frequency of data analysis and reporting • define the maximum acceptable drawdown for each trigger well in the network • provide a statistical analysis of baseline water level data for each monitoring well to distinguish between natural variability and drawdown from pumping b. The GMP will specify the maximum acceptable drawdown for each trigger well in the monitoring network. It is expected that conservative trigger values will be set initially based on predicted drawdown values from the groundwater model and available baseline data for each well. After a specified period of time (e.g., one year), sufficient data will exist to recalibrate the groundwater model. After recalibration, effectiveness of the proposed trigger levels can be reevaluated.

4.2. Hydrology

Question 19: Stormwater Pond Capacity

SIR Response 1 (c), Part 3 – AENV, Pages 101 to 103

JACOS explains that the stormwater pond is sized to accommodate a 1-in-25 year, 24-hour rainfall event, and also that there is 1 m of freeboard to allow for operational flexibility, and that the freeboard will normally be unused and available. One of the effects of climate change is that large rainfall events can occur more frequently. a. What is the additional storage volume provided by the 1 m freeboard in terms of an equivalent 24-hour rainfall event? b. From available precipitation data from nearby stations, are there records showing two 24-hour consecutive rainfall events, such that total storage volume provided by the pond may be exceeded? i. If yes, describe mitigation plans to address possible overflow-related downstream impacts.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Response 19

a. Utilizing the freeboard, the storage pond has a storage capacity of approximately 34,200 m3 and can accommodate runoff volume generated during the 1:100 year 24 hour rainfall event, which has a rainfall depth of 95.9 mm. This event is about 1.25 times the 1:25 year 24 hour rainfall event, which has a rainfall depth of 76.9 mm. b. Historical 48 hour rainfall depths were determined, based on the Environment Canada daily precipitation data set measured at the Fort McMurray Airport between 1944 and May, 2011. The 1:25 year 24 hour rainfall has a total rainfall depth of 76.9 mm, while the 1:100-year 24 hour rainfall depth is 95.9 mm. There were only three 48 hour periods on record where the 48 hour rainfall depth was greater than 76.9 mm. The highest 48 hour rainfall depth over the period of record was 107.5 mm, which is 11.6 mm higher than the 1:100 year 24 hour rainfall event. i. It is possible for the stormwater pond to overflow; however, it will be equipped with an overflow spill route. The overflow spill route will be designed to ensure that any water that overflows from the pond is conveyed in a manner that does not cause erosion downstream.

The spill route will be located to direct the water in a direction that is consistent with the surrounding topography and the normal flow of surface water. The outfall area will be equipped with rip-rap or similar to safeguard the terrain against erosion during the release. JACOS will monitor all retention ponds on a daily basis and also monitor all discharges to crown lands.

Question 20: Winter Runoff

SIR Response 85, Part 3 – AENV, Table 85-1, Page 274

In Table 85-1, JACOS provides a summary of mean monthly runoff, precipitation, and runoff to rainfall ratio for the LSA. Table 85-1 also shows runoff values for the winter months (January, February, November and December). a. Provide sufficient evidence that winter flows, in approximate proportion to the Hangingstone flow gauge, occur within the LSA as assumed to justify the winter flows noted in the annual hydrographs. If not, modify the LSA hydrographs to reflect winter conditions so that future monitoring data can relate better to existing conditions.

Response 20

a. The historical winter runoff values were estimated based on the hydrometric station located on the Hangingstone River at Fort McMurray (07CD004). The field measured winter flow data in the LSA comprises spot-measured flows at three locations near the footprint (see Volume 2A,

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Section 8A, Table 8A-10). These measured flow data indicate that runoff during winter months is higher in the upper reaches of the Horse River watershed compared with the historic mean winter runoff at the hydrometric station located on the Hangingstone River at Fort McMurray (07CD004). Therefore, the Hangingstone River gauged data might not accurately represent winter flows in the LSA. As discussed in Volume 2A, Section 8A.4.5, additional field data is required to better understand the variability of flow in the LSA during the low-flow season. Presently, there are not enough low flow data to develop low-flow statistics for the LSA.

The uncertainty related to the low-flow statistics has no bearing on the predicted effects of the Expansion Project on the hydrology of the LSA. The effect of the Expansion Project on mean seasonal runoff (i.e., non low-flow period) and peak flow was estimated to be not significant. It is expected that the effect of the Expansion Project on-low flow hydrology is expected to be similarly not significant.

Question 21: LSA – Surface and Sub-Surface Flows

SIR Response 89 (a), Part 3 – AENV, Page 278

JACOS states that flows in the LSA have been characterized using a regional analysis based on long-term stream flow data recorded by the WSC. a. Describe how the regional analysis conducted by JACOS characterizes flows in the LSA to account for the effect of linear infrastructure such as gravel roads and pipe racks and spatially- distributed infrastructure such as well pad areas, on surface and subsurface flow patterns.

Response 21

a. The regional analysis was used to establish the baseline case flows for the LSA. The recorded stream flow data used in the regional analysis were collected over the past 20 to 30 years and, therefore, account for the effect of linear and spatially distributed infrastructure that existed in the watersheds over that time. The recorded stream flow data includes surface and subsurface flows conveyed by the watercourses.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

5. Terrestrial

5.1. Conservation and Reclamation

Question 22: Gravel Pits

SIR Response Part 1, Figure 1-1 SIR Response Part 2A, Section 15.4.1.2, Figure 15-4, Page 15-16 SIR Response Part 2B, Section 11.6.1, Figure 11-1, Page 11-2

JACOS has identified a new gravel pit southeast of the proposed CPF, adjacent to Highway 63, but there does not appear to be an identified access to the gravel pit.

a. Discuss how JACOS plans to access the gravel pit. b. Confirm that the access road to the pit, if required, has been included in the Conservation and Reclamation plan for the Expansion Project. c. If the access road has not been included, discuss the rationale for not including or provide updates, as necessary, to the EIA, Conservation and Reclamation Plan, and Terrain and Soil Baseline Report.

Response 22

The gravel pit identified in NW 12-84-11 W4M and its access are an operation belonging to Rickard Excavation, a third-party commercial supplier. Roadways and truck access will be part of the consideration of Rickard’s commercial operation and as such JACOS has no authority to dictate the roadway access for the gravel pit. Rickard’s have advised JACOS that following evaluation of the gravel it is of poor quality. Therefore it is unlikely that this pit will be utilized to supply aggregrate for the Expansion Project.

Question 23: Salvaged Fill and Reclamation

SIR Response Part 2A, Section 15.4.1.2, Table 15-10, Page 15-16 SIR Response 109 (a), Part 3 – AENV, Page 305 SIR Response 121(b), Part 3 – AENV, Page 322 Volume 1, Section 15.4.1.1, Table 15-8, Page 15-19 Volume 1, Section 15.4.1.1, Table 15-9, Page 15-19 Volume 1, Section 15.11.5, Table 15-16, Page 15-29

In SIR Response 109 (a), JACOS indicates that salvaged fill would be used to the greatest degree possible for the construction of roads and wellpads in the later phases of the Expansion Project as the initial developments are decommissioned and reclaimed. JACOS states that they would investigate alternative methods for disposal of any excess material, such as at an approved facility, should the need arise.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Tables 15-10 and 15-8 indicate that development area D would be the last area to be developed, with construction estimated to take place between 2026-2029 under the current plan. Table 15-9 indicates that 25 of the planned 26 pads will be developed by 2028, but that reclamation of the first 4 pads will not begin until 2029 (confirmed in SIR Response 121 (b)). It appears that no reclamation is planned until nearly all construction is complete. Table 15-16 indicates that, at pad closure, the fill and geotextile materials will be removed. a. Clarify the construction and reclamation timelines envisaged for the Project, with an estimate of how much fill material could be reused under the current proposed development schedule. b. Provide an estimate as to how much fill material will be required for construction of the well pads, and how much fill material will be removed from the well pad areas at closure and require disposal. c. Describe JACOS’ plan for these fill materials following their removal from the well pad areas, should it not be possible for them to be disposed of at an approved facility.

Response 23

a. See updated Section 15.4.1.1 Project Development and Reclamation Phasing and updated Table 15-8 and Table 15-9 in Section 15 of the Project Update. Under the current proposed development schedule, JACOS does not envisage that it will be able to reuse fill material. b. As indicated in Table 15-10, the anticipated fill requirements for the project are approximately 2,400,000 m3, including all facilities and infrastructure. Updates to this estimate will be developed on a site-by-site basis following detailed surveying and engineering and provided in JACOS’ annual conservation and reclamation report. c. If fill materials are deemed clean then the removed clay from the reclaimed deep organic area may be used to replace previously cut material to rebuild landforms such as hills or hummocks that were modified during initial construction.

The goal of the reclaimed landscape is to ensure there is sufficient micro-relief within the site to promote water-saturated soils and in all cases, the area will be reclaimed to conditions of equivalent land capabilities present prior to disturbances. Clay will not be removed from mineral uplands sites. It will be decompacted, recontoured, and followed by respreading of the stockpiled subsoil and then topsoil.

In the event that wellpad fill material is contaminated, it will be either disposed of at an approved facility or remediated in situ. Specific remediation plans would depend upon the nature of the contamination.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Question 24: Merchantable Timber Volumes

SIR Response Part 2A, Section 15.5.1.2, Table 15-12, Page 15-19

JACOS has indicated that Table 15-12 has been updated, based on a corrected disturbance footprint of 496 ha. The merchantable timber harvest volumes presented in Table 15-12 (Updated) are the same as those presented in the original Conservation and Reclamation Plan, dated April 2010. a. Confirm that the timber volumes presented in Table 15-12 (Updated) are correct. b. If the volumes are correct, discuss how the timber volumes were calculated and the rationale for why they remain unchanged, despite changes to the Project disturbance footprint. c. If the volumes are incorrect, provide updates as necessary to the Conservation and Reclamation Plan.

Response 24

The estimated merchantable timber volumes removed within the Expansion Project disturbance footprint presented in Table 15-12 (Updated) were incorrect in the February 2011 Supplemental Submission. The merchantable timber volumes presented in the updated Conservation and Reclamation Plan (Part 2A, Section 15, Table 15-12 (Updated)) provides corrected merchantable timber volumes for the updated Expansion Project footprint.

Question 25: Salvage at Source Water Well Pad

SIR Response Part 2A, Section 15.6.2.2, Table 15-13, Page 15-21 SIR Response 107(a), Part 3 – AENV, Table 107-1, Page 298 SIR Response 107 (c), Part 3 – AENV, Table 107-2 and Table 107-3, Page 300 to 303

Note 3 at the end of Tables 107-1 and 15-13 indicates that JACOS plans to pad over all deep organics except those within the CPF and permanent camp areas. However, all four tables listed above also indicate that deep organic material from xtMLD soils on the source water well pad area will be salvaged. a. Clarify if deep organic materials will be salvaged from the source water well pad area. b. Confirm the planned reclamation process for the source water well pad area. c. Indicate the target ecosite for the reclaimed source water well pad area. d. Discuss JACOS’ confidence that they can successfully reclaim the source water well pad area to the target ecosite. Provide operational examples. e. Discuss the timeframe over which the target ecosite is expected to develop.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Response 25

a. See Section 15.6.2.2 Topsoil Salvage Prescriptions, Deep Organic Soils in Section 15 of the Project Update. No deep organic materials will be salvaged at this site. b. This feature is relatively small in area, 0.7 ha, which is situated 0.4 ha on mineral soils and 0.3 ha on organic soil. The organic material will be covered with geotextile material and padded up with fill to provide a stable working surface. At Expansion Project closure the geotextile and fill will be removed and the site reclaimed. The upland and disturbed area to upland and the deep organics will be allowed to return naturally to pre-disturbance conditions. c. See revised Table 15-21 Ecosite Phase Areas in the Footprint, Post-reclamation (Conceptual) (Updated). The target is a d1 ecosite phase for the uplands and disturbed area and SONS for the deep organics. d. This is a common reclamation procedure and JACOS is confident that using experience gained with reclamation at the existing Demonstration Project the source water well pad can be successfully reclaimed and revegetated as described. e. Within 5 to 10 years after reclamation has been completed the monitoring data should provide a reasonable indication of whether the site is progressing along a successional path consistent with the target ecosite phases. Factors such as wildfire (parts of the Expansion Project Area were burned over in 2010) might affect the length to time required and rate of recovery needed to reach a satisfactory outcome. As noted in Response 25d, above, JACOS’ experience with reclamation at the Demonstration Project and the results of the annual reporting will allow for a more accurate estimation of reclamation timeframes.

Question 26:

SIR Response Part 2B, Section 11.6.3.3, Page 11-8

JACOS indicates that of the 15 soil series mapped within the LSA, the McClelland (12.6% reduction), Firebag (7.0% reduction), and Bitumount (5.4% reduction) series will be most affected. JACOS also indicates that 13% of the organic soils will be lost, all relative to Baseline Case. These percent reduction values appear to be based on dividing the total ha lost for each soil series by the total number of ha in the LSA (1539.2 ha), and under represents the percentage loss of each given soil type due to disturbance by the Expansion Project. For example, 206.2 ha of Firebag soils have been mapped within the LSA. JACOS indicates that 113.6 ha of the mapped Firebag soils in the LSA will be lost due to Project activities, suggesting a 56% loss of Firebag soils. a. Discuss the rationale for using the total number of hectares within the LSA when calculating the percent reduction of each soil type due to Project activities rather than the number of mapped hectares of each soil type.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

b. Discuss any changes to the conclusions on Soil Diversity that may result from recalculating the percent reduction values for each soil type using the mapped number of hectares for each soil series. c. Provide updates to the EIA as necessary.

Response 26

a. The calculations illustrate the overall effect of the Expansion Project on each soil map unit by calculating the change in area and proportion (% of LSA) compared to the Baseline Case. For example, McClelland soils occupy 7.8% (122.0 ha) of the LSA at Baseline Case. At Decommissioning this is reduced to 5.5% (86.1 ha), representing a 2.3% overall reduction of McClelland soils in the LSA relative to the Baseline Case. b. No changes to the conclusions regarding Soil Diversity would result from calculating reductions based on mapped hectares of individual map units. Conclusions are based on changes within the context of the LSA and the RSA. Note that approximately 437 ha of the soil units will be disturbed by the Project within the LSA, which represents about 28 percent of the total LSA. No soil map unit within the LSA is reduced by more than 50 percent of its original extent and most lose less than 30 percent. No map units are eliminated and most are well represented within a regional context (see Golder 2004). The exceptions are Atypical Bonnie and Albian, both of which are reduced in extent by approximately 15 percent. c. Table 11-11 has been updated to present percent reductions for each map unit and as proportions of the LSA.

REFERENCES:

Golder Associates. 2004. Acid Deposition Sensitivity Mapping and Critical Load Exceedances in the Athabasca Oil Sands Region. Report for NOx–SO2 Management Working Group, Ft. McMurray, Alberta.

Question 27: Location of Drilling Sumps

SIR Response 102 (a), Part 3 – AENV, Page 289

JACOS indicates that they are conducting a geotechnical investigation program during the winter of 2010-2011 to determine appropriate locations for placement of the sumps to be used for the disposal of non-oily cuttings. a. Based upon this geotechnical drilling program, provide updated information on the number, size, and location of the proposed drilling sumps that will be used for the Project. b. Provide updates as necessary to the EIA, including: i. Project component footprint maps and figures,

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

ii. material balance calculation tables, iii. total disturbance area calculations, and iv. pre-disturbance and post reclamation land capability classes.

Response 27

a. The drilling sumps for the Expansion Project will be located within the three areas that have been identified for clay borrow material (see Part 2A, Section 1, Figure 1-1). Based on the current geotechnical information, JACOS expects there to be sufficient clay within these areas to accommodate both construction borrow pits and drilling sumps. The project sump requirements are approximately 9,290 m3 for drilling activity in 2012; 4,800 m3 for drilling activity in 2013; and 6,200 m3 for drilling activity in 2014.

Additional sump suitability tests will be conducted prior to the start of drilling each year to finalize the number, size, and specific location of the drilling sumps. JACOS expects to locate one sump in each of the three locations referenced.

b. i. For a detailed footprint map, please see Part 2A, Section 1.1, Figure 1-1. ii. See Section 15.11.5 Reclamation Material Balances and revised Table 15-15, Table 15-16 and Table 15-17 in the Project Update. iii. See Section 15.4.1 Project Components and revised Table 15-7: Project Components in the Footprint (Updated) in the Project Update. iv. See Section 15.11.6 Land Capability, revised Table 15-18: Areas of Predisturbance and Post-reclamation Land Capability Classes in the Footprint (Updated) in the Project Update.

5.2. Terrain and Soils

Question 28: Disturbed Areas in the Soils LSA

SIR Response Part 2A, Section 15.1, Figure 15-1 SIR Response Part 2A, Section 15.3.5, Figure 15-3 SIR Response 137 (a) and (c), Part 3 – AENV, Figure 11A-8, Page 337

JACOS indicates that Figure 11A-8 has been revised to reflect the mapping updates described in Response 137 (a). The electronic Figure 11A-8 provided in the SIR Response indicates a map polygon labelled as 10BMTzzpt, adjacent to assessment point 27CB that appears to be a pipeline right of way (ROW). Other polygons along this pipeline ROW have been labelled as ‘disturbed land’. Other soil maps also indicate this polygon as Bitumount soils, while the ecosite phase shown on Figure 15-3 is identified as ‘disturbed’. a. Confirm the appropriate soil classification for this polygon.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011 b. Confirm there are no other pipeline ROWs (or other disturbance areas) within the LSA that have been labelled ‘undisturbed’. c. Discuss any changes to the areal extent of mapped soil series and reclamation material balance calculations that would result if the soils were mapped as ‘disturbed’. d. Provide any changes or updates to the EIA as necessary.

Response 28

a. The ‘disturbed lands’ have been remapped during a footprint revision initiated to update the

project disturbance footprint. The polygon labeled as 10BMTzzpt has been relabeled as ‘disturbed land’. Some additional polygons have been added to the ‘disturbed land’ category in areas previously not part of the LSA. b. There are no additional disturbance areas labeled ‘undisturbed’. c. ‘Disturbed land’ extent has increased slightly, with a corresponding decrease in other soil map units. The previous LSA was 1539.2 ha, of which 92.6 ha was mapped as disturbed. The current LSA is 1554.3 ha in size, of which 118.1 is mapped as disturbed land. This represents an increase of 25.5 ha, or 1.6% of the current LSA. There has been a very slight increase in the size of the LSA and a decrease in the disturbance footprint due to the update. The additional increase in ‘disturbed land’ was primarily due to the addition of a transmission line corridor. This was somewhat offset by a reduction in size of the Project disturbance footprint in other parts of the lease. d. The appropriate sections of the EIA and baseline have been rewritten to reflect the updated labeling and mapping of ‘disturbed land’ (see Volume 2, Section 11 and 11a in the EIA update).

Question 29: Ground Heave

SIR Response 117, Part 3 – AENV, Page 316

JACOS responded to SIR 117 in relation to riverbank instability, steep slopes, erosion, and mass movement, but no mention was made of the possible effects of ground heave and/or subsidence on stream flow direction, flow volumes, or other effects to stream hydrology. JACOS further indicates that no evaluation of the potential effect of ground heave in relation to meandering stream channels has been made. a. As a potential ground heave of 0.40 m has been identified in the EIA, does JACOS expect the SAGD process for the Expansion Project to result in measurable ground heave at surface. If so, what impacts are anticipated on the local meandering streams in terms of flow direction, potential for ponding and general alteration of floodplain character? b. What monitoring measures are planned to assess these potential changes?

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Response 29

a. The potential ground heave because of steam injection was originally estimated at up to 0.40 m in the original Application (April 2010). This value has been updated to 0.28 m, based on modeling completed for JACOS’ Caprock Integrity Study. Topographic relief across the Project LSA ranges from 0.5% to 2% as the LSA experiences a gradual increase in elevation from the northwest (545 m, Horse Creek) to the southeast (680 m) corner. Although there might be potential for localized impoundment of surface water because of ground heave, the ground slope and topographic relief near the project footprint would prevent significant changes in surface drainage patterns and floodplain characteristics. b. JACOS will develop a heave monitoring program for the Expansion Project. The heave monitoring program will likely include heave monument markers measured from the ground using precise levelling equipment, reflectors measured by satellite, or a combination of the two. The measuring points will be mounted on piles driven to refusal (typically 10 m – 20 m) so that heave of bedrock from thermal expansion or pressure from subsurface operations is measured as opposed to movement resulting from frost-thaw cycles. The measuring point piles cannot be situated in watercourses but will be laid out such that movement of watercourse beds can be estimated by interpolation from surrounding heave monuments.

Question 30: Timing of Vegetation Clearing

SIR Response 131 (a), Part 3 – AENV, Page 332 SIR Response 131 (d), Part 3 – AENV, Page 332

In the response to timing of vegetation clearing and mitigation measures, JACOS references the responses to SIR 102 (b) and 102 (a). SIR 102 dealt with the disposal of non-oily cuttings and the location of drilling waste disposal areas. a. Provide the correct reference for SIR Response 131 (a) or provide the required response. b. Provide the correct reference for SIR Response 131 (d) or provide the required response.

Response 30

a. JACOS proposes to minimize to the degree practical, based upon ground surface and weather conditions, the time between the completion of vegetation clearing and the start of topsoil salvage and site construction. b. At this time no specific topsoil erosion mitigation measures are proposed should there be a gap between clearing and the start of topsoil salvage. If, however, there is a delay between these operations a site-specific assessment of the conditions and suitable erosion mitigation measures would be developed and implemented. These measures could include, but are not limited to: spraying with water or a tackifier if the topsoil has dried out and wind erosion is occurring, or installation of silt fences/sediment barriers or temporary berms if water erosion becomes an issue. The experience of the Construction Manager and the site conditions at the

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

time will be the determining factors in the selection of appropriate measures and the timing of their implementation.

5.3. Wildlife

Question 31: Bird and Wildlife Deterrents

SIR Response 140, Part 3 – AENV, Page 340

JACOS has provided a list of potential bird and wildlife deterrents that they may utilize.

a. Confirm which methods would most likely be utilized and describe why. b. Identify the deterrent method(s) that JACOS is committing to utilize.

Response 31

a. JACOS will install a fence around the pond to deter wildlife and utilize effigies as bird deterrents. The pond is located on the CPF where process noise, activity, and lights act as a deterrent to birds and wildlife. Should effigies prove to not be effective JACOS will evaluate and implement other possible deterrent methods such as bird wire. b. JACOS will install a fence around the pond to deter wildlife and utilize effigies as bird deterrents.

Question 32: Light Mitigation

SIR Response 142, Part 3 – AENV , Page 341

JACOS has provided a list of potential light mitigation measures that will be considered.

a. Clarify which options JACOS is committing to utilize.

Response 32

JACOS is planning to utilize the following light mitigation methods:

• Avoid the use of high mast lighting; the lighting philosophy will be based on using task lighting with supplementary flood lighting to meet lighting requirements for personnel safety • Outdoor light fixtures will be equipped with hood reflectors or shields wherever possible to project light downward • Photocells and/or motion detectors will be installed to control light fixtures where appropriate

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

• Depending on the application, high-pressure sodium or fluorescent fixtures will be installed, instead of mercury or metal halide lamps; JACOS is also evaluating the use of LED lighting as an option, which provide directional lighting

Question 33: At Risk Species Mitigation Measures

SIR Response 143, Part 3 – AENV, Page 342

JACOS indicates that they will only mitigate the effects of the Project on caribou if the Project is in a designated caribou protection zone. Caribou are a federally and provincially listed species at risk, and the JACOS Project Area is in known caribou habitat with documented caribou use. a. Clarify how JACOS will mitigate the effects of the Project on woodland caribou. b. Clarify how JACOS will commitment to minimizing the effects of the Project on all species at risk and may be at risk species.

Response 33

a. JACOS has stated that as the Expansion Project Area is not included within a Caribou Protection Zone (CPZ); they would not be developing nor implementing a caribou protection plan. JACOS continues to hold this position. Although caribou have been observed in and adjacent to the Wildlife LSA, observations between the caribou ranges to the west and east and the LSA, have been very infrequent (refer to the Project Environmental Impact Assessment Volume 2, Part C, Section 13.6.1.2, Supplemental Information Request Round 2 Question #34, and Cichowski 2010) suggesting movements between these ranges as opposed to long-term use such as calving.

Strategies to mitigate the effects of habitat loss, connectivity, and mortality on caribou are provided in Volume 2, Part C, Sections 13.6.1.2, 13.6.2.2, and 13.6.3.2 (April 2010) and Table 33-1.

b. The remaining at risk or may be at risk species (ASRD 2010) that could potentially occur in the JACOS Terrestrial LSA include: • Canadian toad – may be at risk; • Short-eared owl – may be at risk; • Olive-sided flycatcher – may be at risk; • Northern bat – may be at risk; and • Wolverine – may be at risk.

JACOS has provided mitigation measures in the EIA (April 2010) to reduce effects on wildlife including at risk and may be at risk species. These measures are provided in Table 33-1.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Table 33-1 Mitigation Measures to reduce Project Effects on Wildlife Including At Risk and May Be At Risk Wildlife Species

Concern Mitigation Habitat Integrate project developments with other existing or proposed land use activities, where possible, Availability to minimize new disturbance, density of linear features, industrial noise and habitat loss. Whenever possible, use existing rights-of-way (ROWs) for access and installation of any new infrastructure to minimize direct habitat loss – JACOS will use existing ROWs that are starting to regenerate only when other reasonable options do not exist. Avoid clearing or conduct preclearing nesting surveys from April 1 through August 31 to avoid active migratory bird nests. Construct AGP crossings at appropriate intervals to allow for wildlife movements; where natural undulations in the topography occur, AGPs may be high enough to accommodate the movement of animals under the pipe. During construction of underground pipelines, leave gaps in linear construction areas to allow animal movements across the work area. Prohibit dogs on site during all phases of the Expansion Project. Reclaim upland sites to an equivalent land capability. Conduct progressive reclamation throughout the Expansion Project development, including actively revegetating utility and pipeline corridors as early as reasonably practical. Use certified native vegetation species in reclamation. Allow natural woody vegetation to grow back along the edge of cleared pipeline and power line ROWs, where possible, to reduce lines of sight while accommodating safety and pipeline monitoring concerns. Provide appropriate supervision during environmentally sensitive construction activities to ensure environmental mitigation is implemented. Implement appropriate erosion control measures. Maintain adequate water flow where all-weather roads cross peatland areas, watercourses or wetlands by installing culverts or other drainage techniques, as deemed appropriate. Take appropriate precautions at all water crossing locations to minimize disturbance of the stream bed and banks. Confine instream construction activities, if required, to isolated channel sections and not interrupt flows. Suspend construction during periods of heavy runoff (e.g., heavy rain or snowmelt events). In the event that a facility interrupts the natural flow of water related to a watercourse or waterbody, install surface drainage to redirect flow around the facility. Conduct fuelling and oil and gas transfer operations at an appropriate setback distance from watercourses and waterbodies. Limit off-road access by rolling back debris or reclaim intersections with existing linear disturbances. Provide facilities, including wellpads, roads and pipelines (except for watercourse crossings), with an appropriate setback distance from watercourses and waterbodies - this will be determined in consultation with ASRD.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Table 33-1 Mitigation Measures to reduce Project Effects on Wildlife Including At Risk and May Be At Risk Wildlife Species (cont'd)

Concern Mitigation Habitat Construct AGP crossings for wildlife at appropriate intervals to allow for wildlife movements. Where Connectivity natural undulations in the topography occur, the AGP may be high enough to accommodate the movement of animals under the pipe during construction of underground pipelines or leave gaps in linear construction areas to allow animal movements across the work area. Direct Maintain setback distances from watercourses and waterbodies. Mortality on Implement fuel and chemical spill contingency and response plans. Wildlife Impose speed restrictions on JACOS roads to improve road safety and reduce risks of wildlife mortality. Prohibit workers from feeding wildlife, to prevent habituation. JACOS personnel will be prohibited from carrying firearms while on shift or staying at camp. Therefore, mortality related to hunting by personnel is not considered a direct mortality risk in this assessment. Consequently, hunting on JACOS surface land dispositions or using these lands to access non-JACOS lands for these purposes by JACOS personnel (including employees, contractors and site visitors) during any phase of the Expansion Project is unlikely. Limit or eliminate, where possible, odours that attract bears. Manage food waste properly. Implement a Bear Management Plan (see Appendix 13D of EIA). Install erosion and sedimentation control measures (silt fences, check dams, biotechnical controls, settling ponds). Implement spill prevention, control, and containment practices.

REFERENCE

Cichowski, D. 2010. Status of the Woodland Caribou (Rangifer tarandus caribou) in Alberta: Update 2010. Alberta Sustainable Resource Development. Wildlife Status Report No. 30 (Update 2010). Edmonton, AB. 88.

Question 34: Winter Aerial Survey

SIR Response 149, Part 3 – AENV, Page 350

The results of the aerial survey completed have not been submitted yet. a. Provide the results of the February 2010 and January 2011 surveys.

Response 34

UNGULATE AERIAL SURVEY

An ungulate aerial survey was conducted for the Project in the Local Study Area (LSA) and within the Regional Study Area (RSA) on February 27 and 28, 2002. Methods and results from the 2002 survey are presented in Appendix 13B in Volume 2 of the EIA (JACOS 2010). An additional

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

ungulate aerial survey was conducted within the LSA and RSA on February 25 and 26, 2010 to supplement data collected in 2002.

METHODS

Sampling in the LSA and RSA in 2010 was stratified to focus on high quality caribou habitat (Figure 34-1). The survey was flown during favourable weather conditions (i.e., good visibility, adequate snow cover, and low to moderate winds) at a speed of 60 to 100 km/h and approximately 150 m above the ground. Three observers observed up to 200 m on either side of each transect, depending on habitat and visibility.

Locations of deer, moose, caribou and their sign (e.g., tracks and foraging craters), were collected using a GPS unit. For each observation, the time, sex, age (if possible), location and habitat type by ecosite phase (as defined by Beckingham and Archibald 1996) was recorded. All incidental wildlife sightings and weather conditions were recorded.

RESULTS

Approximately 1,403 km2 were surveyed during the 2010 ungulate aerial survey and a total of 6 white-tailed deer, 3 mule deer, 30 moose, and 13 caribou were detected (see Table 34-1). Caribou and caribou signs were not observed in the LSA (see Figure 34-2) but were observed in the caribou range to the east and west of the LSA. The closest caribou observation is 6.7 km from the Project LSA.

Table 34-1 Ungulate Observations from the 2010 Aerial Ungulate Survey

Adult Survey Area Distance Flown Species Calves Total (km) Male Female Unknown LSA 104 White-tailed Deer 0 2 0 0 2 Moose 1 2 0 1 4 RSA 526 White-tailed Deer 0 1 2 1 4 Mule Deer 0 0 3 0 3 Moose 1 16 2 7 26 Caribou 0 4 5 4 13

WINTER TRACK COUNT SURVEY

Winter tracking surveys were conducted for the Project in and adjacent to the LSA from February 1-4 and 13-17, 2001. Methods and results from the 2001 survey are presented in Appendix 13B in Volume 2 of the EIA (JACOS 2010). An additional winter track count survey was conducted January 31 to February 2 and March 13, 2011 to supplement data collected in 2001.

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JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

METHODS

Tracking protocols have been developed based on the Finnish Triangle methodology (Hogmander and Penttinen 1996) with consideration of the Alberta Biodiversity Monitoring Institute (ABMI) winter terrestrial protocols (ABMI 2010). Triangular transects were 6 km, two km per side and were placed randomly within the study area.

All tracks that intersected the transect were identified and recorded in 25 m intervals. Waypoints of focal species were recorded with a GPS at the point of intersection of the transect. If a location had more than one snowshoe hare or red squirrel track (i.e., runs) and the number of individual tracks could not be determined, five tracks were recorded for snowshoe hare runs and three tracks were recorded for red squirrel runs. Shrub and tree species composition was also recorded every 25 m interval to verify ecosite phase at each boundary or transition. Snow depths were measured at every 100 m interval. Incidental observations were also recorded (e.g., sightings, old tracks of focal species).

Tracking was conducted after 48 hours of a fresh snowfall greater than 5 cm, allowing time for tracks to accumulate. Tracking occurred over a period of several days and, therefore, a standardized index of track abundance was used to examine the number of tracks observed per kilometre per day (tracks/km/d) for each species. This standardized index of track abundance has been used in other tracking studies and inventory standards (e.g., Raine 1983; British Columbia Ministry of Environment, Lands and Parks 1998).

A total of 27 km were surveyed (see Figure 34-3) in 19 undisturbed ecosite phases, 5 disturbed (burn) ecosite phases, and in anthropogenic disturbances (see Table 34-2). Distances surveyed in each ecosite phase ranged from 25 m to 3,825 m (average 998 m).

Table 34-2 Winter Track Count Sampling Effort By Habitat Type

Habitat Type Ecosite Phase Description Distance Sampled in LSA (m) Undisturbed Ecosite Phases a1 Jack pine-lichen 100 b1 Jack pine / aspen blueberry 425 c1 Jack pine / black spruce-Labrador tea 1,950 d1 Aspen-low- bush cranberry 1,400 d2 Aspen / white spruce-low-bush cranberry 1,050 d3 White spruce-low-bush cranberry 175 e1 Balsam poplar / aspen-dogwood 725 e3 White spruce-dogwood 525 g1 Black spruce / jack pine-Labrador tea 2,575

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Table 34-2 Winter Track Count Sampling Effort By Habitat Type (cont’d)

Habitat Type Ecosite Phase Description Distance Sampled in LSA (m) h1 White spruce / black spruce-Labrador tea 700 i1 Treed bog 1675 i2 Shrubby bog 25 j1 Treed poor fen 375 j2 Shrubby poor fen 50 k1 Treed rich fen 25 k2 Shrubby rich fen 600 FONS Shrubby fen 3,425 FTNN Treed fen 2,800 SONS Shrubby swamp 1,200 Disturbed Ecosite Phases c1-burn Burned Labrador tea-mesic 1,325 g1-burn Burned Labrador tea-subhygric 3,825 i1-burn Burned treed bog 275 j1-burn Burned treed poor fen 50 k2-burn Burned shrubby rich fen 50 Anthropogenic Disturbances CL Clearing 225 DL Disturbed Lands 1,300 ROW Right-of-way 100 Total 26,950

RESULTS

A total of 16 species or species groups (i.e., grouse and deer) were detected during the 2011 winter tracking survey (see Table 34-3). Marten and fisher tracks are often difficult to distinguish and in such cases were identified as fisher/marten. The highest species diversity was recorded in the g1 and g1-burn ecosite phases (10 species or species groups). The lowest species diversity was recorded in the ROW and in the e3, i1-burn, i2, j1-burn, k1, and k2-burn ecosite phases (1 species). Tracks of species at risk and indicator species observed in the LSA include fisher, lynx, and moose (see Figure 34-4). Snowshoe hare occurred in the majority of habitats (all except k1) and had the highest average track density in the LSA (Table 34-3).

! Rg. 12 ! Rg. 11 Rg. 10

! W4M

! LEGEND

! Winter Tracking Survey

! Twp.85 ! !( Locations ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !

! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! Wildlife Local Study Area

! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !

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! I:\8618_514\MAPS\FIGURES\011_FIGURE_13B_2_DISTRIBUTION_OF_2011_WINTER_TRACKING_SURVEY_TRIANGLES.mxd

Rg. 12 Rg. 11 ! Rg. 10

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! Twp.85 ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! and Indicator Species ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !

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! I:\8618_514\MAPS\FIGURES\011_FIGURE_4_LOCATION_OF_KEY_INDICATOR_RESOURCES.mxd

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Table 34-3 Mean Track Densities for Each Wildlife Species or Group by Ecosite Phase in the LSA

Track Densities (tracks/km/d) Red Squirrel Red Short Snowshoe Ptarmigan Fisher / Grouse Weasel Weasel Weasel Coyote Marten Marten Moose Willow Fisher Least Lynx Mink Deer Hare Mean Wolf Habitat Snow - tailed

Type Depth

(cm ± SD) Undisturbed Ecosite Phases a1 - 39.2 5.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 b1 57.0± 10.8 162.9 2.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 c1 52.3±10.8 62.6 3.8 0.0 0.0 0.1 0.0 0.3 0.0 0.2 0.5 0.1 0.0 0.0 0.0 0.0 0.0 d1 51.3±6.7 12.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.2 0.0 0.0 0.0 0.0 0.2 0.0 0.5 d2 46.2±9.2 27.3 0.0 0.0 0.0 0.0 0.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.6 0.0 0.0 d3 - 7.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.9 0.0 0.0 0.0 0.0 0.0 0.0 e1 52.3±8.6 26.2 6.0 0.0 0.0 0.0 2.8 0.0 0.0 0.0 1.4 0.0 0.0 0.0 0.0 0.0 0.0 e3 48.0±10.0 8. 9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 g1 59.5±12.7 14.6 0.1 0.0 0.0 0.5 0.3 1.7 0.0 0.1 0.9 0.3 0.0 0.1 0.1 0.0 0.0 h1 51.4±10.9 20.6 1.4 0.0 0.0 1.4 0.0 2.1 0.0 1.1 0.0 1.8 5.7 0.0 0.0 0.0 0.0 i1 49.7±5.7 31.7 1.5 0.0 0.0 1.2 0.0 0.9 0.0 0.9 0.2 0.3 0.0 0.0 0.0 1.2 0.0 i2 - 10.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 j1 51.5±6.6 10. 7 0.0 0.0 0.0 0.0 0. 9 4.0 0.0 0. 7 0.0 2.0 1.3 2. 7 0.0 0.0 0.0 j2 - 15.0 0.0 0.0 0.0 0.0 0.0 5.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 k1 - 0.0 0.0 0.0 0.0 20.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 k2 55.6±6.7 68.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.8 0.0 0.0 0.0 0.0 0.0 0.0 0.0 FONS 69.6±10.3 23.7 0.0 0.0 0.1 2.8 0.1 2.3 0.0 0.0 0.0 0.0 0.0 1.8 0.1 1.3 0.0

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Table 34-3 Mean Track Densities for Each Wildlife Species or Group by Ecosite Phase in the LSA (cont’d)

Type Depth

(cm ± SD) Undisturbed Ecosite Phases (cont’d) FTNN 54.3±10.0 19.4 0.1 0.0 0.0 0.2 0.0 2.4 0.0 0.4 0.1 0.1 0.4 0.0 0.2 0.0 0.0 SONS 62.6±13.2 63.7 1.1 0.4 0.0 11.2 0.0 0.0 0.0 2.5 0.0 0.0 0.0 2.5 1.0 0.0 0.0 Disturbed Ecosite Phases c1-burn 55.8±6.0 123.0 0.0 0.0 0.0 0.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 0.0 0.0 g1-burn 51.0±6.5 42.0 1.1 0.3 0.0 2.7 0.7 0.0 0.4 0.4 0.0 0.1 0.0 0.1 0.0 1.0 0.0 i1-burn 57.5±7.8 53.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 j1-burn - 230.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 k2-burn 55.6±6.7 40.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Anthropogenic Disturbances CL 44.8±11.6 26.7 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.2 0.0 0.0 0.0 9.6 0.0 0.0 0.0 DL 47.25±15.9 30.6 0.0 0.4 0.0 2.3 0.3 0.4 0.0 0.0 0.3 0.0 0.0 0.4 0.0 0.4 0.2 ROW - 3.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Average 55.3±11.7 38.1 0.8 0.1 0.01 1.6 0.3 0.9 0.1 0.4 0.2 0.2 0.2 0.5 0.2 0.4 0.03

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

REFERENCES:

Alberta Biodiversity Monitoring Institute (ABMI). 2010. Terrestrial Field Data Collection Protocols, Version 2010-04-20. Alberta Biodiversity Monitoring Institute, Alberta, Canada. Report available at: http://www.abmi.ca/abmi/reports/reports.jsp?categoryId=0 [May 19, 2011]

Bayne, E.M., R. Moses, and S. Boutin. 2005. Evaluation of winter tracking protocols as a method for assessing the relative abundance of mammals in the Alberta Biodiversity Monitoring Program.

Beckingham, J.D. and J.H. Archibald. 1996. Field Guide to Ecosites of Northern Alberta. Canadian Forest Service, Northwest Region, Northern Forestry Centre. University of British Columbia Press, Vancouver, British Columbia.

British Columbia Ministry of Environment (B.C. MOE), Lands and Parks. 1998. Standards for Components of British Columbia’s Biodiversity No. 1. Prepared by Ministry of Environment, Lands and Parks Resources Inventory Branch for the Terrestrial Ecosystems Task Force Resources Inventory Committee, Victoria, British Columbia. Version 2.0. November 1998. 119 pp.

Hogmander, H. and A. Penttinen. 1996. Some Statistical Aspects of Finnish Wildlife Triangles. Finnish Game Resources. 49:37-43.

Japan Canada Oil Sands Limited (JACOS). 2010. Application for Approval of the JACOS Hangingstone Expansion Project. Summary Report, Volumes 1, 2A, 2B, 2C. Prepared by Matrix Solutions Inc./Stantec for JACOS, Calgary, Alberta. April 2010. Application available at: http://www.jacos.com/Applications.htm [May 19, 2011]

Raine, R.M. 1983. Winter habitat use and response to snow cover of fisher and marten in southeastern Manitoba. Canadian Journal of Zoology 61:25-34.

6. Health

Question 35: Atmospheric Deposition to Surface Water

SIR Response 159, Part 3 – AENV, Page 363 SIR Response 163, Part 3 – AENV, Page 367

In SIR 159, JACOS states that The ingestion of surface water pathway has been added to the multiple pathway assessment for the Baseline, Application and Planned Development cases.

It is unclear whether atmospheric deposition of COPCs to surface water was assessed in the Application and Planned Development cases.

In SIR 163, JACOS discusses the effect of atmospheric deposition on water in the context of deposition to soil and potential runoff from soil. It appears that atmospheric deposition directly to surface water may not have been considered

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011 a. Clarify if atmospheric deposition of COPCs to surface water was assessed. i. If not, provide an updated human health risk assessment, or provide quantitative evidence that this is not required. b. Provide quantitative evidence that contaminant inputs to surface water, both directly from atmospheric deposition and via runoff from soil, do not affect surface water quality, or include these inputs in an updated assessment of risks from surface water ingestion.

Response 35

a. Atmospheric deposition of COPCs to surface water was assessed as part of the fate and transport modeling conducted for the Application and Planned Development Cases. The model uses an equation recommended by the U.S. Environmental Protection Agency (U.S. EPA Human Health Risk Assessment Protocol, 2005) to calculate Total COPC Load to the Water Body (see equation below). One of the specific parameters used in this calculation is

LDEP which is defined as the total (wet and dry) particle phase and vapour phase COPC direct deposition load to a water body. The resulting exposure point concentrations for surface water were included for the application and planned development cases in the Appendix L supplemental submission which was completed in February 2011.

U.S. EPA Recommended Equation for Calculating Total COPC Load to the Water Body (LT)

LT = LDEP + Ldif +LRI +LR +LE +LI

LT = Total COPC load to the water body (including deposition, runoff and erosion) (g/yr)

LDEP = Total (wet and dry) particle phase and vapour phase COPC direct deposition load to water body (g/yr)

Ldif = Vapour phase COPC diffusion load to water body (g/yr)

LRI = Runoff load from impervious surfaces (g/yr)

LR = Runoff load from pervious surfaces (g/yr)

LE = Soil erosion load (g/yr)

LI = Internal transfer (g/yr)

b. As discussed in the response to Round 1, SIR 159, the ingestion of surface water pathway was added to the multi-media assessment for the Application and Planned Development cases and the results were included in the supplemental submission (Appendix L) in February 2011. The surface water ingestion pathway was one of many pathways that contributed to the multi-media assessment to calculate a cumulative total risk (HQ or ILCR) from all pathways combined. When considering surface water ingestion on its own, the results from the supplemental submission in February 2011 clearly show that for all COPCs HQ values are

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

below the benchmark of 1.0 and ILCR values are below 1-in-100,000. This indicates that there is no unacceptable risk posed to receptors via the surface water ingestion pathway.

Changes in design as outlined in the Project Update have been remodeled for the Project- Alone scenario. Results did not change the conclusions of the Project-Alone case and it is expected that the conclusions for the Application and Planned Development cases will not change for these scenarios. For updated results from the Project-Alone Case, please refer to the updated Volume 2, Section 19 provided in Part 2B of this submission.

Question 36: Modeled Theoretical Maxima Locations

SIR Response 160, Part 3 – AENV, Page 365

JACOS states that they believe that the Human Health and Ecological Risk Assessment satisfies the requirements of the TOR, given the remote location of the Expansion Project and the absence of any current habitation at the maximum point of impingement. a. Provide a map indicating the MPOI for each COPC and the modelled receptor locations to confirm the absence of any current habitation. For MPOI locations not coincident with or close to receptor locations, provide an assessment of the risks to a hypothetical transient receptor (recreational) at the MPOI.

Response 36

To ensure that areas of maximum effect potentially influenced by the JACOS Expansion Project were captured in the air quality and human health risk assessment, the dispersion modeling included receptors placed around the JACOS Expansion Project facility fenceline. Receptors were placed every 20 m along the fenceline and the fenceline receptors were included in the model runs completed for all COPC.

Dispersion modeling indicated that, in the area surrounding the JACOS Expansion Project, the highest concentrations occur near the plant site and decrease with increasing distance from the Expansion Project. As a result, the MPOI for each chemical is the maximum concentration predicted to occur along the Expansion Project fenceline for all COPCs. There is no habitation along the fenceline; therefore, a map is not required.

Furthermore, the HHERA assessed 45 discreet receptor locations including the Central Processing Facility (CPF) fenceline which is the closest in proximity to the facility stack emissions. As stated above, the MPOI for each COPC is predicted to occur along the CPF fenceline location which was included in both the updated Inhalation and Multi-Media Assessments. Although there is no habitation along the fenceline, the two most sensitive receptors were included in the assessment to maintain conservatism. Please refer to the updated Appendix 19A (Part 2B, Volume 2, Section 19) for the HHERA results from the CPF fenceline for both human and ecological receptors.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Question 37: Background Exposure in Water Consumption

SIR Response 164, Part 3 – AENV, Page 364

a. Provide an updated response to SIR 164, as necessary, in light of the additional information requested on the effects of atmospheric deposition directly to surface water with respect the updates requested for SIR Response 159 and 163.

Response 37

Please see the response to Question 35.

The re-modeling that was conducted and submitted (Appendix L) in February 2011 included atmospheric deposition to surface water in the multi-media assessment. This assessment did not identify any additional risks from ingestion of drinking water or fish consumption (inferred from surface water results and lack of baseline data for fish). The response to Round 1, SIR 164 does not require additional updates since the conclusions of the HHERA have not changed and atmospheric deposition to surface water was included in the previous supplemental submission.

Question 38: Additive Risks for Mixtures

SIR Response 173, Part 3 – AENV, Page 385 to 387

JACOS has grouped COPCs with similar critical effects but has not quantitatively considered additivity. Additivity of CR is acceptable for chemicals with threshold toxicity responses which have effects on the same target organ. This approach is common for EIAs in Alberta.

a. Characterize the additive risks for mixtures indicated in Table 173-1.

Response 38

As discussed in Volume 2, Part C, Appendix 19A, Section 19A.6.3.4, Page 19A-61 and in the JACOS response to First Round SIR 173, interpretation of chemical mixtures results is difficult because of both the lack of established standards or benchmarks for the assessment of mixtures by regulating agencies and the high level of uncertainty in chemical mixture evaluations. Health Canada (2004, 2009) and US EPA (2000) have addressed the idea of evaluating chemical mixtures by considering an additive approach “if sufficient data are not available on the effects of the chemical mixture of concern or a reasonably similar mixture” (USEPA 2000). Similarly, Health Canada (2004; 2009), states “for simultaneous exposure to multiple chemicals of potential concern, non-cancer Hazard Quotients should be assumed to be additive, and should be summed for those substances determined by the risk assessor to have similar target organs/effects/mechanisms of action”.

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The potential risks from chemical mixtures including additivity were characterized based on Table 173-1 in SIR Response 173 (provided below) are included in the update to Volume 2, Section 19, Appendix 19A, Section 19A.6.4.2.

Table 173-1 Summary of Composition of Chemical Mixtures Assessed

Exposure Potential Health Endpoint of Characteristics Mixture Chemicals of Potential Concern Acute Air Eye Irritants Acrolein; Dichlorobenzene; Ethylbenzene; Naphthalene; Exposure Toluene; Xylenes Nasal Irritants Acrolein; Chromium; Dichlorobenzene; Ethylbenzene; Toluene, Xylenes Respiratory Irritants Acetaldehyde; Carbon Monoxide; Cobalt; Copper; Formaldehyde; Nickel; Naphthalene; Nitrogen Dioxide; PM2.5; Sulfur Dioxide; Vanadium; Xylenes Neurological Effects Aliphatic C9-C16; Ethylbenzene; Hexane; Manganese; Toluene, Xylenes Chronic Air Nasal Irritants Acetaldehyde; Acrolein; Dichlorobenzene; Hydrogen Sulfide; Exposure Naphthalene Respiratory Irritants Cobalt; Copper; Formaldehyde; Naphthalene; Nickel; Nitrogen Dioxide; PM2.5; Sulfur Dioxide; Vanadium; Zinc Neurological Effects Aliphatic C5-C6; Carbon Disulfide; Hexane; Lead; Manganese; Toluene; Xylenes Reproductive/Developmental Effects Ethylbenzene; Lead Lung Carcinogens Chromium; Carcinogenic PAHs Nasal Carcinogens Acetaldehyde; Formaldehyde Chronic Oral Liver Effects (Hepatotoxicants) Aliphatic C9-C16; Fluoranthene Exposure Kidney Effects (Renal Toxicants) Aromatic C17-C34; Dichlorobenzene; Fluoranthene; Pyrene Haematological Effects Chromium; Cobalt; Copper; Fluoranthene; Fluorene; Zinc Neurological Effects Aliphatic C5-C8; Aluminum; Lead; Manganese

Question 39: Receptor Locations for COPC Maxima

SIR Response 174, Part 3 – AENV, Page 387 a. Provide a map or table indicating the receptor locations at which maximum risks occur for those COPCs that exceed regulatory thresholds.

Response 39

Please see Tables 39-1 through 39-4 for a summary of the location of the maximum risks for those COPCs that exceed regulatory thresholds.

Please note, only the Project-Alone Case data has been re-modeled to reflect the updates to the Expansion Project facility and predicted change in stack emissions. The Application and Planned

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Development Cases have not been re-modeled based on the presumption that the HHERA conclusions will not change for these scenarios.

Please see response to Question 38 for a discussion on assessing health risks associated with chemical mixtures. When assessing mixtures from modeled predictions, the maximum concentrations of the various chemical components of a specific mixture occur at different times and different locations; therefore, a receptor would not be able to inhale the maximum concentrations of all irritants simultaneously. As a result, it is not possible to identify an exact location for a particular chemical mixture exceedance.

Table 39-1 Locations of Maximum Regulatory Benchmark Exceedances (Baseline Case)

COPC Exceedance of Regulatory Benchmark Location Inhalation Assessment

PM2.5 24-Hour Exposure LSA (Fort McKay) Formaldehyde Lifetime Cancer Risk LSA (Fort McKay) Multi-Media Assessmenta Chromium AENV Toddler Receptor (HQ) LSA (Campground West of Clearwater Indian Reserve 175) and (Gregiore Lake Indian Reserve 176) Cobalt AENV Toddler Receptor (HQ) LSA (Campground West of Clearwater Indian Reserve 175) and (Gregiore Lake Indian Reserve 176) Lead AENV Toddler Receptor (HQ) LSA (Campground West of Clearwater Indian Reserve 175) and (Gregiore Lake Indian Reserve 176) Manganese AENV Toddler Receptor (HQ) LSA (Campground West of Clearwater Indian Reserve 175) and (Gregiore Lake Indian Reserve 176) Zinc AENV Toddler Receptor (HQ) LSA (Campground West of Clearwater Indian Reserve 175) and (Gregiore Lake Indian Reserve 176) Benzo(a)pyrene AENV/AHW Composite Receptor (ILCR) LSA (Trapper Cabins 1-4) Odour Assessment Carbon Disulphide 1-Hour Exposure LSA (Fort McMurray) Hydrogen Sulphide 1-Hour Exposure LSA (Fort McMurray) 24-Hour Exposure LSA (Fort McKay) Mercaptans 1-Hour Exposure LSA (Fort McMurray) Thiophene 1-Hour Exposure LSA (Fort McMurray) NOTE: a The CPF Fenceline receptor location was included in the multi-media assessment with the updated (Project-Alone) facility emissions so the Base, Application and Planned Development Cases do not have this location included in their assessments.

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Table 39-2 Locations of COPC Regulatory Benchmark Exceedances (Project-Alone Case)

COPC Exceedance of Regulatory Benchmark Location Inhalation Assessment

SO2 24-Hour Exposure CPF (Fenceline) Hydrogen Sulphide 24-Hour Exposure CPF (Fenceline) Multi-Media Assessment Benzo(a)pyrene AENV/AHW AR Receptor (ILCR) CPF (Fenceline) Odour Hydrogen Sulphide 1-Hour Exposure CPF (Fenceline) 24-Hour Exposure Mercaptans 1-Hour Exposure CPF (Fenceline)

Table 39-3 Locations of COPC Regulatory Benchmark Exceedances (Application Case)

COPC Exceedance of Regulatory Benchmark Location Inhalation Assessment

SO2 1-Hour Exposure CPF (Fenceline)

PM2.5 24-Hour Exposure LSA (Fort McKay) Acrolein 24-Hour Exposure LSA (Fort McKay) Annual Average LSA (Fort McKay) Hydrogen Sulphide 24-Hour Exposure CPF (Fenceline) Formaldehyde Lifetime Cancer Risk LSA (Fort McKay) Multi-Media Assessmenta Chromium AENV Toddler Receptor (HQ) LSA (Campground West of Clearwater Indian Reserve 175) and (Gregiore Lake Indian Reserve 176) Cobalt AENV Toddler Receptor (HQ) LSA (Campground West of Clearwater Indian Reserve 175) and (Gregiore Lake Indian Reserve 176) Lead AENV Toddler Receptor (HQ) LSA (Campground West of Clearwater Indian Reserve 175) and (Gregiore Lake Indian Reserve 176) Manganese AENV Toddler Receptor (HQ) LSA (Campground West of Clearwater Indian Reserve 175) and (Gregiore Lake Indian Reserve 176) Zinc AENV Toddler Receptor (HQ) LSA (Campground West of Clearwater Indian Reserve 175) and (Gregiore Lake Indian Reserve 176) Benzo(a)pyrene AENV/AHW Composite Receptor (ILCR) LSA (Trapper Cabins 1-4)

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Table 39-3 Locations of COPC Regulatory Benchmark Exceedances (Application Case) (cont'd)

COPC Exceedance of Regulatory Benchmark Location Odour Carbon Disulphide 1-Hour Exposure LSA (Fort McMurray) Hydrogen Sulphide 1-Hour Exposure CPF (Fenceline), LSA (Fort McMurray) 24-Hour Exposure CPF (Fenceline) Mercaptans 1-Hour Exposure CPF (Fenceline) Thiophene 1-Hour Exposure LSA (Fort McMurray) NOTE: a The CPF Fenceline receptor location was included in the multi-media assessment with the updated (Project-Alone) facility emissions so the Base, Application and Planned Development Cases do not have this location included in their assessments.

Table 39-4 Locations of COPC Regulatory Benchmark Exceedances (Planned Development Case)

COPC Exceedance of Regulatory Benchmark Location Inhalation Assessment

SO2 1-Hour Exposure CPF (Fenceline)

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Table 39-4 Locations of COPC Regulatory Benchmark Exceedances (Planned Development Case) (cont'd)

COPC Exceedance of Regulatory Benchmark Location Odour Biphenyl 1-Hour Exposure LSA (Fort McMurray) Carbon Disulphide 1-Hour Exposure LSA (Fort McMurray) Hydrogen Sulphide 1-Hour Exposure LSA (Fort McMurray) 24-Hour Exposure CPF (Fenceline)

Mercaptans 1-Hour Exposure CPF (Fenceline) Thiophene 1-Hour Exposure LSA (Fort McMurray) NOTE: a The CPF Fenceline receptor location was included in the multi-media assessment with the updated (Project-Alone) facility emissions so the Base, Application and Planned Development Cases do not have this location included in their assessments.

Question 40: SUM15 Assessment of Fine Particulate Matter

SIR Response 177, Part 3 – AENV, Page 389

a. Provide an assessment of the health risks associated with PM2.5 using the Health Canada SUM15 method, as requested.

Response 40

Exposure to PM2.5 was evaluated by comparing potential exposure to a guideline value in the HHERA and, using the SUM15 method. This statistical concentration-response relationship approach has been developed by the Federal-Provincial Working Group on Air Quality Objectives and Guidelines (Health Canada, 1999) to predict negative health endpoints arising from short

term PM2.5 exposures. The health endpoints considered for association with PM2.5 are:

• the number of cases of non-accidental death • hospital admissions for respiratory causes • hospital admissions for cardiac causes

Health Canada assumes a linear concentration–response relationship for PM2.5 down to the reference level of 15 µg/m3 as a 24 hour concentration. This reference level was considered to be the Lowest Observed Adverse Effect Level (LOAEL).

SUM15 is calculated as the sum of all of the daily PM2.5 concentrations above the reference level of 15 µg/m3 throughout a calendar year. The unit of the SUM15 value is µg/m3-days.

3 SUM15 (µg/m -days) = Σ([PM2.5]daily - 15)

3 where [PM2.5]daily = daily concentrations of PM2.5>15µg/m

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SUM15 values are calculated for all of the sensitive receptor locations. In the assessment of the JACOS Expansion Project the yearly SUM15 values for the 45 receptor locations were calculated for the Baseline Case, the Project-Alone Case, the Application Case and the Planned Development Case.

An assessment of the health risks associated with PM2.5 using the Health Canada SUM15 method has been conducted and the results are provided below. The data set relied upon for the SUM15 assessment included 5 years of air data. To maintain conservatism, the year that had the highest number of days that exceeded 15 µg/m3 was selected for each receptor location. The maximum 3 24-hour exposure concentrations for PM2.5 were all below 15 µg/m for the Project-Alone Case; therefore, the SUM15 values for the COPCs in this scenario are all zero.

Please note, only the Project-Alone Case data has been re-modeled to reflect the updates to the Expansion Project facility and predicted change in stack emissions. The Baseline, Application and Planned Development Cases have not been re-modelled based on the presumption that the HHERA conclusions will not change for these scenarios.

In the determination of the SUM15 value the data were examined to determine the number of 3 days in the receptor locations where the daily average PM2.5 values exceeded 15 µg/m . For the

Baseline and Application cases, the receptor locations had a range of 0-58 days where the PM2.5 values exceeded 15 µg/m3. The highest locations were Fort McKay with 58 days and Fort McMurray with 38 days, all other locations had ≤ 12 days exceeding 15 µg/m3. For the Planned

Development case, the receptor locations had a range of 0-65 days where the PM2.5 values exceeded 15 µg/m3. The highest locations were Fort McKay with 65 days and Fort McMurray with 47 days, all other locations had ≤ 13 days exceeding 15 µg/m3.

The SUM15 values are presented in Table 40-1 with the current populations of the 45 receptor locations, where no population information was available (i.e., Trapper Cabin 1) a population of 10 was assumed to be conservative.

Table 40-1 Receptor Location Populations and SUM15 Values for the Baseline, Project Alone, Application and Planned Development Cases

Baseline Project Application Planned Case Alone Case Case Development Case Location Population(a) SUM15(b) SUM15(b) SUM15(b) SUM15(b) Fort McMurray 76,797 4.80 0 4.93 20.33 Fort McMurray 76,797 133.98 0 134.39 201.58 Fort McMurray 76,797 14.66 0 14.76 21.51 Fort McMurray 76,797 8.03 0 8.08 13.07 Fort McMurray 76,797 30.23 0 30.38 47.09 Fort McMurray 76,797 29.76 0 29.93 58.34 Forestry Station South of 10 25.36 0 25.46 17.74 Ft. McMurray

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Table 40-1 Receptor Location Populations and SUM15 Values for the Baseline, Project Alone, Application and Planned Development Cases (cont'd)

Baseline Project Application Planned Case Alone Case Case Development Case Location Population(a) SUM15(b) SUM15(b) SUM15(b) SUM15(b) Campground West of 10 0.27 0 0.33 3.45 Clearwater Indian Reserve 175 Campground East of 10 0.68 0 0.76 2.77 Clearwater Indian Reserve 175 Anzac 785 0.17 0 0.36 2.98 Gregoire Lake Indian 81 0 0 0 1.72 Reserve 176 Gregoire Lake Indian 81 0 0 0 1.95 Reserve 176 Gregoire Lake Indian 81 0 0 0 0.63 Reserve 176 Gregoire Lake Indian 81 0 0 0 0.31 Reserve 176 Gregoire Lake Indian 121 0 0 0 0.75 Reserve 176A Gregoire Lake Provincial Park 10 0 0 0 1.64 Campground Stony Mountain Fire Lookout 10 0 0 0 0.52 Campground South of Stony 10 0 0 0 0.15 Mountain Fire Lookout Campground Northwest of 10 0 0 0 1.89 Stony Mountain Fire Lookout Engstrom Lake Campground 10 0 0 0 1.07 Trapper Cabin 1 10 0 0 0 1.53 Trapper Cabin 2 10 0 0 0 0.98 Trapper Cabin 3 10 0 0 0 0 Trapper Cabin 4 10 0 0 0 0 Grande Fire Lookout 10 0 0 0 0 Algar Fire Lookout 10 0 0 0 0 Janvier Indian Reserve 194 271 0 0 0 1.67 Marianna Settlement 0 0 0 0 0 Fort Chipewyan 1,261 0 0 0 0 Fort McKay 862 403.44 0 403.76 485.17 Janvier 195 0 0 0 2.33 Conklin Fire Lookout 10 0 0 0 0 Conklin 337 0 0 0 0 Trapper Cabin 5 10 0 0 0 0.88

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Table 40-1 Receptor Location Populations and SUM15 Values for the Baseline, Project Alone, Application and Planned Development Cases (cont'd)

Baseline Project Application Planned Case Alone Case Case Development Case Location Population(a) SUM15(b) SUM15(b) SUM15(b) SUM15(b) Grand Rapids Wildland 10 0 0 0 0.71 Provincial Park Grand Rapids Wildland 10 0 0 0 0 Provincial Park Grand Rapids Wildland 10 0 0 0 0 Provincial Park Grand Rapids Wildland 10 1.29 0 1.34 4.29 Provincial Park Grand Rapids Wildland 10 0 0 0 0 Provincial Park Stony Mountain Wildland 10 0 0 0 0.71 Provincial Park Stony Mountain Wildland 10 0 0 0 0 Provincial Park Stony Mountain Wildland 10 0 0 0 0 Provincial Park Stony Mountain Wildland 10 0 0 0 0 Provincial Park Stony Mountain Wildland 10 0 0 0 0 Provincial Park Central Processing Facility 10 0 0 0 0.64 (CPF) Fenceline NOTES: (a) Population information for the Regional Municipality of Wood Buffalo communities were taken from the 2010 Census (RMWB 2010); Populations of Aboriginal communities and IRs were taken from the 2006 Aboriginal Peoples Survey (Statistics Canada 2006); all unknown populations (i.e., Trapper Cabins and Campgrounds) were estimated. 3 (b) Units for SUM15 values are µg/m -days By combining the SUM15 values and the relative risk statistical relationship presented by Health Canada with the community population figures, the possible health outcomes (both hospitalizations and mortalities) can be estimated.

The equations to estimate mortality and hospitalizations admissions associated with PM2.5 exposure (from Health Canada, 1999) are detailed in Table 40-2.

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Table 40-2 Equations to Estimated Health Endpoints from PM2.5 Exposure

Health Endpoint Equation 0.026 Mortality (deaths per year) SUM15 x x population 1x106 0.0118 Respiratory hospital admissions (RHA per year) SUM15 x x population 1x106 0.010 Cardiac hospital admissions (CHA per year) SUM15 x x population 1x106 The number of excess deaths and hospitalizations for respiratory and cardiac illness resulting

from the PM2.5 concentrations in the 45 receptor locations surrounding the JAOCS Expansion Project facility were calculated. These estimates were based on the most recent available population data obtained from the Regional Municipality of Wood Buffalo (RMWB, 2010) and Statistics Canada (StatCan, 2006).

The estimates of mortality for the 45 receptor locations were very low. There is little or no change in predicted mortalities between the Baseline and Application Cases which can be attributed to the fact that the SUM15 values for the Project-Alone Case were all zero since there were no 3 instances of PM2.5 exceeding 15 µg/m . The Planned Development Case has slightly higher rates of mortality which includes all potential future projects that are currently proposed for the area and are therefore not a result of the JACOS Project Expansion facility. Thus the magnitude of the risk estimate and risk impact is low.

The results of the mortality calculations due to PM2.5 exposure for current population estimates are presented in Table 40-3.

Table 40-3 Estimates of Mortality due to PM2.5 Exposure Based on Current Population Estimates

Deaths per Year Application Planned Location Baseline Case Case Development Case Fort McMurray 0.0096 0.010 0.040 Fort McMurray 0.27 0.27 0.40 Fort McMurray 0.029 0.029 0.043 Fort McMurray 0.016 0.016 0.026 Fort McMurray 0.060 0.060 0.094 Fort McMurray 0.059 0.059 0.12 Forestry Station South of Ft. McMurray 6.6E-06 6.6E-06 4.6E-06 Campground West of Clearwater Indian Reserve 175 7.0E-08 8.7E-08 9.0E-07

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Table 40-3 Estimates of Mortality due to PM2.5 Exposure Based on Current Population Estimates (cont'd)

Deaths per Year Application Planned Location Baseline Case Case Development Case Campground East of Clearwater Indian Reserve 175 1.7E-07 2.0E-07 7.2E-07 Anzac 3.4E-06 7.4E-06 6.1E-05 Gregoire Lake Indian Reserve 176 0 0 3.6E-06 Gregoire Lake Indian Reserve 176 0 0 4.1E-06 Gregoire Lake Indian Reserve 176 0 0 1.3E-06 Gregoire Lake Indian Reserve 176 0 0 6.5E-07 Gregoire Lake Indian Reserve 176A 0 0 2.4E-06 Gregoire Lake Provincial Park Campground 0 0 4.3E-07 Stony Mountain Fire Lookout 0 0 1.4E-07 Campground South of Stony Mountain Fire Lookout 0 0 3.9E-08 Campground Northwest of Stony Mountain Fire Lookout 0 0 4.9E-07 Engstrom Lake Campground 0 0 2.8E-07 Trapper Cabin 1 0 0 4.0E-07 Trapper Cabin 2 0 0 2.6E-07 Trapper Cabin 3 0 0 0 Trapper Cabin 4 0 0 0 Grande Fire Lookout 0 0 0 Algar Fire Lookout 0 0 0 Janvier Indian Reserve 194 0 0 1.2E-05 Marianna Settlement 0 0 0 Fort Chipewyan 0 0 0 Fort McKay 0.0090 0.0090 0.011 Janvier 0 0 1.2E-05 Conklin Fire Lookout 0 0 0 Conklin 0 0 0 Trapper Cabin 5 0 0 2.3E-07 Grand Rapids Wildland Provincial Park 0 0 1.9E-07 Grand Rapids Wildland Provincial Park 0 0 0 Grand Rapids Wildland Provincial Park 0 0 0 Grand Rapids Wildland Provincial Park 3.3E-07 3.5E-07 1.1E-06 Grand Rapids Wildland Provincial Park 0 0 0 Stony Mountain Wildland Provincial Park 0 0 1.9E-07 Stony Mountain Wildland Provincial Park 0 0 0

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Table 40-3 Estimates of Mortality due to PM2.5 Exposure Based on Current Population Estimates (cont'd)

Deaths per Year Application Planned Location Baseline Case Case Development Case Stony Mountain Wildland Provincial Park 0 0 0 Stony Mountain Wildland Provincial Park 0 0 0 Stony Mountain Wildland Provincial Park 0 0 0 CPF Fenceline 0 0 1.7E-07

The estimates of hospitalizations from respiratory and cardiac illness attributed to concentrations

of PM2.5 for the 45 receptor locations were very low. There is little or no change in predicted mortalities between the Baseline and Application Cases which can be attributed to the fact that the SUM15 values for the Project-Alone Case were all zero since there were no instances of 3 PM2.5 exceeding 15 µg/m . In the majority of locations there is an order of magnitude change or less between the number of deaths per year in the Baseline/Application Cases when compared to the number of deaths per year in the Planned Development Case. The Planned Development Case takes into consideration all of those projects currently being considered (not necessarily approved) for the area; therefore, the increased hospital emissions due to cardiac and respiratory illnesses are not a result of the JACOS Expansion Project facility.

The results of the hospitalization calculations due to PM2.5 exposure for current population estimates are presented in Table 40-4 for respiratory illnesses and Table 40-5 for cardiac illnesses.

Table 40-4 Estimates of Hospitalization due to Respiratory Illness from PM2.5 Exposure based on Current Population Estimates

Respiratory Hospital Admissions Application Planned Location Baseline Case Case Development Case Fort McMurray 0.00044 0.00045 0.0018 Fort McMurray 0.012 0.012 0.018 Fort McMurray 0.0013 0.0013 0.0019 Fort McMurray 0.00073 0.00073 0.0012 Fort McMurray 0.0027 0.0027 0.0042 Fort McMurray 0.0027 0.0027 0.0053 Forestry Station South of Ft. McMurray 3.0E-07 3.0E-07 2.1E-07 Campground West of Clearwater Indian Reserve 175 3.2E-09 3.9E-09 4.1E-08 Campground East of Clearwater Indian Reserve 175 8.1E-09 9.0E-09 3.3E-08 Anzac 1.6E-07 3.4E-07 2.8E-06 Gregoire Lake Indian Reserve 176 0 0 1.6E-07

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Table 40-4 Estimates of Hospitalization due to Respiratory Illness from PM2.5 Exposure based on Current Population Estimates (cont'd)

Respiratory Hospital Admissions Application Planned Location Baseline Case Case Development Case Gregoire Lake Indian Reserve 176 0 0 1.9E-07 Gregoire Lake Indian Reserve 176 0 0 6.0E-08 Gregoire Lake Indian Reserve 176 0 0 2.9E-08 Gregoire Lake Indian Reserve 176A 0 0 1.1E-07 Gregoire Lake Provincial Park Campground 0 0 1.9E-08 Stony Mountain Fire Lookout 0 0 6.2E-09 Campground South of Stony Mountain Fire Lookout 0 0 1.8E-09 Campground Northwest of Stony Mountain Fire Lookout 0 0 2.2E-08 Engstrom Lake Campground 0 0 1.3E-08 Trapper Cabin 1 0 0 1.8E-08 Trapper Cabin 2 0 0 1.2E-08 Trapper Cabin 3 0 0 0 Trapper Cabin 4 0 0 0 Grande Fire Lookout 0 0 0 Algar Fire Lookout 0 0 0 Janvier Indian Reserve 194 0 0 5.3E-07 Marianna Settlement 0 0 0 Fort Chipewyan 0 0 0 Fort McKay 0.00041 0.00041 0.00049 Janvier 0 0 5.4E-07 Conklin Fire Lookout 0 0 0 Conklin 0 0 0 Trapper Cabin 5 0 0 1.0E-08 Grand Rapids Wildland Provincial Park 0 0 8.4E-09 Grand Rapids Wildland Provincial Park 0 0 0 Grand Rapids Wildland Provincial Park 0 0 0 Grand Rapids Wildland Provincial Park 1.5E-08 1.6E-08 5.1E-08 Grand Rapids Wildland Provincial Park 0 0 5.1E-08 Stony Mountain Wildland Provincial Park 0 0 8.4E-09 Stony Mountain Wildland Provincial Park 0 0 0 Stony Mountain Wildland Provincial Park 0 0 0 Stony Mountain Wildland Provincial Park 0 0 0 Stony Mountain Wildland Provincial Park 0 0 0 CPF Fenceline 0 0 7.6E-09

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Table 40-5 Estimates of Hospitalization due to Cardiac Illness from PM2.5 Exposure based on Current Population Estimates

Cardiac Hospital Admissions Application Planned Location Baseline Case Case Development Case Fort McMurray 0.0037 0.0038 0.016 Fort McMurray 0.10 0.10 0.15 Fort McMurray 0.011 0.011 0.017 Fort McMurray 0.0062 0.0062 0.010 Fort McMurray 0.023 0.023 0.036 Fort McMurray 0.023 0.023 0.045 Forestry Station South of Ft. McMurray 2.5E-06 2.5E-06 1.8E-06 Campground West of Clearwater Indian Reserve 175 2.7E-08 3.3E-08 3.5E-07 Campground East of Clearwater Indian Reserve 175 6.8E-08 7.6E-08 2.8E-07 Anzac 1.3E-06 2.8E-06 2.3E-05 Gregoire Lake Indian Reserve 176 0 0 1.4E-06 Gregoire Lake Indian Reserve 176 0 0 1.6E-06 Gregoire Lake Indian Reserve 176 0 0 5.1E-07 Gregoire Lake Indian Reserve 176 0 0 2.5E-07 Gregoire Lake Indian Reserve 176A 0 0 9.1E-07 Gregoire Lake Provincial Park Campground 0 0 1.6E-07 Stony Mountain Fire Lookout 0 0 5.3E-08 Campground South of Stony Mountain Fire Lookout 0 0 1.5E-08 Campground Northwest of Stony Mountain Fire Lookout 0 0 1.9E-07 Engstrom Lake Campground 0 0 1.1E-07 Trapper Cabin 1 0 0 1.5E-07 Trapper Cabin 2 0 0 9.8E-08 Trapper Cabin 3 0 0 0 Trapper Cabin 4 0 0 0 Grande Fire Lookout 0 0 0 Algar Fire Lookout 0 0 0 Janvier Indian Reserve 194 0 0 4.5E-06 Marianna Settlement 0 0 0 Fort Chipewyan 0 0 0 Fort McKay 0.0035 0.0035 0.0042 Janvier 0 0 4.6E-06 Conklin Fire Lookout 0 0 0 Conklin 0 0 0 Trapper Cabin 5 0 0 8.8E-08

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Table 40-5 Estimates of Hospitalization due to Cardiac Illness from PM2.5 Exposure based on Current Population Estimates (cont'd)

Cardiac Hospital Admissions Application Planned Location Baseline Case Case Development Case Grand Rapids Wildland Provincial Park 0 0 7.1E-08 Grand Rapids Wildland Provincial Park 0 0 0 Grand Rapids Wildland Provincial Park 0 0 0 Grand Rapids Wildland Provincial Park 1.3E-07 1.3E-07 4.3E-07 Grand Rapids Wildland Provincial Park 0 0 0 Stony Mountain Wildland Provincial Park 0 0 7.1E-08 Stony Mountain Wildland Provincial Park 0 0 0 Stony Mountain Wildland Provincial Park 0 0 0 Stony Mountain Wildland Provincial Park 0 0 0 Stony Mountain Wildland Provincial Park 0 0 0 CPF Fenceline 0 0 6.4E-08

REFERENCES:

Health Canada, 1999. National Ambient Air Quality Objectives for Particulate Matter: Addendum to the Science Assessment Document. Addendum to the Science Assessment Document Particulate Matter 10 µm and 2.5 µm. A Report to the Federal-Provincial Working Group on Air Quality Objectives and Guidelines. Health Canada, Ottawa, ON (December 1997, revised April 1999).

Regional Municipality of Wood Buffalo (RMWB) 2010. 2010 Municipal Census. Available online at: http://www.woodbuffalo.ab.ca/Assets/Corporate/Census+Reports/2010+Municipal+ Census.pdf

Statistics Canada (StatCan) 2006. 2006 Community Profiles. Available online at: http://www12.statcan.gc.ca/census-recensement/2006/dp-pd/prof/92-591/index.cfm? Lang=E

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7. Approvals

The responses to questions in this Approvals section will not be considered as part of the EIA completeness decision made by Alberta Environment.

7.1 Environmental Protection and Enhancement Act

7.1.1 General

Question 41: Septic Field

SIR Response 6, Part 3 – AENV, Page 106

JACOS states that JACOS does not currently have information regarding the suitability of the proposed location of the septic field. If JACOS chooses to install a wastewater treatment facility, an approval will be required before JACOS can construct it. a. Confirm that JACOS does not have a proposed location that is being considered.

Response 41

JACOS has not yet conducted a detailed siting for the proposed septic field. Pending suitable results from geotechnical analysis, JACOS is considering an area in proximity to the Administration Building. Detailed site suitability information and system overall design will be completed in the detailed engineering phase.

Question 42: Drainage at CPF

SIR Response 183, Part 3 – AENV, Figure 183-1, Page 394

The figure does not clearly indicate whether there is a drainage ditch around the plant site or the proposed Landfill. a. Confirm whether there is a drainage ditch surrounding the plant site and proposed landfill that drains towards the stormwater pond. i. If not, how will JACOS ensure that the runoff from the plant site does not flow towards the drainage ditch if it drains towards the surrounding environment? b. Discuss how runoff will be managed within the proposed landfill. c. Confirm whether the Process Water Recycle Pond and the Stormwater Pond are connected as Figure 183-1 has an arrow between the two ponds.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Response 42

a. Confirmed; the elevated road around the CPF provides the outer limit of stormwater management around the plant site. Within the CPF, a combination of site contouring and ditching will ensure runoff water from the plant site will be directed to the stormwater pond. b. As discussed in AENV Round 2 Question 6, JACOS has decided not to include a landfill in the Expansion Project. c. There is no direct connection between Process Water Recycle Pond and Stormwater Pond. The arrows show direction of flow of surface runoff water to the stormwater pond.

7.1.2 Air

Question 43: Evaporator

SIR Response 21, Part 3 – AENV, Page 121

The evaporator was not included in the list of sources listed. a. Discuss whether the evaporator contributes to any emissions. b. Provide the stack parameters for the evaporator exhaust stack. c. Provide updated dispersion modelling, if necessary.

Response 43

a. Although the evaporator vent releases water vapour into the atmosphere it is not a source of other substances of interest considered in the assessment. b. The evaporator exhaust vent is 29 m above grade with a 0.102 m (four-inch) diameter. The manufacturer’s emission rate from the vent is 6.9 t/d of steam. This compares to the 305 t/d water vapour emissions from each Expansion Project steam boiler (see Volume 2, Appendix 5A, Tables 5A-11 and 5A-12, pages 5A-21 and 5A-24). Compared with six OTSG units operating simultaneously, the water vapour emissions from the evaporator vent are 0.37% of the combined steam generator (OTSG) water vapour emissions of 1830 t/d. c. Water vapour emissions from the evaporator exhaust vent are not expected to be substantial enough to warrant visibility and fogging remodelling.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Question 44: NOX and SO2 Emissions

SIR Response 198, Part 3 – AENV, Page 413

Background concentrations represent chemical concentrations from natural, nearby or unidentified distant sources and should be added to maximum model predictions before comparison to the AAAQO. JACOS confirmed that the neighboring continuous emission sources within 5 km of the proposed Project have been included in the assessment for NOX emission sources. Inclusion of neighboring NOX emission sources addresses the background concentration of NOX only for the known industrial sources but does not address the background concentrations for natural and other unidentified sources.

a. Confirm if the neighboring SO2 emission sources within a minimum of 5 km from the proposed Project were included in the dispersion modeling.

b. Include SO2 emission sources within a minimum of 5 km from the proposed Project in the dispersion modeling, if necessary. c. Provide the air dispersion modeling results adding the background concentrations to the maximum predicted concentrations to compare with Alberta Ambient Air Quality Objectives (AAAQO).

Response 44

a. Emission sources of SO2 within 5 km from the proposed Project were included in dispersion modelling. As mentioned in SIR response 198, facilities within 5 km of the proposed Project are as follows:

• JACOS Demonstration Project Plant 1 and Plant 2. The SO2 emission from the Demonstration Project (assuming no sulphur content in the natural gas) is 1.63 t/d.

• Devon Hangingstone 05-13-84-11W4M facility. From Table 5A-9, the SO2 emission for the natural gas fueled engine is reported as 0.0 t/d. Again, this is based on assuming no sulphur content in the natural gas. • Canadian Natural Resources (CNRL) Hangingstone 01-24-84-11W4M facility. According

to the 2008 NPRI database, this facility reported NOX emissions but did not indicate any

SO2 emissions. No emissions were reported in the NPRI database for this facility.

The only substantive SO2 emission sources within 5 km of the Expansion Project are associated with JACOS Demonstration Project Plant 2; these emissions were included in the dispersion modelling.

b. As per Response a., the emission sources located within 5 km of the proposed Project were included in dispersion modelling.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

c. Given the context of this question, the interest appears to focus on the vicinity of the

Expansion Project with respect to confirmation that all NOX and SO2 emission sources located within 5 km of the Expansion Project are included. This can be addressed by considering the

predicted NO2 and SO2 concentrations associated with the Expansion Project and Demonstration Project scenario results that are presented in Section 5E.3.1 in Appendix 5E. The predictions provided in this section do not include contributions from any other sources or the inclusion of a background term.

The Alberta Environment (AENV) Air Quality Model Guideline (AQMG; AENV 2009) recommends a prescriptive process to include background levels. Elements of this process include:

• select a representative monitoring station that has at least one year of quality controlled concentration data • the 1-hour background value can be derived from the 90th percentile measurement • the 24-hour background value can be derived from the 90th percentile measurement • the annual background value can be derived from the 50th percentile measurement

The nearest continuous ambient air quality station to the Expansion Project is the WBEA

Anzac station. This station is not located near any major NOX and SO2 emission sources and is not located in an urban area, therefore, it can be considered representative. Data collected at this station for January 2006 to May 2009 are summarized in Appendix 5B. The station is operated by WBEA and has a rigorous QA/QC program.

Table 44-1 provides a summary of the SO2 and NO2 measurements at this station. Note that the 50th percentile can vary depending on the basis (1-hour versus 24-hour concentrations). A 1-hour median of 0 µg/m3 indicates that most of the 1-hour measurements were reported as 0 µg/m3.

Table 44-1 SO2 and NO2 Values at the WBEA Anzac Air Quality Monitoring Station

Species Averaging Period Statistic Concentration (µg/m3) a c th SO2 1-hour 90 percentile 2.62 24-hour c 90th percentile 4.45 Annual d Median based on 1-h values 0.00 Annual Median based on 24-h values 0.523

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Table 44-1 SO2 and NO2 Values at the WBEA Anzac Air Quality Monitoring Station (cont'd)

Species Averaging Period Statistic Concentration (µg/m3) b c th NO2 1-hour 90 percentile 13.2 24-hour c 90th percentile 12.8 Annual d Median based on 1-h values 3.76 Annual Median based on 24-h values 3.76 NOTES: a Values are summarized from Tables 5B-3 and 5B-6 in the EIA Report (Volume 2, Appendix 5B). b Values are summarized from Tables 5B-9 and 5B-12 in the EIA Report (Volume 2, Appendix 5B). c 90th percentile value from the cumulative frequency distribution of the Anzac ambient monitoring data as per AQMG (AENV 2009). d 50th percentile value from the cumulative frequency distribution of the Anzac ambient monitoring data as per AQMG (AENV 2009).

The maximum predicted SO2 and NO2 concentrations associated with the Expansion Project and Demonstration Project scenario results before and after the addition of the background values are compared in Table 44-2. The following are noted:

• the background SO2 concentrations contribute 0.7 to 3.1% to the predicted values

• the background NO2 concentrations contribute about 13% to the predicted 1-hour and 24-hour values, and contribute about 33% to the predicted annual value

Table 44-2 Maximum Predicted SO2 and NO2 Concentrations Associated with Expansion Project and Demonstration Project Scenario – with and without Background

Without Ambient Ambient With Ambient Substance Averaging Period Background a Background Background AAAQO (µg/m3) th SO2 1-hour (9 highest) 363 2.62 366 (0.7%) 450 24-hour (2nd highest) 145 4.45 149 (3.0%) 150 Annual 28.6 0.523 29.1 (1.8%) 30 th NO2 1-hour (9 highest) 103 13.2 116 (11%) 400 24-hour (2nd highest) 74.7 12.8 87.5 (15%) 200 Annual 7.51 3.76 11.3 (33%) 60 NOTES: a Summarized from Tables 5E-4 and 5E-8 in the EIA (Volume 2, Appendix 5E). The background contribution is indicated as a percent in parentheses.

The maximum predicted concentrations change but the maximum values predicted near the JACOS operating area are expected to remain less than the AAAQO. Therefore, the addition of background does not change the conclusions of the air quality assessment.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

REFERENCE

AENV 2009. Alberta Environment Air Quality Model Guideline. Science and Standards Branch, Alberta Environment. 44.

7.1.3 Terrestrial

Question 45: Erosion Control on Stockpiled Soils

SIR Response 181 (a), Part 3 – AENV, Page 393

JACOS does not indicate “how the sand will be managed for erosion and what will be done with the material at the time of final reclamation”, as originally asked. a. Provide the information as requested.

Response 45

Refer to the response provided for AENV R2 SIR 49 for relevant context for this response

JACOS plans to incorporate the use of soil tackifiers, erosion control matting and seeding with a native seed mix as approved by ASRD. Willow and/or poplar cuttings may also be used to manage erosion of the sand piles. One or a combination of these methods will be chosen once the sand is stockpiled and an assessment of the specific soil properties is completed.

The material will be used on site as fill where applicable or disposed of at an approved off site location at the time of decommissioning.

Question 46: Discharge of Runoff Water

SIR Response 186, Part 3 – AENV, Page 399

JACOS does not indicate “how water will be discharged”, as originally asked. a. Provide the information as requested.

Response 46

Water will be discharged from retention areas only after it has been tested and meets ERCB Directive 55 requirements including, “Criteria for the Surface Discharge of Collected Surface Run- on/Run off Waters”. Temporary pumping equipment will be used to pump the water or water will be allowed to drain (depending on topography and existing surface water flows) from the retention areas to a small designated outfall area. This area will be located to direct the water in a direction that is consistent with the surrounding topography and the normal flow of surface water. The outfall area will be equipped with rip-rap or similar to safeguard the terrain against erosion

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

during the release. JACOS will monitor all retention ponds on a daily basis and also monitor all discharges to crown lands.

Question 47: Topsoil Salvage

SIR Response 187, Part 3 – AENV, Figure 187-1, Page 399 SIR Response 195, Part 3 – AENV, Page 410

Figure 187-1 does not show topsoil storage, as requested. a. Clarify whether topsoil salvaged during road construction will be stored on both sides of the road or only on the powerline side of the road. b. Discuss how JACOS will ensure that this topsoil will not be degraded by ditch erosion, gravel, grading, or other road maintenance activities.

Response 47

a. Topsoil salvaged during road construction will initially be windrowed and then feathered along both sides of the road to allow revegetation and surface stability. b. The topsoil windrows and the road will be separate and distinct features. Therefore, the topsoil will not be degraded by grading or other road maintenance activities. Degradation due to ditch erosion will be prevented by the appropriate application of material such as rip-rap. Erosion due to wind and rain will be controlled by the regrowth of vegetation. Where required, the topsoil windrows will be seeded to accelerate the regrowth of vegetation.

Question 48: Disturbance by Footprint Component

SIR Response 190, Part 3 – AENV, Page 406

JACOS indicates that some areas will have only vegetation cleared.

a. Indicate, for each footprint component, how much of the disturbance will be vegetation clearing only and how much will have both soils and vegetation disturbed.

Response 48

a. Table 48-1 indicates, for each footprint component, the area of associated disturbance and the type of disturbance (vegetation clearing only or both soils and vegetation disturbed).

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Table 48-1 Vegetation and Soil Disturbance by Footprint Component

Disturbance Feature Area Disturbance Type (ha) Initial Piperack and Road Corridor 34.56 Vegetation Only Future Piperack and Road Corridor 98.06 Vegetation Only Initial Powerline 36.36 Vegetation Only Future Powerline 19.28 Vegetation Only Total Vegetation Clearing Only: 188.3 ha Central Processing Facility 64.39 Soil and Vegetation Water Disposal Pipeline 8.95 Soil and Vegetation Source Water Pipeline 1.71 Soil and Vegetation Main Access Road 1.89 Soil and Vegetation Fuel Gas Pipeline 15.03 Soil and Vegetation Product Pipeline 12.41 Soil and Vegetation Borrow Pit Access Road 1.30 Soil and Vegetation Future Hot Bitumen Line 7.56 Soil and Vegetation Source Water Wellpad 0.66 Soil and Vegetation Wellpad – Initial Development 24.33 Soil and Vegetation Wellpad – Future Development 39.17 Soil and Vegetation Borrow Pit 86.84 Soil and Vegetation Total Soil and Vegetation Disturbance: 264.2 ha Total Disturbance Footprint: 452.5 ha NOTE: Subtotals may not equal totals due to rounding.

Question 49: Erosion Control and Vegetation Establishment

SIR Response 194, Part 3 – AENV, Page 408

JACOS indicates that erosion control measures will be similar for both topsoil and subsoil stockpiles. The application indicates that many of the subsoil stockpiles will be very sandy. It has been Alberta Environment’s experience that the vegetation establishment on sandy stockpiles can be quite difficult. a. Indicate how JACOS will address the establishment of vegetation on sand stockpiles.

Response 49

a. Refer to the response provided for AENV R2 SIR 45 for relevant context for this response.

The application of erosion control materials (erosion control blankets or mats) on the sandy stockpiles will affect the options available for promoting vegetation establishment on these

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

features. Matting is typically composed of woven coconut fibre (coir), which biodegrades over time, or straw blankets/mats (generally with a photodegradable top net to hold the straw in place). Matting materials are applied over the surface once seeding is completed and anchored in place to provide protection from wind, rain and sun that can adversely affect seed catch. Various types of mats are commercially available, with formulations that maintain their integrity for up to 3 years; to ensure surface stability while the vegetation becomes established. The stockpiles will be monitored to see if these measures are successful, with site-specific remedial actions developed as needed. For example, if the piles are drying out too quickly for germination and growth, water could be sprayed on and/or coarse woody debris applied as a surface cover, to reduce evapo-transpiration. It might be necessary to use quick-growing agronomic cover crops such as barley or Dahurian wild rye to get a surface cover that can be underseeded to the approved reclamation seed mix, and therefore improve the opportunities for seed catch.

Question 50: Wellpads in Deep Organics

SIR Response 197 (a), Part 3 – AENV, Page 412

JACOS indicates in SIR 197 (a) that the scenario presented in Volume 1, Page 15-39 states, There may be instances when it is determined, at reclamation, that developments constructed on deep organics will not have the geotextile and fill removed will not occur and that well pads constructed in deep organics will always be removed during reclamation.

a. Confirm which information is correct.

Response 50

a. As outlined in the updated Conservation and Reclamation Plan (Part 2A, Section 15), JACOS will remove all materials (gravel cap, fill, geotextile) used to construct wellpads on deep organic deposits in peatland areas. No reclamation materials are required to reclaim deep organic peatlands, as these sites are left to naturalize to their pre-disturbance condition. This is in compliance with typical EPEA approval conditions for construction on organic soils with a peat depth exceeding 40 cm.

Question 51: Material Removal

SIR Response 197 (b), Part 3 – AENV, Page 412

JACOS refers to Table 107-2 in this response. This table does not provide the information requested.

a. Provide the information as requested.

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

Response 51

a. See the response to AENV SIR 50.

7.2. Alberta Sustainable Resource Development

Question 52: Development in Proximity to Waterbodies

SIR Response 54, Part 3 – AENV, Page 203

JACOS indicates that the CPF, pads and other project facilities will maintain a 100 m buffer to water bodies, streams and ponds, when possible. The response does not specifically address the potential cumulative effects to the riparian areas for multiple development activities that will be located within the 100 m setback from a waterbody. a. Identify the locations of each development that will be located within the 100 m buffer. Quantify the footprint of these sites and identify any alternative locations considered and why they will not be used. b. Clarify the setbacks from the water’s edge of a waterbody and provide site specific mitigation measures will be developed for each site identified in (a).

Response 52

a. Since the response to AENV SIR 54 (February 2011), new geological information from the 2010 and 2011 winter corehole drilling programs was received. As a result of the improved subsurface understanding, a number of changes to the project facilities were made in order to take advantage of an opportunity to improve resource recovery and reduce the overall footprint of the Expansion Project.

Development areas located within 100 m of a waterbody are:

• Pad W02 located at 09-15-84-11 W4M – 275 m x 125 m • Pad W04 located at 01-22-84-11 W4M – 245 m x 125 m • Pad W06 located at 09-14-84-11 W4M – 245 m x 125 m • Clay Borrow Pit located at SE¼ 15-84-11 W4M – 300 m x 475 m

Numerous locations were evaluated for each pad location relative to its intended resource drainage area. Factors considered for the evaluation of the pad locations as well as all other developments including the clay borrow pit consisted of the effects on and proximity to surface features, terrain and elevation conditions, distance from the CPF, and the introduction of new surface disturbance. From that perspective, while alternatives were considered, the proposed pad locations for W02, W04 and W06 provide the most favorable

JACOS Hangingstone Expansion Project Description Update and Responses to Second Supplemental Information Request Part 3 – Responses to Round 2 SIRs Alberta Environment September 2011

combination of these factors without compromising the technical feasibility of drilling from these locations and the associated effect on resource recovery. Further, JACOS is confident that it can effectively mitigate any potential environmental effects at these proposed sites and will use appropriate engineering practices and adhere to applicable regulatory requirements.

Linear features (roads, power lines and piperacks) will cross watercourses with defined bed and banks following the Code of Practice for Watercourse Crossings.

b. Presence of waterbodies and drainage patterns for each site will be confirmed as part of the Pre-Disturbance Assessment (PDA) and appropriate site specific mitigation will be developed and included within the Conservation Plan and Environmental Field Report. JACOS is committed to ensuring its facilities will not disturb the bed and banks of watercourses to protect riparian areas and specifically fish and fish habitat. Where 100 m setbacks from waterbodies is not practical, JACOS will develop appropriate mitigation to minimize effects on surface drainage and surface water quality prior to construction. The evaluation of appropriate mitigation will include erosion control measures, stormwater management, secondary containment and contouring of sites to maintain natural drainage.