Drilling

DEEPERTHE IN SITU OIL SANDS REPORT CARD

JEREMY MOORHOUSE • MARC HUOT • SIMON DYER

March 2010

Oil SANDSFever SERIES

Drilling Deeper The In Situ Oil Sands Report Card

Jeremy Moorhouse Marc Huot Simon Dyer

March 2010 The In Situ Oil Sands Report Card

About the Pembina Institute

The Pembina Institute The Pembina Institute is a national The Pembina Institute provides policy Box 7558 non-profit think tank that advances research leadership and education on Drayton Valley, Alberta, T7A 1S7 sustainable energy solutions through climate change, energy issues, green Phone: 780-542-6272 research, education, consulting and economics, energy efficiency and advocacy. It promotes environmental, conservation, renewable energy, and E-mail: [email protected] social and economic sustainability in environmental governance. For more the public interest by developing information about the Pembina practical solutions for communities, Institute, visit www.pembina.org or individuals, governments and businesses. contact info @pembina.org.

Acknowledgements

The Pembina Institute thanks the graciously reviewed and commented William and Flora Hewlett Foundation on the data the Pembina Institute for its support of this work. The had collected for this analysis. Their Pembina Institute would also like to comments and insights improved acknowledge the support of Cenovus, the quality of this report and the Shell and Husky for participating in this Pembina Institute’s understanding process. Each of these companies of in situ operations.

ii DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card About the Authors Jeremy Moorhouse of Alberta, and a Master of Arts in Technical Analyst natural sciences Jeremy is a Technical Analyst with the from Cambridge Pembina Institute’s Corporate University. Simon is Consulting team. He provides technical the co-author of analysis for life cycle value assessments Death by a for decision-making. Thousand Cuts: Jeremy’s other projects Impacts of include conducting In Situ Oil Sands research into practices Development on and strategies for Alberta’s Boreal sustainability and Forest and Haste evaluating the Makes Waste: The Need for a New Oil performance of current Sands Tenure Regime. and proposed oil sands projects. Assessing and evaluating emerging Marc Huot technologies is also a Policy Analyst key focus of Jeremy’s work. His technical background Marc Huot is a Policy Analyst with the includes experimental mining Pembina Institute’s Oil Sands Program. equipment design and production, as Marc is involved with researching and well as experimental data analysis. He reviewing environmental impacts has experience and knowledge in energy associated with systems, water management and solid- oil sands waste management. Jeremy holds a development. bachelor’s degree in mechanical His technical engineering from McGill University. background includes Simon Dyer knowledge of renewable Oil Sands Program Director energy, life cycle Simon Dyer is a registered professional assessment biologist and has worked on land use methodology issues in western Canada since 1999. and energy Simon represented the Pembina systems. Marc holds a Bachelor of Institute on the Sustainable Ecosystems Science and a Master of Science in Working Group of the Cumulative mechanical engineering from the Environmental Management University of Alberta. Association (CEMA). Simon holds a Master of Science in environmental biology and ecology from the University

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD iii The In Situ Oil Sands Report Card

Drilling Deeper: The In Situ Oil Sands Report Card

March 2010 The Pembina Institute Editor: Roland Lines Box 7558 Layout: J&W Communications Inc Drayton Valley, Alberta Cover Photo: T7A 1S7 Canada Courtesy of Husky Energy Phone: 780-542-6272 Cover Photo / Inset: E-mail: [email protected] David Dodge, The Pembina Institute Additional copies of this publication ©2010 The Pembina Institute may be downloaded from our website, www.oilsandswatch.org.

iv DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card

Table of Contents

Executive Summary ...... ix

Introduction ...... 1 Project Scope ...... 3 Data Collection ...... 4 Performance Criteria ...... 4 Cogeneration ...... 14 Scoring ...... 15 Limitations ...... 16

About In Situ Production ...... 17 Alberta’s Oil Sands ...... 17 In Situ Production Technologies ...... 17 Mining ...... 19

SURVEY RESULTS ...... 20

General Environmental Management ...... 21 1. Continuous Improvement ...... 22 2. Third-Party Validation ...... 23 3. Public Data Reporting ...... 24 4. Regulatory Compliance ...... 26

Land ...... 29 5. Footprint ...... 30 6. Conservation Offsets ...... 32 7. Caribou Habitat ...... 34 8. Conservation Planning ...... 35 9. Biodiversity Monitoring ...... 37

Air Emissions ...... 39 10. Nitrogen Oxides Emissions ...... 40 11. Sulphur Dioxide Emissions ...... 42 12. Reduction Targets ...... 44

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD v The In Situ Oil Sands Report Card TABLE OF CONTENTS

Water ...... 45 13. Total Water Consumption ...... 46 14. Freshwater Consumption ...... 48 15. Liquid Waste ...... 50 16. Reduction Targets ...... 52

Climate Change ...... 53 17. GHG Emissions ...... 54 18. Reduction Targets ...... 56

Conclusions ...... 57

Recommendations ...... 61 Government ...... 61 Industry ...... 63

Summary of Conclusions and Recommendations ...... 66

Appendix: Project Summaries ...... 69 Canadian Natural Primrose/Wolf Lake ...... 70 Cenovus Christina Lake ...... 71 ` Cenovus Foster Creek ...... 72 Husky Tucker ...... 73 Imperial Oil Cold Lake ...... 74 JACOS Hangingstone ...... 75 Shell Peace River ...... 76 Suncor Firebag ...... 77 Suncor MacKay River ...... 78

Endnotes ...... 79

vi DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card TABLE OF CONTENTS

List of Figures Figure 1: In situ oil sands development has the potential to occur over a region 30 times larger than the mineable oil sands area north of Fort McMurray ...... 1 Figure 2: Map of in situ oil sands projects included in this report ...... 5 Figure 3: Industrial development within caribou ranges is largely responsible for the decline of woodland caribou herds in Alberta ...... 7 Figure 4: Growing acidifying emissions from oil sands development may pose a risk to northern lakes ...... 10 Figure 5: Water treatment facilities at Husky Tucker ...... 11 Figure 6: Simplified life cycle activities included or excluded in this analysis ...... 13 Figure 7: Cogeneration allocation methodology ...... 15 Figure 8: Actual and forecast bitumen production volumes from in situ and mining sources in Alberta ...... 17 Figure 9: In situ oil sands production by technology type, including water injection, cyclic steam stimulation, steam assisted gravity drainage and experimental technologies ...... 18 Figure 10: SAGD wellpads at Suncor Firebag ...... 18 Figure 11: Cyclic steam stimulation ...... 19 Figure 12: Steam assisted gravity drainage ...... 19 Figure 13: Seismic lines cross-cut the boreal forest near Fort McMurray ...... 20 Figure 14: Project land use intensity based on footprint area and bitumen production volumes over the total project lifetime ...... 30 Figure 15: Conservation offsets can compensate for the residual, unavoidable harm to biodiversity caused by development projects ...... 32 Figure 16: The cumulative impacts of in situ oil sands projects need to be included in land use planning ...... 35 Figure 17: NOx emissions per barrel of bitumen produced ...... 40

Figure 18: SO2 emissions per barrel of bitumen produced ...... 42 Figure 19: Total water consumption per barrel of bitumen produced ...... 46 Figure 20: Freshwater consumption per barrel of bitumen produced ...... 48 Figure 21: Liquid waste production per barrel of bitumen produced ...... 50 Figure 22: Greenhouse gas emissions per barrel of bitumen produced ...... 54

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD vii The In Situ Oil Sands Report Card TABLE OF CONTENTS

List of Tables Table 1: List of projects included in the assessment ...... 3 Table 2: Summary of general environmental management scores per project ...... 21 Table 3: Summary of compliance records by in situ operator for 2007 ...... 27 Table 4: Summary of land scores per project ...... 29 Table 5: Summary of air emission scores per project ...... 39 Table 6: Summary of water scores per project ...... 45 Table 7: Summary of climate change scores per project ...... 53 Table 8: Summary of project scores ...... 57 Table 9: Best practice in situ development checklist ...... 65 Table 10: Summary of Canadian Natural Primrose/Wolf Lake’s 2007 environmental performance ...... 70 Table 11: Summary of Cenovus Christina Lake’s 2007 environmental performance 71 Table 12 Summary of Cenovus Foster Creek’s 2007 environmental performance .... 72 Table 13: Summary of Husky Tucker’s 2007 environmental performance ...... 73 Table 14: Summary of Imperial Oil Cold Lake’s 2007 environmental performance 74 Table 15: Summary of JACOS Hangingstone’s 2007 environmental performance .. 75 Table 16: Summary of Shell Peace River’s 2007 environmental performance ...... 76 Table 17: Summary of Suncor Firebag’s 2007 environmental performance ...... 77 Table 18: Summary of Suncor MacKay River’s 2007 environmental performance ... 78

viii DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card Executive Summary

L Forest fragmentation is one of the environmental impacts of in situ oil sands development. PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

evelopment of deep oil sands sands companies were asked to respond deposits using in situ (in place) to questions in five categories: general Dextraction techniques is growing environmental management, land, air rapidly in Alberta, Canada. There is emissions, water and climate change. limited information and discussion The average score for in situ operations about the environmental impacts and in the survey was 44%. Suncor Firebag performance of in situ oil sands received the highest overall score of development. This report represents the 60%, followed closely by Cenovus first attempt to compare the environ- Foster Creek (57%), Imperial Oil Cold mental performance of in situ oil sands Lake (55%) and Suncor MacKay River operations that were in operation in (53%). Canadian Natural Primrose / 2007 (the most recent period for which Wolf Lake received the lowest overall data was publicly available). The oil score (25%).

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD ix The In Situ Oil Sands Report Card EXECUTIVE SUMMARY

General Air Climate Environmental Land Water Overall Project Emissions Change Management (out of 5) (out of 4) Score (out of 3) (out of 2) (out of 3) Suncor Firebag 1.5 3 1.75 3 1 60%

Cenovus Foster Creek 2 2.75 2 2 1 57%

Imperial Oil Cold Lake 2.5 2* 1.25 2.5 0.5 55%

Suncor MacKay River 1.5 2.5 1.75 2.5 0.75 53%

AVERAGE 1.83 2.36 1.06 1.56 0.50 44% Shell Peace River 3 3* 0 0 0 38% (demonstration) Cenovus Christina Lake 2 2 1.5 0 0.75 37% (pilot) Husky Tucker (start-up) 2 3 0 1 0 35% JACOS Hangingstone 0.5 2* 0.5 2 0.5 34% (demonstration) Canadian Natural 1.5 1 0.75 1 0 25% Primrose/Wolf Lake

L Summary of project scores (*Imperial Oil Cold Lake, Shell Peace River and JACOS Hangingstone were scored out of four for land indicators because they were not scored on land use intensity.)

Key Findings T Only two companies have third- party accredited environmental 1. CLEAR ROOM FOR IMPROVEMENT management systems for their projects. The majority of in situ operators lagged in the following areas: 2. POOR DISCLOSURE OF ENVIRONMENTAL T Few projects have established absolute PERFORMANCE DATA reduction targets for air emissions, The quality and quantity of project- water use and GHG emissions that specific environmental data makes go beyond government requirements. comparing in situ projects a time- T Few projects have invested in consuming enterprise. There is limited biodiversity offsets to compensate for publicly available and accessible the impacts associated with in situ environmental impact data to inform development. discussion of in situ environmental T Only three companies currently performance. support regional biodiversity monitoring.

x DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card EXECUTIVE SUMMARY

3. IN SITU AND MINING PROJECTS regional environment is protected from BOTH HAVE SIGNIFICANT cumulative impacts. ENVIRONMENTAL IMPACTS While the analysis shows that oil sands Recommendations mining is more intensive on a per barrel for Government basis in some environmental impact Government and industry both have categories, such as land use, nitrogen clear roles in improving environmental oxide emissions and water intensity, a performance in the oil sands. One of typical in situ project has more intensive the main barriers to adopting leading greenhouse gas and sulphur dioxide environmental practices is a lack of emissions than mining. In addition, our incentive. Oil sands companies that land intensity assessment did not adopt leading practices receive very little incorporate the impacts of fragment- reward for their environmental initia- ation and upstream natural gas produc- tives, while laggard companies receive tion associated with in situ operations.1 very little punishment. Government can 4. BEST PRACTICES ARE NOT help improve environmental performance in the oil sands by creating WIDELY ADOPTED a competitive environment that rewards The average project score of 44% clearly environmental stewardship and demonstrates the need for improvement. innovation while penalizing laggard A fictional project designed from the companies. best elements of each oil sands project could achieve a score of 85% in this 1. Mandate environmental stewardship assessment. In other words, in situ Weak government requirements for operators could achieve a score of 85% environmental performance appear to in this assessment by incorporating be responsible for the inconsistent current industry best practices. A 100% application of best practices across the score is also achievable by combining industry. To correct this situation, current in situ industry best practices government should do the following: with two best practices from other T Encourage companies to establish industries: setting public environmental public reduction targets by providing targets to reduce absolute water use, air some benefit to companies that set emissions and greenhouse gas emissions; targets and punishing laggard and establishing biodiversity offsets. companies that do not demonstrate 5. CUMULATIVE IMPACTS ARE continuous environmental improvement. GENERALLY NOT CONSIDERED T Mandate compensatory offsets to This assessment considers the impacts mitigate the terrestrial impacts of in and performance of in situ oil sands situ oil sands development, and projects at the project level. Given the develop conservation offset policies overall pace and scale of oil sands as recommended by the proposed development – in both in situ and wetland policy for Alberta2 and mining operations – there is an Responsible Actions: A Plan for inadequate level of environmental Alberta’s Oil Sands.3 management to ensure that the

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD xi The In Situ Oil Sands Report Card EXECUTIVE SUMMARY

T Integrate mandatory financial support 1. Demonstrate leadership for the Alberta Biodiversity T Establish project-specific absolute Monitoring Institute into existing reduction targets for water use, air and future approvals. emissions and greenhouse gas T Mandate third-party accreditation of emissions that go beyond government environmental management systems requirements. for in situ projects. T Invest in biodiversity offsets 2. Make oil sands environmental commensurate with the terrestrial performance data more impact of the in situ project. comparable and accessible T Financially support the Alberta Project-specific and cumulative oil sands Biodiversity Monitoring Institute and in situ environmental performance data integrate its results into management needs to be available in an accessible planning. and comparable format. T Implement a third-party accredited environmental management system 3. Limit in situ environmental impacts for the in situ project. In situ operations have significant cumulative and long-term impacts and 2. Provide accessible public data should be submitted to rigorous Project-specific environmental data environmental impact assessments, should be disclosed publicly in a format monitoring and regulation. that is comparable across the in situ industry. 4. Create a regulatory system that rewards innovation 3. Focus on the issues In situ operators have very little In situ developments have significant incentive to improve their environ- environmental impacts and there is mental performance. Government must significant room for improvement across consider how harness the innovative the industry. Seriously engage stake- capacity of the oil sands industry to holders and publicly discuss solutions to address environmental issues. these issues. 5. Halt new approvals until 4. Incorporate best practices environmental management and lead improvements systems are complete Adopt current best practices and Complete a regional management continuously improve once best system to protect the ecological integrity practices have been adopted. of Alberta’s ecosystems from the cumul- 5. Acknowledge cumulative impacts ative impacts of oil sands development before approving new projects. of in situ development Take a leadership role in support of Recommendations for Industry establishing regional environmental thresholds and of completing land Government action must be supported use planning. and matched by the oil sands industry. xii DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card Introduction

eople in Canada, in North The oil sands are among the most America and around the world controversial energy sources in Canada. Pare searching for sustainable The Pembina Institute’s perspective is energy supplies for their growing energy that in order to support a transition to a demands. Sources of sustainable energy sustainable energy future, any would allow people to meet their needs development of the oil sands must occur today without sacrificing the long-term in a responsible manner that addresses needs of future generations. More the need to make global reductions in specifically, a sustainable energy source greenhouse gas (GHG) pollution and provides the environmental services protects regional ecosystems. (clean water, air and land), social As a way of gauging the sustainability of services (health, equal opportunity and mining-based oil sands operations and rights) and economic services (wealth, highlighting best practices, in 2008 the profit and tax revenue) to satisfy our Pembina Institute and World Wildlife needs today without preventing future Fund Canada published a report that generations from receiving the compared the environmental environmental, social and economic performance of 10 existing and services they need. proposed oil sands mines. That report,

L Figure 1: In situ oil sands development has the potential to occur over a region 30 times larger than the mineable oil sands area north of Fort McMurray. PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 1 The In Situ Oil Sands Report Card INTRODUCTION

Under-Mining the Environment: The Oil The Impacts of In Situ Oil Sands Sands Report Card,4 found that given Development on Alberta’s Boreal existing practices and available Forest,5 the Pembina Institute and technologies, even the top performer the Canadian Parks and Wilderness had significant room for improvement. Society concluded that in situ oil The aim of this report is to conduct a sands development itself is an similar analysis for in situ oil sands intensive and long-lived form of development. It provides quantitative unconventional energy development information on the current that has significant environmental environmental performance of in situ oil impacts. This new report, Drilling sands projects and attempts to define Deeper: The In Situ Oil Sands Report what responsible in situ oil sands Card, offers greater context for that development means at the individual finding. By presenting the project level. In doing so, it will clearly environmental impacts of in situ demonstrate which companies are production on a project-specific basis, leading and why, and offer suggestions it can serve as a resource for on how poorly performing companies regulators, companies and can improve their environmental stakeholders to more clearly assess, performance. As with the 2008 limit or decrease cumulative impacts. assessment, it is the first of its kind. 3. Proponents of in situ oil sands The importance of objectively assessing development increasingly assert that the relative environmental performance in situ production has considerably of in situ operations is three-fold. lower environmental impacts than mine-based production. To date, no 1. Although mining is currently the one has undertaken a definitive dominant form of oil sands comparison of the two modes of production on a volume basis, and is production on an intensity basis (or projected to stay dominant until some other relative indicator), which 2030, the majority of oil sands makes it difficult for stakeholders to deposits are only accessible through adequately evaluate this claim. This in situ technologies. Understanding report compares in situ production the differences in environmental with mining production where performance between operations can possible to objectively highlight the help regulators and companies design relative benefits and drawbacks of projects with less impact on the each bitumen production method. It environment than current ones. also provides a clearinghouse of in 2. The individual impacts of each in situ situ data for such a comparison where operation contribute to cumulative none previously existed, and can environmental impacts, which can therefore aid a future, more robust lead to significant regional comparison of oil sands mining environmental impacts. In the 2006 versus in situ development. report Death by a Thousand Cuts:

2 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card INTRODUCTION

Project Scope with data. Instead of providing performance data for different years, This report ranks thermal in situ only 2007 data were used to provide a projects that were in operation for all consistent comparison. Where possible, of 2007, including both commercial we have noted if a project’s and pilot projects. The Pembina environmental performance has Institute chose to include only these improved since 2007. Secondly, based projects for a number of factors. Firstly, on our experience with Under-Mining during the time of the assessment only the Environment, it is more complex to 2007 data was publicly available for compare active projects with planned active in situ projects. The Pembina projects. Finally, the nine projects Institute requested more recent data included in the assessment represent from each of the companies including the full range of commercial in situ in this survey, but only three responded technologies and producing regions.

M Table 1: List of projects included in the assessment

2007 Average Lead Company Project Name 2007 Status Technology Production (bbl/day) Canadian Natural (Canadian Natural Primrose/Wolf Lake Commercial 61,050 CSS Resources Limited) Cenovus (Cenovus Christina Lake Pilot 5,295 SAGD Energy Incorporated) 6 Foster Creek Commercial 49,258 SAGD (Husky Energy Commercial Husky Tucker 1,672 SAGD Incorporated) Start-up Imperial Oil Cold Lake Commercial 153,459 (Imperial Oil Limited) CSS (Japan Canada JACOS Hangingstone Demonstration 7,069 SAGD Oil Sands Limited) Shell mix of Peace River Demonstration 9,560 (Royal Dutch Shell PLC) techniques 7 Suncor (Suncor Energy Firebag Commercial 36,893 SAGD Incorporated) MacKay River Commercial 21,248 SAGD

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 3 The In Situ Oil Sands Report Card INTRODUCTION

Table 1 contains a list of all the projects challenges facing in situ operators and included in the assessment. The two comprehensive enough to meaningfully Canadian Natural projects – Primrose rank oil sands company commitments and Wolf Lake – are grouped together and environmental performance. in this survey because that is how In June and July 2009 the Pembina Canadian Natural reports the data in Institute provided each company with a public submissions and applications. completed survey and a request for In addition to its research and advocacy review and comments. Pembina work, the Pembina Institute provides Institute staff contacted each company consulting services to industry, by telephone and by electronic mail to government, First Nations and solicit feedback on the accuracy of the environmental organizations. Since data presented. Husky, Cenovus and 2006, Pembina Corporate Consulting Shell participated in the survey, reviewed has completed work for Suncor Energy the information and provided additional Ltd. and Shell Canada Ltd. This context and information to improve the consulting work has influenced neither analysis. The Pembina Institute the development nor the results of this incorporated their comments into the survey; rather it helped to provide the analysis and informed each of the Pembina Institute with the appropriate participating companies about how their technical knowledge to complete this information was incorporated. Canadian comparative analysis. Natural, Imperial Oil, JACOS and Suncor responded but declined to Data Collection participate in the survey. The Pembina Institute first gathered information on all of the indicators Performance Criteria from public data sources, primarily the The Pembina Institute selected criteria Alberta Energy and Resources to use by considering the following: Conservation Board (ERCB) in situ oil T Environmental issues and suitable sands progress reports, the National performance criteria: Each criterion Pollutant Release Inventory (NPRI) and must first represent a potential environmental impact assessments. environmental issue of concern in Disciplinary specialists in emissions, the oil sands region that in situ water, land management and industrial developments are contributing to. waste at the Pembina Institute created For example, the Under-Mining the representative questions addressing Environment report on oil sands environmental performance and mining operations included volatile commitments to continually minimize organic compound emissions because environmental effects. Although the these emissions have potential survey does not address all aspects of environmental impacts and the environmental performance, the tailings ponds at mining operations Pembina Institute is confident that the emit volatile organic compounds. indicators selected are representative of In situ operations, in contrast, the environmental management

4 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card INTRODUCTION

Peace River Suncor Firebag

Suncor MacKay River Fort McMurray

Athabasca River Shell Peace River JACOS Hangingstone Peace River

Cenovus Christina Lake Lesser Slave Lake

Cenovus Foster Creek

Canadian Natural Primrose Husky Canadian Natural Wolf Lake Tucker Athabasca Beaver River Fort McMurray Cold Imperial Oil Lake Cold Lake

North Saskatchewan River Edmonton Edmonton

LEGEND Projects Surveyed for the In Situ Oil Sands Report Card Calgary Oil Sands Lease Agreements Producing Projects Surface Mineable Area Non-producing Projects Oil Sands Area Approved Projects 0 km 50 100 150 200

L Figure 2: Map of in situ oil sands projects included in this report. PROJECT DATA: ALBERTA ENERGY, DECEMBER 2008 MAP: ROLAND LINES, THE PEMBINA INSTITUTE

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 5 The In Situ Oil Sands Report Card INTRODUCTION

emit far fewer volatile organic com- assessments. This assessment uses 2007 pounds, so these emissions were not data because that is the most recent included in the performance survey. year where data exists for all projects T Global Reporting Initiative (GRI): considered in this assessment. Where Many companies are familiar with possible we have indicated whether a GRI indicators8 because these specific project’s performance has likely indicators are often used in their increased or decreased between 2007 sustainability reports. Wherever and present. possible, the Pembina Institute used The survey questions are grouped into GRI indicators to increase the five broadly recognized areas of comparability of this report with environmental performance and current corporate social responsibility management: general environmental reporting practices and to reduce the management, land, air emissions, water reporting burden of the companies and climate change. providing information for this report. T Public data: The Pembina Institute General Environmental Management only included indicators that could be determined using public data sources because not all companies This section concerns principles of had the time or interest in environmental management that are participating in the survey. valid for any natural resource–based T External validation: Pembina Institute company or project. These principles include the development of an effective staff spoke with several industry and environmental policy, a strong record of non-governmental organizations to compliance with environmental ensure the indicators included in this regulations, third-party validation of report were of value and accurately and fairly compared projects. Each environmental management systems and company being assessed was invited transparent public reporting of to participate in the survey process to environmental data associated with a ensure the purpose was understood project. and the best available data could be What follows are the specific survey included. questions, the context for including the The questions themselves can be split questions in the survey and the into two main categories: quantitative equivalent GRI indicators. questions, which relate to criteria with 1. Does your company have an environmental a numerical value, such as air emission policy that commits to continuous intensity, and qualitative questions, improvement in environmental performance? which relate to environmental management and public policy actions. Context: A company’s published Quantitative data is based on publicly environmental policy is the public available 2007 data and some inform- expression of its environmental ation from environmental impact management system and values.

6 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card INTRODUCTION

The Pembina Institute supports 3. Do you publicly report project-specific companies that articulate a commitment environmental data for your project? to continuous environmental Context: Public reporting allows improvement because companies must stakeholders to assess and compare the now be held accountable. ISO 14001 environmental performance of in situ also requires that companies include operators. Industrial operators that a commitment to continuous provide detailed data on their operations improvement in their policies.9 encourage trust and assist in creating a GRI Indicator: None applicable transparent system from which environmental issues and solutions can be identified more quickly. In the context of this report card, public reporting is defined as project-specific environmental parameters that companies make directly available to the public through company websites, annual sustainability reports and government reports or websites. GRI Indicator: None applicable

4. Please summarize all ambient air exceedances and all environmental enforcement actions (including warning letters, prosecutions, fines, L 2. Does your oil sands operation have etc.) in 2007 for this oil sands operation. Figure 3: an environmental management system that Context: Environmental regulations exist has been accredited by an independent third Industrial to ensure industrial operations do not party, such as ISO 14001 or equivalent? development unduly harm the natural environment. within caribou Context: ISO 14001 is an internationally These regulations grant the government ranges is recognized standard for environmental largely the authority to punish companies responsible for management systems. It has clear whose projects are exceeding the rules the decline of requirements for establishing an laid out in the regulation and may woodland environmental policy, determining ultimately be causing harm to the caribou herds environmental risks and setting goals to natural environment. Companies with in Alberta. reduce environmental impacts. Third- PHOTO: WAYNE LYNCH poor environmental compliance records party validation of an environmental are therefore more likely to cause management system provides external environmental damages. evidence of the rigour of the GRI Indicator: environmental management system. EN28. Monetary value of Although ISO 14001 does not significant fines and total number of provide standards for environmental non-monetary sanctions for non- performance, it does provide a globally compliance with environmental laws recognized framework for developing an and regulations. environmental management system. GRI Indicator: None applicable

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 7 The In Situ Oil Sands Report Card INTRODUCTION

unavoidable harm to biodiversity caused Land by development projects, thereby aspiring to no net loss in biodiversity.10 In situ development results in significant Biodiversity offsets attempt to mitigate fragmentation and disturbance of boreal ecosystem disturbance and habitat loss by forest ecosystems. This section contains restoring or conserving substitute forest indicators relating to disturbance areas so that no net loss of critical habitat footprint, the monitoring of biodiversity is maintained in perpetuity. Conservation impacts, strategies to offset terrestrial offsets compensate for development impacts and company leadership in impacts as part of a complementary supporting the establishment of strategy involving significant new protected areas in the boreal forest. conservation and protected areas and enhancing mitigation practices and 5. What is the total expected land disturbance reclamation. The Government of Alberta including exploration and production footprints is exploring the establishment of 2 (m ) for your oil sands operation? conservation offset policies to mitigate Context: The majority of oil sands in situ terrestrial impacts of oil sands develop- development is or is planned to occur in ment.11 The Pembina Institute considers relatively intact boreal forest. Any the voluntary establishment of development in this environment results conservation offsets an important in an increased cumulative impact on indicator of environmental performance species and ecological systems. in the absence of regulated offset Determining the exact impact of each programs. facility requires specific knowledge of GRI Indicator: EN13. Habitats protected where it is being built and the or restored. techniques used for forest clearing and construction. However, because any 7. Is your project lease area located in woodland clearing will have some impact on caribou habitat as defined by Alberta wildlife, the total project footprint was Sustainable Resource Development? used for the calculations. Context: Woodland caribou are a GRI Indicator: EN11. Location and size of threatened species in Canada and land owned, leased, managed in, or adja- Alberta. Environment Canada has cent to, protected areas and areas of high concluded that all woodland caribou biodiversity value outside protected areas. herds in Alberta are considered to have non-self-sustaining populations.12 6. Please report and provide documentation of Industrial development within caribou total hectares of biodiversity/conservation ranges is largely responsible for these offsets established to compensate for declines.13 It is recommended that terrestrial impacts of your oil sands project. habitat restoration is necessary if these Context: In situ facilities have a residual populations are to be maintained, yet impact on biodiversity regardless of a new in situ developments are proposed company’s on-site mitigation measures. in the ranges of these declining herds. Biodiversity and conservation offsets offer In the absence of a land use plan that a method to compensate for the residual, identifies how woodland caribou habitat

8 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card INTRODUCTION

is to be protected, any in situ oil sands Albertans can rely on for high quality development, regardless of mitigation monitoring and reporting on the state of measures, contributes to the decline of biodiversity in Alberta.”17 It is capable of this threatened species. providing statistically rigorous GRI Indicator: None applicable information about regional-level changes in biodiversity and has protocols that can 8. Did your company support Cumulative be adapted to determine site-specific Environmental Management Association changes at the level of a single oil sands recommendations for conservation planning, project. Without a credible, regional specifically the recommendation to program such as the ABMI, there is permanently protect 20-40% of the Regional insufficient information to adequately Municipality of Wood Buffalo from industrial assess changes to biodiversity in the development? region. The ABMI is supported by both Context: The Cumulative Environmental government and voluntary industry Management Association (CEMA) is a funding but does not currently have multi-stakeholder body charged with sustainable long-term funding. Financial assessing cumulative impacts of develop- support for the ABMI is a key indicator ment and making recommendations to of an oil sands companies’ commitment improve environmental management in to meaningful biodiversity monitoring northeastern Alberta.14 In 2008, CEMA until a comprehensive regulated recommended that between 20% and approach to biodiversity monitoring is 40% of northeastern Alberta should be developed. (The Pembina Institute sits permanently protected from industrial on the ABMI board as the representative development through the establishment for Alberta’s environmental community.) of legally designated conservation areas.15 This indicator reflects which companies GRI Indicator: None applicable have been constructive participants in supporting the establishment of conserv- Air Emissions ation areas free of industrial activity. GRI Indicator: None applicable Oil sands projects are major emitters of 9. Does your company provide financial support many chemical pollutants. Air emissions to the Alberta Biodiversity Monitoring Institute of particular importance generated at in (ABMI) in order to provide meaningful, long- situ operations include nitrogen oxides term information about changes in biodiversity (NOx) and sulphur dioxide (SO2). in the oil sands region? Have you incorporated Both emission types contribute to smog, ABMI biodiversity monitoring protocols into have potential human health impacts your project-specific reporting requirements? and are contributors to acid rain. This If so, please describe this support. section reports on project emission levels Context: Effective monitoring for and voluntary company targets to changes in wildlife species is an essential reduce air pollution. component of oil sands management. One of the goals of this survey was to An independent science advisory com- quantify NOx and SO2 emissions for mittee found the ABMI16 to be “a each project in order to highlight best comprehensive world-class program that

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 9 The In Situ Oil Sands Report Card INTRODUCTION

practices. For this analysis to be Despite these technologies, in situ oil meaningful the data collected for each sands operations still result in the release project had to be comparable. To be of 9,752 tonnes NOx of each year.18 comparable, the Pembina Institute incorporated life cycle emissions and SO2 is similarly formed during the allocated cogeneration emissions for air combustion of natural gas and produced emissions. A more detailed explanation gas for heat and electricity used on-site of the methodology is available in Life at in situ facilities. Upstream natural gas Cycle Approach and Cogeneration production also produces relatively sections. significant quantities of SO2 during the natural processing phase. Operators can NOx are formed during the combustion reduce their SO2 emissions by reducing of natural gas for heat and electricity at the quantity of natural gas combusted in situ sites. In situ operators use or by installing technologies, such as technologies, such as low NOx boilers, sulphur recovery units. Despite these to reduce NOx emissions. Some of the technologies, in situ oil sands operations lowest NOx intensities result from still result in the release of 9,043 tonnes reduced natural gas consumption. SO2 of each year.19

L Figure 4: Growing acidifying emissions from oil sands development may pose a risk to northern lakes. PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

10 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card INTRODUCTION

10. What are your overall project-specific nitrogen 12. Does your company have publicly reported oxides (NOx) emissions in grams (g) per targets to reduce or offset NOx or SO2 beyond barrel (bbl)? government regulations? If so, what are they?

Context: NOx emissions contribute to Context: NOx and SO2 emissions both the formation of ground level ozone and contribute to acid rain and affect acid rain. Ground level ozone can human health.23 The Pembina Institute irritate the respiratory system. Current believes that oil sands projects should acid deposition in Saskatchewan may reduce their NOx and SO2 emissions exceed the buffering capacity of lakes whenever possible, given their and soils in regions close to the oil contribution to acid deposition and the sands.20 NOx are emitted in large potential for human health impacts in quantities from in situ projects and have and around oil sands facilities. The known human health impacts and Pembina Institute encourages companies impacts on the environment.21 For the to take a leadership role and commit to purpose of comparing projects, the GRI voluntary reduction targets because the indicator was converted to a per barrel Pembina Institute believes companies emissions intensity measure. should be minimizing impacts where possible regardless of regulated limits. GRI Indicator: EN20. NOx and SO2 and Companies that are able to achieve other significant air emissions by type emission reductions above and beyond and weight. regulated limits encourage other

11. What is your 2007 average SO2 emission companies to achieve similar results. intensity in grams (g) per barrel (bbl)? This indicator is not included under the GRI guideline, but setting internal Context: Once released into the targets is considered to be an essential atmosphere, SO2 contributes to the component of an environmental formation of smog and haze. In high management plan.24 concentrations, SO2 emissions can have a direct impact on human health, GRI Indicator: None applicable causing respiratory illness and aggravating pre-existing cardiovascular disease.22 SO2 is also the major component in the production of acid rain. As with NOx emissions, the GRI indicator was converted to a per barrel emissions intensity measure for the purpose of comparing projects. GRI Indicator: EN20. NOx and SO2 and other significant air emissions L Figure 5: Water treatment facilities at Husky Tucker. by type and weight. PHOTO: COURTESY OF HUSKY ENERGY

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 11 The In Situ Oil Sands Report Card INTRODUCTION

14. What is the total volume of freshwater Water use in 2007? 26 Context: Freshwater resources, which Because of the cumulative scale of oil include rivers, streams, lakes and fresh sands projects, in situ operations groundwater, are defined as water with consume a considerable amount of total dissolved solids (including sodium water. This make-up water volume is in content) below 4,000 ppm.27 With the addition to water that is recycled large water demands required by in situ through the processes. In situ facilities operations, it is essential that oil sands use either surface water or groundwater projects minimize their use of freshwater (fresh or saline), or any combination of resources by making use of saline water these sources. In situ operators also resources when available. produce waste products that are typically injected deep underground or shipped GRI Indicator: None applicable off-site to a waste treatment facility.25 15. What is the average volume (bbl) of liquid This section compares projects on waste produced per barrel (bbl) of bitumen absolute water use, freshwater use, for 2007? liquid waste production and public Context: When in situ operators re-inject targets to reduce water use. liquid waste products deep under- ground, there is a risk that the waste 13. What is your project’s 2007 average water fluids will flow underground and consumption (brackish and fresh water) per contaminate other groundwater sources. barrel of bitumen produced? To avoid this problem, operators limit Context: Withdrawing any type of water, the re-injection pressure, but the even saline water, can have direct or increased volumes of underground indirect impacts on surrounding wetlands, liquids risk future flow.28 Some in situ lakes, aquifers and other water systems. facilities also ship solid and liquid waste However, groundwater monitoring and off-site to a waste treatment facility. The current data are insufficient to accur- GRI indicator was converted to a per ately judge potential impacts and safe barrel intensity measure for the purpose withdrawal limits. The Pembina of comparing projects. Institute believes that in the absence of sufficient data, operators with lower GRI Indicator: EN22. Total weight of consumptive water use intensity pose a waste by type and disposal method. lesser risk to groundwater resources. The 16. Does your company have publicly reported GRI indicator was converted to a per targets to reduce water intensity and barrel intensity measure for the purpose consumption in your operations beyond of comparing projects. government regulations? If so, what are GRI Indicator: EN8. Identify the total your targets? volume of water withdrawn from any Context: Withdrawing any type of water, water source that was either withdrawn even saline water, can have direct or directly by the reporting organization or indirect impacts on surrounding water through intermediaries such as water systems. Public targets ensure companies utilities. quantify their commitment to

12 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card INTRODUCTION

continuous improvement, help spur is to achieve the necessary deep technological innovation and application reductions in overall GHG emissions, and lead to real reductions in water use. emissions must be reduced in absolute The ISO 14001 standard recognizes terms. However, GHG intensity is a internal water reduction targets as a key useful way to compare the efficiency component of a complete environmental of oil sands operations. It is important management system.29 to note that the emissions presented here are from the production of GRI Indicator: None applicable bitumen only. GRI Indicator: EN16. Identify direct Climate Change emissions of GHGs from all sources owned or controlled by the reporting Extracting bitumen from the oil sands is organization. very energy intensive. As a result, in situ operations are major emitters of GHGs. 18. Does your company have publicly reported The data used for this section of the absolute greenhouse gas emission reduction report are derived in the same manner targets beyond government regulations? discussed in the air emissions section. If so, what are they? Context: A public opinion poll 17. What is your 2007 average greenhouse gas conducted by Probe Research in 2007 emission intensity in kilograms (kg) per barrel showed that 92% of Albertans polled (bbl) of bitumen? felt that oil sands companies should Context: Over 44% of the increase in reduce greenhouse emissions at all their Canada’s GHG emissions from 2006 to facilities. The same poll showed that 2020 is projected to be a direct result of 70% of Albertans felt that absolute new oil sands development.30 If Canada reductions in GHGs were appropriate, compared to the 20% of Albertans polled that preferred targets that reduced only the intensity of GHG emissions per barrel.31 Voluntary targets are recognized by ISO 14001 as a necessary component of an environ- mental management system. GRI Indicator: EN18. Report quantitatively the extent GHG emissions reductions achieved during the reporting period as a direct result of the initiative(s) in tonnes of CO2 equivalent.

Life Cycle Approach Each in situ oil sands project is slightly L Figure 6: Simplified life cycle activities included or different, but all projects require some excluded in this analysis. similar types of equipment and energy

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 13 The In Situ Oil Sands Report Card INTRODUCTION

sources. To ensure a fair comparison of have a cogeneration site, an on-site projects, this analysis uses a life cycle facility that produces both electricity approach. Each project was compared and heat, additional methodologies were on a per barrel of bitumen basis. needed to ensure that those facilities Upgrading was not included in the were not unfairly disadvantaged. While assessment. Figure 6 identifies activities cogeneration facilities produce heat, that were included or excluded in the which is provided exclusively to the site, analysis. only a portion of the electricity they The main purpose of using a life cycle produce is used by the in situ operation. perspective is to ensure that projects that The remainder of the produced reduce on-site emissions are not electrical power is redistributed to the transferring those impacts to other electrical grid. It was therefore necessary locations. For example, an in situ to ensure that emissions associated with project with a cogeneration facility that the portion of electricity redistributed produces its own electricity will likely to the grid were not allocated to the have higher on-site emissions than one project. without. The project without a Allocating cogeneration emissions cogeneration facility still requires was difficult due to a lack of publicly electricity, however, and the emissions available data, but in general terms, from that electricity generation should a cogeneration allocation ratio was be attributed to the project’s bitumen calculated and then applied to the production. Increases or decreases in off- total emissions value to determine site emissions are important to quantify what portion of the emissions should to provide the fairest assessment of life be allocated to the site. cycle environmental impact. Figure 7 depicts the cogeneration Because applicable life cycle data does allocation methodology. The allocation not exist for all indicators, only those ratio is simply the portion of produced with Alberta-specific life cycle data are heat and electricity used by the in situ included. Life cycle data is used for facility (E1 and H1 in the diagram) GHG, NOx and SO2 emissions. There divided by the total heat and electricity are also water and land impacts produced by the cogeneration facility associated with natural gas production, (E1, E2 and H1 in the diagram). In this but quality data on these indicators are way, in situ operations that incorporate not readily available. cogeneration facilities are not penalized for the air emissions associated with the production of electricity they do not Cogeneration use. In other words, the in situ operators This survey includes air emissions are only responsible for the air emissions (NOx and SO2) and GHG emissions associated with the heat and electricity associated with off-site electricity and they use to produce bitumen at the site. natural gas production. For facilities that

14 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card INTRODUCTION

An operation that has adopted a number of these management practices is clearly making an effort to implement systems to better manage its environmental impacts. The remaining questions consider the environmental impact associated with the production of a barrel of bitumen from each operation, in terms of water use, air emissions, land impacts and GHG emissions. For quantitative indicators, such as GHG emissions per barrel of bitumen, projects were ranked in quartiles from highest to lowest performer. Projects within 25% of the top performer were granted full points for that question. L Projects performing within 25–50% Scoring of the top performer were granted 0.5 Figure 7: For each environmental indicator we points, projects performing within Cogeneration 50–75% of the top performer were allocation identify leaders and laggards and score methodology. the projects accordingly. For yes/no awarded 0.25 points and projects in the questions, a project receives either 1 or 0 bottom quartile were awarded zero points. In limited circumstances we points. Using this relative scale clearly provide 0.5 points for projects that distinguishes the leaders and laggards partially achieve a yes/no indicator. For among projects, but it does not indicate example, although all projects publicly whether the best performer is truly a report project-specific environmental leader in an absolute sense. For example, indicators, this information is often the project with the lowest GHG difficult to find and inconsistent intensity is awarded full marks under between projects. For this reason, most this methodology, but this does not projects received only a 0.5 for public mean that project should not be reporting instead of 1. achieving better performance; it is simply the best relative to its peers. The yes/no questions were designed to determine which projects and We aggregated the scores within the five companies demonstrate a progressive categories to facilitate comparisons approach to environmental management among projects and among companies. by participating in exemplary We calculated an overall project score management practices, such as for each project as the percentage of the independent performance verification, possible total for all questions. Where mitigation and monitoring efforts, and a project was scored as not applicable voluntary performance targets in the (n/a) on any question, that question absence of clear regulatory requirements. was not included in the calculation of overall score.

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 15 The In Situ Oil Sands Report Card INTRODUCTION

Limitations The concern with this phenomenon is that naturally occurring minerals, such We believe that this report represents as arsenic, become highly concentrated the most comprehensive and rigorous in thermal plumes and, through publicly available assessment of migration, risk contaminating ground- comparative environmental performance water systems.33 Another example is of in situ oil sands operations. This cumulative impacts. This report report focuses on current environmental focuses on comparing individual in performance of in situ oil sands situ operations, but the combined operations only. It does not consider existence of all in situ projects corporate governance issues, the health contributes to cumulative impacts and safety of employees, or the that must be addressed differently adequacy of consultation and than project-specific impacts. accommodation of aboriginal interests This report should be considered a by oil sands companies. For information snap-shot of project-specific environ- about other indicators, readers are mental performance, based on data that encouraged to examine sources such was available during our analysis period. as Lines in the Sands: Oil Sands Sector Companies update their performance Benchmarking by Northwest and Ethical regularly. For example, most companies Investments.32 That survey is based on a have subsequently updated their in situ broad assessment of potential risks and performance reports for 2008. company mitigation strategies. The Pembina Institute attempted to The Pembina Institute attempted to appropriately credit facilities that have compare in situ projects on as many incorporated cogeneration. However, environmental issues as possible. to do this correctly requires detailed However, data are not available for some natural gas and electricity generation issues and for others the environmental and use values. This information is not issue is not fully addressed. For example, available in the public domain. The when high-temperature and high- Pembina Institute estimated emissions pressure steam is injected underground, based on available information, and it creates a region where underground these calculations should only be temperatures are significantly higher considered as estimates. Our approach than normal conditions. This region, is discussed in detail in the Cogener- called a thermal plume, can slowly ation section. migrate underground with time.

16 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card About In Situ Production Alberta’s Oil Sands coming decades. Oil sands suitable for in situ extraction underlie about il sands are naturally occurring 135,000 km2 – nearly 30 times the mixtures of sand or clay, water 4,800 km2 of oil sands that is potentially Oand tar-like bitumen. In an oil surface mineable. Figure 8 displays the sands deposit, each grain of sand is actual and forecast contribution of covered by a thin layer of water and bitumen production from mining and then by a layer of the highly viscous in situ sources. bitumen.34 Bitumen is a heavy form of crude oil. In Situ Production Technologies The Alberta oil sands contain an estimated 175 billion barrels of crude Oil sand deposits that are more than bitumen that can be recovered using 100 m below the surface are generally current technology.35 They are primarily recovered using in situ techniques. In found in three deposits – Athabasca, situ extraction involves drilling several Cold Lake and Peace River36 – and wells into the deposit and then heating underlie approximately 140,000 km2 or diluting the oil sands underground so (20%) of Alberta, which is an area the bitumen can flow to a well and be 42 about the size of Florida.37 As of June pumped to the surface. Most in situ oil 2009, the Alberta government had sands deposits are more than 400 m 43 granted 84,000 km2 of oil sands below the surface. extraction leases,38 which accounts for almost 60% of the total oil sands area. Unlike conventional crude oil, bitumen is too thick and viscous to flow naturally or to be pumped out of the ground unless it is heated or diluted with a solvent. Before it can be refined into useable petroleum products, bitumen must be upgraded into synthetic crude oil.39 The two primary extraction techniques for oil sands are mining and in situ (Latin for “in place”). Mining, which is currently the dominant form of oil sands extraction, accounted for 55% of L Figure 8: Actual and forecast bitumen oil sands production in Alberta in production volumes from in situ and mining 2008.40 However, as over 80% of sources in Alberta. Alberta’s oil sands resource is too deep SOURCE: ERCB 41 for surface mining, in situ extraction will become increasingly important in

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 17 The In Situ Oil Sands Report Card IN SITU PRODUCTION

The two main types of thermal in situ seen in Figure 11. After a period of technology are steam assisted gravity soaking, the warmed bitumen flows drainage (SAGD) and cyclic steam toward the well bore and is pumped to stimulation (CSS). Bitumen is also the surface through the same well bore produced using water injection, but that that injected the steam. Then the whole production technique is not included in process starts again, with the “huff and this report because of the greater pace puff” cycle continuing until oil recovery and scale of thermal in situ development is no longer economical.47 The recovered and its known environmental intensity. Figure 9 shows historical in situ bitumen production by technology type.

CYCLIC STEAM STIMULATION (CSS) The CSS process requires a caprock and overburden of more than 300–400 m to withstand the high pressure created by the steam.45 CSS has been used in the Cold Lake and Peace River areas for more than 20 years.46 In the CSS process, high-pressure steam is injected into the bitumen-bearing formation through a combination of vertical and horizontal wells, as can be bitumen is diluted with condensate L (pentanes and heavier liquid hydro- Figure 10. carbons obtained from natural gas SAGD wellpads production) and shipped by pipeline. at Suncor Firebag.

The steam condenses in the formation, PHOTO: and most of it will be pumped to the SUNCOR ENERGY surface with the fluidized bitumen. In most situations this produced water is de-oiled and treated so it can be recycled to generate steam for the next injection cycle. Additional water is needed to replace water lost in the formation and treatment process.

L Figure 9: In situ oil sands production by STEAM ASSISTED GRAVITY DRAINAGE technology type, including water injection, (SAGD) cyclic steam stimulation, steam assisted The government-led Alberta Oil Sands gravity drainage and experimental Technology and Research Authority and technologies. SOURCE: ERCB 44 the oil sands industry developed the SAGD process after more than a decade of research.49 SAGD is used to extract

18 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card IN SITU PRODUCTION

Mining L Figure 12: Although oil sands mining is not a focus L Steam assisted bitumen in areas where mining is not of this report, a brief description of gravity Figure 11: possible but where the bitumen is not mining operations is warranted because drainage. Cyclic steam deep enough for high-pressure CSS this report compares the environmental ILLUSTRATION: J&W stimulation. 50 COMMUNICATIONS, techniques to work. In the SAGD impacts of a typical oil sands mine THE PEMBINA INSTITUTE SOURCE: process, steam is continuously injected IMPERIAL OIL 48 with average in situ environmental underground through one set of pipes performance. and the heated, fluidized bitumen and In mining operations, bitumen-laden water (from the condensed steam) are oil sands are mined using trucks and collected and pumped to the surface shovels. The trucks transport the oil through a lower, parallel set of pipes. sands to a preparation plant, where the The bitumen is recovered and in most oil sands are crushed and mixed with cases the produced water is de-oiled and water before being transported to the treated so that it can be reused. Several bitumen extraction plant. At the wells are drilled from a single well pad, bitumen extraction plant the bitumen and a SAGD project can have many is separated from the water and sand. pads over an extensive areas. The bitumen is then sent to be upgraded into synthetic crude oil. EMERGING IN SITU TECHNOLOGIES The waste material, called tailings, Entrepreneurs are researching and is sent for further processing before testing a range of in situ technologies, being disposed of in tailings ponds, such as toe-to-heel air injection (THAI), which in 2009 covered 130 km2 and vapour extraction and electric induction. held 720 billion litres of tailings waste. While proponents claim these technologies can economically produce bitumen with fewer environmental The Pembina Institute and World Wildlife Fund impacts, none has yet been Canada ranked environmental performance of demonstrated at a commercial scale. 10 proposed and operating oil sands mines in The analysis in this report includes only the 2008 report Under-Mining the Environ- existing commercial technologies. ment: The Oil Sands Report Card. It is available for download at www.oilsandswatch.org/pub/1571.

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 19 The In Situ Oil Sands Report Card Survey Results

his section provides the results laggards. For yes/no questions, projects of the survey per issue area for that receive a 1 are considered leaders Tall of the in situ projects included and those with a 0 are laggards. In some in the assessment. Scores are provided circumstances a project will receive a on a per indicator basis, on a 0 to 1 0.5 and be placed in the middle scale. The environmental indicators category. For questions that are scored are organized into five general on a relative scale, such as GHG categories: general environmental intensity, projects that are better than management, land, air emissions, average are considered leaders, those water and climate change. close to the average are middle and those worse than the average laggards. For each indicator the in situ projects are divided into leaders, middle and

L Figure 13: Seismic lines cross-cut the boreal forest near Fort McMurray.

20 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute eneral Environmental Management

G Sur vey Results

his category assesses the following 3. transparent public reporting of G indicators of a sound approach environmental data associated with Tto general environmental the project management: 4. strong compliance with 1. development of an environmental environmental regulations policy that commits to continuous Project scores for this category are environmental improvement summarized in Table 2. Question 4 2. validation of the environmental (regulatory compliance) was not scored. management system by a third party

M Table 2: Summary of general environmental management scores per project.

Continuous Third-Party Public Data Total Project Improvement Validation Reporting Score

Shell Peace River 1 1 1 (demonstration) 3 Imperial Oil Cold Lake 1 1 0.5 2.5 Cenovus Christina Lake 1 0 1 (pilot) 2 Cenovus Foster Creek 1 0 1 2 Husky Tucker (start-up) 1 0 1 2 Canadian Natural 1 0 0.5 1.5 Primrose/Wolf Lake Suncor Firebag 1 0 0.5 1.5 Suncor MacKay River 1 0 0.5 1.5 JACOS Hangingstone 0 0 0.5 (demonstration) 0.5

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 21 General Environmental Management 22 DRILLING DEEPER:THE INSITUOIL SANDS REPORT CARD impr a commitmenttocontinuous also requires thatcompaniesinclude now beheldaccountable.ISO14001 improvement becausecompaniesmust to continuousenvironmental acommitment companies thatarticulate values. The Pembina Institute supports environmental managementsystemand policy isthepublicexpression ofits A company’s publishedenvironmental CONTEXT CONTINUOUSIMPROVEMENT 1 ovement intheirpolicies. in environmental performance? policy thatcommitstocontinuousimprovement Does yourcompanyhaveanenvironmental The InSituOilSandsReportCard 52 improvement. environmental performance that committocontinuous compr All theinsituoperatorsabove have Suncor MacKayRiver Peace River, SuncorFirebag, Imperial OilColdLake,Shell Foster Creek,HuskyTucker, Christina Lake,Cenovus Primrose/Wolf Lake,Cenovus Canadian Natural % continuous environmental improvement. policy thatmakesacommitmentto not appeartohave anenvironmental JACOS istheonlycompanythatdoes JACOS Hangingstone None ! LAGGARDS LEADERS MIDDLE ehensive environmental policies SURVEY RESULTS The Pembina Institute The In Situ Oil Sands Report Card SURVEY RESULTS General Environmental Management 2 THIRD-PARTY VALIDATION Does your oil sands operation have an environmental management system that has been accredited by an independent third party, such as ISO 14001 or equivalent?

CONTEXT % LEADERS ISO 14001 is an internationally Imperial Oil Cold Lake, recognized standard for environmental Shell Peace River management systems. It has clear requirements for establishing an Imperial Oil Cold Lake has an environmental policy, determining operations integrity management system environmental risks and setting goals to that has been registered by a third party reduce environmental impacts. Third- as meeting the intent and requirements party validation of an environmental of ISO 14001. Shell Peace River is ISO management system provides external 14001 registered. evidence of the rigour of the environmental management system. ! MIDDLE Although ISO 14001 does not provide standards for environmental None L performance, it does provide a globally recognized framework for developing an LAGGARDS environmental management system. Canadian Natural Primrose/Wolf Lake, Cenovus Christina Lake, Cenovus Foster Creek, Husky Tucker, JACOS Hangingstone, Suncor Firebag, Suncor MacKay River None of these projects provided evidence of an independently accredited environmental management system.

LAGGARDS

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 23 The In Situ Oil Sands Report Card SURVEY RESULTS

3 PUBLIC DATA REPORTING Do you publicly report project-specific environmental data for your project?

CONTEXT % LEADERS Public reporting allows stakeholders to Cenovus Christina Lake, assess and compare the environmental Cenovus Foster Creek, Husky performance of in situ operators. Tucker, Shell Peace River Industrial operators that provide detailed data on their operations Cenovus, Husky and Shell all encourage trust and assist in creating a participated in the survey for this report transparent system from which and provided clarifications to public environmental issues and solutions can data the Pembina Institute had

General Environmental Management be identified more quickly. In the collected. The assistance of Cenovus, context of this report card, public Husky and Shell staff reduced the effort reporting is defined as project-specific required to analyze the public data and environmental parameters that improved the accuracy of the final companies make directly available to the conclusions. For several other projects, public through company websites, the Pembina Institute had to estimate annual sustainability reports and values based on publicly available government reports or websites. information.

L The Husky Tucker project (shown), along with the Cenovus and Shell projects, participated in the survey for this report. PHOTO: COURTESY OF HUSKY ENERGY

24 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card SURVEY RESULTS General Environmental Management 3 PUBLIC DATA REPORTING

! MIDDLE ance data, no company reported all of the data needed for this report. In some Canadian Natural cases, data crucial to a comparison of Primrose/Wolf Lake, operational performance was unavailable Imperial Oil Cold Lake, and information provided in project JACOS Hangingstone, applications and environmental impact Suncor Firebag, Suncor assessments was used to fill the gaps. MacKay River Project applications often do not All in situ oil sands operators provide represent actual performance. annual performance updates to the ERCB. These reports include LAGGARDS operational data, such as sulphur None emissions, water consumption, wastewater production and bitumen production. Some companies produce sustainability reports that summarize environmental impacts on a project-by- project basis, but many companies aggregate their environmental performance data into other operations. For example, Suncor reports some indicators for the Firebag facility independently, but reports other indicators only for Suncor’s facility as a whole, which includes mining, upgrading and in situ operations. In situ operators are required to report annual GHG and air emissions to government agencies, such as Environment Canada. The Pembina Institute found it difficult to compare in situ projects because the in situ operators provided data in different formats and used different methodologies to generate the data. For example, companies used different start L Lack of consistency in reporting between oil and end dates for data reporting sands operators and a shortage of comparative periods. In addition, while companies information provided by Government makes it challenging to compare the environmental publicly report much of their perform- performance of oil sands projects. PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 25 The In Situ Oil Sands Report Card SURVEY RESULTS

4 REGULATORY COMPLIANCE Please summarize all ambient air exceedances and all environmental enforcement actions (including warning letters, prosecutions, fines, etc.) in 2007 for this oil sands operation.

CONTEXT Evaluating projects according to this parameter proved to be more challenging Environmental regulations exist to than anticipated. In some cases, ensure industrial operations do not regulators found that a given company unduly harm the natural environment. exceeded compliance requirements and These regulations grant the government the regulator asked that the company the authority to punish companies

General Environmental Management rectify the situation. In other cases whose projects are exceeding the rules companies self-reported compliance laid out in the regulation and may issues and then rectified them without ultimately be causing harm to the any government action. In a few cases natural environment. Companies with regulators fined companies for operating poor environmental compliance records out of compliance for extended periods are therefore more likely to cause of time. environmental damages.

L Meeting all applicable laws is a key component of environmental management. PHOTO: THE PEMBINA INSTITUTE

26 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card SURVEY RESULTS General Environmental Management 4 REGULATORY COMPLIANCE

The Pembina Institute could not 1. self-disclosed incidents that resulted develop a fair metric to compare in no release of material to the projects on this indicator. The variation environment in the level of accountability and 2. non-disclosed incidents (such as those response is not clearly identified in all discovered by an ERCB facility audit) data sets, making it difficult to rank that resulted in no release the projects against one another. As such, environment there is no scoring for this environmental performance indicator. 3. self-disclosed incidents that resulted However, the compliance record for in a release of material to the each company is provided below in environment Table 3 for reference. The data is 4. non-disclosed incidents that resulted organized into the following five in a release of material to the compliance infraction types: environment 5. fines for compliance infractions

M Table 3: Summary of compliance records by in situ operator for 2007.52

1) No release, 2) No release, 3) Release, 4) Release, 5) Fines Project self-disclosed non- disclosed self-disclosed non-disclosed

Canadian Natural 1 1 1 1 Primrose/Wolf Lake Cenovus Christina Lake 1 1 4 (pilot) Cenovus Foster Creek Husky Tucker (start-up) 1 Imperial Oil Cold Lake 1 JACOS Hangingstone 5 (demonstration) Shell Peace River 2 9 (demonstration) Suncor Firebag 211 Suncor MacKay River 2 8

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 27 The In Situ Oil Sands Report Card SURVEY RESULTS General Environmental Management

L The seismic lines, roads, well pads and other facilities associated with in situ development contribute to direct habitat loss and fragmentation. PHOTO: DAVID DODGE, THE PEMBINA INSTITUTE

28 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute and

L Sur vey Results

he seismic lines, roads, pipelines, indicators relating to project land use, power lines, well pads and conservation offsets to mitigate Tfacilities associated with in situ oil biodiversity impacts, development in sands development contribute to direct threatened woodland caribou habitat, habitat loss and the fragmentation of support for conservation targets through additional habitat. This section contains protected areas planning, and monitoring of impacts on biodiversity.

M Table 4: Summary of land scores per project. (*Imperial Oil Cold Lake, JACOS Hangingstone and Shell Peace River were not scored on land use intensity, therefore their total score is out of four instead of five.)

Conservation Caribou Conservation Biodiversity Total Project Footprint Offsets Habitat Planning Monitoring Score

Shell Peace River n/a 0 1 1 1 * (demonstration) 3 Husky Tucker (start-up) 1 0 1 1 0 3 Suncor Firebag 0.5 0.5 0 1 1 3 Cenovus Foster Creek 0.75 0 0 1 1 2.75 Suncor MacKay River 0 0.5 0 1 1 2.5 Imperial Oil Cold Lake n/a 0 1 1 0 2* JACOS Hangingstone n/a 0 1 1 0 * (demonstration) 2 Cenovus Christina Lake 000 1 1 (pilot) 2 Canadian Natural 1 0 0 0 0 1 Primrose/Wolf Lake

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 29 The In Situ Oil Sands Report Card SURVEY RESULTS

5 FOOTPRINT Land What is the total expected land disturbance including exploration and production footprints (m2) for your oil sands operation?

CONTEXT produces more bitumen per unit area of footprint than another, is making more The majority of in situ oil sands efficient use of land. The metric for this development is or is planned to occur indicator is footprint (m2) per barrel of in relatively intact boreal forest. Any bitumen production, where the footprint development in this environment results is the total disturbance over the life of in an increased cumulative impact on the project and bitumen production is species and ecological systems. the total expected production associated Determining the exact impact of each with that footprint. The metric was facility requires specific knowledge of converted to the more appropriate units where it is being built and the of hectares per million barrels. techniques used for forest clearing and construction. However, because any Insufficient data exists in the public clearing will have some impact on realm to estimate land use intensity for wildlife, the total project footprint was Imperial Oil Cold Lake, JACOS used for the calculations. Hangingstone and Shell Peace River. Therefore, those projects were not However, an adjustment has been made scored on this indicator. to this metric in order to account for project production rates. It is necessary to acknowledge that a project that RESULTS

L Figure 14: Project land use intensity based on footprint area and bitumen production volumes over the total project lifetime.

30 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card SURVEY RESULTS Land 5 FOOTPRINT

% LEADERS LAGGARDS Canadian Natural Cenovus Christina Lake, Primrose/Wolf Lake, Suncor MacKay River Cenovus Foster Creek, Both Cenovus Christina Lake and Husky Tucker Suncor MacKay River have The land disturbance intensities for considerably larger land disturbance Canadian Natural Primrose/Wolf Lake intensities than the other in situ and for Husky Tucker, as measured by facilities. the total expected land disturbance over the lifetime of the project divided by HOW DOES MINING COMPARE? the total expected production, are lower At first glance, oil sands mining than for most other projects. operations show an almost six times Cenovus Foster Creek has the next greater direct footprint intensity smallest land use intensity. This project compared with in situ oil sands reduced its land use intensity by using projects. However, this metric only underground storage caverns to replace includes direct land disturbances like aboveground storage, by reorganizing roads and well pads and not the impact its well pads to reduce their footprint, of reduced use of habitats adjacent to and by using the “Mega Bin” 3D in situ developments through forest system to lower seismic impact. fragmentation. Other studies have shown that when land disturbance and ! MIDDLE fragmentation effects associated with natural gas production are considered, Suncor Firebag the influence on wildlife habitat of in situ operations can reach levels that are equal to and sometimes greater than oil sands mining.53 The land impact and subsequent wildlife impact of mines and in situ projects are different and require different mitigation approaches.

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 31 The In Situ Oil Sands Report Card SURVEY RESULTS

6 CONSERVATION OFFSETS Land Please report and provide documentation of total hectares of biodiversity/conservation offsets established to compensate for terrestrial impacts of your oil sands project.

CONTEXT Conservation offsets compensate for development impacts as part of a In situ facilities have a residual impact complementary strategy involving on biodiversity regardless of a company’s significant new conservation and on-site mitigation measures. Biodiversity protected areas and enhancing and conservation offsets offer a method mitigation practices and reclamation. to compensate for the residual, The Government of Alberta is exploring unavoidable harm to biodiversity caused the establishment of conservation offset by development projects, thereby policies to mitigate terrestrial impacts of aspiring to no net loss in biodiversity.54 oil sands development.55 The Pembina Biodiversity offsets attempt to mitigate Institute considers the voluntary ecosystem disturbance and habitat loss establishment of conservation offsets an by restoring or conserving substitute important indicator of environmental forest areas so that no net loss of critical performance in the absence of regulated habitat is maintained in perpetuity. offset programs.

L Figure 15: Conservation offsets can compensate for the residual, unavoidable harm to biodiversity caused by development projects. PHOTO: DAVID DODGE, CPAWS

32 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card SURVEY RESULTS Land 6 CONSERVATION OFFSETS

% LEADERS LAGGARDS None Canadian Natural None of the in situ operators Primrose/Wolf Lake, Cenovus demonstrated an investment in Christina Lake, Cenovus biodiversity or conservation offsets to Foster Creek, Husky Tucker, fully mitigate terrestrial impacts related Imperial Oil Cold Lake, specifically to their in situ operations. JACOS Hangingstone, ! Shell Peace River MIDDLE None of the other companies have Suncor Firebag, made investments in biodiversity or Suncor MacKay River conservation offsets to mitigate the land use impacts from their in situ Suncor has invested in the protection of operations. nearly 600 ha of boreal forest in northern Alberta under its “Boreal Shell invested in conservation offsets as Habitat Conservation Initiative” part of the Albian Sands Energy Muskeg program.56 However, as noted in its River Mine Expansion Project. Albian sustainability report, this conservation Sands Energy signed a commitment effort helps offset the environmental with the Alberta Conservation footprint of all Suncor operations and Association to provide $200,000 does not specifically relate to the Firebag per year for 10 years to purchase in situ operation. In 2007, Petro-Canada conservation offsets.58 This commitment committed to establish conservation does not extend to offsetting impacts offsets on 194 ha of forest to partially associated with the Peace River project. offset impacts associated with what is now the Suncor Mackay River expansion project.57

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 33 The In Situ Oil Sands Report Card SURVEY RESULTS

7 CARIBOU HABITAT Land Is your project lease area located in woodland caribou habitat as defined by Alberta Sustainable Resource Development?

CONTEXT % LEADERS Woodland caribou are a threatened Husky Tucker, species in Canada and Alberta. Imperial Oil Cold Lake, Environment Canada has concluded that JACOS Hangingstone, all woodland caribou herds in Alberta Shell Peace River are considered to have non-self- sustaining populations.59 Industrial These four in situ operations are all development within caribou ranges is located outside of the regions in Alberta largely responsible for these declines.60 identified as woodland caribou habitat. Habitat restoration is necessary if these populations are to be maintained, yet ! MIDDLE new in situ developments are proposed None in the ranges of these declining herds. In the absence of a land use plan that identifies how woodland caribou habitat LAGGARDS is to be protected, any in situ oil sands Canadian Natural development, regardless of mitigation Primrose/Wolf Lake, Cenovus measures, contributes to the decline of Christina Lake, Cenovus this threatened species. Foster Creek, Suncor Firebag, Suncor MacKay River The remainder of the in situ facilities are located in areas defined as caribou habitat and risk further diminishing this already threatened species.

34 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card SURVEY RESULTS Land 8 CONSERVATION PLANNING Did your company support Cumulative Environmental Management Association recommendations for conservation planning, specifically the recommendation to permanently protect 20–40% of the Regional Municipality of Wood Buffalo from industrial development?

CONTEXT of legally designated conservation areas.62 This indicator reflects which The Cumulative Environmental companies have been constructive Management Association (CEMA) participants in supporting the is a multi-stakeholder body charged establishment of conservation areas with assessing cumulative impacts free of industrial activity. of development and making recommendations to improve Land use planning is currently environmental management in north- underway in northeastern Alberta.63 eastern Alberta.61 In 2008, CEMA Without an effective land use plan recommended that between 20 and that identifies conservation areas and 40% of northeastern Alberta should be sets cumulative limits on disturbance, permanently protected from industrial criticism of in situ land use impacts development through the establishment will continue to grow. L

Figure 16: The cumulative impacts of in situ oil sands projects need to be included in land use planning. MAP: ROLAND LINES, THE PEMBINA INSTITUTE. SATELLITE DATA: NATURAL RESOURCES CANADA, 2006

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 35 The In Situ Oil Sands Report Card SURVEY RESULTS

8 CONSERVATION PLANNING Land

% LEADERS ! MIDDLE

Cenovus Christina Lake, None Cenovus Foster Creek, Husky Tucker, Imperial Oil LAGGARDS Cold Lake, JACOS Canadian Natural Hangingstone, Suncor Primrose/Wolf Lake Firebag, Suncor MacKay Canadian Natural provided a response River, Shell Peace River to CEMA stating that it would be According to CEMA’s online unable to support the conservation documentation, all of the above planning framework. Canadian Natural companies responded in support of the noted that the framework would recommendations for conservation directly affect 44,000 ha of its mineral planning.64 Suncor is a member of the leases and wished to have further Boreal Leadership Council, whose discussion on many of the key members are signatories to the Boreal requirements.66 Forest Conservation Framework, which identifies the need to protect 50% of Canada’s boreal forest from industrial activity in perpetuity.65

36 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card SURVEY RESULTS Land 9 BIODIVERSITY MONITORING Does your company provide support (financial or other) to the Alberta Biodiversity Monitoring Institute (ABMI) in order to provide meaningful, long-term information about changes in biodiversity in the oil sands region? Has it incorporated ABMI biodiversity monitoring protocols into your project-specific reporting requirements? If so, please describe this support.

CONTEXT Without a credible, regional program such as the ABMI, there is insufficient Effective monitoring for changes in information to adequately assess changes wildlife species is an essential component to biodiversity in the region. The ABMI of oil sands management. An is supported by both government and independent science advisory committee voluntary industry funding but does not found the ABMI67 to be “a comprehen- currently have sustainable long-term sive world-class program that Albertans funding. Financial support for the can rely on for high quality monitoring ABMI is a key indicator of an oil sands and reporting on the state of biodiversity companies’ commitment to meaningful in Alberta.”68 It is capable of providing biodiversity monitoring until a statistically rigorous information about comprehensive regulated approach to regional-level changes in biodiversity and biodiversity monitoring is developed. has protocols that can be adapted to (A Pembina Institute employee sits on determine site-specific changes at the the ABMI board as a representative for level of a single oil sands project. Alberta’s environmental community.)

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 37 Land 38 DRILLING DEEPER:THE INSITUOIL SANDS REPORT CARD % current sponsorsoftheABMI. All oftheabove companiesare listedas Suncor MacKayRiver Peace River, SuncorFirebag, Cenovus FosterCreek,Shell Cenovus ChristinaLake, accor not possibletodifferentiate companies on thevalue ofcontributions,soitwas However, noinformationwasavailable BIODIVERSITYMONITORING 9 LEADERS ding totheirlevel ofcommitment. The InSituOilSandsReportCard 69 otherwise. sustainability r information wasavailable intheir or pastABMIsponsorsandno and JACOS were notlistedascurrent Canadian Natural, Husky, Imperial Oil Lake, JACOSHangingstone Tucker, ImperialOilCold Primrose/Wolf Lake,Husky Canadian Natural None ! LAGGARDS MIDDLE eports tosuggest eports SURVEY RESULTS The Pembina Institute ir Emissions A Sur vey Results ir emissions from the oil sands The Pembina Institute calculated both region have the potential to on and off-site emissions associated with A affect human and environ- the in situ operations. On-site emissions mental health. For example, current acid were calculated using company reported deposition in Saskatchewan, which is emissions available in the NPRI or partially caused by NOx and SO2 ERCB reports. Off-site emissions emissions from the oil sands, may associated with electricity generation exceed the buffering capacity of lakes and the production of natural gas and soils in regions close to the oil required for the operation of the in situ sands.70 This means that lakes and soils facility were calculated using generic in Saskatchewan could become more emissions factors. For facilities with acidic, which would present risks to the cogeneration units that provide power health of plant and animal species. NOx to both the grid and the in situ and SO2 are both produced at in situ operation, emissions were allocated facilities. This section reports on project using the cogeneration allocation emission levels and voluntary company methodology described in the targets to reduce air pollution. introduction.

M Table 5: Summary of air emission scores per project.

NOx SO Total Project 2 Reduction Emissions Emissions Targets Score Cenovus Foster Creek 1 1 0 2 Suncor Firebag 0.75 0.5 0.5 1.75 Suncor MacKay River 0.75 1 0 1.75 Cenovus Christina Lake (pilot) 1 0.5 0 1.5 Imperial Oil Cold Lake 0.5 0.75 0 1.25 Canadian Natural Primrose/Wolf Lake 0 0.75 0 0.75 JACOS Hangingstone (demonstration) 0.5 0 0 0.5 Husky Tucker (start-up) 0 0 0 0 Shell Peace River (demonstration) 0 0 0 0

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 39 The In Situ Oil Sands Report Card SURVEY RESULTS

10 NITROGEN OXIDES EMISSIONS What are your overall project-specific nitrogen oxides (NOx) emissions in Air Emissions grams (g) per barrel (bbl)?

CONTEXT % LEADERS NOx emissions contribute to the Cenovus Christina Lake, formation of ground level ozone and Cenovus Foster Creek, acid rain. Ground level ozone can Suncor Firebag, Suncor irritate the respiratory system. Current MacKay River acid deposition in Saskatchewan may exceed the buffering capacity of lakes These projects have NOx emissions that and soils in regions close to the oil range between 82 g and 130 g per barrel sands.71 NOx are emitted in large of bitumen (g/bbl). These projects create quantities from in situ projects and have NOx emissions by combusting natural known human health impacts and gas to produce steam. Natural gas impacts on the environment.72 For the production itself also generates NOx purpose of comparing projects, the GRI emissions. Reducing the amount of indicator was converted to a per barrel natural gas per barrel of bitumen emissions intensity measure. produced is one of the best ways a project can reduce NOx emissions. One indication of a project’s natural gas intensity is its steam-to-oil ratio. The steam-to-oil ratio is a measurement of the total volume of steam required per RESULTS unit of bitumen production. As natural

M Figure 17: NOX emissions per barrel of bitumen produced.

40 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute Air Emissions 41 s SURVEY RESULTS SURVEY s can be very difficult. ’ low steam-to-oil ratio has the STEAM-TO-OIL RATIO ratio is a measure- The steam-to-oil volume of steam ment of the total of bitumen required per unit ratio is The steam-to-oil production. compare projects an easy way to and provides a superficial indication technical of an in situ operation’s and environmental performance. Operations with high steam-to-oil rations tend to require more water than and combust more natural gas operations with low steam-to-oil ratios. In general an in situ operator steam- will aim to reduce its project’s costs. to-oil ratio to reduce operating A added benefit of reducing the environmental impact by project’s reducing water requirements and air emissions. Determining why one company’ steam-to-oil ratio is lower or higher than another It is determined by a number of factors, such as reservoir character- istics, operator experience, extract- ion technology and operating procedures. In this report the Pembina Institute often refers to the steam-to-oil ratio as a justification for leading or lagging environmental performance on specific indicators. is the steam-to-oil ratio However, really an indication of the ability for an in situ operator to optimize its the operator’s experience, reservoir, the the extraction technology, operating procedures and in some instances luck. . DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD DRILLING DEEPER: THE IN SITU OIL SANDS REPORT usky Both 74 e NOx emissions that ojects surveyed. ose/Wolf Lake and H ose/Wolf ucker facility noted a The In Situ Oil Sands Report Card Report Sands Oil In Situ The In addition, each of these In T 73 rimr usky MIDDLE LAGGARDS e natural gas per barrel of bitumen e natural gas per barrel el of bitumen (g/bbl). Canadian el of bitumen (g/bbl). atural P om the nine pr 10 10 OXIDES EMISSIONS NITROGEN N Canadian Natural Lake, Primrose/Wolf Husky Tucker hav These projects 180 g and 620 g per range between barr Imperial Oil Cold Lake, JACOS Hangingstone, Shell Peace River NOx emissions that have These projects 130 g and 150 g per range between barr ! gas is used to heat water for steam gas is used to heat steam-to-oil ratio a higher production, consumption. natural gas means more Firebag, Creek, Christina Lake, Foster relatively all have River and MacKay 2.4:1 steam-to-oil ratios between low and 3.3:1. of these projects consume significantly of these projects mor than the other projects. produced projects has a cogeneration facility. projects efficient way of Cogeneration is a more heat and electricity (rather producing heat and electricity than producing NOx emissions separately) that reduces of bitumen produced. per barrel steam-to-oil ratio that was three times as steam-to-oil ratio that was three steam-to-oil ratio high as the average fr The H Tucker have the second highest and have Tucker highest steam-to-oil ratios, respectively The Pembina Institute The In Situ Oil Sands Report Card SURVEY RESULTS

11 SULPHUR DIOXIDE EMISSIONS

What is your 2007 average SO2 emission intensity in grams (g) per barrel (bbl)? Air Emissions

CONTEXT % LEADERS Once released into the atmosphere, Canadian Natural SO2 contributes to the formation of Primrose/Wolf Lake, smog and haze. In high concentrations, Cenovus Foster Creek, SO2 emissions can have a direct impact Imperial Oil Cold Lake, on human health, causing respiratory illness and aggravating pre-existing Suncor MacKay River cardiovascular disease.75 SO2 is also the These projects have SO2 emissions that major component in the production of range between 44 g and 86 g per barrel acid rain. As with NOx emissions, the of bitumen (g/bbl). Like NOx emissions, GRI indicator was converted to a per SO2 emissions are also linked to steam- barrel emissions intensity measure for to-oil ratios. Generally, a higher steam- the purpose of comparing projects. to-oil ratio means more natural gas consumption, which in turn would suggest more SO2 emissions associated with the upstream production of natural gas and from the on-site combustion emissions. Cenovus Christina Lake, Suncor MacKay River and Cenovus Foster Creek have the three lowest steam-to-oil ratios, which could in part explain why these projects have low SO2 RESULTS emission intensities. Additionally, most

M Figure 18: SO2 emissions per barrel of bitumen produced.

42 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card SURVEY RESULTS Air Emissions 11 SULPHUR DIOXIDE EMISSIONS

in situ facilities make use of sulphur a relatively high amount of sulphur is recovery technologies to reduce on-site emitted to produce the natural gas used SO2 emissions resulting from natural gas at the facility. JACOS Hangingstone is combustion. Produced gas is another currently a pilot project. Its absolute factor that influences SO2 emissions. emissions (tonnes of SO2 per day) fall In situ operations combust purchased below its regulated sulphur emission natural gas where sulphur has been limit. However, because JACOS has not removed during the processing phase. installed sulphur recovery technology, its However, produced gas, which is SO2 emissions intensity is relatively produced during bitumen production high. Shell Peace River has the highest and combusted to produce heat, can SO2 emission intensity of projects contain varying amounts of sulphur examined because its operations do not depending on reservoir characteristics. include sulphur recovery technology. Because the project’s sulphur emissions ! MIDDLE are below the 14 tonnes per day licence limit, it is not required by law to install Cenovus Christina Lake, sulphur recovery technology.76 Suncor Firebag These projects have similar SO2 HOW DOES MINING COMPARE? emission intensities of around 110 g The sulphur intensity of mining per barrel of bitumen (g/bbl). operations, excluding upgrading, are well below the average sulphur intensity LAGGARDS of in situ operations and are Husky Tucker, approximately 30% lower than the lowest sulphur intensity in situ facility, JACOS Hangingstone, Cenovus Foster Creek. Mining Shell Peace River operations use primarily commercial These projects have SO2 emissions that grade natural gas to produce steam and range between 214 g and 1,000 g per electricity, which has a lower sulphur barrel of bitumen (g/bbl). Husky content. The trucks used to transport Tucker’s relatively high sulphur intensity bituminous sands use diesel, which is a result of off-site natural gas emits sulphur, but the resulting SO2 production. Because Husky Tucker’s emission intensity per barrel is lower operation requires relatively high than for an in situ facility. amounts of natural gas for each barrel,

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 43 Air Emissions 44 DRILLING DEEPER:THE INSITUOIL SANDS REPORT CARD human health. contribute toacidrainandaffect management plan. component ofanenvironmental targets isconsidered tobeanessential the GRIguideline,butsettinginternal This indicatorisnotincludedunder companies toachieve similarresults. regulated limitsencourageother emission reductions above andbeyond Companies thatare abletoachieve possible r should beminimizingimpactswher Pembina Institute believes companies reduction targetsbecausethe voluntary to takealeadershiprole andcommitto P and around oilsandsfacilities. The potential forhumanhealthimpactsin contribution toaciddepositionandthe whenever possible,given their reduce theirNOxandSO believes thatoilsandsprojects should NOx andSO CONTEXT 2REDUCTIONTARGETS 12 embina Institute encouragescompanies If so,whatarethey? beyond governmentregulations? NOxorSO targets toreduceoroffset reported havepublicly Does yourcompany egardless ofregulated limits. The InSituOilSandsReportCard 2 77 emissions both The Pembina Institute 78 2 emissions e 2015. facilities, includingFirebag, by 10%by absolute airemissionsfrom itsoilsands S Suncor Firebag % River inthemergerwithPetro-Canada. facilities before itacquired MacKay targets were madeforS emission reduction targets.Suncor’s assessment hav No othercompaniesreviewed inthis River, SuncorMacKayRiver Hangingstone, ShellPeace Cold Lake,JACOS Husky Tucker, ImperialOil Cenovus FosterCreek, Cenovus ChristinaLake, Primrose/Wolf Lake, Canadian Natural None ! and SO uncor hascommittedtoreducing LAGGARDS LEADERS MIDDLE 79 The actualreduction ofNOx 2 emissions are unclear. e public voluntary air e publicvoluntary 2 SURVEY RESULTS uncor oilsands The Pembina Institute ater W Sur vey Results

ack of information on impacts on steam, which is then injected into the groundwater is a major concern reservoir to liquefy the viscous bitumen. L associated with groundwater use Wastewater is often disposed of in deep for in situ operations. On January 30, disposal wells. When considering the 2008, the Alberta Water Council noted scale of in situ operations (213 million that “there was a concern that research barrels of bitumen in 2008), the annual and technology support is unable to water withdrawals are significant. sustain the planning envisioned by However, given the lack of data, the the Alberta Water for Life Strategy.” potential risks of current operations It further referenced the need for more and planned expansions cannot be mapping of quality and quantity of determined. groundwater.80 Without sufficient data, This section concerns in situ operator government agencies and other water use, the management of liquid institutions are unable to assess the risk wastes and voluntary company targets posed by large sale in situ developments. to reduce water consumption. In situ operators heat water to produce

M Table 6: Summary of water scores per project.

Water Freshwater Liquid Waste Project Targets Total Intensity Targets Intensity Suncor Firebag 1 0.75 0.75 0.5 3 Imperial Oil Cold Lake 0.75 0.75 1 0 2.5 Suncor MacKay River 1 0.5 1 0 2.5 Cenovus Foster Creek 0.5 1 0.5 0 2 JACOS Hangingstone (demonstration) 0.75 0.5 0.75 0 2 Canadian Natural Primrose/Wolf Lake 0.5 0 0.5 0 1 Husky Tucker (start-up) 0 1 0 0 1 Cenovus Christina Lake (pilot) 0 0 0 0 0 Shell Peace River (demonstration) 0 0 0 0 0

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 45 Water 46 DRILLING DEEPER:THE INSITUOIL SANDS REPORT CARD M 3TOTAL WATER CONSUMPTION 13 RESULTS safe withdrawallimits. accurately judgepotentialimpactsand current dataare insufficientto H aquifers andotherwatersystems. impacts onsurrounding wetlands, lakes, saline water, canhave direct orindirect Withdrawing anytypeofwater, even CONTEXT GRI indicatorwasconv lesser risktogroundwater resources. The consumptive wateruseintensityposea sufficient data,operatorswithlower Institute believes thatintheabsenceof of comparingprojects. barr owever, groundwater monitoringand Figure 19: Total waterconsumptionperbarrelofbitumenproduced. el intensitymeasure forthepurpose barrel of bitumen produced? barrel ofbitumen per (brackishandfreshwater) consumption What isyourproject’s 2007 averagewater The InSituOilSandsReportCard The Pembina er ted toaper steam-to-oil ratioanditsr of wateruseintensityare apr barrel ofbitumen. drivers The primary range from 0.4bblto0.5waterper These projects’ totalwateruseintensities Suncor MacKayRiver Suncor Firebag, JACOS Hangingstone, Imperial OilColdLake, % bitumen. P less watertoproduce abarrel of Projects withlow steam-to-oilratiosuse and r both r intensity. Allthree leadingprojects have reducewater tofurther wateruse LEADERS ecycle produced water. elatively low steam-to-oilratios r ojects mustalsorecycle SURVEY RESULTS ecy cle rates. oject’s The Pembina Institute Water 47 ces. SURVEY RESULTS SURVEY ces and are ces. The average oil sands mine uses The average ces. easingly using saline sour COS Hangingstone and Suncor COS Hangingstone olf Lake, Cenovus Christina Lake, olf Lake, Cenovus have relatively high steam-to-oil ratios high steam-to-oil relatively have reduction the water that outweigh facilities. capacity of the recycling was in Tucker addition, Husky In start-up during this assessment. phase the as use intensity will decrease Water matures. project MacKay River and Suncor Firebag all Firebag and Suncor River MacKay of use significantly less water per barrel bitumen than a mining operation. Primrose/ Canadian Natural However, W all Tucker and Husky River Peace Shell mining water than an average use more other distinctions are There operation. operations use water Mining as well. the Athabasca primarily drawn from in situ operations tend to whereas River, sour use groundwater incr HOW DOES MINING COMPARE? that in situ This assessment shows 1.1 bbl water operations use on average for every of bitumen produced. barrel intensities vary actual water However, 0.5 bbl to just under from project by 5 bbl water for every of bitumen barrel This additional water is produced. or saline either fresh from sourced sour twice as much water as the average over of bitumen in situ operation per barrel Cold Lake, Oil Imperial produced. JA , DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD DRILLING DEEPER: THE IN SITU OIL SANDS REPORT n cling ent factors. I The In Situ Oil Sands Report Card Report Sands Oil In Situ The Both Canadian Natural and Both Canadian Natural 81 MIDDLE LAGGARDS usky have installed water recy usky have hell plans to recycle produced water produced hell plans to recycle 13 CONSUMPTION WATER TOTAL H facilities. However, both these projects facilities. However, Canadian Natural Lake, Cenovus Primrose/Wolf Christina Lake, Husky Tucker ! Creek Cenovus Foster just requires Creek Foster Cenovus of bitumen per barrel under 1 bbl water produced. Shell Peace River total water use intensities These projects’ 2.5 bbl to just under 6 bbl range from of bitumen produced. water per barrel high water intensities These relatively two differ by driven are the cases of the Christina Lake and and Shell, Cenovus projects, River Peace water not installed have respectively, that is injected Water facilities. recycling to the surfaceinto the reservoir returns with the bitumen and is then disposed Both these in deep disposal wells. every that to replace barrel have projects accounting is sent to deep disposal wells for the high water use. Cenovus facilities at its installed water recycling Christina Lake facility in 2008 and S expansion as part of the Carmon Creek project. The Pembina Institute Water 48 DRILLING DEEPER:THE INSITUOIL SANDS REPORT CARD r r projects minimize theiruseoffreshwater operations, itisessentialthatoilsands large waterdemandsrequired by insitu RESULTS content) below 4,000ppm. total dissolved solids(includingsodium groundwater, are definedaswaterwith rivers, streams, lakesand fresh Freshwater resources, whichinclude CONTEXT M 4FRESHWATER CONSUMPTION 14 esources whenavailable. esour Figure 20:Freshwaterconsumptionperbarrelofbitumenproduced. ces b in 2007? What isthetotalvolumeoffreshwateruse y makinguseofsalinewater The InSituOilSandsReportCard 82 83 With the operations surveyed. lo and cleaningpurposes,resulting inthe fresh waterisusedonlyfordomestic preference. At theHusky Tucker facility, water resources andcompanypriorityor depend ontheav water usedataninsitufacilitywill barr at0.04bblfresh waterper this survey is thelowest oftheprojects includedin Husky Tucker’s freshwater useintensity Husky Tucker % west freshwater useintensityamong el ofbitumen. The volume offr LEADERS ailability ofsaline 84 SURVEY RESULTS The Pembina Institute esh Water 49 of 3 Requirements ARE? 85 SURVEY RESULTS SURVEY . ear n Situ Oil Sands Oil n Situ olf Lake and no water mal I ecycling facilities for Cenovus Christina facilities for Cenovus ecycling Primrose/W r all However, River. Peace Lake and Shell to use increasing companies will need water to comply with amounts of saline draft directive the ERCB and Reporting, Measurement, Water for Ther for Use HOW DOES MINING COMP oil sands After accounting for recycling, four times as mines use approximately basis as water on a per barrel much fresh sands in situ operation. Oil the average water drawn mainly mines use fresh of this Much River. the Athabasca from fine water is trapped in the mature in tailings at oil sands facilities. Some which situ operators use saline water, intensity. their freshwater reduces . In this draft directive, fresh this draft directive, Schemes. In water may only account for 10% of that makeup water for in situ schemes than 500,000 m more require makeup water per y DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD DRILLING DEEPER: THE IN SITU OIL SANDS REPORT el of bitumen. The In Situ Oil Sands Report Card Report Sands Oil In Situ The om 1 bbl to 5 bbl fresh water for om 1 bbl to 5 bbl fresh MIDDLE LAGGARDS eryAs of bitumen produced. barrel 14 CONSUMPTION FRESHWATER ev discussed in the water intensity section, higher water use have these projects intensities because of high steam-to-oil ratios for Canadian Natural Canadian Natural Lake, Primrose/Wolf Cenovus Christina Lake, Shell Peace River use intensities freshwater These projects’ range fr ! Creek, Cenovus Foster Lake, Imperial Oil Cold JACOS Hangingstone, Suncor Firebag, River Suncor MacKay freshwater have projects All five average. the weighted intensities below use intensities freshwater These projects’ 0.4 bbl to 0.5 bbl fresh range from water per barr The Pembina Institute Water 50 DRILLING DEEPER:THE INSITUOIL SANDS REPORT CARD future flo v injection pressure, buttheincreased this pr other groundwater sour flo there isariskthatthewastefluidswill waste products deepunderground, When insituoperatorsre-inject liquid CONTEXT comparing projects. intensity measure forthepurposeof indicator wasconv a wastetreatment facility. The GRI ship solidandliquidwasteoff-siteto M 5LIQUIDWASTE 15 olumes ofunderground liquidsrisk w underground andcontaminate Figure 21:Liquidwasteproductionperbarrelofbitumenproduced. oblem, operatorslimitthere- for 2007? barrel(bbl)ofbitumen per waste produced What istheaveragevolume(bbl)ofliquid w. 86 The InSituOilSandsReportCard S ome insitufacilitiesalso er ted toaperbarrel ces. T o av oid all operations. all liquidwastesare r whether calculate becauseitisuncertain Liquid wasteintensitiesare difficultto water thatcannotorisnottreated. of r waters from softeners,brine,anyform sev include volumes ofliquidwastefrom The results illustratedinFigure 21 RESULTS eral sources, suchaslimesludge, e-injected wastesandproduced epor SURVEY RESULTS ted equallyfor The Pembina Institute Water 51 . It SURVEY RESULTS SURVEY ecause Husky Tucker ecause Husky cling facilities installed at The facility has a relatively low The facility has a relatively , Shell Peace River MIDDLE LAGGARDS erage. ucker steam-to-oil ratio and incorporates water recycling. has the highest water use intensity, it has the highest water use intensity, also has a high liquid waste intensity Creek’s Foster is unclear why Cenovus wastewater the intensity is higher than av ! Canadian Natural Lake Primrose/Wolf Lake’s Primrose/Wolf Canadian Natural the average wastewater is below disposal bbl disposed water at 0.2 disposal value of bitumen produced. per barrel Cenovus Christina Lake, Husky Cenovus Foster Creek, T water per barrel of bitumen production. water per barrel As noted for question 13, neither Shell Christina Lake nor Cenovus River Peace had water recy their facilities. B These projects’ liquid waste intensities These projects’ 1 bbl to 4.5 bbl disposed range from e DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD DRILLING DEEPER: THE IN SITU OIL SANDS REPORT water cling facilities. The In Situ Oil Sands Report Card Report Sands Oil In Situ The In a zero liquid discharge a zero In aporators and a crystallizer ar 87 om 0.005 bbl to 0.2 bbl LEADERS oduction. The combination of oduction. 15 WASTE LIQUID used to essentially eliminate wastewater concentrated a However, production. must be disposed in a salt byproduct landfill. system, ev These two points lead to less waste pr low relatively River’s MacKay Suncor liquid steam-to-oil ratio and its zero account for its discharge process leadership position in liquid waste intensity. disposed water per barrel of bitumen. disposed water per barrel liquid waste with low All the projects steam-to-oil both low have production ratios and water recy % Canadian Natural Lake, Primrose/Wolf Lake, Imperial Oil Cold JACOS Hangingstone, Suncor Firebag, Suncor MacKay River liquid waste intensities These projects’ range fr The Pembina Institute Water 52 DRILLING DEEPER:THE INSITUOIL SANDS REPORT CARD to theS operations asawhole,notspecifically this targetisappliedtoitsoilsands intake by 12%by 2015. Suncor statesatargettoreduce water Suncor Firebag % r in wateruse. The ISO14001standard application andleadtoreal reductions technological innovation and continuous improvement, helpspur quantify theircommitmentto Public targetsensure companies impacts onsurrounding watersystems. saline water Withdrawing anytypeofwater, even CONTEXT system. complete environmental management targets asakeycomponentof 6REDUCTIONTARGETS 16 ecognizes internalwaterreduction LEADERS 88 uncor Firebag facility. If so,whatareyourtargets? beyondgovernmentregulations? your operations to reducewaterintensityandconsumption in targets reported havepublicly Does yourcompany , canhave direct orindirect The InSituOilSandsReportCard 89 However, None ! P M oil sandsfacilitiesbefor Suncor’s targetswere madeforSuncor targets fortheirinsitufacilities. committed toabsolutewaterreduction N Shell PeaceRiver Suncor MacKayRiver JACOS Hangingstone, Imperial OilColdLake, Husky Tucker, Cenovus FosterCreek, Cenovus ChristinaLake, Primrose/Wolf Lake, Canadian Natural etr one oftheseoperatorshav acKay River inthemergerwith o-Canada. LAGGARDS MIDDLE SURVEY RESULTS e itacquir e , ed The Pembina Institute Survey Results 53 0 0 0 1 1 0.5 0.5 0.75 0.75 Total 0 0 0 0 0 0 0 0 Targets 00 0 0 1 1 eates carbon dioxide, a significant eates carbon dioxide, 0.5 0.5 0.75 0.75 at limiting global GHG emissions, it is at limiting global necessary countries such for developed emissions. reduce as Canada to rapidly this to take place, Canada would For and growing the large need to address derived that are of emissions volume oil sands operations. from large situ operators consume In quantities of natural gas to produce The combustion of natural gas steam. cr This contributor of GHG emissions. section examines GHG intensity and absolute company targets to reduce amounts of GHG pollution. the on- The methodology used to derive site, off-site and allocation of in this cogeneration emissions presented in section is the same as that discussed section. the Air Emissions GHGs DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD DRILLING DEEPER: THE IN SITU OIL SANDS REPORT If the If 92 oto y “Reference case” “Reference 91 According to Environ- According (demonstration) 90

wth in emissions stands o ding to international law, source of GHG emissions in of GHG emissions source ccor Canada. il sands are the fastest growing the fastest growing il sands are

d. A

Table 7: Summary of climate change scores per project. Table M limate Change limate as a potential barrier to Canada’s the K commitments through accor a legally as of 2005, Canada entered binding commitment to set emissions annual its average targets to reduce 1990 emissions 6% below greenhouse 2008 and 2012. between levels ment Canada projections, oil sands ment Canada projections, for about 44% of operations will account GHG emissions in Canada’s the increase 2006 to 2020. from projections from this study show oil sands show this study from projections rising contributions to national emissions emissions in 2006 4% of Canada’ from to 12% in 2020. This rate of gr

international community is to succeed O

Project Husky Tucker (start-up) Husky Tucker Canadian Natural Primrose/Wolf Lake Canadian Natural Primrose/Wolf Shell Peace River (demonstration) Suncor MacKay River Imperial Oil Cold Lake JACOS Hangingstone Cenovus Foster Creek Suncor Firebag Cenovus Christina Lake (pilot)

The Pembina Institute

C G Climate Change 54 DRILLING DEEPER:THE INSITUOIL SANDS REPORT CARD be reduced inabsoluteterms.H ov deepreductions in achieve thenecessary production ofbitumenonly. the emissionspr operations. It tonotethat isimportant compare theefficiencyofoilsands GHG intensityisausefulwayto RESULTS sands development. projected tobeadirect result oil ofnew GHG emissionsfrom 2006to2020is Over 44%oftheincrease inCanada’s CONTEXT M 7GHGEMISSIONS 17 erall GHGemissions,emissionsmust Figure 22:Greenhousegasemissionsperbarrelofbitumenproduced. (bbl) bitumen? barrel emission intensityinkilograms(kg)per What isyour2007averagegreenhousegas The InSituOilSandsReportCard esented here are from the 93 If Canadaisto ow ev er , oil sandsoperations. enable afaircomparisonbetween used byinsituoperatorsandto considerable amountofnaturalgas included herebecauseofthe is notastandardpracticebut upstream naturalgasproduction GHG emissionsassociatedwith natural gasproduction.Reporting those associatedwithupstream well asoff-site emissions,including Note: This surveyincludeson-siteas SURVEY RESULTS The Pembina Institute Climate Change 55 94 eek r SURVEY RESULTS SURVEY ebag, generate just under ir uncor F LAGGARDS The average in situ operation generates The average GHGs per two and half times more in of bitumen produced barrel comparison with oil sands mining GHG intensity The lowest operations. C Foster in situ operations, Cenovus and S Husky Tucker Tucker the Husky As noted previously, in 2007 was three steam-to-oil ratio steam-to-oil average times as high as the surveyed. the nine projects ratio from GHG Tucker’s This explains why Husky so high in comparison emissions are with the other projects. HOW DOES MINING COMPARE? twice the GHG emissions per barrel of twice the GHG emissions per barrel oil sands mining project. an average at the The explanation for this difference is energy requirements. most basic level of bitumen produced Each barrel energy than a more in situ requires of mined bitumen. barrel corresponding the energy used in oil sands Since fossil fuel sources, operations is from in primarily natural gas, an increase energy use leads to a corresponding in GHG emissions. increase DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD DRILLING DEEPER: THE IN SITU OIL SANDS REPORT usky Tucker usky ee of these operations ee of these projects have ee of these projects The In Situ Oil Sands Report Card Report Sands Oil In Situ The Thr ojects. e combust less natural gas and ose/Wolf Lake, ose/Wolf MIDDLE LEADERS efor e also incorporated cogeneration into owever, all of these projects have all of these projects owever, n comparison with the H elatively lower steam-to-oil ratios, and lower elatively elatively low steam-to-oil ratios that low elatively 17EMISSIONS GHG produce fewer GHG emissions. produce H higher steam-to-oil ratios than the leading pr ! Canadian Natural Primr Imperial Oil Cold Lake, JACOS Hangingstone, Shell Peace River, Suncor MacKay River I hav their facilities. these operations have all of facility, r ther r GHG emission explains their low intensities. % Lake, Cenovus Christina Creek, Suncor Cenovus Foster MacKay Firebag, Suncor GHG to NOx emissions, Similar to steam-to-oil closely tied emissions are ratios. All thr The Pembina Institute Climate Change 56 DRILLING DEEPER:THE INSITUOIL SANDS REPORT CARD polled thatpr compar reductions inGHGswere appropriate, feltthatabsolute 70% ofAlbertans facilities. The samepollshowed that greenhouse emissionsatalltheir sands companiesshouldreduce polledfeltthatoil 92% ofAlbertans Probe Research in2007showed that A publicopinionpollconductedb CONTEXT mental managementsystem. componentofanenviron- necessary ar emissions perbarrel. reduced onlytheintensityofGHG 8REDUCTIONTARGETS 18 e recogniz ed tothe20%ofAlbertans If so,whatarethey? targets beyondgovernmentregulations? absolute greenhousegasemissionreduction reported havepublicly Does yourcompany ed by ISO14001asa The InSituOilSandsReportCard eferr ed targetsthat 95 V oluntar y targets y ! None % GHG emissions. r N Suncor MacKayRiver Suncor Firebag, Shell PeaceRiver, JACOS Hangingstone, Imperial OilColdLake, Husky Tucker, Cenovus FosterCreek, Cenovus ChristinaLake, Primrose/Wolf Lake, Canadian Natural None eported targetstoreduceeported absolute one ofthesecompanieshave publicly LAGGARDS LEADERS MIDDLE SURVEY RESULTS The Pembina Institute The In Situ Oil Sands Report Card Conclusions

able 8 summarizes the project expected rates. They all have relatively scores by category for each project. low steam-to-oil ratios, which helps T It also includes the average score account for relatively lower intensities across all projects. for air and GHG emissions, total and fresh water use, and liquid waste As Table 8 indicates, Suncor Firebag, production. A low steam-to-oil ratio Cenovus Foster Creek, Imperial Oil results from the quality of the reservoir Cold Lake and Suncor MacKay River and the production choices of the in are above average in overall situ facility operator. All four projects environmental performance compared include cogeneration, which further to their in situ peers. These operations reduces their air and GHG emission have several features in common. Each intensities. Each of the operating project is a commercial scale operation companies also perform relatively well that is performing at or slightly below

General Air Climate Environmental Land Water Overall Project Emissions Change Management (out of 5) (out of 4) Score (out of 3) (out of 2) (out of 3) Suncor Firebag 1.5 3 1.75 3 1 60%

Cenovus Foster Creek 2 2.75 2 2 1 57%

Imperial Oil Cold Lake 2.5 2* 1.25 2.5 0.5 55%

Suncor MacKay River 1.5 2.5 1.75 2.5 0.75 53%

AVERAGE 1.83 2.36 1.06 1.56 0.50 44% Shell Peace River 3 3* 0 0 0 38% (demonstration) Cenovus Christina Lake 2 2 1.5 0 0.75 37% (pilot) Husky Tucker (start-up) 2 3 0 1 0 35% JACOS Hangingstone 0.5 2* 0.5 2 0.5 34% (demonstration) Canadian Natural 1.5 1 0.75 1 0 25% Primrose/Wolf Lake

L Table 8: Summary of project scores (*Imperial Oil Cold Lake, Shell Peace River and JACOS Hanging- stone were scored out of four for land indicators because they were not scored on land use intensity.)

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 57 The In Situ Oil Sands Report Card CONCLUSIONS

on environmental management, regional There is substantial room for commitments and, in Suncor’s case, environmental improvement published reduction targets for air The average score in our survey was emissions and water use. The project 44%, suggesting there is substantial scores range from 53% to 60%. room for improvement in the Canadian Natural Primrose/Wolf Lake, environmental performance and Cenovus Christina Lake, Husky Tucker, management of in situ oil sands JACOS Hangingstone and Shell Peace projects. The highest-ranked project was River all score below the average Suncor Firebag, with a score of 60%. environmental performance. The The lowest-ranked project was reasons for these lower scores are mixed. Canadian Natural Primrose/Wolf Lake, The Shell, Cenovus and JACOS with 25%. Most projects demonstrate projects were all pilot or demonstration leadership in some areas of project- projects during 2007. Pilot and specific environmental performance and demonstration projects do not often most have an environmental policy that incorporate technologies like produced commits to continuous improvement. water recycling and sulphur recovery Projects scored consistently poorly on technologies and tend to have higher four indicators: steam-to-oil ratios compared with commercial projects leading to lower 1. Reduction Targets: Very few in situ overall scores. The Husky and Canadian operators have established absolute Natural projects were designed as reduction targets for air emissions, commercial projects but still performed water use and GHG emissions that below the average score. Husky Tucker go beyond regulated requirements. experienced a number of challenges Only Suncor has absolute reduction associated with its operation and was in targets for air emissions and water start-up phase in 2007. The project was use. Despite the significant GHG performing well below its designed emissions of the oil sands industry, bitumen production rate. Canadian no operators have voluntary targets Natural Primrose/Wolf Lake has a to reduce GHG emissions. relatively high steam-to-oil ratio, leading 2. Biodiversity Offsets: Suncor was also to high water use and disposal, and air the only company to invest in and GHG emission intensities. biodiversity offsets to compensate for Canadian Natural also scored poorly on the impacts associated with in situ environmental management and oil sands development, and even here commitments to regional initiatives such level of commitment is not as the ABMI and public support for commensurate with the level of conservation planning. terrestrial impacts. The purpose of a There are a number of important biodiversity offset is to mitigate conclusions that can be drawn from impacts associated with habitat loss Table 8 and the report in general. These and the disturbance of ecosystems by conclusions are outlined below. restoring or conserving substitute

58 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card CONCLUSIONS

forest areas so that no net loss of Both in situ and mining projects have critical habitat is maintained in significant environmental impacts perpetuity. We compared an average mining project 3. Biodiversity Monitoring: Only three against the in situ projects on land use, companies, Suncor, Cenovus and air (NOx and SO2) and GHG Shell, financially support the Alberta emissions, water use and freshwater use Biodiversity Monitoring Institute. intensities. As one might imagine, the 4. Third-party Accredited Environmental average oil sands mine disturbs more Management: Only Imperial Oil and land, emits more NOx and is more Shell have third-party accredited water intensive than the average in situ environmental management systems. project. However, in other categories in situ projects are more environmentally intense. For example, the average Disclosure of environmental performance mining operation is less GHG and SO2 data is not accessible or comparable intense than all in situ projects surveyed. Husky, Cenovus and Shell fully Some of the poor performing in situ participated in this assessment and projects were more NOx and water provided the Pembina Institute with intense than the impacts associated with environmental data and detailed an average oil sands mine. In addition, explanations regarding their operations. our land intensity assessment did not However, the Pembina Institute found it incorporate the impacts of fragment- difficult to compile comparable data for ation and upstream natural gas all projects using public data sources. production associated with in situ The data are distributed over a number operations.96 of different databases and are often not reported in a consistent manner across Best practices are not widely adopted or within those databases. For example, There is a wide variation in performance the ERCB in situ progress reports between in situ operators. If a fictional in contain significant information on water situ operation, in this assessment, took use and wastewater disposal. However, the aspects of the best project in each each company reports data slightly category it could achieve a score of 85% differently and it can take a significant on this survey. That is to say that any amount of time to calculate water use project could achieve a score of 85% values that are comparable between simply by incorporating the best practices projects. Weak public disclosure of of the leading in situ operator into its environmental impact data weakens own operations. This result suggests transparency and risks undermining substantial room for improvement. Given public understanding and confidence in that many in situ operators have not the sector.

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 59 The In Situ Oil Sands Report Card CONCLUSIONS

voluntarily adopted viable strategies to as a whole. There are also numerous address some of the environmental risks examples of biodiversity offset programs. posed by in situ oil sands development, Both Suncor and Shell have invested more consistent regulation by the Alberta in these programs. An in situ operator and federal government could also drive that incorporated the best practices the kind of environmental outcomes that in the industry and established GHG are possible. reduction targets and biodiversity offsets To achieve 100% on this survey would could achieve 100% on this survey. require in situ operators to improve upon policies and actions that are also Cumulative impacts are already being implemented by in situ generally not considered operators. The only questions where no This assessment considers the impacts project received full points were on and performance of in situ oil sands establishment of GHG emission, water projects at a project level. Although and air targets and biodiversity offsets. important, given the overall pace and Setting environmental targets is a policy scale of oil sands development, both in widely used by industries around the situ and mining, there is an inadequate world to demonstrate a commitment level of environmental management to to continuous improvement. Suncor ensure that the regional environment is has already established environmental protected. performance targets for its facilities

60 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card Recommendations

Government weak government requirements for environmental performance are responsible for the inconsistent o date the government has application of best practices across failed to establish regional the industry. Tenvironmental thresholds that will ensure the oil sands are developed Specific policy improvements include in manner that protects the ecological the following: integrity of the region. Government has T Absolute environmental reduction also failed to create an atmosphere that targets: Most companies have not encourages oil sands companies to defined their commitment to continuously improve their environ- continuous environmental 97 mental performance. There is still time improvement by setting public to establish these limits and encourage reduction targets. Government should continuous environmental improve- encourage setting public reduction ment. The oil sands are a financially targets by providing some benefit to valuable energy resource that some of companies that set and meet public the world’s largest energy companies are targets. Government could equally competing to develop. As demonstrated support leaders by penalizing laggards in the analysis of this report, there are who are not adopting the technologies examples of leading performance for and practices that leading companies the majority of environmental indicators are employing. The EnviroVista in this report. However, no single Leaders is an example of a policy that project has incorporated all the best provides some benefit to practices available in the industry. The environmental leaders. Government of Alberta is in a unique T position to leverage the international Biodiversity offsets: Government interest in the oil sands to mandate should make compensatory offset application of best practices and mitigation of terrestrial impacts of in innovation in environmental practices situ oil sands development mandatory, and technologies. and develop conservation offset policies as recommended by the proposed wetland policy for Alberta99 1 Mandate environmental stewardship and Responsible Actions: A Plan for Alberta’s Oil Sands.100 Most companies have not developed T Biodiversity monitoring: Government project-specific reduction targets, should integrate mandatory financial invested in biodiversity offsets, support for the ABMI and mandatory biodiversity monitoring through ABMI reporting using ABMI protocols into or third-party accredited environmental existing and future approvals for in management programs. It appears that situ oil sands development projects.

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 61 The In Situ Oil Sands Report Card RECOMMENDATIONS

T Third-party accredited environmental approach to the management of management: Only two in situ cumulative effects, this remains a work operators have implemented third- in progress. Necessary elements include party accredited environmental a land use plan, requirements for GHG management systems at their facilities. emissions reductions and a framework Given the significant environmental for water management. These regulatory impacts of in situ oil sands projects gaps mean that expanded in situ oil the Government of Alberta should sands development is risky from both an make this a mandatory requirement investment101 and an environmental for all oil sands facilities. perspective. Given that many of the elements in management of cumulative environmental impacts in the oil sands 2 Make oil sands environmental are either absent or under development, performance data more comparable it is appropriate to pause approval of and accessible new oil sands developments until appropriate environmental management It remains difficult to find and compare systems and regulations are environmental data for in situ projects implemented. and for the oil sands region as a whole. As the regulator, the Government of Create a regulatory system Alberta already receives environmental 4 data for each of the in situ operators. that rewards innovation The Government of Alberta should help disseminate this information by Best environmental practices are not providing environmental performance widely adopted between in situ indicators, similar to those used in this operators. The Government of Alberta report, on a project by project basis. For should catalyze innovation and the example, while the ERCB in situ adoption of best practices in the in situ progress reports provide a wealth of industry. Most oil sands applications are information on in situ operations, they for the two primary in situ technologies, only include information on select SAGD and CSS, and promise no environmental indicators and the data is improved environmental performance difficult to find and aggregate for each relative to already producing commercial project. operations. The Government of Alberta could encourage innovation and technology development by requiring 3 Halt new approvals until environmental each new proposed project to perform management systems are complete better than the present best in class project. Such a policy would encourage Leading in situ oil sands projects need new technology development and the to operate within a regulatory system adoption of proven best practices to that sets cumulative thresholds or limits continuously raise the bar in environ- to protect the environment. Although mental performance. Once a new bar is Alberta has committed to a new set, regulations similar to Directive 74

62 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card RECOMMENDATIONS

(The Tailings Directive) and the draft water directive, Requirements for Water Provide accessible public data 2 Measurement, Reporting, and Use for Thermal In Situ Oil Sands Schemes, could The level of reporting on environmental set performance requirements to ensure indicators required by government is improvements in existing projects for all insufficient to accurately assess and elements of air, water, land and GHG compare in situ oil sands projects. management. Reporting frameworks, such as the GRI, do exist that provide a clear list of social, Industry environmental and economic reporting indicators that can be compared across Industry must acknowledge the real projects. In situ operators should report and significant project-specific and on project-specific environmental cumulative impacts of in situ oil sands indicators similar to the indicators development. While there is a clear need included in this report. A recent report for government leadership in many areas by Northwest and Ethical Investments, industry can support government by Lines in the Sands: Oil Sands Sector demonstrating leadership on a project Benchmarking, also concluded that oil by project basis and displaying a sincere sands operators must significantly effort to address environmental impacts improve their public disclosure to by incorporating best practices, support- provide investors with a “true picture ing progressive public policy and of oil sands risk.”102 innovating environmental practices and technologies. Focus on the issues 3 Demonstrate leadership 1 In situ operators should acknowledge the real environmental impacts of in There are four specific environmental situ development, both cumulative indicators that very few projects scored and project specific, and describe their well on: reduction targets, biodiversity strategies for addressing these impacts offsets, biodiversity monitoring and over time. Only this approach will lead third-party accredited environmental to increased environmental performance management. There are already overtime and create an atmosphere examples of in situ oil sands operators conducive to collaboration and that have implemented policies or constructive dialogue between practices in these four areas. Suncor government, industry and external has set absolute reduction targets for stakeholders. water use and air emissions, has invested in biodiversity offsets and supports the ABMI. Both Shell and Imperial have third-party accredited environmental management systems.

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 63 The In Situ Oil Sands Report Card RECOMMENDATIONS

Incorporate best practices Acknowledge the cumulative impacts 4 and lead improvements of in situ development 5

Our assessment demonstrates that any Many of the most serious impacts of in oil sands in situ operator could achieve a situ oil sands development are a result of score of 85% on this survey simply by the cumulative impact of in situ adopting current best practices for each operations. It is the role of government environmental indicator. At a minimum to establish regional environmental in situ operators should be incor- thresholds that protect the ecological porating the best practices of their peers. integrity of the oil sands region. Oil Those operators that are already leading sands in situ owners and operators in specific indicators, such as Cenovus, should acknowledge the extent of Suncor and Imperial Oil, should current and projected cumulative continue to build upon their leadership impacts in the oil sands region and take position by innovating new technology a leadership role in support for the and practices to continually reduce their establishment of regional environmental environmental impact. Achieving 100% thresholds and completed land use on this assessment in the future is planning. possible by incorporating best practices in the in situ oil sands industry and Follow the best practice in situ supplementing those practices with 6 common practices from other development checklist industries. For example, the only indicators for which no in situ project An in situ oil sands operator can satisfy received full marks are environmental all of the points above by ensuring its targets and biodiversity offsets. project follows the best practice in situ development checklist in Table 9. The As the analysis in this report numerical targets represent the top demonstrates, there is also clear link quartile of 2007 performance of the between environmental performance on projects included in this assessment. some indicators (water use, air emissions and GHG emissions) and a project’s An in situ operation that ranks well on steam-to-oil ratio. Minimizing a this checklist is a leading in situ facility project’s steam-to-oil ratio reduces relative to its peers. However, in the environmental impact and delivers cost absence of regional regulations to savings. protect the ecological integrity of the oil sands region, even a leading project may contribute to unacceptable cumulative impacts in the oil sands region. Further, as this is a relative assessment a leading project today. Improvements in environmental performance are expected to continually reduce per barrel impacts.

64 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card RECOMMENDATIONS

General Environmental Management

K An environmental policy that commits to K Publicly reported project-specific environmental continuous improvement in environmental data performance K A strong legal compliance record K An environmental management system that has been accredited by an independent third party, such as ISO 14001 or equivalent

Land

K Land use intensity below 0.5 hectares per million K Public policy support for establishing large barrels, measured by total expected disturbance conservation areas free of industrial development over the life of the project divided by total to provide habitat for wildlife affected by in situ expected production oil sands development K Compensation for the terrestrial impacts of K Financial support Alberta Biodiversity Monitoring the in situ project by establishing biodiversity/ Institute in order to provide meaningful, long-term conservation offsets equivalent to the area information about changes in biodiversity in the affected by the in situ oil sands project oil sands region K In the absence of a land use plan that shows how woodland caribou will be conserved in northeastern Alberta, no operations in threatened woodland caribou habitat Air Emissions

K NOx intensity below 0.08 kg/bbl (including off- K Publicly reported targets to reduce absolute NOx site electricity and natural gas production) or SO2 emissions beyond government regulations

K SO2 intensity below 0.08 kg/bbl (including off- site electricity and natural gas production) Water

K Total saline water use intensity below 0.5 bbl/bbl K Publicly reported absolute water reduction targets bitumen beyond government regulations K No freshwater consumption except for domestic use Climate Change

K Greenhouse gas emissions intensity below K Public absolute greenhouse gas reduction targets 78 kg/bbl bitumen beyond government regulations

L Table 9: Best practice in situ development checklist.

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 65 The In Situ Oil Sands Report Card Summary of Conclusions and Recommendations

Conclusion Government Industry Recommendations Recommendations

Substantial room Mandate environmental Take the lead for improvement stewardship Industry leaders must demonstrate There is substantial room for Government must provide their capacity to implement reduction environmental improvement incentives or regulate as needed targets, biodiversity offsets and in the following areas: to encourage action in the four monitoring and third-party accredited T Reduction targets areas on the left. Specific environmental management. Specific recommendations are as follows: recommendations are as follows: T Water use T Provide some benefit to T Establish specific absolute reduction T GHG emissions companies that have voluntary targets or water use, air emissions T Air emissions targets such as reducing regula- and GHG emissions. T Biodiversity offsets tory hurdles or providing finan- T Invest in biodiversity offsets T Biodiversity monitoring cial incentives. Supplement commensurate with the terrestrial T Third-party accredited incentives with a clear message impact of the in situ project. environmental management that continuous improvement T Support the Alberta Biodiversity is expected. Monitoring Institute and integrate its T Make compensatory offset results into management planning. mitigation of terrestrial impacts T Implement a third-party accredited in situ oil sands development environmental management system mandatory. for the in situ project. T Integrate mandatory financial support for the ABMI into existing and future approvals. T Make third-party accredited environmental management systems mandatory for in situ projects.

66 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card SUMMARY

Conclusion Government Industry Recommendations Recommendations

Disclosure Make oil sands environmental Provide accessible public data The Pembina Institute found it performance data accessible Disclose project-specific environmental difficult to compile comparable data Make project-specific and data in a format that is comparable for all projects using public data cumulative oil sands in situ across the in situ industry. sources. Weak public disclosure of environmental performance data environmental impact data weakens available in an accessible and transparency and risks undermining comparable format. public understanding and confidence in the sector.

Mining vs. in situ Mining vs. in situ Focus on the issues On some important environmental In situ operations have significant, In situ developments have significant indicators, like NOx and GHG cumulative and long-term impacts environmental impacts and there is emissions, in situ operations and should be submitted to substantial room for improvement are more intensive than mining rigorous environmental impact across the industry. In situ operations operations. In addition, our land assessments, monitoring and should seriously engage stakeholders use intensity assessment did regulation. and publicly discuss solutions to these not incorporate the impacts of issues. fragmentation and upstream natural gas production associated with in situ operations.103

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 67 The In Situ Oil Sands Report Card SUMMARY

Conclusion Government Industry Recommendations Recommendations

Best practices Create a competitive Incorporate best practices and There is a wide variation in atmosphere for innovation lead improvements performance between in situ There is very little incentive Adopt current best practices and operators. All projects could for in situ operators to improve continuously improve once best achieve 85% on this survey by environmental performance. practices have been adopted. incorporating already existing Government must consider how best practices. harness the innovative capacity of the oil sands industry to address environmental issues.

Cumulative impacts Halt new approvals until Acknowledge cumulative There is an inadequate level environmental systems impacts of in situ development of environmental management are complete Take a leadership role in support to ensure that the regional Complete regional management for the establishment of regional environment is protected. of cumulative impacts from oil environmental thresholds and sands development that protects completing land use planning. the ecological integrity of the Alberta’s ecosystem before approving new projects.

68 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card

Appendix: Project Summaries

he previous sections summarized experienced. The section also summarizes, performance by indicator to where possible, actions that each Tidentify leading practices in each company is taking to resolve outstanding category. This section provides environmental issues. The Pembina information on a project by project Institute provided each project summary basis. The purpose of this section is to to participating companies to ensure a highlight where each company is doing fair representation of each company’s well, why the project is doing well and performance and plans to resolve what challenges the project has outstanding environmental issues.104

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 69 The In Situ Oil Sands Report Card PROJECT SUMMARIES

Canadian Natural Primrose/Wolf Lake: 25% Canadian Natural’s Primrose and Wolf Lake operations in 1985, and then added projects are located about 55 km north of Primrose South in 1998 followed by Bonnyville, Alberta. Canadian Natural Primrose North in mid-2006. Canadian wholly owns and operates both projects. Natural’s operations also include a Canadian Natural started Wolf Lake cogeneration unit.

SCORE RANK General Environmental Management

1.5/3 Below Canadian Natural Primrose/Wolf Lake’s environmental management score is on par with other projects. To Average improve its performance in this area Canadian Natural should implement a third-party management system. Land

Canadian Natural Primrose/Wolf Lake scores well below the average in the land category because the 1/5 Below Pembina Institute found no evidence that Canadian Natural supports CEMA, the ABMI or has purchased Average biodiversity offsets. Canadian Natural’s project is also located in caribou habitat. Air Emissions

Canadian Natural Primrose/Wolf Lake outperforms other operations on its SO2 emission intensity. However 0.75/3 Below its NOx emissions are relatively higher than other projects. NOx emissions are strongly correlated to the Average steam-to-oil ratio of the project. Canadian Natural could reduce its NOx emissions by reducing its steam-to- oil ratio. Canadian Natural could also create public emission reduction targets to achieve a better score in this category. Water

Canadian Natural Primrose/Wolf Lake’s water use intensity, freshwater use intensity and wastewater production is higher than the average in situ project. A relatively high steam-to-oil ratio of about 5:1105 1/4 Below is partially responsible for this result. Canadian Natural is also behind its peers in incorporating brackish Average water into its water use profile. However, Canadian Natural is aiming to reduce freshwater use by 73% by 2013 in response to the ERCB’s draft directive.106 Climate Change

Canadian Natural Primrose/Wolf Lake’s GHG intensity is one of the highest in the industry, and Canadian Natural currently has no public emission reduction targets above and beyond government regulations. GHG emissions are strongly tied to steam-to-oil ratio, so reducing steam-to-oil ratio should lead to better GHG 0/2 Below performance. Public targets could help to drive this change internally. Canadian Natural is focusing on Average technology such as follow up production with SAGD or solvents and in situ combustion schemes to increase production. These technologies may have environmental benefits as well because they require less energy production per barrel of bitumen produced. Overall

Canadian Natural Primrose/Wolf Lake is the lowest-scoring project reviewed in this assessment. Its project has 4.25/17 Below a relatively high steam-to-oil ratio, which results in higher water use, air emissions and GHG emissions relative 25% Average to other projects. In addition Canadian Natural has not supported initiatives, such as the ABMI and CEMA, which most other operators have participated in. Public targets to reduce absolute air emissions, water use and GHG emissions would also help increase the score of Canadian Natural Primrose/Wolf Lake.

L Table 10: Summary of Canadian Natural Primrose/Wolf Lake’s 2007 environmental performance.

70 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card PROJECT SUMMARIES

Cenovus Christina Lake: 37% (PILOT) Cenovus’s Christina Lake project is and it uses SAGD to recover the bitumen. approximately 75 km north of its Foster Cenovus Christina Lake became a Creek project. Like Foster Creek, Christina commercial project in 2008, and it made Lake is owned 50/50 by Cenovus and operational changes that are not reflected in ConocoPhillips and operated by Cenovus. this survey. Christina Lake operations began in 2003,

SCORE RANK General Environmental Management

Cenovus Christina Lake’s environmental management score is on par with other operations. It publicly reports 2/3 Average project-specific data and has an environmental policy that commits to continuous improvement. It could achieve a higher score by implementing a third-party certified environmental management system. Land

Cenovus supports the ABMI, and provided conditional support to the CEMA TEMF recommendation regarding biodiversity conservation in the Regional Municipality of Wood Buffalo.107 However, Christina Lake is located in 2/5 Below caribou habitat and the land use intensity of the project is relatively high compared to other in situ projects. To Average improve its score in this category Cenovus should reduce the land use intensity of the project and invest in conservation offsets. Air Emissions

Cenovus Christina Lake’s NOx and SO2 emissions are relatively low compared to other operations because it has a relatively low steam-to-oil ratio. Although SO2 emissions are within regulated limits, Cenovus could 2/3 Below further reduce SO2 emissions by incorporating a sulphur recovery unit. Cenovus has approval to incorporate Average a sulphur recovery facility once additional production trains come online.108 To score better in this category Cenovus should develop public absolute reduction targets. Water

Cenovus Christina Lake received a zero score in the water category because in 2007 it required relatively high amounts of water, high amounts fresh water and produced high amounts of wastewater.109 In addition, the 0/4 Below brackish wells that Cenovus was using to supply water to its facility fell below the threshold of 4,000 ppm total Average dissolved solids, changing their classification to fresh water.110 Since 2007, Cenovus has optimized its boilers and installed a water recycling facility at Christina Lake. It has also drilled new saline water wells. Together, these efforts are likely to enhance the project’s water use performance. Climate Change

Above As with air emissions, Cenovus Christina Lake’s relatively low steam-to-oil ratio means the project has a 0.75/2 Average relatively low GHG intensity. However, to improve in this area Cenovus should develop absolute GHG targets. Overall

To improve its score Cenovus should create public targets committing to reducing absolute air and GHG emissions and water use. These commitments would help to quantify Cenovus’s commitment to continuous 6.25/17 Below improvements. Cenovus would also show leadership in establishing biodiversity offsets to offset the impact of 37% Average its operations in the boreal forest. Christina Lake has transitioned from a pilot to commercial project since this report was written. The Pembina Institute looks forward to scoring its commercial operations during the next report card period.

L Table 11: Summary of Cenovus Christina Lake’s 2007 environmental performance.

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 71 The In Situ Oil Sands Report Card PROJECT SUMMARIES Cenovus Foster Creek: 57% Cenovus Foster Creek, located 75 km north facility. Commercial operation started in of the city of Cold Lake, Alberta, uses 2001, and it produced just under 50,000 SAGD technology to extract bitumen. bbl/day on average in 2007, making it the The project is co-owned by Cenovus and largest SAGD bitumen producer. Cenovus ConocoPhillips in a 50/50 partnership and Foster Creek incorporates a cogeneration operated by Cenovus. The Foster Creek unit and has one of the lowest steam-to-oil operation was the first commercial SAGD ratios in the in situ industry.

SCORE RANK General Environmental Management

Cenovus Foster Creek’s environmental management score is on par with other operations. It publicly reports 2/3 Average project-specific data and has an environmental policy that commits to continuous improvement. It could achieve a higher score by implementing an externally verified environmental management system. Land

Cenovus has reduced the land use intensity at Foster Creek by using underground storage caverns to replace aboveground storage, reorganizing their well pads to reduce footprint, and has lowered the seismic 2.75/5 Above impact by using the “Mega Bin” 3D system. Although Cenovus supports the ABMI, its Foster Creek project is Average located in an area with nearby caribou herds,111 reducing a portion of its land score. Cenovus could improve its score by investing in conservation offsets. Air Emissions

Cenovus Foster Creek’s NOx and SO2 intensities are among the lowest of the in situ facilities scored in this assessment. The primary driver for these two indicators is the project’s relatively low steam-to-oil ratio. 2/3 Above Cenovus Foster Creek also uses a cogeneration facility, further reducing NOx and SO2 intensities. Although Average Cenovus Foster Creek has delivered reductions in its emission intensity, to remain a leader in this area requires continuous reductions in absolute air emissions and public air emission reduction targets. Water

Cenovus Foster Creek has among the lowest fresh and total water use intensities of the compared projects. In addition, Cenovus Foster Creek is currently piloting a re-boiler which will recycle a portion of the facility’s blowdown 2/4 Above water further reducing water make up requirements.112 However, its wastewater production is considerably above the Average average in situ project.113 To score better in this category Cenovus should strive to reduce its liquid waste production and develop public water use reduction targets that go beyond government regulated water reduction targets. Climate Change

Cenovus Foster Creek’s GHG intensity is among the lowest of the compared in situ projects. Foster Creek 1/2 Above achieves this relatively low GHG intensity by maintaining a relatively low steam-to-oil ratio and by Average generating heat and electricity using cogeneration. To achieve a better score in this category Cenovus should publicly state absolute GHG emission reduction targets. Overall

Overall Cenovus Foster Creek’s environmental performance is among the best in the industry. Its operations are performing well technically which results in reduced environmentally impact. To Cenovus’s credit it is 9.75/17 Above investing in new technologies to more efficiently produce bitumen and further reduce the environmental 57% Average impact intensity of its operations. For example, Cenovus has developed and is implementing wedge wells and is experimenting with second stage “once through steam generation,” which together are likely to improve the energy efficiency of its operations. Cenovus could invest in several areas to maintain its lead in environmental performance, including setting public targets and investing in land offsets.

L Table 12: Summary of Cenovus Foster Creek’s 2007 environmental performance. 72 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card PROJECT SUMMARIES

Husky Tucker: 35% (START-UP) Husky Tucker, located 30 km northwest of 2006. However, average production was the city of Cold Lake, Alberta, uses SAGD 1,700 bbl/day in 2007, well below the technology to extract bitumen from the 30,000 bbl/day design capacity. Well Clearwater formation. Husky has 100% production issues at Husky Tucker have interest in the project. Steam injection resulted in a very high steam-to-oil ratio of commenced in late August 2006, and first about 14:1 in 2007.114 production was achieved in late November

SCORE RANK General Environmental Management

This project’s environmental management system score is similar to other operations’ scores. Husky publicly reports project-specific data and has an environmental policy that commits to continuous improvement. To 2/3 Average achieve full marks in this category, Husky should implement an environmental management system certified by a third party. Land

The land use intensity for Husky Tucker is lower than for most other projects. To improve its score in this 3/5 Above category, Husky should invest in biodiversity offsets and provide support to the ABMI. It has committed to Average financially support the ABMI in 2010.115 Air Emissions

Husky Tucker underperforms compared with other operations in NOx and SO2 emissions. This project’s high NOx and SO2 intensities are both linked to its high steam-to-oil ratio. If Husky Tucker reduced its steam-to-oil 0/3 Below ratio to the design level (3:1) then it would likely compare well with other projects on air emissions. Husky is Average considering different production strategies, such as changing the pre-heat strategy in new wells and potentially re-drilling existing wells or drilling infill wells between current wells to enhance production.116 Water

Husky Tucker’s overall water use is very high compared with other projects because of its high steam-to-oil ratio. 1/4 Below Water with total dissolved solids of about 19,000 mg/L is treated for use as process make-up water. Husky Average Tucker uses very little fresh water compared to other projects – fresh water at the Tucker site is reserved for domestic and cleaning purposes, so it is independent of the project’s steam-to-oil ratio. Climate Change

As with air emissions and water use, Husky Tucker’s GHG emissions are tied to its steam-to-oil ratio. Because 0/2 Below this project has a high steam-to-oil ratio, its GHG emissions are also high. Husky Tucker does not have any Average publicly available targets. Overall

Overall, the Husky Tucker project scores poorly because of poor bitumen production. Absolute emissions are 6/17 Below well within regulatory limits for the operations, but the relatively high intensities of water use, air emissions and GHG emissions reflect the project’s poor performance. Environmental data reported for 2008 shows 35% Average improvement from 2007, and Husky expects the Tucker project’s performance to improve in 2009.117 Nonetheless, Husky should invest in several actions, such as air, water and climate targets, and supporting the ABMI, while improving the technical performance of its project.

L Table 13: Summary of Husky Tucker’s 2007 environmental performance.

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 73 The In Situ Oil Sands Report Card PROJECT SUMMARIES

Imperial Oil Cold Lake: 55% Imperial Oil Cold Lake, located approx- 1985 and 1994 and then phases 11 to 13, imately 25 km northwest of the city of which included a cogeneration facility in Cold Lake, Alberta, was among the first 2002. Imperial Oil Cold Lake produced attempts at thermal oil production. The just under 50% of the in situ produced commercial pilot began production in bitumen, making it the single largest 1975, followed by phases 1 to 10 between in situ project. It uses CSS technology.

SCORE RANK General Environmental Management

Imperial Oil Cold Lake scored above average with 83% in the environmental management category. 2.5/3 Above The only difference between Imperial Oil’s project and most other projects is that the Cold Lake facility Average is ISO 14001 certified. Land

Imperial Oil Cold Lake scores average in the Land category because it is not located in caribou habitat and Imperial Oil supported the CEMA recommendation to preserve 20–40% of the Regional Municipality of Wood 2/4 Average Buffalo. However, it could improve its score further by investing in conservation offsets and supporting the ABMI. In addition there was insufficient information in the public realm to calculate Imperial Oil Cold Lake’s footprint intensity so this project was not evaluated on this metric. Air Emissions

Imperial Oil Cold Lake scores average in this category because its SO2 emission intensity is relatively low compared to other projects, its NOx emission intensity is on par with other projects, and Imperial Oil has not generated public targets to reduce air emissions. Because this project already has a relatively low steam- 1.25/3 Average to-oil ratio and a cogeneration unit, reducing these emission intensities will likely be difficult. Fortunately Imperial Oil is already experimenting with solvents to further reduce energy use, water use and air emissions. The results to date show an increase in bitumen recovery.118 If Imperial Oil Cold Lake can reduce its NOx emission intensity and publish public targets it will improve its score in this category. Water

Imperial Oil Cold Lake scores well in this category because it has a relatively low water and freshwater use 2.5/4 Above intensity and low liquid waste disposal intensity. The primary driving forces behind these lower intensities are Average Imperial Oil Cold Lake’s relatively low steam-to-oil ratio and recycling of produced water. To score better in this category Imperial Oil should develop public water use reduction targets for the Cold Lake facility. Climate Change

Imperial Oil Cold Lake scores average in the climate change category mainly for not incorporating GHG 0.5/2 Average emission reduction targets into its operations. Imperial Oil could also improve its score slightly in this category by reducing its GHG intensity. Overall

Overall Imperial Oil Cold Lake scores relatively well in this survey because of a combination of good 8.75/16 Above environmental management and technical performance which results in relatively good environmental 55% Average performance. However, Imperial Oil can still improve significantly by setting public targets, investing in conservation offsets and further reducing its NOx and GHG intensity.

L Table 14: Summary of Imperial Oil Cold Lake’s 2007 environmental performance.

74 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card PROJECT SUMMARIES

JACOS Hangingstone: 34% (DEMONSTRATION) JACOS Hangingstone, located 50 km 2000 and by another 4,000 bbl/day in southwest of Fort McMurray, started as a 2002. In 2007, JACOS Hangingstone pilot project in 1999 at 2,000 bbl/day produced just over 7,000 bbl/day. production. It expanded to 4,000 bbl/day in

SCORE RANK General Environmental Management

JACOS Hangingstone’s environmental management score is well below the average of the projects compared 0.5/3 Below for this assessment. JACOS does not appear to have an environmental policy that commits to continuous Average improvement and the Hangingstone operation does not have a third-party certified environmental management system. Land

JACOS Hangingstone scores around average in the land category because the facility is not located in caribou habitat and JACOS has agreed to the CEMA recommendation to conserve 20-40% of the Regional 2/4 Average Municipality of Wood Buffalo. It could improve its score by investing in biodiversity offsets and supporting the ABMI. In addition insufficient information existed in the public realm to calculate JACOS’ footprint intensity. Air Emissions

JACOS Hangingstone’s air emission intensities are well above average. JACOS Hangingstone’s NOx emissions are strongly correlated to steam-to-oil ratio, so reducing steam-to-oil ratio will also lead to a corresponding decrease in NO emissions. For sulphur JACOS Hangingstone is currently performing within 0.5/3 Below x its regulated sulphur emission limit; however, it could reduce its sulphur intensity by reducing its steam-to-oil Average ratio as well as installing a sulphur recovery unit. JACOS Hangingstone should be able to increase its score in this category by decreasing its steam-to-oil ratio, investing in sulphur recovery technology and establishing air emission reduction targets. Water

JACOS Hangingstone has a relatively low water use intensity in comparison with other projects. This project recycles its produced water which is rare for a pilot project. The other two pilot projects, Christina Lake and Peace River, do not recycle produced water. JACOS Hangingstone has also been able to achieve a relatively 2/4 Above low steam-to-oil ratio of 3.24 which keeps its water use intensity low. Despite JACOS Hangingstone’s relatively Average good water performance the project experienced a number of challenges in 2007. Its zero liquid discharge system did not perform as expected leading to increased total liquid waste from the project. It also experienced lower steam quality and reduced blowdown recycling than designed.119 JACOS Hanginstone’s score will likely improve in the future if it is able to rectify some of these challenges. Climate Change

JACOS Hangingstone’s score in this category is average relative to the compared projects. JACOS Hangingstone has a relatively low steam-to-oil ratio which results in a relatively low GHG intensity for a pilot 0.5/2 Average project. It could improve its score in this category by further reducing its GHG intensity and developing public GHG emission reduction targets. Overall

As a pilot project, JACOS Hangingstone scores quite well in the water category. However, to increase its score 5.5/16 Below JACOS Hangingstone will need to implement air and GHG emission and water use targets, improve its 34% Average environmental management score and further reduce its steam-to-oil ratio to reduce its NOx, SO2 and GHG emissions.

L Table 15: Summary of JACOS Hangingstone’s 2007 environmental performance.

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 75 The In Situ Oil Sands Report Card PROJECT SUMMARIES

Shell Peace River: 38% (DEMONSTRATION) The Shell Peace River complex is located It produced at 9,130 bbl/day in 2007. 40 km northeast of the town of Peace River, Shell has experimented with a number of Alberta. Shell began operations there in technologies at this site, including SAGD, 1986. Today the Peace River operation CSS and J-Wells. is defined as a demonstration project.

SCORE RANK General Environmental Management

Shell Peace River is the only project to score 100% in the environmental management category. The only 3/3 Above difference between the Shell Peace River and most other projects is that the Peace River facility is ISO Average 14001 certified. Land

The project does quite well in the land section. The project is not in caribou habitat and Shell provides support 3/4 Above to both CEMA and the ABMI. To improve this score further Shell should invest in biodiversity offsets specifically Average for the Peace River complex. Air Emissions

The project is among the worst projects from air emission intensity standpoint. Shell Peace River’s relatively high air emissions are tied to its relatively high steam-to-oil ratio at 5.8. This high steam-to-oil ratio means Shell combusts significantly more natural gas relative to other projects to produce a barrel of bitumen at

Peace River. In addition, Shell Peace River is currently licensed to emit a maximum of 14 t/d SO2 and does 0/3 Below not have sulphur recovery at the facility. However, the SO2 waiver will expire at the end of 2010. Shell has Average recently submitted a regulatory application for the Three Creeks project (see reference below), which will

decrease SO2 emissions to 2 t/d by the end of 2010. Sulphur recovery is planned for the Carmon Creek 120 project. To improve its score in this area Shell will need to significantly reduce the NOx and SO2 intensity of its facility and provide public absolute reduction targets. Water

Shell Peace River currently only uses freshwater sources and does not recycle produced water. These two points combined with a high steam-to-oil ratio results in the Peace River complex being among the worst projects in terms of water use. Shell is planning to rectify these concerns in a number of ways. In the proposed Carmon Creek project 0/4 Below that was filed in January 2010, Shell plans to recycle produced water and use brackish water as the primary Average make-up water source, which would be aligned with the draft ERCB directive.121, 122 These two actions should reduce Peace River’s water use intensity, freshwater intensity and wastewater intensity. However, Shell will have to reduce its steam-to-oil ratio as well to compare well against other projects. Climate Change

Like air emissions Shell Peace River has a high GHG emission intensity because of its high steam-to-oil ratio. In addition Shell does not have public emission reduction targets for the Peace River facility. The proposed 0/2 Below Carmon Creek project includes several GHG abatement measures, including heating integration, cogeneration Average and acid gas injection. Shell would score better in this category if it could significantly reduce the GHG intensity of its Peace River facility and develop public GHG emission reduction targets. Overall

Shell Peace River is a demonstration project and so underperforms relative to its peers. Shell will have to 6/19 Below significantly reduce its air and GHG emissions and well as water and freshwater use and liquid waste 38% Average production as part of its Carmon Creek expansion to perform well relative to other projects.

L Table 16: Summary of Shell Peace River’s 2007 environmental performance. 76 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card PROJECT SUMMARIES

Suncor Firebag: 60% Suncor Firebag is located 65 km northeast operation. Production during 2007 of Fort McMurray, Alberta. Suncor started averaged 37,000 bbl/day, well below the stage one of Firebag in 2004, followed by 70,000 bbl/day capacity. Suncor Firebag’s stage two in 2006. Both phases use SAGD production was lower than expected because to recover bitumen. The project also of plant turnaround, chamber pressure includes a cogeneration facility to produce restrictions imposed by the ERCB, pump electricity and steam for the SAGD failures and downsizing of pumps.123

SCORE RANK General Environmental Management

Suncor Firebag’s environmental management score is on par with the in situ operations compared in :1.5/3 Below this assessment. To improve its score Suncor should invest in a third-party certified environmental Average management system. Land

Suncor Firebag scores relatively well in the land category for a number of reasons. Suncor supports both the 3/4 Above ABMI and the CEMA recommendation to preserve 20-40% of the Regional Municipality of Wood Buffalo. Average Suncor also receives partial credit for protecting nearly 600 ha of boreal forest in northern Alberta.124 However Suncor’s facility is located in caribou habitat so loses a portion of its score on this indicator. Air Emissions

Suncor Firebag’s low steam-to-oil ratio means Suncor combusts less natural gas, producing fewer NOx and SO2 emissions per barrel of bitumen produced. The cogeneration facility produces steam and electricity 1.75/3 Above more efficiently than producing steam on-site and importing electricity, which also reduces emissions. Average Suncor has also established absolute air emission reduction targets which help improve its score in this category as well. Water

Suncor’s relatively high score in this category can be attributed to Firebag’s relatively low steam-to-oil ratio, water 3/4 Above recycling and public water use reduction targets. Suncor recycles 90% of its water and the water used at Firebag is Average itself primarily sourced from reverse osmosis reject stream from Suncor’s base facility. Climate Change

Suncor Firebag’s GHG intensity is among the lowest of the compared in situ projects. Firebag has a relatively 1/2 Above low steam-to-oil ratio and also uses cogeneration to produce heat and electricity. Both of these factors result in Average Firebag’s low GHG intensity. However, to improve its score further Suncor should develop public targets to reduce absolute GHG emissions. Overall

Suncor Firebag scores the highest of all the compared projects; however there is still considerable room to 10.25/17 Above improve. Suncor could increase its environmental performance and score on this survey by providing absolute 60% Average GHG reduction targets, expanding its biodiversity offsets program to account for new developments and by implementing a third-party audited environmental management system.

L Table 17: Summary of Suncor Firebag’s 2007 environmental performance.

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 77 The In Situ Oil Sands Report Card PROJECT SUMMARIES

Suncor MacKay River: 53% Suncor MacKay River is located 60 km SAGD to produce bitumen, and it has a northwest of Fort McMurray. Petro-Canada cogeneration unit operated by TransCanada (now part of Suncor) first steamed the to produce heat and electricity. In 2007, MacKay River operations in September Suncor MacKay River averaged 21,248 2002 and first produced bitumen in bbl/day bitumen production. November of the same year. The project uses

SCORE RANK General Environmental Management

Suncor MacKay River’s environmental management score is on par with the in situ operations compared 1.5/3 Average in this assessment. To improve its score Suncor should invest in a third-party certified environmental management system. Land

Suncor MacKay River scores average in this category because it provides support to the ABMI, supports the CEMA recommendation to conserve 20–40% of the Regional Municipality of Wood Buffalo, and has invested 2.5/4 Average in conservation offsets. However, MacKay River is located in caribou habitat and has a relatively high footprint intensity. To improve its score in this category Suncor should reduce the footprint intensity of MacKay River and invest in biodiversity offsets specifically for the MacKay River project. Air Emissions

Suncor MacKay River scores well in this category because its air emission intensity is quite low relative to other projects. MacKay River’s steam-to-oil ratio is relatively low compared to other in situ projects which 1.75/3 Above helps explain the low air emission intensity. Suncor could score better in this category by providing air Average emission reduction targets for the MacKay River. It is unclear whether Suncor’s published targets for its oil sands facilities also apply to the MacKay River complex. Water

From a water perspective, Suncor MacKay River uses a zero liquid discharge system which essentially eliminates the need for wastewater disposal and increases recycle rates at the operation. Its low steam-to-oil ratio also means the 2.5/4 Above facility requires less water per barrel of bitumen produced than other facilities. To improve its score in this category Average Suncor should reduce freshwater consumption at the MacKay River project and provide public water reduction targets for the facility. Climate Change

Suncor MacKay River’s GHG emission intensity is among the lowest of the compared projects. Its relatively low 0.75/2 Above steam-to-oil ratio and the incorporation of cogeneration explain this relatively low GHG intensity. However, Average Suncor could score better in this category by developing public absolute GHG emission reduction targets. Overall

Suncor MacKay River is performing well technically as suggested by its low steam-to-oil ratio, but to improve its 9/17 Above score further, Suncor MacKay River must quantify its commitment to continuous improvement by establishing 53% Average public targets to reduce absolute air, GHG emissions and water use. Suncor MacKay River also has one of the larger footprints of the operations reviewed and is located in caribou habitat, which further reduces its score.

L Table 18: Summary of Suncor MacKay River’s 2007 environmental performance.

78 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card Endnotes

1 Sarah Jordaan, David Keith and Brad Stelfox. 2009. Quantifying 23 Environment Canada (NPRI), “National Pollutant Release land use of oil sands production: a life cycle perspective. Inventory 2007 Summary — 3.1.1.1 Criteria Air Contaminants,” Environmental Research Letters, 4 (2009) 024004, www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=0D743E97-1, www.iop.org/EJ/article/17489326/4/2/024004/erl9_2_ (last modied May 14, 2009). 024004.pdf. 24 Global Environmental Management Initiative, “ISO 14001 2 Available at www.albertawatercouncil.ca/Portals/0/pdfs/ Environmental Management System Self Assessment Checklist,” WPPT%20Policy%20web.pdf. www.gemi.org/docs/PubTools.htm (accessed August 29, 2007). 3 Available at www.treasuryboard.alberta.ca/docs/GOA_ 25 Mary Griths, Amy Taylor and Dan Woynillowicz, Troubled ResponsibleActions_web.pdf. Waters, Troubling Trends: Technology and Policy Options 4 Simon Dyer, Jeremy Moorehouse, Katie Laufenberg and Rob to Reduce Water Use in Oil and Oil Sands Development in Powell, Under-Mining the Environment: e Oil Sands Report Alberta (Drayton Valley, AB: e Pembina Institute, 2006), Card (Drayton Valley, AB: e Pembina Institute, 2008), www.pembina.org/pub/612. www.oilsandswatch.org/pub/1571. 26 In response to industry recommendations, this indicator has 5 Richard Schneider and Simon Dyer, Death by a ousand Cuts: been modied from its original format. e survey question e Impacts of In Situ Oil Sands Development on Alberta’s initially read: What ratio of water use is derived from fresh water, Boreal Forest (Drayton Valley, AB: e Pembina Institute, as compared to saline water, for 2007? As noted in the survey 2006), www.oilsandswatch.org/pub/1262. responses, using the ratio method allows projects with very high water consumption rates to use more fresh water while still 6 Cenovus was formed on December 1, 2009, when EnCana maintaining a low ratio. Adjusting the metric to focus on total Corporation formally split into an integrated oil company volumes of fresh water removed this potential for misleading (Cenovus) and a natural gas company (EnCana). results and provides a comparison according to the key issue, 7 Shell has tried a number of bitumen production techniques at its which is to promote conservation of fresh water. Peace River operations, including SAGD, J-wells, multi-lateral 27 Government of Alberta, Water (Ministerial) Regulation, legs and HayBob. Chapter/Regulation: 205/1998 (Edmonton, AB: Queen’s Printer, 8 Global Reporting Initiative, Environment: Performance 1998), section 1, 1(z), www.qp.alberta.ca/index.cfm. Indicators (Amsterdam, e Netherlands: Global Reporting 28 Mary Griths, Amy Taylor and Dan Woynillowicz, Troubled Initiative, 2008). Information about specic indicators can be Waters, Troubling Trends: Technology and Policy Options found at www.globalreporting.org/ReportingFramework/ to Reduce Water Use in Oil and Oil Sands Development in G3Online/PerformanceIndicators/. Alberta (Drayton Valley, AB: e Pembina Institute, 2006), 9 Northwest and Ethical Investments, Lines in the Sand: www.pembina.org/pub/612. Oil Sands Sector Benchmarking (Vancouver, BC: 2009), 29 Global Environmental Management Initiative, “ISO 14001 www.ethicalfunds.com/SiteCollectionDocuments/docs/lines_in_ Environmental Management System Self Assessment Checklist,” the_sands_full.pdf. www.gemi.org/docs/PubTools.htm (accessed August 29, 2007). 10 Kerry ten Kate, Josh Bishop and Ricardo Bayon, Biodiversity 30 Environment Canada, Turning the Corner: Detailed Emissions Osets: Views, Experience, and the Business Case (Washington, and Economic Modelling (Ottawa, ON: 2008), 42, DC: 2004), 13, www.forest-trends.org/publication_details.php? www.ec.gc.ca/doc/virage-corner/2008-03/pdf/571_eng.pdf. publicationID=660 (accessed November 27, 2009) 31 Probe Research, Albertans’ Perceptions of Oil Sands 11 Government of Alberta, Responsible Actions: A Plan for Development Poll: Part I, Pace and Scale (Drayton Valley, AB: Alberta’s Oil Sands (February 2009), 19. e Pembina Institute 2007), www.pembina.org/pub/1446. 12 Environment Canada, Scientic Review for the Identication 32 Northwest and Ethical Investments, Lines in the Sand: of Critical Habitat for Woodland Caribou (Rangifer tarandus Oil Sands Sector Benchmarking, (Vancouver, BC: 2009), caribou), Boreal Population, in Canada (Ottawa: Environment www.ethicalfunds.com/SiteCollectionDocuments/docs/lines_ Canada, 2008), vi. in_the_sands_full.pdf. 13 Ibid., 145. 33 Ibid. 14 www.cemaonline.ca 34 Energy Resources Conservation Board, “Oil Sands,” 15 Terrestrial Ecosystem Management Framework for the Regional www.ercb.ca/portal/server.pt?open=512&objID=249&PageID=0 Municipality of Wood Bualo, prepared by the Sustainable &cached=true&mode=2 (accessed May 14, 2009). Ecosystems Working Group of the Cumulative Environmental 35 Ibid. Management Association, June 2008, 3. 36 Alberta Energy, “What Is Oil Sands” (last revised June 11, 16 abmi.biology.ualberta.ca 2009), www.energy.gov.ab.ca/OilSands/793.asp. 17 Jari Kouki, Jeremy Kerr, Reed Noss, John Reynolds, Jim Schiek 37 Energy Resources Conservation Board, “Oil Sands,” and Stan Boutin, “World-Class Biodiversity Monitoring Makes www.ercb.ca/portal/server.pt?open=512&objID=249&PageID=0 Alberta a World Leader,” (2008). &cached=true&mode=2 (accessed March 30, 2009). 18 Environment Canada (NPRI), “2006 Air Pollutant Emissions 38 Alberta Energy. June 24, 2009. Alberta’s Leased Oil Sands Area. for Canada Version 1,” (April 2008), www.ec.gc.ca/pdb/websol/ www.energy.alberta.ca/OilSands/pdfs/OSAagreesStats_June2009 emissions/2006/2006_canada_e.cfm (accessed April 2009). vkb.pdf. 19 Ibid. 39 Alberta Energy, “What Is Oil Sands,” revised June 11, 2009, 20 Julian Aherne, “Critical Load and Exceedance Estimates for www.energy.gov.ab.ca/OilSands/793.asp. Upland Forest Soils in Manitoba and Saskatchewan,” (2008). 40 Imperial Oil. Cold Lake Approvals 8558 and 4510 2008 ERCB 21 U.S. Environmental Protection Agency, “Health Eects of Annual Performance Review. Calgary: ERCB; 2008, Pollution,” www.epa.gov/Region7/programs/artd/air/quality/ www.ercb.ca/portal/server.pt/gateway/PTARGS_0_0_321_256_ health.htm (updated November 2007). 0_43/http%3B/ercbcontent/publishedcontent/publish/ercb_hom e/industry_zone/industry_activity_and_data/in_situ_progress_re 22 Ibid. ports/2008/.

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 79 The In Situ Oil Sands Report Card ENDNOTES

41 Energy Resources Conservation Board, ST98: Alberta’s Energy 62 Terrestrial Ecosystem Management Framework for the Regional Reserves 2008 and Supply/Demand Outlook 2009–2018, Municipality of Wood Bu alo, prepared by the Sustainable (Calgary, AB: ERCB, 2009), Figure 2-13, www.ercb.ca/docs/ Ecosystems Working Group of the Cumulative Environmental products/STs/st98-2009.pdf. Management Association, June 2008, 3. 42 Energy Resources Conservation Board, “Oil Sands: Develop- 63 Lower Athabasca Regional Plan, www.landuse.alberta.ca/ ment,” www.ercb.ca/portal/server.pt/gateway/PTARGS_ RegionalPlans/LowerAthabasca/Default.aspx. 0_0_312_249_0_43/http%3B/ercbContent/publishedcontent/p 64 Cumulative Environmental Management Association, CEMA ublish/ercb_home/public_zone/oil_sands/development/ (accessed Responses Received on TEMF Recommendation (CEMA, August 2009). 2008), www.cemaonline.ca/component/option,com_docman/ 43 Alberta Energy, “What Is Oil Sands,” www.energy.gov.ab.ca/ task,doc_download/gid,1438/. OilSands/pdfs/FactSheet_OilSands.pdf (accessed May 14, 2009). 65 www.borealcanada.ca/framework-e.php 44 Energy Resources Conservation Board, ST98: Alberta’s Energy 66 Cumulative Environmental Management Association, CEMA Reserves 2008 and Supply/Demand Outlook 2009–2018, Responses Received on TEMF Recommendation (CEMA, (Calgary, AB: ERCB, 2009), Figure 2-12, 2008), www.cemaonline.ca/component/option,com_docman/ www.ercb.ca/docs/products/STs/st98-2009.pdf. task,doc_download/gid,1438/. 45 Alberta Chamber of Resources. Oil Sands Technology Roadmap: 67 abmi.biology.ualberta.ca Unlocking the Potential. Final Report (2004), 28, www.acr- alberta.com/projects/Oil_Sands_Technology_Roadmap/OSTR_ 68 Jari Kouki, Jeremy Kerr, Reed Noss, John Reynolds, Jim Schiek report.pdf. and Stan Boutin, “World-Class Biodiversity Monitoring Makes Alberta a World Leader,” (2008). 46 Imperial Oil’s rst pilot project in the Cold Lake area started near Ethel Lake in the 1960s. Its rst commercial project was 69 Alberta Biodiversity Monitoring Institute, Previous Sponsors, approved in 1983. Shell started operations in the Peace River www.abmi.ca/abmi/sponsor/sponsors.jsp (accessed June 2009). area 25 years ago, using a variant of the CSS process referred to 70 Julian Aherne, “Critical Load and Exceedance Estimates for as the “radial soak” method that has a vertical well with four Upland Forest Soils in Manitoba and Saskatchewan,” (2008). horizontal arms that extend into the bitumen. 71 Ibid. 47 e ultimate recovery rate with CSS is expected to be 20–35% 72 U.S. Environmental Protection Agency, “Health Eects of compared to 40–70% for SAGD. Alberta Chamber of Pollution,” www.epa.gov/Region7/programs/artd/air/quality/ Resources, Oil Sands Technology Roadmap: Unlocking the health.htm (last updated November 2007). Potential, Final Report (2004), 28–29, www.acr-alberta.com/ Projects/Oil_Sands_Technology_Roadmap/PSTR_report.pdf. 73 From reported valuables for each of the projects available in their ERCB progress reports. 48 Imperial Oil. Cold Lake Approvals 8558 and 4510 2008 ERCB Annual Performance Review (Calgary, AB: ERCB, 2008), 74 Husky Tucker’s steam-to-oil ratio is 14:1. e average steam-to- www.ercb.ca/portal/server.pt/gateway/PTARGS_0_0_321_256_ oil ratio is (including Husky Tucker in the calculations) is 4.6:1. 0_43/http%3B/ercbcontent/publishedcontent/publish/ercb_ 75 U.S. Environmental Protection Agency, “Health Eects of home/industry_zone/industry_activity_and_data/in_situ_ Pollution,” www.epa.gov/Region7/programs/artd/air/quality/ progress_reports/2008/. health.htm (last updated November 2007). 49 Alberta Oil Sands Technology and Research Authority, History 76 Shell Canada Energy, Peace River In Situ Oilsands Progress of AOSTRA and Accomplishments. (2002), www.aeri.ab.ca/ Report Commercial Scheme Approval 81431, 2008,135, sec/new_res/docs/history_on_the_web_020130.pdf. www.ercb.ca/portal/server.pt/gateway/PTARGS_0_0_303_263_ 50 Alberta Energy Research Institute, Steam Assisted Gravity 0_43/http%3B/ercbContent/publishedcontent/publish/ercb_ Drainage (SAGD) (2002) www.aeri.ab.ca/sec/suc_sto_001_2.cfm. home/industry_zone/industry_activity_and_data/in_situ_ progress_reports/2008/. 51 Northwest and Ethical Investments, Lines in the Sand: Oil Sands Sector Benchmarking, (Vancouver, BC: 2009), 77 Environment Canada (NPRI), “National Pollutant Release www.ethicalfunds.com/SiteCollectionDocuments/docs/lines_in_ Inventory 2007 Summary – 3.1.1.1 Criteria Air Contaminants,” the_sands_full.pdf. www.ec.gc.ca/inrp-npri/default.asp?lang=En&n=0D743E97-1, (last modi ed May 14, 2009). 52 e information in this table is sourced from ERCB monthly progress reports for 2007, from sustainability reports and 78 Global Environmental Management Initiative, “ISO 14001 responses from the companies to our surveys. Environmental Management System Self Assessment Checklist,” www.gemi.org/docs/PubTools.htm (accessed August 29, 2007). 53 Sarah Jordaan, David Keith and Brad Stelfox, “Quantifying land use of oil sands production: A life cycle perspective,” 79 Suncor Energy, Summary Report on Sustainability (2009), Environmental Research Letters 4 (2009), 024004, www.suncor.com/pdf/2009_Report_on_Sustainability_ www.iop.org/EJ/article/1748-9326/4/2/024004/erl9_2_ Summary.pdf. 024004.pdf. 80 Alberta Water Council, Water for Life recommendation for 54 Kerry ten Kate, Josh Bishop and Ricardo Bayon, Biodiversity renewal, Appendix A (2008), 30. O sets: Views, Experience, and the Business Case (Washington, 81 Shell. Shell Canada Peace River In Situ Expansion: Carmon DC: 2004), 13, www.forest-trends.org/publication_details.php? Creek Project (2009), 17, www-static.shell.com/static/can- publicationID=660 (accessed November 27, 2009). en/downloads/aboutshell/our_business/e_and_p/carmon_creek_ 55 Government of Alberta, Responsible Actions: A Plan for disclosure_mar16_09.pdf. Alberta’s Oil Sands (February 2009), 19. 82 In response to industry recommendations, this indicator has 56 Alberta Conservation Association, www.ab-conservation.com. been modi ed from its original format. e survey question initially read: What ratio of water use is derived from fresh water, 57 Petro-Canada, personal correspondence to the Oil Sands as compared to saline water, for 2007? As noted in the survey Environmental Coalition, September 25, 2007. responses, using the ratio method allows projects with very high 58 Shell, personal correspondence, 2009. water consumption rates to use more fresh water while still 59 Environment Canada, Scientic Review for the Identication of maintaining a low ratio. Adjusting the metric to focus on total Critical Habitat for Woodland Caribou (Rangifer tarandus volumes of fresh water removed this potential for misleading caribou), Boreal Population, in Canada (Ottawa: Environment results and provides a comparison according to the key issue, Canada, 2008), vi. which is to promote conservation of fresh water. 60 Ibid., 145. 83 Government of Alberta, Water (Ministerial) Regulation, Chapter/Regulation: 205/1998 (Edmonton, AB: Queen’s Printer, 61 CEMA. 2009. Cumulative Environmental Management 1998), section 1, 1(z), www.qp.alberta.ca/index.cfm. Association (CEMA). www.cemaonline.ca.

80 DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD The Pembina Institute The In Situ Oil Sands Report Card ENDNOTES

84 Husky Energy Inc., Husky Oil Operations Limited: Tucker 104 Husky, Shell and Cenovus provided comments. However, the ermal Project Commercial Scheme 9835.; 2008:144, Pembina Institute produced the nal summary. e companies www.ercb.ca/docs/products/osprogressreports/2008/2008Cold consulted do not necessarily agree with the provided summaries. LakeHuskyTuckerSAGD9835.pdf. 105 Canadian Natural has a number of well pads all with dierent 85 ERCB. Draft Directive: Requirements for Water Measurement, steam-to-oil ratios. Reporting, and Use for ermal In Situ Oil Sands Schemes. 106 ERCB, Draft Directive: Requirements for Water Measurement, 2009. Reporting, and Use for ermal In Situ Oil Sands Schemes 86 Mary Griths, Amy Taylor and Dan Woynillowicz, Troubled (2009). Waters, Troubling Trends: Technology and Policy Options to 107 Cenovus responded that it supports the TRIAD philosophy Reduce Water Use in Oil and Oil Sands Development in Alberta outlined in the TEMF, however believes that specic numerical (Drayton Valley, AB: e Pembina Institute, 2006), designation of intensive, extensive and protected areas is www.pembina.org/pub/612. premature prior to a complete analysis of the environmental, 87 Suncor Energy, Report to the Community 2007–2008, economic and social aspects of such land designations. Opportunities Tomorrow. Performance Today (2008), 17, 19. 108 Cenovus Energy, EnCana Christina Lake In-situ Oil Scheme 88 Global Environmental Management Initiative, “ISO 14001 2009 Update, 2009:272, www.ercb.ca/docs/products/ Environmental Management System Self Assessment Checklist,” osprogressreports/2009/2009AthabascaEncanaChristinaLake www.gemi.org/docs/PubTools.htm (accessed August 29, 2007). SAGD8591.pdf. 89 Suncor Energy, 2009 Summary Report on Sustainability. 109 is conclusion is uncertain due to the lack of veriably 90 e ecoENERGY Carbon Capture and Storage Task Force, consistent data on liquid waste disposal across the projects. Canada’s Fossil Energy Future (Natural Resources Canada, 110 Cenovus, personal correspondence, 2009. 2008), www.nrcan-rncan.gc.ca/com/resoress/publications/fosfos/ 111 While the Cold Lake Air Weapons range that hosts it has not fosfos-eng.php. ocially been designated as caribou habitat, there is a nearby 91 Environment Canada, Turning the Corner: Detailed Emissions herd, and the Foster Creek project has developed a Caribou and Economic Modelling (Ottawa, ON: 2008), 42, Management Plan for the area. www.ec.gc.ca/doc/virage-corner/2008-03/pdf/571_eng.pdf. 112 Cenovus, personal correspondence, 2010. 92 Canada ratied the Kyoto Protocol on December 17, 2002. 113 is conclusion is uncertain due to the lack of veriably (maindb.unfccc.int/public/country.pl?country=CA). consistent data on liquid waste disposal across the projects. 93 Environment Canada, Turning the Corner: Detailed Emissions 114 Husky, personal correspondence, 2009. and Economic Modelling (Ottawa, ON: 2008), 42, www.ec.gc.ca/doc/virage-corner/2008-03/pdf/571_eng.pdf. 115 Husky, personal correspondence, 2010. 94 Husky Tucker SOR = 14, Average SOR (with Tucker in 116 Husky, personal correspondence, 2009. calculations) = 4.57 117 Husky, personal correspondence, 2010. 95 Probe Research, Albertans’ Perceptions of Oil Sands 118 Imperial Oil, Cold Lake Approvals 8558 and 4510 2008 ERCB Development Poll: Part I, Pace and Scale (Drayton Valley, AB: Annual Performance Review (Calgary, AB: ERCB, 2008), e Pembina Institute 2007), www.pembina.org/pub/1446. www.ercb.ca/portal/server.pt/gateway/PTARGS_0_0_321_256_ 96 Sarah Jordaan, David Keith and Brad Stelfox. 2009. Quantifying 0_43/http%3B/ercbcontent/publishedcontent/publish/ercb_ land use of oil sands production: a life cycle perspective. home/industry_zone/industry_activity_and_data/in_situ_ Environmental Research Letters, 4 (2009) 024004,www.iop.org/ progress_reports/2008/. EJ/article/1748-9326/4/2/024004/erl9_2_024004.pdf. 119 ACOS. ermal In-Situ Scheme Progress Report: 97 Pembina compared an application for approval for a new in situ HANGINGSTONE DEMONSTRATION PROJECT 2007 oil sands facility against the operating facilities in this report. On (2008), www.ercb.ca/docs/products/osprogressreports/2008/ all metrics that could be measured (NOX, SO2, GHG, land use 2008AthabascaJACOSHangingstoneSAGD8788.pdf. and water use) the project scored in the middle of the pack. 120 Shell Canada Energy, ree Creeks 8-11-86-19 W5 Underground 98 Alberta Environment, EnviroVista, Gas Storage Scheme Requirements – Directive 65 application www.environment.alberta.ca/867.html. submitted to the ERCB, 2009. 99 Available at www.albertawatercouncil.ca/Portals/0/pdfs/WPPT 121 ERCB, Draft Directive: Requirements for Water Measurement, %20Policy%20web.pdf Reporting, and Use for ermal In Situ Oil Sands Schemes (2009). 100 Available at www.treasuryboard.alberta.ca/docs/GOA_ ResponsibleActions_web.pdf 122 Shell, Shell Canada Peace River In Situ Expansion: Carmon Creek Project (2009), 17, www-static.shell.com/static/can- 101 Northwest and Ethical Investments, Lines in the Sand: en/downloads/aboutshell/our_business/e_and_p/carmon_creek_ Oil Sands Sector Benchmarking (Vancouver, BC: 2009), disclosure_mar16_09.pdf. www.ethicalfunds.com/SiteCollectionDocuments/docs/lines_in_ the_sands_full.pdf. 123 Suncor Energy, 2008 ERCB Annual Review Suncor Firebag (2008), www.ercb.ca/docs/products/osprogressreports/2008/ 102 Ibid. 2008AthabascaSuncorFirebagSAGD8870.pdf. 103 Sarah Jordaan, David Keith and Brad Stelfox. 2009. 124 Alberta Conservation Association, www.ab-conservation.com. Quantifying land use of oil sands production: a life cycle perspective. Environmental Research Letters, 4 (2009) 024004, www.iop.org/EJ/article/1748-9326/4/2/024004/erl9_2_ 024004.pdf.

The Pembina Institute DRILLING DEEPER: THE IN SITU OIL SANDS REPORT CARD 81